Document p2MYJew99Jeownydy273DpxzB

A, J W ^ 7 hUiU` *1 1 * J ? JW a . W l J , ' i *' ' i \_ t . j 0*1.. 4* '] 1 * * 1/ i, . V' ` ^ lJ M I t V kVV \ c- *->*. Tm^sJ>* V^ **/ /A j^. <a 1 -- -t >_ N \\ * * \ .v 1V ./ NcV T* o / UJ / C-J V" \<\ {///r#* r , 4vf -- V 1 FnO'' 'in ? A"*f *:,r' < id*'.' ,,- --i / *................. ... : ^ ;> i <Ti * 4. / | l J | 1 444 ? j ' J Ir* r r p HONS 201307 EPA 560/6-77-035 MICROECOimiC mciz CF toe proposed 'FCB Ml REGULATIONS' Final Task Repcrt Sufcmitted to: . U.S. Ehvixorrrnntal Protection Agency Office of Planning and Management Washington, D.C. Attentions Mr. Steven B. Malkenson Project officer Contract No. 68-01-4771 Submitted by: VEPSAR DC. 6621 Flcctronic Drive Springfield, virc-mia 22151 (703) 750-3000 May 1C, 1978 HONS 201308 This document is available in limited quantities through the U.S, Environmental Protection Agency, Office of TOxic Substances ('VH--794), 401 M Street, S.W., Washington, D.C. 20460. This dccuivnt will subsequently be available through the National Technical Inform,vtion Service, Springfield, Virginia 22151. HONS 201309 j eport has been reviewed by the Office of Planning and ManagoEnvironrental Protection Agency, and approved for publication, ics rot signify that the contents necessarily reflect the vie?vs is of the Environmental Protection Agency, nor does rrenticn of i or canrercial products constitute endorsement or reccrmenda Lion MONS 201310 PREFACE Shis report was prepared by Versar hie. for the Office of Planning and Management of the U. S. Environmental Protection Agency. The report svtTimxircs Versar's estimates of the prcbeble costs and impacts of cemplying with the prcrcccd "PCI Ban Poguiaticnr." These regulations were prepared by the ERA Office of Tonic Substances and the Interagency PC3 Work. Group to implement the requirtrents of Sections 6(e) (2) md 6(e) (3) of the Ttceic Substances Control Act (Append!:.: A). This economic analysis program was sponsored by the EPA, but the re sults reported are these of Versar lr,c. Tliio report was prepared in partial fulfillment of the requirements of Contract No. 63-01-4771. The report is not a statement of ESA policy. However, this study does rest the requirements of an economic uroact analysis of the proposed regula tion. This report was prepared under the supervision of Mr. Robert Wes tin, Principal Investigator. Major contributors wares Louis Fourt, Ph.D. (economic methodology, waste oil, railroads) _ Robert Mastin, P.E. (transformers, dry pigments) David Eerkey (capacitors*, mining machines) Bruce Woodcock (hydraulic systems, turhines) Special ackrowledgeiiEnts must be given for the close support received frem Mr. Steven B. Malkenson, ETA Project Officer, and Mr. Joseph F. Lackey, FPA Regulations Development Group of die Office of Toxic Substances, The factual strengths of this report are due to the close cooperation received firzn industry, particularly representatives of the transformer and capaci tor manufacturers arvd the electric utilities. i HONS 201311 This report is being released ard circulated prior to the public hearing on the preposed regulation. It will bo considered along with the information received during the hearing in establishing the final regular tiona. Prior to final prcirulcuticn of the regulations, this study shall have standing in any tPA proceeding or court proceeding only to the extent that it represents the views of Versar Inc. It cannot be cited, referenced, or represented in any respect in any such proceeding cs a statement of EPA's vievs regarding the impact of the proposed regulations. U HONS 20131* Page preface 1.0 rtnrorjcriCN............................................................................ l 1.1 Purpose and Scope . ................................................... 1 1.2 PCBs Usage in the United States.......................... 2 1.2.1 1.2.2 1.2.3 1.2.4 1.2.5 1.2.6 Production of POs...................................... LTXDrtS Of FCEs................. 5 Hydraulic System, SeatTrrj-a for System, and cerorccsor Use................... Trrnsformr >tir.ufacturing and Maintenance......................................... niectrcraqnets.............................................. Canceltors....................................................... 4 5 7 8 9 1.3 PCS Restrictions in the Tbxic Substances Control Act................................................................... 9 1.4 Summary of Proposed Ban Regulations......................10 1.5 Effects of the Proposed Regulations by PCB Use........................................................................ 12 2.0 tCTICDOLCXTf FOR FCCfCMtC IMPACT ANALYSIS OF THE PROPOSED "PC3 BAN KEGULAIICNS".......................... 14 2.1 General Approach............................................................14 2.2 Definition of Economic Inpact.................................. 16 3.0 IMPACTS OF BANS ON 7HS DISTRIBUTICN OF PCB CAPACITORS AND DQUITMENT...............................................17 3.1 Effect of Uie Ban Regulations.................................. 17 3.2 Suurory................................................................................ 18 4.0 IMPACTS CN USERS OF ASKAREL TRANSFORMERS......................19 4.1 Requirements of the Proposed Regulations. . . 19 4.2 Conpliancc Costs........................................................... 19 4.3 Eoonanic Inpact of Cbst Increases ...... 22 4.4 Sumnary................................................................... .... . 22 iii HONS 201313 TABLC CF or.mTTS (.Cant'd.) Page 5.0 impacts cn transformer service cc::?ANrr.s...............................23 5.1 Directs of the Prxrpcc^d Regulations;.............................. 23 5.2 Summery........................ 25 6.0 RSJXRCID LOCCi'DTTi" TROh'STCrMERS............................................... 26 6.1 Requirements of the Proposed Regulations .... 26 6.2 Present Ownership and Use........................ 27 6.3 Technical Alternatives for PCSs in Railroad Trmsfomcrs............................................................ 27 6.4 Coot Impacts of the Proposed Regulations...................... 30 6.5 Economic Dipacts of the Proposed regulations. . . 13 6.6 Summary......................................................................................... 33 7.0 OIL ITLLED POWER ANT) DISTRU30TICNTRANSFCR>ERS .... 36 7.1 Requirements of the Proposed Regulations............... 36 7.2 Estimation of the Extent of Trans former Oil Ccnteininaticn by PC3s...................................36 7.3 Costs or Ccrplying with, the Proposed ' Regulations .......................................................................... 41 7.4 Stemary......................................................................................... 49 8.0 MINING MAOtQEHf . . . . `................................................................ 51 8.1 Requirements of the Proposed Regulations...................... 51 8.2 Ownership and Use of PCB Mining Machinery .... 51 8.3 Compliance costs.................................................................... 54 8.4 Summary......................................................................................... 59 9.0 EI^aTOSVaJETS..................................................................................... 60 9.1 Requirements of the Proposed Regulations.....................60 9.3 Compliance Costs................................................................... 61 9.3 Suumiy........................................................................................ 62 iv HONS 201314 tafte or cznrNTS (cont'd.) Pace 10.0 HYDRAULIC SYSTEMS.................................................................................64 10.1 R-quirettrsits of the Proposed Regulations.......................64 10.2 O/rr-rrhip and us? of Contaminated Hydraulic Systems........................................................ 65 10.3 Compliance Costs........................................ 66 10.4 Summary......................................................................................... 73 11.0 HEAT TRAWSESE SYSTET3........................................................................ 75 11.1 Requirements of the Proposed Peculations.......................75 11.2 Ownership and Use of Contaminated Heat Transfer Systems . . . ............................................... 76 11.3 Compliance Coots.................................................................... 76 11.4 Summary......................................................................................... 77 12.0 COMPRESSORS............................................................................................. 78 12.1 Requirements of the Proposed regulations.......................78 12.2 Compliance Costs.................................................................... 78 12.3 Sunmary ................. ................ 79 13.0 RECLAIMED Oil..................`............................................................... 80 13.1 Requirements of the ProposedRegulations .... 84 13.2 Sources and Amounts of Contaminated Waste Oil ... 84 13.3 Compliance Costs.................................................................... 86 13.4 Summary......................................................................................... 91 14.0 PCB3 AS UmflENTICNAL PRODUCT CDOTSMEffiNTS...............................92 14.1 Requirements of the Proposed Regulations...................... 92 14.2 Compliance Costs.................................................................... 92 14.3 Summary......................................................................................... 95 v MOHS 201315 15.0 CAPACITOR Wi-TJRACICRU.'G................................................................ 96 15.1 rcquiron'cnto of tha Proposedregulations. ... 96 15.2 Capacitor Production and Sales,...................................97 15.3 Compliance Costs................................................................ 98 15.4 Surety...................................................... 108 16.0 mTKSFOKMER >W^T?TUKE;G......................................................... 109 16.1 Raquircnants of tine Proposed Regulations. . . . 109 16.2 Industry Structure, Production, and Sales . . . 109 16.3 Substitutes for PC3 Transformers.................... . . Ill 16.4 Relative Prices of Nan-PCBTrans footers .... 116 16.5 Canpliar.ee Costs..............................................................117 16.6 Scimery........................................................................... .... 118 17.0 TOTAL CCST AND EOCWCMIC EXACTS.............................................. 120 17.1 Transitional Cost Inpacts.............................................120 17.2 Long Turin Cost Impacts............................. 123 17.3 Employment Impacts......................................................... 123 17.4 Other Economic Inpacts................................................. 124 APPTIvDDC A - TOXIC SUBS'BWCES CONTROL ACT KEFERE'CCS V` HONS 201316 list rr Table Mo Paae 1.2- 1 Estimates of Cumulative t J3i Production, Usage, ;nd Gross Envn ronmental Distribution an the United States Over the Period 1930-1975 in Millions of Fcundj . ...................................... 3 L 5-1 Effect of the Proposed PCI Ban Regulations on Various Uses of FC3e................................................................................................ 13 6.2- 1 Railroad PCD Transformers................................................................... 28 6.4- 1 COst of Processing Rg'trofilled Ru-i freed Transferrer Liquid to Reduce the Concentration of FCSs . . .............................. 32 6.5- 1 1976 Operating Losses of Railroads Using FCB Transferrers . 34 6.5- 2 Labor and Overhead Costs of Retrofill and Processing Program for Railroad Transformers................................................................... 7.2- 1 Number of Liquid Cooled Transformers Manufactured: 1972 , , 35 37 7.2- 2 Annual Sales of Transformer Oil in the U.S..................................... * 38 " 7.3- 1 Preliminary Cost Estimate for a Chemical fasts Lncmerator for Transformer Oil Contaminated with La/ Concentrations of PC3s......................................................................................................... 43 7.3- 2 Annual Operating Costs for Contaminated Oil Incinerator , . 44 7.3- 3 Testing and Disposal Costs for Transformer Oil................. 47 7.3- 4 Testing and Disposal CDSL3 for Transformer Oil 48 8.2- 1 Production Statistics & Present Use Status of PCB-Ccoled Mining Machines.................................................................. 52 D.3-1 Cost Impact of Forced Retirement of PCD Continuous Mirers . 57 10.3- 1 Present PC3 Levels in Die Casting Machine Hydraulic Systems ......................................................................................................... 67 10.3- 2 Industry Estimates of the Cost of Draining, Flushing, and Refilling Die Casting Machine Hydraulic Systems ...... 63 10.3- 3 Estimated Cost of Decontaminated Hydraulic Systems ..... 70 D .0-1 Mow Oil Usage and Waste Oil Availability for :^cycling in 1975 81 15.2- 1 PCD Capacitor Production and Bales*. 1972 97 vii MONS 201317 us? cf c^rmiTD Table Mo. 15.2- 2 PC3 Capacitor Sales - by Year................................................... Pace 90 15.3- 1 Currently Available Mrr.~?C3 Pcwcr Factor Correction Capacitors................................................................................................ 101 15.3- 2 MinuTactute-rs of FC3 Industrial Capacitors in ]976 .... 102 15.3- 3 Manufacturers of Small liquid Dielectric AC Capacitors . . 103 16.2-1 U.S. Transformer Manufacturers Which Used PC8s After 1970 . 110 16.4- 1 Polativo Transformer Price3..................................................... 116 17.1-1 Transitional Cost Impacts.............................. 121 viii MOMS 201318 Figure No. page 7.3-1 Decision Criteria for Analyzing Transformer Oil for PCUs Z'eforc Disposal................................................................................... 46 13.0.-1 Distribution and Utilization of t-reste Oil in the United States Curing 1970-71 .................................................................. 82 Lx HONS 201319 1.0 INTFCDCCTICN 1.1 Purpose gril Scope lho purpocn of tliJ-S study (.-us to evaluate tile economic urpacts of the prcocsed "PCB Fan Peculations. '* These regulations were prepared by the Office of To:ac Substances of the 0. S. rhvircraiEntil Protection Agency with the technical support- of the Interagency FC3 Tor.< Group. These rcgulaticrv; urplmcnt the bans cn 'tnciu PCD cctiviticn winch were estab lish'd by Congress in Cccticn 6 (e) of the Ttodc Substances Control Act Public lav 94-469 Coca Appendix A). The economic costs reported herein are those directly and in directly attributable to those changes in future PCD activities which would be caused by irrplc;rantatier, of tba proposed regulations. From the wording of Section 6 (e}, it is clear that the intent of Contross was to bon the manufacture of FC23 after December 31, 1978, and to ban the distribution of polychlorinated biphenyls (PCEs) after June 30, 1979, Therefore, the long term coots of using substitutes for PCDs will be a consequence of this legislated ban on the manufacture of PCDs and not a consequence of dis cretionary regulatory actions taken by the Environmental Protection Agency. The effect af the authorizations in Section 761.31 of the pro posed regulations will, in each case, be bo reduce the economic impacts which, could have resulted from the immediate application of the bans set forth in the act to PCS equipment and articles. The costs which were es timated as resulting from these authorizations were the incremental costs bused on the pre-1977 base, and rat the changes frem the Iiighar costs which would result in the absence of these authorizations. However, the assumptions behind the analysis of the individuaJJLy identified impacts ore explicitly identified, and the analysis should support the evaluation of alternative regulatory approaches. -1MONS 201320 This analysis of the proposed regiilcticns considered both the direct costs of ccrrpJying with, the requirements and the indirect effects of these rcquircrcnts on price levels, capital needs, erplcyrant, energy consuirpU.cn, and the availability of strategic materials. The calcv.l. economic e*pects were the incremental impacts of the proposed regulations on a base of 1976 practices as modified by the previously promulgated ;C3 effluent standards and the marking and disposal regulations. The costs of these ether PQ3 regulations were considered during their development and arc not considered to be a result of these proposed ban regulations. PCEs have bean used in the United States since 1929. mjor uses of this chemical Iiave included transformer cooling liquids; capacitor di electric liquids; lieat transfer and hydraulic liquids; as a dye carrier in carbcnler-3 copy paper; as a plasticizer in points, adhesives and caulking cotpcunds; and as a filler in investment casting wax. A previous D?A contractor report^ estimated the usage and distribution of PC3s to be as shewn in Table 1.2-1. El) Versar Inc. PCTSs in the United States; Industrial the and Tnvircsmantal Distribution, burinCjiiiid, Vd.: TC.tional lt_C;riical Lmoiuratbn Service UThfi FD 252 102/jWp). February 1976. -2HONS 201321 Table 1.2-1 Estimates or emulative PCBs Production, usage, and Gross Envirorwental Diatritaitljon-ia the ttrftaiStatea .Over the Period io-7s >n n.iii^ nf iv,1in11 0.1. Id fipjuctlan Tvul i;.l ra t^ort* U s* fCD Daw*l UM9 itui o 8. fd oiporit W bi U* C-tef3fyi Ml jI ft MV far fltx InivltcUt CftY Clftf Uyi.Ui-.tk* diil Oilier J'lnU'.Iirr Vat# C VcVl* Ti diitfufrvfi UkL| tHh<x iKs* El:t(tul tQl flojf^iad or tfL/>fcrldi (-LNa*vrnC^ Lt y pjyr**ted (jCinUitvi UidllUi M KS* CS|. 1 TTlWH. rmJtlCVlOA \ ulUl tU- Online** OMur rtoil ICO* l tlM G.VJ rt1bvrit luiU vir *lr CaoncitU], rroOtssiJcn 1,400 1 l 1,401 1.151 IW 1,*01 1/Ouarrial rCDi Currant If flDl Currcnily dud^ui* ot iq In r<rvjce U* PCX'* l 29 it 4* 1) m 420 Hi -- ^-- tin 490 JM 1 ' 119 99 109 ISO 751 *49 19 21 a tllta'ied fMHvlllly M m 51 i'll / 2nt i 111 251 I 'A r 101 hi l ioi 1 Jul i 131 1 7b l i lot z 201 411 l <i ) 101 I *t HONS 201322 1.2.1 Production of FCts Hie major U.S. irnnufacturvu: of PCEs has been Monsanto. Since 1972, Monsanto has lira.ted talcs of PC2s to manufacturers of trans formers and capacitors. Mcncancc ceased r.anufacturing PCEs in mid-1977, and chipped the last ror.lining in'nan tor/ by October- 31, 1977. A previous UFA sponsored study^ indicated that about one mJlicn pounds of PC_x ware also manufactured by a r.tall chemical cumauy fron 1972 througn 1974 for use as a heat transfer liquid. PCBs may also be mode as unintentional by-products of other chemical processes. For instance, the manufacture of thn dry pig ment plithalocyaiv-ne blue by reaction of precursors dissolved in tricnlcrobenzena nay result in the formation of pces from reactions involving the trichlorefcanscne. These PCEs may contas'inniie the pigment at PCE concen trations from parts per mi.ll.ion to as much as 0.1 percent. Production of diarylife yellow pigments also results in the formation of dichlorobipb.cry1 due to a side reaction involving the pigment precursor dichloroLentidii.a. This results in PCI concentrations in the yellow pigment of up to several hundred ports per million. Chlorination of water wiiich contains appreciable concentrations of biphenyl (which is used as a dyo carrier in eying poly ester fibers and which, is a ctsnvon pollutant of water discharged firm dying plants) can result in the unintentional formation of PCBs to a concentra tion of several parts per million, Ko natural (nen-industrial) sources of PCBs have been identified. (1) Vcrsar Inc. Usaca of rCT-i in Co~r. cor! Fcra.-Clcved 5voter? xd the PesultLna Lcr.Ui' u or . ~ -o ilT"1' -'-mrerm -- t. eP.C Siry/i-TT009 (unpuoiJjsuod Draxt it ..art) topee:n;ar 1, jh>76. -4-- MONS 201323 1.2,2 Inverts of PC':- PCBs have been xiportrd for use in investment costing wax, for maintenance of certain mining mudiinery, and as the ccoLnt in electrical transiomars. ^ Decachlcrcbiphtnyl v.us imported from rtaiy for cevcral years for use as a filler in investment casting wax; this use was enr'-d in mid-1976. ^ Several itmufactutr'rs of imminent casting wax are presently using imported polychj oi-Loatcd tcrcbenyls (TClb) in their products. 'Zjs U. S, distributor of PCTs has given assurances that PCTs are present only r2) ' at concentrations Lclcw 0.005 percent, 1 but id data lire available on the actual concentration of PC's found in these PCTs. Over 7CO,OOCf pounds of FCEs have been imported since 1972 to maintain certain mining machines which, usci PCTs as a motor coolant. ^ _ No additional PCEs will be inported for this use as existing u.S. inven tories are reported to be sufficient to meat maintenance rcouirsTents fer tha rcnviining service life of the machines. and capacitors, present. PCBs have also been imported as corponents of transformers this source of PC3s does rot seem to be significant at 1.2.3 flydrauli.c System, Heat Transfer System, and Ccmarcssor Use pQJs have- not been ccrrarercially available for open system uses since 1974. Lea)cage of PQJ liydraulic fluid was replaced by FC2s taken from remaining maintenance supplies and, after these were exhausted, by (1) Vorsar Inc. Assessiiiant of trs Environmental ?r.d vcorcmic Broads of tha Ban on In .ports or rC..u. cfn GoD/ o- fr^SoTT'^^T^'"*. (2) Personal ccrmnicnticn, Mr. L. K. Argucso (M. Aryueso and Co., Mansuxnedc, N.Y.), August 30, 1977. (3) Vercar Inc. Assessment of t!*-* rnvircrrvr.bil end rccnonuc Lmrctt cf tin Can on Inriortn~or b".' ^ juO/G- t -vjV, juiy , 15=/ 7, pp i, To. -5MONS Z013Z4 compatible ncn-PCB fluids. As a result, the rcic in service in these ma chines in the early 1970*3 hive tom cli'lubd. InXceration cbt-aincd dunr.g the coureo of this study through a pho.-.e sur.ty of uiero of ttr -ia system indicates that the iluid presently in the iv.cniucs ray contain fitmi 0 ppm to 50 percent PCs, depending on the amount of leakage and replace.'ittnt c\tr the pent five yean;. Hhan Monsanto ciccentire.d the nnr.uf ctoro of rc bared heat transfer liquid in 1972, they reccr.vrer,clod that existing systems be drained and flusncd and the liquid replaced with a ncn-PCB liquid. A num ber of systems were maintained throuefi 1974 with PCs manufactured by a snail chemical company, but no PC3 heat transfer fluids were manufactured or Lrportod after ]974, and it is believed that all systems have been drained and converted to ncn-PCB fluid, 'll1.a effectiveness of the initial ' flushing procedure is known for only one system which was flushed in 1972 and presently is using a fluid which is contaminated by two percent PCEs, PCBs were used as a working fluid in a number of turbine compressors on natural gas pipelines in the early 1970's. Although the rCB oil has since been drained and the turbines flushed and refilled, residual PCBs ate present to a concentration of i? to several thousand parts per million in the oil. Another use of PCBs was as a minor additive to certain automobile transmission fluids to cause controlled swelling of rubber seals. Although, this use stepped in the early 1970's, waste lubricating oils have been reported to contain PCPs in concentrations of parts per million. Transmission fluid from older automobiles nay be the source of this HONS 201325 unintentional contamination of wonte oil, but no inforrviti.cn 15 available on the extent of FC3j in transr.ussicn fluids. - Contaminated oils have not bean oc-grconted from the flew of oil collected for reclamation. As a result, :moh of the oil presently handled Ly the waste oil collectors, processors, and it*-refiners appears to fco contaminated with lew levels of FCDs. 1.2. A Transformer .Vonulacturino sr.d Mnnttirar.03 Most largo electrical transformers arc dosin',ad to cccrata with the currcnt-cotryir.g coils immersed in a dielectric liquid. This liquid provides electrical insulation Lcfvracin the windings by filling in any pinholes in the enamel cr paper insulation, ''ha liquid also par-forms as a heat txnnsfor media Ly absorbing heat from the coils and conducting it to the outer shall or heat transfer surfaces by natural or forced ccn- . vecticn. Most liquid-filled transformers are cooled with mineral oil. This oil can present a significant fire hazard in the event of a short circuit within the transformer. Therefore, oil-filled transformers axe not allowed to La used in hazardois locations such as buildings except when installed in a fir?- resistant concrete vault. In the past, most transformers used in hazardous locations have been filled with non-flammable coolant liquids containing PCQs as a major component. Thcsa PCD transformer liquids are krot/n by the generic tern "asharel" and have been in comon use since the 1930's in Iiazardcus trajisfouTur applications. Although U.e FC3 filled transformers have ccct 20 percent more than oil filled units, they liave found wide use as they are non-flfjurrable and more reliable than oil-filled transformers. The manufacturers of PCD transformers discontinued manu facturing PCD transformers by the end of 1977. There are presently in use approximately 1*50 ,000 PCB transformers which contain an average of 300 gallon* of liquid (2,150 lb PCS). Tlx? average service life of these -7MONS 201326 askard Lrnnsfomidis is about 40 yours, if curtain routine maintenance 13 performed. ' The electrical orcr-ertics of .I'jfca.rel are significantly degraded by the pretence of roiiturc. Thermal cycling of the transformer during normal use can d: :,w air into trio teens forear thiouce minor leaks in bushings, and the askarel will absorb moisture ire.n tiiis air. It is routine practice to check the electrical properties or tile osknrcl periodically ac intervals from 1 to 5 years depending cn rntnent air rroisture. If noisture is detected, the askarel is drained and filtered (to remove the moisture] , and tha bushires are repaired. T5tic maintenance, usually performed in the fieJ.d, is necessary to assure continued safe operation of the transformer as severe degradation of the ask anal can causa nu^or arcing within .the transformer. ' Similar maintenance has been routinely performed cn tha ' several million oil-filled transfoirrars. The oil in many of these units may fcts ccntamincd with PCDs to a concentration of several hundred parts per million due to past use of the same equipment to service both oil-filled and askarel transformers. It is also possible that PG3 ccntaminaticn of tha oil muy have occurred in the manufacturing process where plants rede both oil-filled and acJcarel transformers. Disposal of transformer oil has bean through ccrrmorcial wasto oil haulers, which has apparently further increased levels of PCD contamination of reprocessed and reclaimed oils. 1.2.5 Electromagnets Several hundred electromagnets have been manufactured with PCB oil as a coolant. These magnets are used as magnetic separators over coal conveyor belts. The magnets are similar in construction to trans formers. There is no present use of PCBs by tills industry for cither manufacturing or maintenance. -0- MONS 201327 1.2.6 G'nacitors PCEs have. been 'ircd as the liquid dielectric in almost all AC (alternating current) capacitors nod? in the United States since the rud- 1930'o. FClit arc unexcelled m their properties of chemical stability, fire rcriatar.cn, and high dielectric strength. Although, no ether dialec tic c liquids equivalent in porfonrar.ee to PC3s have been do, sloped, oC.;r liquids are being ucad successfully in capacitors which perform the s-siss function as PCS capacitors. All of the manufacturers of larcya spc-^cr fic'scr capacitors have switched to ncn-DC9 substitutes. Most of the manufacturers of small capacitors have cither stopped using FCEs or announced their in tention to switch to other liquids early in 1970. ' Prior to the enactment of the Toxic Substances Control Act, the only authority of the nrA with respect to PCEs dealt with discharge of con taminated water from industrial point sources. Cn February 2, 1977, the FPA premtlgatcd regulations under Section 307 (a) of the Federal Water Pollution Control Act which banned the direct discharge of water contami nated with IXSs by electrical transfocrer and capacitor manufacturers after February 1, 1978. ^ - The enactment of the Tbxic Substances Control Act (in Cctcbcr, 1976) placed additional requirements on the use of PCBs and required that certain actions be taken by the F.PA. Section 6 (e) (1) of the Act required that the EPA promulgate marking and disposal regulations for PC3s. These regulations were prtmulqated on February 17, 1978. (21) 2 The regulations re quire that special warning labels be applied to I*C3 equipment, containers, (1) ESA "Final Decision" Fadar.i-t r.~-is ter, Feb. 2, 1977, pp. GS 31-6555. (2) EPA, "Polychlorinated nlrh(iT/.ln (F05) : Dixs-mal and .'burking," Federal roister, February 17, 1978, pp. 7109-7164. -SI MONS 201328 ard storage areas. The regulation, aloe require tKit disposal of ?C3 liquids, materials and equipment by by approved no'brxls (generally high temperature incineration or chemical waste landfill) end establish approval criteria for the disposal facilities. The Toxic Substances Centro 1 Act also established cutoff dates for certain PC3 activities as follets; January 1, 1978: January 1, 1579: July 1, 1979: All nvuciacturing prom sing, distribution and use rust be in a totally enclosed muter. Co further mnufacciring or importing of PCEs allowed. " No further processing or distribution in com merce of reds alleged. The proposed PCD Ban Peculations implement these requirements of the Act and also authorize the continuation of specific activities where the CPA has determined that cud', activities will rot present an unreasonable risk of injury to health, or the environment. 1.4 Snrrviry of Pioooscd Can Peculations The continued manufacturing, processing, distribution in canterc and use of PCBs has been regulated by Congres3. Section 6(e) of the Toxic Substances Control Act (Public L. 94--469, 90 STAT 2025), established various restrictions on FCS activities and the dates on wiiich these re strictions become affective. EPA is required by Section 6(e) to establish by rule several technical findings regarding PCD activities. These find ings must establish: (1) The level of exposure of human bsinrs and the environ ment to PCEs that may h? connic1 "-'cd insignificant [Section 6(e)(2)(C)]. This level of exposure is the basis for judging v.r.athor any activity or use is in a totally enclosed nvonrer." -10- MONS 201329 "t2f- MlcLher ccrtnn uin pro? tnt t^n unro-isciihle rick to health or tin; ci .^cnwit. This cr;`oric.i is to to used os the i.si-. ior -u',,hor,,-:atiC'r.> of -ota.vi.tLe5 that axe not ccr.uectcd in a totally enclosed manner, and in evaluating petitions f. ?r ere year cmroticns iron the mandated bans on the mimviacturing, processing, and distribution in corj-arcc of FCTo. It action G(a) (3) CO)]. C31 Those activities unich, although not concocted in a totally ciclccod "inner, nevertheless wii] rot pre sent an unreascr iole rush of mgury to healtn or the environment. [Section 6 Co) [2] CBJ ]. The proposc-d "PCS Elan Regulations" state these findings, incor porate the mandatory requirer-ent, established by Congress, and would grant authorisations for continuation of certain activities based on the findings. These regulations were prepared by the EPA Office of Toxic Sibstancss in cooperation with, tic Interagency PCS Work. Group. The basis for the proposed regulations is the finding that there is no identifiable level of PC3 re- lease to the envirc.vtrsit that can be considered insignificant. Therefore, only totally enclosed activities such as continued usage of existing trans formers and capacitors will moet the criteria required after December 31, 1977. The Toxic Substances Centro1 Act grants the EPA authority to permit other PCB activities after the end of 1977 if the activities do net present an unreasonable risk to health or the environment. Acting under this authority, the EPA in the proposed ban regulations wuuld permit tie fcllowing PC3 activities in other than a totally enclosed manner. (a) Continued minor maintenance of FC3 transfonrers to minimize the ccorcraic impacts tint vculd result from premature rctirevent and lack of replacement units. <b) Continued use and scheduled phnse-out of use of rCD railroad loccmativc power transformers. 11- MONS 201330 (cj Continued use ar.d scheduled ;hnso-out of e-o of PCSfilled r.otors used cn certain mining cqui[ .rent. (dj Continu'd use of certain hydraulic systerre contami nated v.\th FCSs if offorts exc ocxiodicall/ r.'ade to deoonUmiinate the systems. (c) Use of ovate oils centamijuted with PC3s balov a con centration of 50 pan, except an a sealant, casting or dust control ay -nt. "ins could ban too u;e of oil centvnir.r.ted with. any nr:nr;ible arourt of ?C3 for oiling roads or as a pesticiue earner. 1.5 Effects of the Proposed Regulations bv PCS Use Hie economic impacts resulting from the proposed regulations were deter.Tun.od by evaluating the effects of the regulations on each identifiable PCB use. lhe report of the analysis also addresses each use in a separate chapter, and tie format of the repart, therefore, does not parallel the format of the regulation. A guide to the discussion of the various sections of the proposed regulations is presented in Table 1.5-1. The various cost and economic i:.pacts are surmarised in Chapter 17. x -12- NONS 201331 Table 1.5-1 J-ffeefc of the Prrr.pc?;^<i PC3 Ban Ferula tncim cn Various (h-a, of PCT'J subfvuT of rropcai'd PCS Km dentiljL* on Guottr of report Di.as'uM Ir^wcts | SU S3 b li . ;l Mi C, r> !' dd t. 23 1 1 L i vl- 1 | "l li * () 1 L/ 1 ' [1 J If f| k ' :: p d3 _< i .-t 1- r* r in J -* -1 (j J r. $ 32 fi i/> f* (J L3 li 1 a n u 1*1 u t. Li ~ ) it -. . VI Vf o 3| 5 O ** O dt 3h 0> CT p 1 if .ii i' ; C1 t1 J, .=] `i c fr ji r ** iX I r-4 o *4 <0 os CN ri k*"t n r-f A3 Deini tia\3 to) renj (w) tlzruro (or) Dj.t Cr itrol .V^nt (till Prtvt on a JO Tc-' tally Dtcl. KJnrcr (Li.) KviCn Oil if) (1) (0) Tranofor-'r, (Ml )rj-*ii Unit 1.00 rpB C (a) (3) (i) Tiwiaformr, PCS lCLLtl til'll '00 ppi D PirfitMiio'-i 701.20 T>A. Fncl. Mvwer ini K*nuf. t na/t CKCcst In totally enclosed iner (b) 1-1-79 Kaput, 4 Osn KS1 (c) 7-1-79 I'latrib. bin ' 761.11 AutfcorLaatirn* (a) Tmnafomr'r forvJcing (b) Vrr-.-.forrur Dlatn-bu- tim L.1 (c) Ft.tlfop'l TrrnnforTum (dl Kinlnq Hdumj (t-l Hydraulic SyJtuW Annex VII - Spill Ctxitrol Plus X X X X X X X XX XX XX XX X -X X X X X XX X XX XX X X X X X X - X XX XX * XX XX XX XX X X X XXXX X * X XXXX X X XX X XX X X XX X X X XX XX "13- NONS 201332 2.0 MPTHCDOLCC/ TOR ECCNOMTC litPACT MFi.YSIS GF T.Z PROPOSED "PC3 SAW RfcXSJLATICt*a" _ 2.1 Genera l Acprcc.cn The approach used in developing the econcxuc impact analysis of the proposed "?C3 Regulations" is svaimcizod beiew; (1) Each industry significantly affected by the drain regulations is `cansidt=a`cd separately, The ar.alycic.al rru-thcdology used is the same for each industry, and the results era presented m a loimt permitting aggregation. ' (2) Analysis is United to impacts expected to result frem the proposed ban regulations, lb3 Impacts are the tnermental changes fran a base condition assumed to be the industry practices in 1975 as ircdific-d by the FC3 effluent standards, and the PC3 Disposal and lurking regulations. '' `" (3) Increased industry costs due to the use of substitutes for PGJs and the resulting product development costs or the costs of dis continuing certain products are the basis of the calculation of cost hirpncts. The resulting price and product quality effects are used to calculate expected changes in demand and market duffs among carpeting products. The impact of these market effects on individual industries is used to calculate employment changes. (4) Each indiistry is regarded as a link in an input-output drain or web. Thus, changes in output affect cos tar-or industries and, logically, costoners1 customers. In most cases, the economic analysis is extended only to the first tier cos tenors, and second ary impacts vrere assumed to be negligible. -14 HONS 201333 (5) The chain effects arc al*>o traced bucJr.nxd at least enc etree to suppliers; pcica, qualify and doltvety effects arc considered as determinants of quantity detrended. (S) At each stage (suppjier, dircstly impacted producer, custcrer) , impacts on the varicus factors of production 'cars considered. Physical factors of production at each stage include labor, materials, ccui^runt, factory space and land. There may also be impacts on fink'd and. torkir.g capital requirements ar.d capital . markets, including rental or leasing arrangements. (7) Significant externalities are considered in the analysis. (8) The analysis considers only the costs incurred by tha regulations. No estimates are cede of the benefits to health or the environment achieved by banning the use of PCBs. (9) Distinction is made betv.cen transitional and long term effects. ~ Transitional effects include the costs of premature obsolescence of production facilities and equipment, retooling, reneoroh and development, and temporary unemployment caused by market emits. Long tern effects include increased prices and changes in aggre gate market demand. -" The economic impacts for each affected industry are tabulated in the following format: Variable price of outfit quantity produced labor employed Transitional hroact Long Term Imoact -15- MGNS 20X334 Secondary oconoruc effects winch ore aiscu-sod wnere relevant include wages paid, materials used, product reassign, n^w mvesboant, space require ments. servicing costs, product reliability, fire safety, and analytical testing costs. Impact is defined as the charges resulting fran tho lmplotventaticn of tiie regulation. Calculation of the impact requires tint the base con dition be carefully defined to occlude the effects of the proposed regu lation but to include the effects of standard industry piactices ard other relevant regulations and laws. In the pLesent case, the base period used to define industry practices is assured to be 1973. Thus, the effects of the voiuntary ban on open system uses of PC3s that was taken by Monsanto in 19,'2 is fully reflected in the base condition, but other actions taken by industry in anticipation of the requirements of the Toxic Substances Control Act do rot affect this base condition. The impact analysis then distin guishes the impacts of the proposed bin regulations frcm the effects of the rCD Effluent Discharge regulations, the PCB Disrcsal and Marking Regulations, and the ban provisions of the Act which caused Monsanto to cease PCD production in 1977. Versar used two major data resources to establish the base condition: * (1) Testimony at the public hearings in Washington {July 15, 1977) and in Chicago (July 19, 1977); and (2) Interviews with affected parties, conducted mostly by telephone with information contacts established by versar during previous PCBs study tasks. -16- MONS 201335 3.0 ]>7\cis<?r ivi'is c Tire distrix'ticn of pcb cap/citcrg and Ecyirf-nri ' The proposed bon regulations would require that FC3 capacitors ret to installed in newly manufactured products after Decamber 31, 1978, and that new equipment containing PCB c-pccitcrs not be distributed in commerce after June 30, 1S79. The bail cn manufacturing '.oula apply not only to era instal lation of a capacitor in a piece of electrical apparatus, but also to tr.e installation of any 1PC3 Equipment1 in a larger asseiibly, Tor instance, the December 31 ban would apply to the assembly of a PCB capacitor into a lighting billatt, the asscutbly of a PC3 ballast into a lighting fn-.tito, and to the assembly of a PCD ligntung fixture into a subway car. Buildings con taining PCB capacitors, however, are specifically defined as not being 'TO Equipment' . The ban on distribution of newly manufactured goods in connerce would also apply to all of the varieties of `PCB Equipment'. 3.1 Effect of the Pan Peculations Most manufacturers of ac capacitors switched to substitutes for the PCD dielectric liquids Ly early 1973. No FC3 capacitors are expected to be manufactured after August, 1978, when Aerovox Corporation expects to exraest its inventory of PCB liquids. Manufacturers who use PCB capacitors as com ponents of 'PCB Equipment' will generally be able to use up their inventories of FC3 capacitors by the end of the year, and little inventory loss is expected. The greatest impact of this portion of the ban regulations may be on retail inventories of appliances such as air conditioners und television sets. Units manufactured before Eecnrber 31, 1978 with rC3 capacicors tray not all be sold to the ultimate user by June 30, 1979 when their further 'distribution in ccicncrce' would be banned. The practical effect of this bun is not expected to be great since such appliances would not be labeled as PCB equipment (since the labeling requirement dees not became effective until January 1, 19791, and the appliances would be widely distributed in retailer's -17- HONS 201336 inventories. 'The limited number cf items still in inventory could not easily be identified, ard the practical difficulty of enforcement would limit the real impact of the reguu. Lion. Should any special situations result in large numbers of new PCS appliances in wholesaler's or retailer's inventories cn June 30, 1979, the owners of the units could apply to the SPA for a tempore ry exemption front the provision of the ban regulations similar to that /inch is discussed in the prcanbla to tl-.u proposed regulation for the continued usa of PC3 cop':citors in the repair of electrical equipment. 3.2 Suirraxy The only impacts of the proposed bans on 'distribution m certrurce' may te the obsolescence of certain retailer inventories of PC3 appliances. Options available to suen mulcted parties include the replacement of PC3 capacitors with r.on-PC3 units, or the application to the IIsA for an excep tion to the bon regulation. Total coots are unlikely to exceed a few hundred dollars per affected establisnment, ar.d would likely total loss than cne million dollars. The practical difficulty Ln enforcing this part of the regulation will probably result in real impacts considerably lower than these estimated amounts. -10- HONS 201337 4.G IMPACTS CM USERS OF ASKATHX TrhUSL cr.MERS Vercar estimates that tncra arc about 110,000 tskarcl Lrrjisfccrcru xn use. About 1,000 of these arc being used on raiirc-id locomotives and ccrvmutnr cars; the impact of the draft regulations cn these rax] road ice. nauivtis 15 discussal in detail xn diopter 6. Of Lae remxaxr.g units, rose fio fed mounted distribution ana power Lransienmrs located xn bull'll-,gs and elettrve generating stations, with a substantial nuifccr of oekarol precipitator tiancfomurs being mounted on stacks. The distribution of ownersnxp of tbt;e traiixfoirnrs is sunmrized in Table 4.0-1. With an estimated'average oi 2,500 pounds of FCEs xn each trancforxar, the total in-service inventory of PQ3s in transformers is approximately 300,000,000 pounds. The transformers are owned arid mauite-mcd by either the utility or the user, depending on the business arrangements nude at tho time of each installation. Table <1.0-1 Estimated Nlirber of PC3 Transformers in Service Category of User Utilities Industrial and Ccrtnercial Railroad Number of Units 42.000 97.000 1,000 140,000 PCS Content-Pounds 105,000 ,000 191.000.000 4,000,000 300.000.000 4.1 Roouircments of the Proposed Regulations The proposed ban regulations forbid the major rebuilding of askarel ti on-> formas. Therefore, failed askarel transrormrrs would have to fc<s replaced with suitable non-PCD replacement units rather than being rebuilt. Increased costs will be incurred at the time of failure of all 140,000 exist ing askaral transformers. 4.2 Qanpliarce Costs Foregone Sawings fvont Rc"mldi>v7 If it is assumed that a roplaccmant transformer of a satisfactory high fire point liquid cooled design would cost the same as the historical -19- MONS 201338 price for an askarcl transform1:2 (res Cirpter lu) , and flit rebuilding -cold cost 703 of the coot of the transfer , r if allowed, ^ then the tore--,ore savings from banning rebuilding cl eskaral tranform*vs could be 301 of the cost of the units. Eased on an average cost of $20,COO per transformer, fore gone 'livings will Ixj $$,000 per a-'tarel tranrsfornor. Total foregone savu-q* will depend on tl.e properncn or asxnrel transCoimavs 'Inch ere scrapped because ncn-rccanabJo failures or obso lescence rather than because of repairable failures. An active market in uscc askarel transformers existed m the past, but this market has become rear. let: active over the oast year beenute the provisions of toe water pollution control regulations and the Cfi-A regulations on marker exposure to PC3s have increasei the risk of using uskarel transformers. Mo data is available on the proportion of asltarel transferrers that are removed from service prior to failure, and even if historical data were available it could be misleading because nost askarcl tearsfor.ro.ts have net boon in service long enough for aging of the insulation to increase the risk of failure of the units. It is likely, based on Vcrsar's estimates rather tnan on hard data, that one-third to tota-thirds of the existing askarel transformers will be retired, due to obsolescence prior to failure. The tot-nl foregone savings would therefore be $6,000 par unit x 1/3 to 2/3 of the 1*10,000 units in service, or a total of $2S0 million to $560 million. _. Timing of these foregone savings will depord cn the rate at which askarcl transformers fail. Present failure rates are low because of ere relatively young age of most existing units. A previous EPA sponsored studyustimattd that approximately 30,000 gallons of PC2s ware used m (1) ltucd on a consensus of industry estimates obtained by Veroar during a telopiono survey of transfer: or manufacturers and rehuildrrs. (2) vercar Inc., PCT3 in the rn* tod States; Industrial U~~o ard Envi-cr-ontol Distribution. Springncl-, VA: National Technical Inrunraticn c.rvice, (NTEi PB 252 402/3W?), Fchruor/, 1976. p. 114. -20- M0NS 201339 the rcr-n* of ask-jj-'d trarsfov . rs in 1971. 7rcuminy ,m average; trrr.s former capacity of 240 gallons, of rc.I; (.'00 gallom of 'ajk.aaL' nu-<turc) tms implies tliat a total of 335 n:A -rcl transformers were repaired during that year. Tins wtuId have to be considerr 1 a lower fcc'inl estimate of the future impacts of the tin on rebuilding as `J'.u rate of failure of aa.kr.rel transferrors is expected to irr.rtat, > as the r.vLrrga age increases. An upper bcurd < ?Lunate might rc-'-onably be r'sed on tii average e'-poctod remain.'rg service life. If it is a.'iui id, for eri,pie, tint or.o--half of the exasbirg nsJorel ir-rrfcnr.are will be rmoved frem service over the rent twenty years dva to failure or obsolescence, an average rate of removal fre.n service of 3.43; of existing i units it implied. If the probability of failure or removal were in.e-pendent of the age of the unit, it would be expected tint 3.4% of the 140,030 existing units would bo ictarcd m 1979, or a total or 4,760 unite removed, of which 1/3 to 2/3 (1,507 to 3,173) ;u.ld have failed. Use range of expect!"! failures would therefore ba about 335 to 3,173 transformers par year, resulting in annual costs due to foregone savings of $2 million to $19 million per year during the next few years. At an average failure rate of 47G0 units par year and, an averacrc rebuilding ratio of SOI, foregone savingg would ha $14,280,000 m 19 79, test Sex`TJ'i.('p Time Transformers can bo rebuilt and returned to service m Loren to four weeks, compared to a delivery time of 12 to 16 weeks for new units. In the case of many snail manufacturing ccrnpain-es, failure of the single tranc- " forncr which supplies all of the power for the facility can stop all oper ations until a satisfactory replacement unit is obtained. It is likely that a greater supply of replacement units will become available m response to a growing demand for fast restoration of service. This increased in;eatery of spare units will result in increased costs to the companies maintaining the units and increased prices to the users who will be willing to pay mare to avoid prolonged loss of electric service. There is no information available as to the costs of renting replacement transformers, but assuming a reasonable menthly rental of 2% of the cost of the unit, total costs due to the longer -21- HQNS 201340 lead tiros Cor replacement trinsfcnrcrs ocu.ld I'crea' o by the cost oC fvo to three month's rental of on average 5*20,000 aut or T300 to $1,200 per Called transformer. Eased on the asmrr.od ntr.uiar and frequency of asbarel transform or failures, total costs doe to lost service tore* would ho. ($300 x 140,000/3 - $37 nullion) to ($1,200 x 130,000 x 2/3 -- $112 null .on), and annual costs of ($000 >: 335 units $2G0,Q0G) to ($120 x 3,172 units = $3,COO,COO) -sould be expected, with an average cost of (.5 x 47C0 ur,*.ts x $1000 rental per unit = $2,330,000) expected )n 1070. 4,3 Ecrear.ic Xnv-^ct of Cost Increases The increased costs to users of ar.karel tranvformers will be home by the owners of the units. 7-pprcoamataly cr.e-h.alf of tha units are c.vncd by utilities, and their increased costs are expected to be factored into tns rate lyise and passed aJ.ong to the users of electricity. The other lislf of the units are C'/ned by major office and apartment buildings and by shopping centers, factories, arrl other establishments, Increased facility maintenance coots vould be incurred by a Large number of facilities. Significant micro economic impacts are not anticipated, and no changes in the level of employ ment frem microeconomic effects is expected. 4.4 Summary Ccnolicrac ~C3t3 Foregone cavings from rebuilding Lost service time Total 1979 $2,000,000 to $19,000,000 ($14,230,000 Lost estimate) $268,000 to $3,000,000 {$2,380,000 best estimate) $2.3 million to $23 million Tbtnl_______ $280 million to $560 million $37 million to $112 million $317 milicn to $672 millicn Finvtevment a r'/tc : Sane short term lay-offs possible due to 3 nek of back up transformers. Impact' my be limited to small manufacturing firms. -22- HONS 201341 5. o EMP'\r,r>s g-j Tr.~rTcr --: ;r7To'-hrirh Maintenance of o.ckcrol tra.r fc.-rrrs is usuiliy contracted cut to specialised service chops or to the n.-.rufacturrr or tha unit, Major rcLoiiding is usually perforated by the m-uvoiaecurcr, Tharo arc cpprcmTdtcly 250 ."mull service campon) cs winch o-n ^ rfona rcat-ine transformer servicing such as gas hot replacement and testing of tj-.a liquid. Bared cn a telephone canveVi, of independent ccmronics vnich service srei repair transfenrers end cn infcrirviticn obtained during visits to GE raid Wosung house snrn.ee sr.cyc, it ic iv-patent tJiat causing PC3 transfer:'cr re quiring in-shop re;Mir vork aid being serviced c.ily by tha GO and "eatinghouse service operaticas. These tut companies Iiavc reduced the number of shops presently peicrutted to service FCB transformers to 15 and 8, respec tively j for a total of 23 chops nation,/ice. ^ These shops are poriormmg the major warontee jiuuitci'anco for both CZ and he51mg-house ar.d for the other transformer manufnccarers. There are approximately 250 email electric apparatus service shops winch repair tr.innfoi'r :rs. ^ These shops no longer work cn askart.l transformers because cf the neks of major cleanup costs ard worker cspo'cire that would be incurred by any accidental spill. 5.1 Impacts of the Piocosid Pccu) ations ., The effect of the proposed regulations would be to end the practice of rebuilding transformers, but there would bo ro constraints on continued minor field maintenance. Tha effects would therefore be limited to a de creased demand for the major services performed by the service shops owned by tlto manufacturers. These same orxajuos would be faced with an increased (1) Versar Inc., PCEl Activity AnaWsis Pacers, Special Report, EPA/OT5, July 11, 1977. (2) Electrical Apparatus Service Association Inc., 1977-1973 yearbook, St. Louis, MO: 1977. -23- MONS 201342 don-rd for new" transformers. Ascunum tbit r.i\uf; c taring and rebuilding arc equally labor intensive, there voutd hi a charge of: cmploym'tt from the? i.;rv:oo shops to the centred manufacturing plants, but rro not change in erployrent. A rough estimate of the crmloymr>nt effects may bo calculated from the total of the transformer rebuilding busin'ts. it vas estimated in Chapter 4 that a minimum of 335 asbavcl transfer,sir:: arc rebuilt each yemr at an estimated cost of 514,OCO tmeh (70% of an average $7.0,000 t^r unit rcplrcv- merit cost), resuming that one half of the coot './as dun to direct and rente: labor, the annual payroll resulting from this activity v.ould he equal to (335 >; $14,000 / 2 - $2,345,000). Assuming an average burdened labor rata of $30,00q per year, this payroll is cquvilunt to 7S full, tar'll jobs. Since the estimates of percent la).or and annual voces are rough estimates, the employment impacts might be better stated as ranging from 50 to 100 jobs. It should be noted that increased employment at the manufacturing plants will offset these jcb losses, so any structural une, lployment frust be considered to be a transitional cost of the regulation. ' The FOJ disposal regulations require that units be drained and flushed prior to disposal. Survey of a number of users has indicated that this will usually be contracted out to experience! reliable trua,foraor service organist .ions. This increased demand for the services of the larger (usually manufacturer cviod) service chops may offset most of the business lost by the bon cn rebuilding of asJtarsl transformers. Therefore, the draft bon regulations are not expected to have a significant economic impact cn tho transformer service and maintenance industry. Hie only direct] v iuentifiob]c impact of the draft regulations cn transformer maintenance corpenies is tho requirement tint a spill prevention arri control plans be prepared. Preparation of these plans and the required professional engineering review may require four nun-days of effort and result in a cost of S1000 per firm for firms handling ashard transformers. iWr. ,.ould tend to bar the aiull operator, resulting in minor market shifts. Cost of the required plan could equal $1000 for each of about 100 firms, or a HONS 201343 nuximn .total cost of SICO, 000. If profcrrra plans <*ere prepared er.der the sponsorship of a trade associit'.on or rr.iJo av.ul^le by a .ujor .tuiiuj' tear ex, the only costs to a .Trull operator ^cuid be on day of service; frerr a registered professional engnef to adapt, review, and anptove the plans. The cost of this service should run about 5230, reducing tire total costs to a range of 525,COO to 5100,000 for roill ccntircl plans. 5.2 Suinrviry Lost tc.gn (trarnorary structural uncarployrrant) Anntvil Costs (1573) 0 to 52,5-15,000 _ Total Cert 50 to' 52,2-15,000 Spill prevention and control plans Ttjtal $25,000 to 5100,000 $25,000 to SI 00,COO $25,000 to $2,500,000' $25,000 to $2,300,000 -23- HONS 201344 6.0 PAILrnAD ECOCtDTTVE Tsrusrcrrj-is The railroads in the noriceastern United States frein Washington, D. C. lo K:w York and nearby areas are electrified. Die po-er to the loco motives and so]C-po^ered cars is curried to tr.a equipment threugn hjii vol tage cc catenaries. Transformc-rs on the Iccc rotivi; and cart reduce tT-c voltage to that recoiled by the traction motorr. It has been standard prac tice to use asiarcl C1C3 based) liquid in trice transformers cue to tic links thac would result Iran spills of ilcjorrhle Jjquid following an .* cor don t in a tunnel. ' 'Ihe transformers in the railroad lecccotivcc and transit cars are Jaiavn to bo n maintenance problem because of the design t.unitetiers imposed by apace requirements ;x,d because of the severe chock, vibration, and mechanical impacts encountered in service. Lcatage of PCSs is r.ot an unusual occurrence, and control and diqxcal of this leakage is impossible as it is ' usually sprayed on a well-drained road bed. Therefore, the railroad trans formers present a significantly more severe risk of loss of PCSs to the environment than do stationary traceforms. 6,1 requirements of tha Protcsed r.tqulaticns ` The proposed PCB ban regulations will allow continued use and maintenance of railroad locomotive and car trrns formers for five years, but with the following limitations: 1. Each owner cf a PCG mlrced transformer must report the liquid volume of eacn trans fornor to the HA withm 90 days after the effective date of the regulation. 2. Each, person who uses a PCD railroad transformer rust de velop and implement a formal spill prcvrnticn and control plan. - 3. The concentration of Pds m the dielectric liquid in PCB railroad trens formers mist be reduced to bolcv four -26- HONS 201345 percent vntdiin In rmdh-: after the effective date of the rcgulatr;.?. Tu: r:U Lint the tr. '.sfonnii' bo drained a..d fit.1 rd to rcr.ovu the PC3 liquid ord re filled with a nor.-iCE liquid. 1 Trunnioi-rcr J^cuid .rest bo coaly cod lnrudiatcly after tbs triurirnr.' ..j_ is retrod l lad cv tlvj liquid is proi-e:?d '13 dccr&ru U-<? cct'ccr.tvow. ion of PCo. This anriy-id mv bo iquU'd tut ;oi 12 er.d di i.tv'-bs after ench eten c vicing to c\ .or;n..o `du- id-;or FC'.b lorchinci cut cf the w ingi have mere red the ccreontrroUcn to greater thin -- moxinvjn dllc/..-d by lb 5. The concenmotion of PC's in the dielectric lirmd met be rcdixcd trj less tran 0.1 percent within three years of the effective cbte of tho regulation. 6.2 Present Cencxihio and Tea ilie cwr.errhip and use of PC3 transferrer? installed in railroad locoraotivoo and ccmiutcr cars 1s sunmarized in Table G.2-1. Present plans are to convert the electric pew-ar cn the Northeast Corridor iron Washington, D. C. to he,'/ York City to GO hr 25 KV by the raid-IS30s. The Nov Haven line north of New Ycric ray oa converted later in the 19G0s. As a result of this change, new tramfomurs will be required in sera of the cars, and the oldest curs and loccrotivc.5 will be retired from service. The effects of tills vol tage change on the transformers in each type of car is indicated in Table 6.2-1. " 6.3 Technical Alternatives for PCC--: in Railroad Transformers PCEs have fcacn used in nilrccd transformers to decrease fire hazarcu in accidents. European practice has traditionally been to ire mineral oil in this application, and this dcc3 not appear to result in an unreasonably hazardous condition. The Japanese National Railroad retrofit lad a niarbour of locomotive transformers with silicone fluid and has operated them successfully for several years. A^HTAX hu; recently been testing an experimental loccmntiue on the Northeast Corridor (built in Sweden by ASEA) -27- MONS 201346 TABLE 6.2-1 Ou>W* 6UTA 2EPlA ttfjlfl irtfjrtjftCil tOrt* l6 yilwrltnar l Spi| TytaC* aw. an. 6LVfc\ SilverllWir 2 9i)vri iswr J LfcJ'lA Mtukllivj} ' (i<LlikkU|]) m ujr in iur hi ix/r KIA Slivor)Innr 4 Silvudliur 1 MlvdrUjvr 4 Jy>-'-y Alt Cm I Juuuy Aj. >w 2 GC l H2 CLM- .nn aw. aw. aw, uw. LOCO aw, Li_nat uur H 2 nj. ror IXnimU If 60 C ti I L 32 L If 44 /afttrmil Atirk /tfwt E aft GGt ft 60 nilrOliiltf <XM, lOOO UXD IJ/YI UJCO 44X30 IJCO aw. Uoi iw ; Lffix,t of a!*** Ur JO OhliH3* Trefts former CdpocitY, r_ \ * n 46 Gcr^jk iji lIJ 63* - 3 ur tv\>\*an " iiitu hi Mid i?30* 17 IV \A<m trutiu will I9L0j - 20 Ifrjrlji-** t ruiL'i rritd - Tr&i'-afomor Transforwr 1W- fly .refill Oaat pti.c js_r>t_Q>t $ 5,000 3.000 f 50.000 134,000 5.003 64,000 5. COO 64,000 no Mxu - 5,000 65.003 17 !u i4 Mh* - 5,030 61.fL'3 - S.OC3 6J.CC0 - 5.300 CS/.^O 70 tftinu - 5,000 6ri,C'.3 u l*;r.ip in aid 1400* - 131 |V_vl dOU tlAlU 1L* i,i 1360 15.COO 5,000 105,000 52,000 131 16-1*1 LCUfia hit* hi I1U10 5.0C0 52*009 0 run 710 14,030 160,030 31 U Lap in *1<4 10WU* - 15,033 i.s.ocn 10 HLpliaiM trt* in nid 1900* 500 lo.ooo 157,000 4 I6*p4d* tfatt* in uKL iVlitht 500 ^ io.ooo 142.CJOO 40 60t4i|i in aid 19110* - 15.000 105,000 54 rUu ( no 14,000 160,000 60 l4ri'ii*uu 4 (.rum* 355 . \rf iid |9'i0*. rot ok 5,0o0 130.00Q 1 Ji* nrfjtlvi fr IXbtl VbltJiv * Dul t t Offoonc1/ fibroin n, MONS 201347 winch toes sidicatc co a trr.rr. fceicr cooUint; U`,2 tests :eve net revualod any prcblc:rs clue to the use of si; a cere. ' . Tie Federal Poi-lrond Dcruri. tration tos suonsored tv:; ouch by Westirgheusa^ and Central Electric^ to dr_tortur.G the fcuarbili t/ cf retrofxLLLr.g cir-iting TC3 railroad trnusitrtere with silicone, The vo. h per forat'd under titere ccntrccts mclud-d the pcrtoirrmca charactoratatien cf a 418 KVA transit ear t_ci'c.`u;:i:r wadeh Cw.-rtrincd 1(38 fillers of at Karel; draining, flurhing, and retrofilliny tide transformer vdtih silicone; ,_rd chaivcicrizatr.cn of the trcnafcu.nr pjrdhrmico then filled vveh silicone. The tests conducted under these progrrirs indicated that drairieg and fleshing could reduce the .mount of residual PCI in a Ironsformer to a level lew enough to assure diet the concentre teen of FC3 in the siliccna liquid t culd recoin belew four percent. The use of silicons as a replacement for PC3 re sults in a transformer that runs hotter* by perhaps five to ten degrees C. This increase in temperatore will not necessarily docrscise the service life of a transformer, is the solid insulation used in transformers may degrade less rapidly in siliccr.c than in PCEs. PCBs and trichlorcbanrcr.a are selectively adsorbed from siliccre liquid by activated carton. Dev Coming recently d..tonstrated chat filtru-' ti.cn of silicone frort a rctrofilled FCT transformer that iiad been in service for ten months reduced the concentration of FCSs front 2.53% to 472 ports per million. (3) For there transformers crumped with a punp, it may be (1) w,d =h, F.J.; Vcyt*'<*, D. r.; P'^exco, H.A. {I'tstinghovsc* Electric Corn.) Evaluation of stllccr,o Fluid foe 1 *o]sc-stwit of 103 CcoJ. `W m fa: i*av incuse."/, Licit Final'"deport, :vjporc~'*io. `li/iv-Ti"C-12i4,' utllyT-1.3V 77 " (2) Foes, Stephen D.; Higgins, fern !3,; Johns ton, Donald L.; IlcCtodo , Jure3 M. (General Electric Co.), r-'tvp "111 r.a of Pot Ire, d Traurfo^rors , Draft Final Report, Contract DO'f-'.wC-lllJ, Duly, li?/7. ~ (3) Dcs# Com.ing Corpora ticn, R -nved of ?C3 fro it ret Comm 561 (p` ) `tor rnfoEirer Liquid by Cl: trcca!**'-' ""..'.''i.Ar .1, unanccci. -?S>- MONS 201348 possible to install a cartridge filter contci::':.; activated carton in tto liquid circulation pjpor.g. lho ill tar ,,cuid continually converge rei-j*.! il tods from the silicons after most of tto PCEs rad aLr:rdy boon replaced when the transferror ini rotroftllod. Tlriir prcctouic !>u;ht accura tint the corccrtrataon of tChs m the Silj-COi'O would not increase to corocntrscions above: the 1000 ppn required by the proposed regulation. The decontamination of raj icor.e tramror.Ter liquids is stall m the erperinvented tooting stage. Wo sctogreure Llictric Corporation hr . re portedly applied for a pucent on tha process or using activated carton to remove PC3s from silicone. No results have been made public on techmc_..e5 to remove PChs from hydrocarbon transformer liquids, although RTE Corporation is reportedly doing research in this area. 6.4 Cost- Impacts of the Proco^-d Peculations It is not known at this taraa whether the liquid uted to replace the rC3s will be silicone or a high fire point hydrocarbon liquid. Ito-aver, silicone has been extensively tested and is the :iost expensive or the alter native:;; accordingly, costs based on the use of silicone provide an vcy-ir bound estimate of the costs of retrofidling. Silicone liquid prices range from $11.00 to $14.to per gallon. Fgcent charges for field retrofilling of transforrers have run from $20 to $40 per inr-tilled gallon, including disposal of the rC2s and contmlnatori flushing liquid and analysis of the rctrofilled liquid for PC3s, Since the ratrofillmg of locemotive transformers will be dons only in a few well-equipped shops, the instilled costs siiculd not exceed $20 per gallc.i of siliccr.e. Depending on the specific design and use, the average service life of railroad transformers is fron four to 30 years. Failed transformers are presently rebuilt by the manufacturer for approximately 251 of the come of a new transformer. Rebuilding requires approximately 4-6 weeks while de liveries of new replacement transformers require 12 to 13 months. -20- HONS 201349 - ~ The ina'jor cost crpact r. ejected to result fren the retrof HIma and decontamination cf the transform. The co:m< etraticn of ?C3s can lo reduced to tlie required limit of -16 by d ..unuig tie .'slnrol, flu-.ang the* tmsfcr.tars, and replacing the liquid with a suitable lugh tec point transformer liquid Such as silicone, rased on tie rctrofidl costs presented in Table 6.2-1, the costs UKunrcd by the railroads m ihe first 15 months folio/mg the effective date of tho re-qulution will total $7,043,000, Reduction of the concentration of ITT", to 1000 prm by three years after the effective dele of the regulation would re-quire that a tranrformer be re trof illcl an addiuic.ial two tanas or that the liquid be process--.:', at least twice to remove PCIis. No estimates hive been mads by ti'inszorrir componies as to the coot of processing to recove MBs. Ths cost should be similar to tlie cost of retrofill less pcriiaps 903 of the cost of the replace,1ret liquid. The cost of processing as calculated in Table 6.4-1 would therefore be about 37% of the cost of rctrofiliing. fdditional analyses would to required 12 to 24 months uftrx each rctrofillmq or processing at a coat of about $75 per * analysis. The total cost of reducing the FC3 concentration In the retroiilied transformers would therefore include botil the cost of the processing and the additional cost of ai-alyzing the liquid after the trinefevenr is rat-arr.cd to service. The additional oost to the railroads cf achieving this low level of PCDs is calculated in Table 6.4-1 to be $5,460,000, These costs will be In curred during tho years 1980 and 1981. Spill prevention and control plans will have to be prepared by each of the seven owners. Because of the complexity of railroad opera tic ns, these plans vail cost several thousand dollars to prepare and implement for a total Lduruy expense of perhaps $20,COO. Finally, the initial reporting of the identity of the PC3 cqiuproent and tho liquid capacity of each transformer will coot several dollars per unit, for an additional cost of perhaps $5,000. -31- MONS 201350 Cost of Processing Intro:": llv.l P.-tiircad lro.isfoj.rvr Liquid ro try. f... eo M..--t:rn ci -O; Cost of rctrofill less cost or silicone lciu coot of flushing imsd less cost of inoircratacn of 2 gallons $ 20.00 oar gallon 12.00 " " .42 " " 3.00 " " Libor, ovcrhvsd, arid analysis coots 4.58 per gallcr. plus .1 gal silicone per cal of transformer capacity .1 x 12.00 * plus 2 lb carbon tor gal 3 .60/lb plus disposal of 3 lb sat carbon per gal ? .15/lb 1.20 1.20 .45 TOTAL PI'CCLCSLiG OOST $ `7.43 per gallon Cost of processing as a` fraction of cost of rctrofilling 7.43/20.00 = 37% Cost of trccossinq i`trofillcd transforr.irs Analysis for PC3s* 1,003 units 9 $75 Processing $7,043,000 X .37 Analysis* _ See end processing Analysis* Total cost of processing to .meet 1,000 ppm limit ` on IXTDs $ 75,675 2,616,000 75,675 2,616,000 75,675 $5,460,000 Analysis conducted 12 to 24 ::tnu'.s following previous retrofill or processing. -32- HONS 201351 The proposed n.-gulation aui!ori'.cs ao.iL.U'ucd uce of the retrofilloi transformers for only five years frcri ihe effect Ivq date of the re71st1atj.cn. ' It is assumed that a review of the environmental urpict of locoes from the retrofillcd units will result in this auUhor1tuL1.cn being extended indefinitely. 6.5 ~cc.i,s'X'.c "1--acts of the Prccm-cd Regulations 201 of a con ear able program bo replace all of the tronsformers within the next several years, ard the. re* rofill program should avoid any significant dis ruptions of railroad service on the horchenst Corridor. ' All of the affected owners of PCD railroad transforrrors are govom- mental or sem-govemmental corporations wiuch are running operating deficits as sunnariccd in Table 6.5-1. These deficits, of over $300 .nillicrt per year, are presently being covered by subsidies fran tax revenues. _ Tlie rcUrofill and processing program is not expected to result in significant service disruptions, end no offset on railroad operating employ-- mant is anticip ited. The retro fill and processing programs are cirpocted to generate a considerable dewand for labor. Calculated total labor ar.d overhead costs are surrmneed in Table 6.5-2. This would be the equivalent of 165 ram years of einplo/.Pint, assuming a burdened labor rate of $30,000 per man year. Additional coplaymant would result frost the increased production of the silicone liquid and activated carbon and increased disposal incineration services. 6.6 Sunmary CostIwsaois: Cost of retrofill program Cast of processing program Reporting p<11 prevention plans , Amount $7,043,000 5,460,000 5,000 20,000 $12,528,000 Tilling 1979 1930-3931 1979 1979 -33- HONS 201352 Kailrcad CONN DOT^11 smi'. {211 NJ Dorf3) AT-ITAAK1-34'5516 ccnpaii/61 1976 Operating Lc;:.cc of Pailmdo L'sing PC3 Trvnr-Va.-.-'XS 1976 Operating `Vsults $ mil] r -e Total Tcio 1976 $ mid liens 19.1 otcroting deficit 3.2 KEa dr>;cciation 1.25 eparatir j loss 6,38 daprcciat:cn _ 38.5 subsidy 441 total loon other than NS conidir mint. 37.5 1/2 of $75 nillicn lers for NE Corridor operation ' 205.5 looses for 9 tenths, April-Dee. 1976 22.3 7.6 38.5 478.5 (Est.) 2 BO (Est.l Total Looses $ 82G.9 (1) Metropolitan Transit Authority, A-nual Pcport, 1976, p. 44. ~ (2) SliPTA, P.-rort to the ''vblic and Fir-ncia! St-'-t^Tcnts for 1974 and 1976 ^ vi. ~.m cJ P:: era tier (3) NJ Depirt,trnt of Transportation, Hidilirhts of Activities, 1976, p. 14 (4)' AmtraJc, 1976 Annual P-~ort, pp. 6, 7, 28. (5) Antrak, Fivi-Yeer Com--Pte Plan, 1977, p. 153. (6) Cbnsolidated Bail Corporation, Annual Farort, 1976, pp. 1, 14, 18. -34- MONS 201353 Labor 2nd Overhead C .it.', of He Lroll 11 ord Procosring rrcf,rm for llnlrcrd Tr refor--ers Total C3o:;cj ty of transferrer:;; 57,0-13,000 ivtrofiil rr.3t./?20 per gallon = 352,150 gdllc.jm Labor <md overhead coot of each rctrof; 11 or processing Q <1-53 per gallon = 332,150 x 4,58 = $1,(0 3,000 Total labor cento for ore rstrofill end two processing of eta1! transferrer 4,839,000 Labor find overliead costs of 3 addition?!. analyses par transferrer 3 501 of $75 test once: 1,009 units x 3 tests par unit x $75 p_r text ,x 50? = 113,000 TOTrAL LABOR AND OVERHEAD COSTS $4,952,000 TOTAL LABOR DElAliD 3 $30,000 PER BURDENED YEAR 165 iron years EcoT'Crria Trace is: Increased costs are expected to be paid from goverrment subsidies, Frmlotjir.ent: An increased Lirrlcyircnt totaling at least 161 iran yaa.vs is anticipated over three years. -35- MONS 201354 7.0 OIL FIXUP IX; ZR LM> DICTPJLJTICN TTV'iZFQn CR3 PCD-btsed ankarel liquids have luctoricaJly been offered es a higher priced alternative to the petroleum transformer oil need in most Liquid cooled transferrers. The FG3 end oil filled transferrers ware manufactured Ln tha ?omo facilitJ.es, end a'rr.y opportunities ware present for the ccivteminnticii of treesfoit.cz oil witn rctu, In addition, field ecr/icur.g of rCB tcid oil filled tiunsforr..ii'J has been perJ-or.red using the name equip ment providing eccuticrvol potential for cento oinat; cn of the oil by PCIs reoidual in tiie eqT.u_i.~ent from previous uses. Qicra arc no report'd incidents where PCPs ha\o been intentionally added to oil filled transfounirs, and such an occurrence would be unlikely because of the higher cost of PG?3 relative to oil* However, analysis of oil taken from transferrers has Indicated that a significant nirrbar are con taminated with FCLo at a concentration clave 50 prn. These contaminated * troutfemurs would be subject to certain requirements under tr.e provisions of the proposed regulations. ' 7.1 Itacruiromants of the Proposed Peculations Transformer oil contaminatsd with PC3s in concentrations above 50 ppm will have to bo disposed of by high temperature chemical waste in cineration. Htwevor, transformers contaminated with PCZs in the range of ' 50 to 500 ppm will not have to be marked, nor will there be any restrictions on servicing, rebuilding, or disposal of the drained transformers. 7.2 Estimation of the Extent of Transferrer Oil Contn.Tr;r.'11on i~v kVts Number of Trcn3 forrrr rz Available data cn C3 trenefouner production and sales do not differentiate between oil filled and nskarel transformers, but indicate cnly tha tntid. production of liquid filled units of `/arious sizes and types. The -36- M0NS 201355 .Test recent data, for 1972, lLre 5urm-nrimsi u\ Table 7.2--1, below* Class . Distribution Tror.sfcrmira Overhead nrd Polotbuntrd Pad Mounted _ , Small Powsr Transfoirrars (less than .10,000 KVA) Sect's xldry Chit Substation Transformers large Pc*n;r Transformers {above 10,000KVA) Total Qr-'ntvc,* 1,253,400 231,600 13,000 3,400 3,400 1,504,800 Tiie number of overhead and pole maun tad transformers currently m service is r.ot accurately known, but an estimate of 30,000,000 units is usually accepted in the industry. These transformers contain on average of about 16 gallons of oil each. Very few of these tronsfcnrcirs have ever been filled with PCT-s, and nvany of them were built in manufacturing plants v.ftich made only this typo of transformer and never handled asfcarel. Therefore, it is unlihcly that these trarsfonrers vera contaminated with FOj when manu factured, and the units are seldom serviced in the field. The failure rats of those pole counted transformers is about 0.5% per year, (2) and most failed units aru rebuilt. No data have been found concerning the extent of PC3 (1) ClVeat*of the Census, Electric."! M^urn-ont end Distribution pc'irpnryji ' Khport No. MC72 (2) Consensus of opinions of trnnsfoisror manufacturers contacted by Versor by phone, 1978. -37- HONS 201356 contamination of this typo of trsns former. The remaining 250,000 liquid cooTcd tmnsfoiTrors nunufacturcd in 1372 included about 5,000 aslcurel unito. ium-niing that there are 140,000 askarrl units in ccivica ,_r.J tbit the ratio of oil ccoolud to ai-hnrul turnsforntrrs lias always burn 40 to 1, ns was tno ca.ua in 1972, than the calculated number of oil ccolud tmns formes other dion pole mounted would bo 0,850,000, Altcmnti'.oly, it could ta argued that since die ratio or die total number of pole mounted trees forr-ers to the 1072 pi eduction of this typo of unit is 30,000,000 to 1,233,000, that this ratio tires the 1972 production of other typos of liquid filled transformers would give the number of ether tons formers presently in use. By this method of calculation, there are 6,000,000 non-pole mounted liquid filled torns formers rn use, mines the 140,000 r->-rcarel units, or a total of 5,850,000 oil filled inits. Another method of deriving the total nurher of oil-filled trans formers is to calculate the production of transformers from available data cn sales of transformer oil. The annual sales of transformer oil fxcm 1968 through 1977 arc suniurizcsd in itible 7.2-2, below: TABLE 7.2-2 Annual Salts of Transformer Oil in the U. S. (U Year 1968 1969 1970 1971 IS 72 1973 1974 1975 1976 1977 Sales: ' Million Gil 70 72 75 76 02 94 96 70 75 70 (est.) (11 ltoo-e, T.; R-iub, H. (Gar/enil Electric Co.), q. S. Trrnsfnmr->r Oil Sr-dv and t\ - I'd, 197C--!^,J'1, Irtiir"; `.'mrt, l\ao .Tco, Cu-ii.*. EL etrTc' J'ever"iosunrch institute q"L;or'u ,vo. Eli-30 3) , Nov. 1976. -38- MQNS 201357 These data suggest that the szlos of trrr.sfcnrcr oil have e-.crpmd goonutrically at a rate of 5.it, per year (average increano) fre.:i 163 thrcucu 1974. Assuming that this growth rate describes oil sales prior to 17(58, total or] sales tln-ouch 1774 --culd have lc_r l.G biUrcn galic.i., or a total sale of fr.!o billies gallons up to tho present. Srroe f w trjnofor.u r-: have ever beta eciepp,! tad since transformer oil Ins been routinely recipe..ed fci route, tl.a total anvunt of oil in servica is prcbaoly about 90's of the total amount produced, or 1.8 billion gallons. Assuming thit the polo nrtneed tri iferrors require an aveil go of 16 gal.lcn of oil cor unit, the 1972 transform!' production required 20 nillicn gallons of oil for the polo mounted transformers and 60 to 62 .rullicn gallc.it (clrer-d.' r.g on the i-ov-nt of oil usad in tmsroitiar imintaia-.c *) to fill the ivraining 245,000 oil filled transformers. This gives an average oil capacity for non-pole mounted trrtafornu"s of 250 cpilions per unit ^hreh. is not significantly different than the 300 gallons per aobarcl transformer used in previous calculations. The thirty million pole mounted transfers 'rs con tain drcut 500 million gallons of oil at 16 gallons par unit. The res,lining 1.3 billion gallons of oil would fill 5,200,000 trans.formers having on average capacity of 250 gnllcns. Since improved transformer designs have reduced the quantity of oil required par transformer over the years, tdiis figure tirhaps overstates the number of transformers in service, but an estimate of 5,000,000 transformers other than pole mounted units is perilags reasonable based on the available data. Ownership of Tiyimformers Mast of the power and substation transformers are owned and main tained by utilities. The ownership of Id:-o small power transformers and the pad mounted distribution transformers depends on tho policies of indivi dual utilities, and there does not appear to ho any standard policy that applies across the country. Almost all the larci distnbuticn transformers arc owned by utilities; those owned by industrial plants and large buildings are -3C- MONS 201358 generally crr.aJ.ler units, ratccatcc 'ey kncwlr.ehc ble Industry r'"presey.n'._'..vc5 contacted by Versar suggest that p_ri\ ns 801 of the total voler.o of oil in tr;nsformers other them pole mounted units is in units owned by utiiifu:n. (yf C*'' iiL'~r'*.l'rZ't ?d C' T--` * ' Zed rr'r " '* ^ r"c The only avail.-cle rrfor-.\ "cr. on tho a: tent of PO contrnur.aL;on of oil-filled umsfoctni'c 15 the results cbtu.v.1 by cm r..a;or transfe-ror nt.-H'dactuner ' :iich analy,,,ed tho oil four. 55 units. Ibis oil was token f.c.n d1' ctrihuticn tearsCormrrr -*rd ccv.er t.rr n^formr.:, rr.d in a fc. ceres kr 1 bushings cn tr:uis formers. based cn the results of quantitative analysts fer PCSs jn the aid, 25 of the 55 timcforrurs ware oentnnujiAted with PCTs in. excess of 50 pp.ti in the oil. Hie concentration of FCBs in the samples varied from 5 rpn to 155 ppm. This senple was t?ken cn tho basis of conven ience, end probably dees not represent an unbiased sanplc of all oil filled transformers presently in use. In addition, it is not known hew any biases nay affect the accuracy of extrapolate ng tho above data to all oil filled, units. If this sanplc v.rie unbiased, it would indicate that dS% of all oil filled transiomors ware contaminated with PCEs in excess of 50 ppm. The 951 confidence interval for this ectimite is from 325 to 59"$ of the trans formers presently contaminated with FCEs above 50 ppm. . No data is available cn possible contamination of the 30 million pole top transfooters, and it is not possible to calculate tl'.e effect of the KB ban regulations on these unite 01 til this information is available. Cased on the results of the smll and possibly hia-,ed sarple described above, it would appear that possibly as many as 2,200,000 oil filled transfcrmais could he contaminated with PCDs at concentretiens above 50 ppm, that ncr.e of these transformers are contaminated at levels cnove 500 ppm, and dint the transformers contaminated at levels above 50 pr.-n contain about 600,000,000 gallon# of oil. At an average concentration of SO ppm PC2s, tins vculd suggest that the material affected by the regulations oonsiets of 384,000 pounds of K3is dissolved in 4 8 billien pevnde of oil. -40- MONS 201359 7.3 Gods of O'-ir-'Tyr'^a v/ith '1 _^-rou^ ' h Mens " Eta proposed regulations do r.ot affect the continued use and tcnancc of oil filled transformers that, are ccnt-anurated with PCTU in con centrations below 500 ppm. Dispcral of oil cant'uunatrd with PC3o in excess oi to span wall cu dla ^.d only by ar-preved ch.-mixaL waste incineration. com pliance with th.-v"'. rent: la tie no ould requires that c-ntomonatr d turns:formers b-a identified by analysing the oil for PCCo, end tint the oil from, these tovr.sComoro be disposed of in a special inc.tr.t -ator. Ceuta will be incurred for 'Kipling, eredyum, end a: stxssad. Hie coot of disposal of rC3 liquids was investigated in an ERA. sponsored study of the cccicin.c impacts of the FC3 working end Disposal Regulations. ^ ^ The foidcwir.g costs for dispcting of ccntrmnatod trans form:r oil are developed from these previously reported costs. Sarroliva erd ? . .. Detcxrunaticii of the DCS content of transformer oil requires that a couple of the oil be analyzed by an experienced laboratory using a gas chrc-.utogxr.ph <qiu pped wj th an electro", captura detector. .'-Pot liquid filled trsnsfonrors have a provision for obtaining a simple of the oil. Assuming th.it a transformer has a drain cock wnich can be used to obtrm a sample of the oil, the cost of obtaining the sairple should bo little different than the cost of applying a InbsT calculated for the marking regulations. ^ Present ccnmcrcial charges for the required analysis are 560 per sairple for , (2) quantity orders of six to eleven samples analyzed at one turn. Order proo-ssing <ud slapping coats of $50 par order of ten samples would be in curred by the transformer owner, resulting in a total cost of analysis of $67 to 580 per transformer in a routine sampling and analysis program: (1) Varsar Inc. Kicroccono nj r. Thru-eta of the Piccoiod M-irkirc fid Piece oil Regulations tor .'C:z, U-'-V* j-vorc :o. 560A-77-uJ3) , Sjcuririaia, Va. i Nataonnl Technical Information i'ccvicc (Nl'IS Mu. PB-2C7 333/2TCP) , April 26, 1977. {2) Vurrar Trc., Price ~ r->.untile.tivc* Analysis of FCBo in 10-C TlJirifri),r'oLI~(;il; v. ~.u j cu), ,`jpiu-griciu, Vi.. ,''uy i l37o. --'ll-- HONS 201360 52 to 515 tempi Jing; 55 order nroco'-rj'y; $C0 ^>\'Jytr.cal services. Dji'ilQSC.l ' The tncancrntj.cn of oil contei,u.mtiul with PCTSs in the urge of 50 to crortl h'ardic-J parts per million would i.ot ro'auro any cddincnal C.-l, but U.p certs cf fee: Irty amorcizat ion, rcuntciriunce, operation, and capital would to too come ae for a unit hui-rury pire PCs. The cost of u caiaoriting thct oil c. ~;v_ Lc criticdy cn the value of the material as fuel m an rs'r.omtc hrndluiy fuel--peer tralnrisls such ct pure TCrs or thread.d cnracitora. Pre sent practice- is to fuel such ir.car.rrator:--. \nth chemical wastes -vnich tue a ha eh fuel v.jAuc-. Present charges for the incinoratacn of PC3 solids run about $0.15/lb., ^ which reflects the availability of essentially free fuel. There fore, under poocent conditions, there is little demand for tha PC3 centra.united oil as i fuel for FC3 incinerator:, and the oal has no eccr.tmic wiLua an a fuel in such units. It is possible that tne demand for incineration of capacitors will increase to such an extent that the fuel requirements cannot he mat by waste solvents; the ccntminutcd trmrfcrmr oil may then have sorts economic value us a fuel, and the incineration costs would ha expected to decrease to reflect this value. The use of the oontrninated oil in any chemical waste incinerator other than one which is burning PCLn would result in additional analytical . costs and record keeping rajuirtments. Because of the limited mmbox of PC3 incinerators that will be in use,-it is not likely that a carpet!tivc market for ccntuninated oil for use 03 fuel in PCS incinerators will develop and the charges for incinerating contaminated oil would then be controlled by tiie prioo that could be charged by a special purpose oil incineration vrut. A cost analysis for such a special purpcce incinerator is summarised in Tables 7.3-1 and 7.3-2. This unit is of a size equivalent to the incirciatcr used to evaluate the disposed, costs for PCBs and capacitors resulting from (1) ElSCOr General Infcrraticii rmo-rre-OOl P.cv. 3-7S, El Coredo, Arkansas: >iiicn^_iiiT3. -42- HONS 21361 T7T'1!" 7,3-1 rej.mm.-ry cost sot''-si.? for a C'z. Ir,ci.7orr.v-r for r..-.-:- oil ccr - '.atndvian, r Ccnc.-r.;:- ' tA' -j* cZ rc~& Plant C: (rarity: 4,000 Ub cil/l-,r. (500 gr-l/nr.) prgjr.-ont Gsdaeoticn r-umntibe, nfbar burner, associitE.d ducting SdtchLr-7 ^uiprcnt, TarJcigs, purps SfcacJc, rconditions, Sits and Site Preparation Activated Cssbcn Filtrstiai System Settling Tend Subtotal Piping ard Valves a 25% Subtotal Engineering 7% Subtotal Ccntinguncy 3 20% Total $ 1,000,000 ' 500,000 150.000 250.000 ____ 100,000 5 2,000,000 500.000 5 2,500,000 175.000 $ 2,675,000 !>35,000 $ 3,210,000 -43- mons *0V3>* TAFUJ-J ir-2 Pi-ant Capacity: 500 gal/hr. ('*,000 lb/iir.) Cteratir.y Farter: 7,500 haur-/i-it /ruia,;l Cl racial': 3,650,000 re 1/yaar ( 30,000,000 1h oJJ,/yorx) Capital iv ccerrant: $3,210,000 * y-t.ia^ t r. Cosi.3; Direct Cpcratiig laior, 2 ron/shift 0 $10/hr. Supervision i, ,'drujiLstra.ticn 0 50ti of direct cp-rating .tier Activated Garber. System*^ Maintcncn-ra G 203 of capital investr-nnt ` Fewer: 100,000 K5\H 3 3C/;a<d Sampling and Analysis . Fixed Certs: Return on Invested Capital (10s!) Capital Recovery (10 years g_10%) Taxes and lururmca (4% of capital cost) Total Fixed Costs $ 175.000 87,000 122.000 ' 640.000 3,000 100.000 $1,127,000 321,000 321,000 123,000 $ 770,000 Total j'it-.ual Cceta Ccst/Tb. ccntrndnatod oil Cost/gal. ccntaminatad oil $1,897,000 $ .0632 $ ,511 (1) Tliis includes replaccnant r.f 43,0C0 Lb/yr. of spent activated earben ard incineration of ths spent ratarial by a g.anerol purpesa che;aical t.-uetc incinaratacn. MONS 2013*3 the "PCS Disposal re9uL1t1.cn?." The incineration cost of $.0632 per ;ound of ccntaminutsd oil is similar to Liza ]o<.i_r bored ect umtt of probable market prices reported informally by presently excreting chemical waste mcinc-vation cc.rpanics. Tmnrpcctation costs incurred in delivonjag tie1 oil to the incinerator would be about $.02 per pound based on costs previously calculated for uskurcls. ^ Comlt/jjc'c Co<sx3 The effect of the proposed revelations vail be to rcouirc the in cineration of oil ccntccjnatr-d with PCSs. Control of the disposition urd cue Of used transformer oil will rcouire the analysis of oil for PCEs. Analysis of oil for KTs will only be GooncrracuHy justified if the ejected value of the .savings in disposal costs if the oil. is not contaminated exceeds the cost of analysis. For instance, it would cost $75 to sample and analyte the oil m a transformer tint has a 45% e:<pcctaticn of being contaminated with PCBs at a concentration in excess of 50 ppm. the value of oil to the transformer cwrai* is zero if the concentration of FCTs is less than 50 ppm (i.e., a carrrerci.il collcctcr will bo willing to pick it up and haul if away for free). Disposal would cost $0.0332 pec pound for transportation ar.d m cinoration if the oil is contaminated above 50 ppm. The expected savings to bo obtained by analyzing the oil would be equal to (0.0332/lb x number of pounds of oil * probability tire oil is not contaminated with more than 50 ppm PC3c) mints tiie co3t of the analysis. Analysis is therefore a good in vestment for large transformers and those transformers less likely to be contaminated with FCBs. This relationship' is presented in graphical form in Figure 7.3-1. (1) Veroar Inc., Mjcrocconamlc linnets of the P-crof'-d Harking ard Diaoooal Peculaticty: rcr . fryerc : j. joO/tr-// 013) , Springfield, Va.: Notion, ti lurfmcal Information Service CNTIS NO. PD-267 833/2WT) April 26, 1977, pp. 3-19. -45- HONS 2013** FIGURE 7.31 DECISION CRITERIA FOR ANALYZING TRANSFORMER < OIL FOR PCfli BEEQfiE-DISRQSAt. 4 HONS 201365 Although the sversgc irtunt or oil pot: transformer has teen calcu lated to bo cixjut 250 gallons, i'jo information is available on the dirti"button of brenrfomars- by oil c. do city. As a reescnoble guess, the mr-diun trarafoinrar ccyncrty might bo 110 gallons. A lower I'ontd estimate of the fraction of trann 101-ti:3 oontaiRineLf.d is 321. At tiiis level, testing uculd be noti fied for ersTra irately cna-holf of the oil filled ti-ar-sfcrrarn other th..i pole mounted units. These larger tiersformers would accent fer narhi-.'S 751 of the tctul oil. Incineration would thesviere be the required dlrro'-il motied for cJ I of the 211 oZ the oil in live smell toisfcncr; end -Z . o tin rest of the oil. Tie resulting analytical and disposal costs would then he calculated as ihem in T'ablo 7,3-3, helw: TAEST-E 7.3-3 Assume: 32l of all transformers con tain noro than 50 ppm PC3s. NtrtbGr of transformers Analytical Costa 6 $75 Oil in transformers Oil requiring incineration Tncinemticn cost $.0832 Size* of Transformer > ISO cal. < Tsu- cal. 2,500,000 $187.5 rnd.lli.cn 7.9 billion lb. 2.5 billion lb. $210 million 2,500,000 0 2.6 billion lb. 2.6 billion lb. $215 miUior Total analytical and incineration costs: $612.5 million HW upper bound estimate of the fraction of transfoorors that are contaminated vros calculated to be 50^. At this level of ecntjianaticn, testing would ha justified only for transformers containing itore than 270 -47- HONS 201366 gallons of oil. This criteria mry result in the- testing of perfcacs 20^ of all (Transformers containing :0: of all of the oil. 'flu? calculation of the resulting analytical and disposal costs arc siunonzed in Table 7.3-4: TAfllz: 7.3--1 Testing end Dirreeal Coots for Trensforrer Oil Assume: 59" of all trir.-fcm?rs con tain noru than 5tl ppsi PCEs, NuTber of transformers Analytical Costs $ $75 Oil in transformers Oil requiring incineration Incineration cost 5 $.0832 Size of Transformer >~m > al. < 2YiHrTT 1,000,000 $75 million 5.'25 billion lb. 3.1 billion lb. $257 million 4,000,000 0 5.25 billion lb. 5.25 billion lb. $437 million Total analytical and incineration costs: $769 million By comparison, arbitrarily incinerating all 10.5 billion Founds of possibly contaminated transfoerrr oil would cost $880 million. Assuming that no additional contamination of transformer oil by PCHs will occur, re placement of the oil in any contaminated oil filled transformer would he expected to reduce the concentration of residual PCB3 to well under 50 ppm. The rata at which these disposal costs will be incurred depends on the rate of disposal of contaminated transformer oil. The regulations do not prohibit the processing of oentanonated oil so long as it is returned to the sons* transformer it was token from. Processing losses are expected to be lav, so most of the contaminated oil would rot be disposed of until the -48- HONS 201367 transform its aro retired iron rirvicrj duo to failure. If ono-lmlf ethe FC3 contaminated transfer m x s will ) j :-j reip--<-rj or refilled with rew oil within tic next twenty years, aeri the rate of such oil disposal does not depend on the 10 of the transformers, the rate of disposal would f>2 3.41 per year (i.e., a foilin'* rota of 3.4% per year inplies a 20-year half li;c), Eased on these assumptions, annual i-rrlytic.il and disposal cents would be from $21,) million to $26.1 millien in 19 79, and deertara m future years by 3.11 per year rs the n11.'her of ccntominotrd rrannrcvr.-i-'? in service decree.;c.r; by this fraction. 7,4 Sumrary Artalutiaal vd Z\zvo^al Cozz': 1979 ~ $21.4 million to $26.1 million Succeeding Yrs - 3.4% less each year Tbtal - $612 million to $769 million Broloi'Tnsmt Bf'-cis: - Analytical services - Assisting that 50% of the cost of the analysis is for lahor and tint the burdened labor rate ls $30,000 per year, the analytical costs of $75 million to . $187 million imply a total labor demand of 1250 to 3117 man years. Initial demand would t-s 3.4% of tills, or an in creased employment in 1979 of 42 to 106 jobs. Disposal - The disposal cost analysis presented in Table 7.3-2 assured that direct labor and supervisor leboi costs were 14% of the coot of disposal. At tho labor rates assured in the tabic, disposal demand of $425 million to $694 millicn would imply a labor demand at an avexami rata of $30,000 per year of ($435 million >: .14/?30,OOO/.r.tn /car = 20301 to ($694 iullion x .14/$30,000/man year J 3239) ;;on HONS 2013* years of labor. At a doiand rate of 3.41 during the first year, this iraiics an increased c-Tplcyment of 69 to lit) joLs in the drrocral industry in 1979, -50- MONS 201369 8.0 XCffiv'G friAGUHERf Tho only known use of PCEs ni electric rotors was by reliance Elocvri.c G~,p.iny o' Clcvelrr.l, Chio, which used PCBs as a coo lint m certain special: <.cd motors. H`.c-:e rotors wore lo. d by Joy riccufacturir.g Cc-pmy of Franklin, Pa., in cv.wal tvp<m of raning aociiinec built during the lata 1960s ,ill early 1970s. Too rotors require rebuilding cv-iy f-.v yciia. Althouqn Itrr, are so1 i:m lost firm the rotor housing when the rotor fells, men loss of fluid would result in substantial ccrcsure of U:a machine operator to i'C'j. The proposed regulations allcw a limited period of tiro for ccr.version of tiie machines to rotoiu v/hich do r.ot cm FCEs, All of tlic FCB rotors meet fca removed from service in mining ` machinro by December 31, 1981, The rotors on ilia coatin'jous miners ray be rebuilt at PCB rotors for one year after the effective date of the regula tions. The rotors on the loaders must be rebuilt as dry type rotors './hen tie rotors are returned to the shop for servicing. Continued use of PC3 rotors cn mining machines must be reported to ITA within 90 days after the effective date of the regulation, and a spill response plan mint be developed and approved by a registered professional engineer for each user installation. ` B.2 Ownership and Uso of PCS [lining yrohinery Joy Manufacturing Canpcny was the solo U.S. producer of raining equipment wiiich used PCBs as a motor coolant. Both continuous miners and loaders were built using ECU rotors. Table 8.2-1 runmantes the prcducroon statistics and the present use status of these machines. 0ns snail coal mining operation located in Pennsylvania is operating the three remaining model CU-13 continuous miners known to be -51- H0MS 201370 Table 8.2-1 Production Statistics & Present Use Status of PCB-Cooled Mining Miclungs HKlilia ContiTMcu* Nine Hxlol CWl COutirtuu* Mime Prodtctlon IK 1-1904 1907-1970 Hvter of nxhitici ixitU 17 57 Hiitnr of Kv_hlni St Ul In Service ) - 15 rtnUr of LicjuidOoolod Hutom t'er hVicMno J 1 >fcsn!)&r of tvm-cooled KHors Still III bCfVICii 1 ' 45 lAftu of Gallons of 1X33 llod Ter rtjtor 4, 5 ,U Wjr MaJcl HUHO luior* tor ttsUil HWlO 1971-197) 1971-191) 5)) 34 nuUn -5)J 2 Ml *) 4 HONS 201371 still in service. TUo cl these m.durcs presently esc siljccra-ccolcd motors 'Idle the third maclutie has only coo PC3 mosor remaining - i.g., two of the three motor-. arc siliccir--cooled. Fifvy-four of tre fifty-seen modal 9C1 contlnu,e; miners bu.ilt by Joy Manufacturing have been located in the course of this investigation. Thirty-five of these located arc idle (standby service or stored .is a source of spare par to) , thirtcan arc being fed to mine coal, Uhm are in uses other dim cool prodcctic.i (e.g. , c.icing ovorcom and clearing air rruraos) , two are used an spare equipment, and cne is being used in a training program at a vocational school. tVo of the three ncdcl SO I centinuous miners that have not bom accounted for ware rcI"ortedIy sold. Therefore, it is estimated that a total of approximately fifteen units arc still in service. The PCU loaders were sold to eighty-eight different mining opera tions, the majority of than small ccal mines. ' Sixty of these mines use ' three or fewer loaders and, based on a survey of thirty-six mines, it is esti mated that nearly all of these loaders are still in service. The motors in loaders generally require rebuilding every 18 to 24 mmthe, the time to failure depending `upon cpers.ting conditions. The notorr used in continuous miners usually require rebuilding every 12 weeks because continuous miners are operated un,d?r relatively severe conditions. rebuild ing, from the time the motor is removed from service until the machine is returned to rorvice, usually requires one to two weeks. Both the continuous miners and the loaders are used in underground mines, Joy Manufacturing reported that a few of the machines were originally cold for use in potash, mines, but all of the mines that were identified in die course of this surrey were coal mines. The continuous miners gouge the coal off the face of the seam and continuously load it onto shuttle cars which haul it to a conveyor. After the minor bus driven into the icmr about twenty feet, it is moved to a nearby section while the roof that it -S3- H0M3 201372 e:cx'd is bolted. Ilic 1coders ;ir,2 trod jn ccr.\zpaJcnal mining in uudi the co.il face is drilled ora undercut by a dn. Iliac machine. fter the cool is blasted, the loader scoops it up and Ic^ds it into a shuttle c^r. Prof bolting is also required m this type of railing operation. In cither con tinuous or cun'.' 'HionrlL mining, an entire section with all associated equip ment will be idle if the miner or loader i:i out of service and there vs no sr.snd-ty c; cnoicy, ns is cciicmlly the case for small mrvig cr. 'ntavc/i. The output of convenliicnal and continuous mining cporaticns lias been conservatively citinted at 250 tens of oc iL per section per shade, (eight hour v.oihir.g dry). Clven two shifts pc:: day, each coal reining tech nique preduces over $10,000 worth of ccr.l per day (valued at current prices). Conventional coal urming operations conemlly require eleven to thirteen iron; continuous mining operations require only eleven men. 8.3 COiTnlisrcn Cents ; -~ loaders _ Hie PCB-cooled rotors presently used in loaders can be readily replaced or converted to aix-ccoled (i.e., dry) motors when ser*;iced every 18 to 24 ronvhrs. Ths cost of replacement vdth a new air-cooled unit is , $6,258 ixir motor or $12,518 par loader. Ktowevnr, conversion kits arc avail able fron Reliance Electric Corpeny, sole motor supplier to Joy h-anufac faring Company, for $3,100 par kit. Each kit converts one rotor, and each loader uses two rotors. Over the past few years, Jcy Manufacturing has been converting the motors on loaders to air cooling. At a PC? hearing in Giicrgo on July 19, 1977, Jby Manufacturing stated that they tied converted 353 of these motors. An additional 95 rotors hud been converted as of the middle of Movusribeor, 1977, leaving 652 loader motors to t>e ronvorted (note that tnis figure includes the thirty-four spare loader rotors). Joy Manufacturing estinutos that all remaining rcD-ccolcd loader rotors can be converted to -34- HONS 201373 ajjo-coolcd by the end of 19C1.' Thu cost of this conversion is $3100 per motor, re-fruiting in a total cost ex about 6? million to convert the rarair.ing 652 Rotors. Contiim'i I '``rrf'x The PGB ml siliocnc-crolod inofoi.s ui miners! present trenavtien prcblcrr. As a remit cf the nrgesod li'm1 ..tie:-,;, the ivtovet for md PCE-coolcd ccncinuouc miners equiuronu will virtually d.ar.crear, T. urefen, various mining operations will ixa confronted with obeolct" cquicruro oarhnrs prematurely, result:ny in oubst-ntial capital looses which depend upon the retaining useful life of the equipment. All but cr.o of the nine rotors in the Joy Manufacturing ioiel CUi3 continuous miners tint arc still in service have bean converted to silicone coolants by the owner. However, it has recently teen found that silicone ~ vapors nay deactivate the electrodes in methane detectors which era ured to monitor the arbient air conditions in underground inir.es. Thus, silicons fluids toy not Lo acceptable v.he-o such detectors arc u.:ed. Model 9Qi ocuxtinuous miners canrot be refitted with air-cooled motors due to space limitations, ror can such equipment house converted . motors. Therefore, unless a satisfactory replacement heat transfer liquid can be developed for use in motors, this equipment must be scrapped .nd new equipmir.t purchased. ` The value of the continuous minors is best approximated by its value of $40,000 on Uie used equipment market. The new replacement rrnchir.es will haves a much higher price, but will be rrore productive and reqva rc less maintenance. Historically, mining equipment has beoerne obsolete after about ten years o service, and root mining eperations tend to upgrade their equip ment pcioar to tha end of its uo ful life. Since 1970 ws the last production date of FCD-ccoled ccntinuous miners by Joy Manufacturing Ccnpcny, all such -55- MOHS 2131' equipment is likely to roach obuolcscc-ncc by rho proposed ccrrolianoe data - i.e., 1501. Fr.pl nccvnt of this cquipi-ront, tr.:r:^Joru.ay occur rcgoroloss of the proposed PCD ban rogulatj cn. rlcr.i :vcjr, mining crorutions will r.o longer be able to i.nploy the obsolete equipment fs rtvra equipment to tare up the slack rcuultir.j fre 1 iraclur.o s_r;icii,g, ror will they bo able to sill it m the uocxl cguiwiont .r. rket:. rorcc.1 ucrapprr.g of this cquipiuant prior to the end of its uooful life can result in siamf Leant costs (losses) to a mining operation, cirpe-dir.g upon the rc-nining useful life of such equip, ant. Sir: of the eight- companies using the FC3 mino'-s ore rclarival-/ '7-all, with, production of from ,7 to 4.2 million tons per year. The other PC3 miners ire in usa in mires owned ty oenglcraratcs *,.filch produce considerably greater tcruiage of ceal. Any emts viiicii ore likely to ho home by those ccrpenics as a result of the lest opportunity to sell their FC3 equipment in the used market will have little cr negligible impact on the naikct price of coal. This stesu from the small irartiet stiare of U. S. coal new mined by POr cooled continuous minors and the ability of cc-np'-titers to enpand operations. Purthetncro, Versar estimates tiiat whatever casts are incurred ty these eight mining cc-rpanics. will not result in company closures and subsequent losses of crploj-mant. Table 8.3-1 sunrarizes the possible economic coots of the proposed 1X23 bun regulation to the eight mining eerrpanies using the continuous miners. Note that: only pcL-cooled craitinurus miners that are still in service are ccnsid'ircd in this amir'sis because it is not known hew irony of the remaining forty-one continuous miners locate! have a positive market value and useful life. Assuming that forty of these miners can be sold in the used equipment market (i.e., emitting the one continuous miner that is being used by the vocational school), the additional eooncmic ccots wuld be a maxunuri of (?40,00ft x 40 * $1,600,000). In no ense clous tlm economic impact on any ccnpony csicoed one percent of the annual volua of the coal mined by the company. -56- HONS 201375 Company No. 1* 2* 3* 4* 5 6* 7 8* 3,>i Cost Impact of lorced i'jL'/irJit of FC3 Contmnciis Hirers Number of Continuous Minors Model OJ4j 1 <1} Nurrbc-x of Continuous Miners Model 9C; in Forvica 0 3 2 1 1 1 2a 5 - Opportune tv Cost Due Co Absence of Usr-d Fqui;r;i Nirhet S 40,000 $ 120,000 $ 80,000 $ 40,000 5 40,000 ? 40,000 $ 80,000 $ 200,000 TOmi, 1 IS ? 640,000 (1) Note that ccapany no. 1 cerates three model CU43 continuous mines but aily ci> machine still uses FCSs as a motor coolant; end only cnc motor of the three used-to crexate the machine cccs contain PCBs - i,e., the other two motors employ silicone as a coolant, * Small pnxlucer (less than five million tons per year total company production). -57- MONS 201376 Rcvovt-ir.a Ccs The prcpoced regulations would re-iuin: that tie PA be informed of the identity ar.J c^nerriup of each I'd1) niifxg machine within 90 days of the efff.et_i.VF! date of the regulation, and `Jut the c,..v.(W'i maintain. current records of the rr.'d'.uory red report ch iy;=s of cvn :r. ,uiip to the P\\. There arc t^pi'C'.ciiri.teJl y 96 mining corpanicr, tinea c.m PO machines. lhc informuticn required for the initial report should fre avcrl-ble Iran inventory records, end pmparaticn of the report rhould tcauiie no more then one bo two dr/a per company. Aa.o.'ir.q an aw a ego of cne t_;id oner-half ran days per carpeny lrpcit, and an avarega burdened labor rata of $30,000 per nun year, the reporting rc.quirc:ncnt will result bn costs of (56 conpanics :t 1.5 men days per carpany y. $30,000 pa': man year/2>;0 ran days per man year - $3 8,000). Ihe other record keeping requirements ate similar in scepe bo normal inven tory proccciUics and should not result in significant additional costs to die mining cenpanies. Sot'll Frcvcntzci'`. and Control l>7s;ns A formal conti-nyarxy plan will ha required of each company vhich operates PC3 mining rachir.es. This plan will have to be specific for each, company, end a/ill Jiave to be reviewed and approved by a registered profes sional engineer. A striple plan for those m?chines will be prepared by Vcrsar Inc. under a contract sponsored by the U. S. Dureau of Minos. Using this published plan as a basis for the preparation of a specific ccnpany pirn should reduce the effort to one day of company tine end one day cf profes sional engineering services per company. This will result in costs to the mining conpanics of (1 man day x $30,000 per man year/240 man days per man year + 1 day consulting x $250 tier day =* $375 per copany). For the entire industry, total costs will bo (96 car-panics x $375 per company =* $36,000). -50- MONS 20137? 8.4 Smnv'rv Loaders rebuild: 652 motors 3 S310Q Continuous Juncr-J Pi.mfcura nr'typing: IS e'''rating minors Q $40,060 40 other n:u:_rs 3 0 - ?'0,000 Reporting Cent; Spill prevention and control pirns S 2,021,000 640,000 0 - 1,600,000 18,000 36,000 Ttotal $ 2,715,000 [Plus up to $1,600,000 additional. All costs util be inc erred in the period 1579 through 1981.1 ProaiiCvior: and Pv'-C". Ir:rsccrs: No loss of cool production is antlerrated. Since coal prices are set by cernpotitivs imrhet forces and are usually set by long term con tracts, it is expected that the additional costs of th'-se regulations will be absorbed by the mining companies as reduction in profits. Emploitme'tt Effects: - No reduction in mine employment i3 anticipated. Hie requiremchts Cor additional reporting and the preparation of spill prevention plans will result in a total increased labor cur.rid of one to two man years durir.q 1579. -39- HONS 201378 9. o ku:cti o: Actors Largo cloctroroguefn arc ir.aU U c i ovur cciv'yor bolt": to ri.trov=* tr.'mp iron from non-magnetic ccrosTcdilu.r'inch cits co.il and cram. Mrot of the-' cIcctrr rot? arc ccoird with 100 to 150 g.llc -s of tu.rvr.rol oil. Whore lncrtoSid fire safety was roquiaxd, tre r.arorotn wore often fillo-J with PCI:,-.:. Iho three merit manufacturers v-to rood 1C1J wire: Storr:? K?cr?ticc, Cud-'ny, Wro. Ld.cz r. grits, `pe, Pa. Dings Co,, Mi.lvei -Q, o'j.s.' Dings Co. stepped using PCTs in aid-1976; the other tr./o manufac turers have not usiad PCfls since 1971 or 1972. A total of about 290 rCB magnet's were rwiufuctured; ropro:" rrateJy 2`JO of ike''" ray still to in use in the United States. Moot of the PCD magnets are being used in oral mines, coal preparation nl?nts, and in cc-il-firrd girorating etatiers. It is * possible, tut net confirm?:!, that sore of the FC3 magnets nmy bo used on groan conveyers because of the flormnability of grain dust, Tiie electromagnets are of completely walc'od construction, and very few 1callage irroicents have occurred with either oil filled or PCS filled magnets. Dosed on design considerations, electromagnets would be' expected to be less likely to fail than would transformers. Those leaks whi oh hero occurred hove boon caused by physical abuse or lack of adequate maintenance, faintnance requirements do rot expose workers or the environ ment tn contact with PCSs. Ctily transformers and capacitors arc defined as "totally enclosed uses" of PC3s. /Ill other PCS equipment, including I'CD electronroet~, must be rr.roved from service by the effective date of tin regulation, and dis posed of in accordance with the "PCS Disposal and Marking" regulations. -GO WNS 201379 Since incineration of the elc'ctr^'rr.rr-'tr'i is rot fr-`"'able, each earner will be required to submit a written eradication to tie regional /'cbuiixstrator requesting' perndssien to dispose of Uu uiivr in a chcmcal waste landfill. 9.2 Cc. n^i.vce Cr ;te Hie FC3 el cctrcr.-grata could he replaced with oil filled up its at an average coot of $3,020 pir lrcgrjit. iJc .T,,vcr, use of rain oral oil in the'v* applications would aucciificanUy utc-ooeso fire rin'ts. All of the manufac turers regularly fu-iith ;'.wncts filled with o:.licf"j fluid fob use nero fire cha rectorintics :,'Jp_L'ior to txtns.fonr.er oil are required. Such silicon filled tirosfarmers are -'0 to SCI more c:<p<nnivu than oil filled units, i.e., $12,000 per average unit. Ericz also offers a proprietary air coole-d electromagnet diicii has Underwriters Laboratory approval for use in dirty and dusty environments. "This unit costs about 30 percent more than an oil filled magnet, i.e., $10,400 per average unit. Replacement costs for suititle macrotn would be $10,400 to $12,000 x 200 units = $2,000,000 to $2,400,000. Delivery and installaticii costs would bo an additional ten to twenty percent. As m the case of mbting machines (chapter C), the increased costs would be expected to be absorbad by the coal mines as reductions in profits. Jlliese costs should not result in any loss of _ aiploymait or production. Delivery of 200 replacement magnets would require four to six months.^ Oporaticn of the coal crusher? wttJout urotscticn to remove tramp metal could result in a high risk of damage of the crushers with substantial losses in production, Radio frequency metal detectors can detect metal ar.d shut down a conveyor belt until the metal is moved manually, These systems (11 Consensus of industry opxru.cn obtained through a phone survey by Vfersar Inc. -61- MONS 201380 are cxper&iva in terns of irenpewor cuiU lost P'*oduct.icn ccrp-irt-d to the ur-> of copamtor magnets, but ratal ditcciors could provide the tfirorary pie-- Uocticn needed until replacement u "rata: war.? c'jliwred, tet-ector c.yste.-.s pinch ore provontly in vec are not tv mud ccnrinv-Jlv, to it nrst be ar-ot-.rod tut the loot production from belt, cirppocos :.s loon e-vnensivo than ivenning would be. 7iruu,ar.g that a rvo-i;Cnti cvlay would bj cxpirium d in obtaining rtp\,\ccT..-m vi .gnetn, full data (3-i'llCl comatica) winning of tlie detectsua at a burdened labor rate of $30,000 would cent (GO days x 24 houis per d.y x $30,000 rr.r ir.tn ycor/iflO ni Iujut.: per irun year " $22,300 ;tr rmgr.^t ). Actual lalaar requiro.tsnrs riacnt res-cncnly ha 10b ct this ffgu. c. lliis labor reruirciirmt would have to ba acx :d to the cent of a detector system, All of these additional costs arc very dependent on the timing of the effective date of the regulation, and would ba eliminated if the industry had six mantes notice of the intinlien of the Agency. 9.3 Sutrtrv Cos t Lords' Replacarnnt cost - 200 electrcragnats - $2,080,000 to 2,ICO,000 Delivery and installation costs - 200 elcctrcaragrvat-3 - $208,COO ba 480,000 , Labor coot increases due to short term lade of replacement regrets - $0 to $4,500,000 (probably , $500,000) . Production and Price Ideas r Costs arc expected to be absorbed by tee coal mining industry aa a reduction in profits. dtto lotting n t Zffca to: No loss of crployrent at the nines is anticipated. Assuming that one-third of the manufacturing and installation costs of the replac^rer.t units represents labor at $30,000 oer iron year, increased labor of -G2- MQNS 201381 {%?., 28$,000 to ?2,3S0,000/ 530, COO : x ran yen: x 1/3 doll nr labor p-.r dollar cost =* 25 to 32 nun yearn} '^culd Li r reared In lut; 1973 end t.irly 1979. juxtr.l labor doc to a le.r'e o replace tat ueits rniral increase c.cplcyront by ($500,000/330,COO per ran year = 17 :r,\n yearn) during the. firs few nmLV, of 1979. -63- HONS 2013*2 lo.o iiYtt^uL_C's,iC,rnr) PCS Quids wore used, in a h'lrue rvnior or hydraulic systems, particu larly in dic-casting machines and J_n steel it-:''.. -try applications whcue higii- thu K31 Quids, tic i.-uciures were not drained t-cd flu.tcrl Lut w^ui siuly topped oi an rttmrcri \ . uh the r~w fluid. To meg off usually requires addition of now fluid at the rate of 2 to 10 hi: os the systr-n capacity oar year to replace leakage losses, , Available data on residual PC3 levels in die casting machine hydraulic systems indicate td*at ..cr.y of the tested miclimrs conta.ir.ci PCSs in ccncentratiors of 60 ppm to as hign as 50% in a fcTM cases. Tho differences m con centration apparently reflect differences in the rate of leakage from various in-icliir.es airl differing ccrouny maintenance policies regarding periodic total, rcpl accnont of hydraulic fluid, 10.1 requirements of the Tmrc-.rd Raguiaeicns - The proposed FCB Ivan regulations wild prohibit die use of flu ala which contain over 50 pen PC3s m open or r,-mi-closed systems. l^ever, hydraulic systems on petal die casting xncnines which contain fluid with rare than 50 ppm PC3o would be allowed to rerain in service if they are drained, flushed with clean solvent, and refilled with uncjontanunatcd hydraulic fluid. Hie fluid m.vjt ho re-prccessed or replaced at intervals of six months to remove PCBs until the concentration of PGli rern'ins beJcw SO ppm, In addition, users of cciituminatod systems would have to report such use to ETA and petition annually for exemptions to continue using and periodically decontaminating the equipment. The provision for continued uca of these cystcis is limited to five years in the proposed regulation. However, : t is anticipated tint the retjuiroi periodic decontamination of the system will reduce the concentration of ICES to below 50 ppm before the provision e'-orres. *lydr mile systis on -SI MONS 20U83 other types of machines would not be allowed to continue in service if Uv. fluid contains mere than 0 p-.n i'CJi ire rrcch'.r;o w'uld hive to be rc.-o-od front service Joy the effective date of the regulation end not need until the PCD h:vol in the fluid is reduced to a concentration below 50 nr. 10.2 O- :\ rrlup ard U~o of Cent : urated rA'dicr1 ic 5 vet',. ~ A. previous E'-A sponsored study reported tnat sale; oC PCS hydraulic fluid during the period J970-3971 totaled over 13.5 million poinds to 5C5 different firm. ^ Except for a fa; ceramics with contiruretid die canting systems which ],.ve hem identified tiuougn ntatf.inio at public 1 carings on PCUc, little information is available cn the owr.arsrup of contaminated systems or the? levels of PC3n m the Quid. , Blood on stater,'tits mode by several die canting corrnles ard by a representative of the American Die Casting Institute, ^ PC3s `..are used as a premium priced alternative fluid in the hydraulic systems of die casting machines used to form aluainun, magnesium, aid zinc castings. Hierc are apparently few harriers to entry in this industry, and the constant entry of nev die casting ccnrames has provided a reedy market for used machines. A review of the Monsanto customer list reveals that about 80s of tile 40 largest companies purch*ising PC3 hydraulic fluid in 1970 and 1971 v.-cre die casting ccn.pcnics. ^ Assuring that die costing companies purchased 8Cri of the fluid sold and used it in die casting machines, a total of (13,5 . TI)--VcrsaFlnc., Usace of PCBs m Ooon and Sami-closed Systems. j^theJVg^ suit inn loners or IQis to' the thyi; t.^nint, UnnuDiisnes Drurt import, VnrA C^SnctTtor^8r6i-J2b9`, Vex car Report Ho. 474-50, Ragtarter 30, 1976, p. 13. .. T. (2) Teleplione conversation, Mr. Cornel {Arrurican Die Casting Institute, -nc.) with Robert Westin (Versar), April 25, 1973. -63- HONS 201384 million lb x 0.8 / 11 lb per gallon = 1 irullion gallon',) of PC3 fluid was used in these iruchines during tnc L ij y.\ a pci iud. Assuming furtd or tliat each nuchiro Ivtd a hydraulic iystem tnntiuuny 300 gallons uid acquired that aireuut each year to rep lice- leakage, the total ore million gallons of fluid could have been used by 1000 i".-1 chines which used 1000 gallons each. Hie rcnuxnj: .g 203 of tie largest purchasers of ?CB hydraulic fluid wore ctcel mills. rcb hydraulic fluid was rrcorcsdly used as a standard fluid in ir.my plants an tlrose applicaujoris wnera leakage would present a fire hazard. Popvoi'-ntativ.? aces would include steel furnaces, ladles, strip mills, vacum degas,rs, <ud continuous casting machines. There is no information nailable on the total nanisr of hydraulic systems in the steal industry that uce-i PCS fluids, ncr is there any information avail,ible as to the present concentration of PC?s in these system,. 10.3 Ccmoli.irce Costs Dig Ccotirx; '/gghinea " ' Most die casting machines were flushed and refilled with a non-FC3 hydraulic fluid after the wi ers become aware of tha environmental arvd health hazards associated with rcss. The hydraulic fluid recantsndc-d by Monsanto as a replacement for the FCB fluid in 1971 was based on polychlorinated tarphony Is (rCTs). The ironufacturir.g of PCT fluid was discontinued in 1972 or 1973 and the product lines were replaced with other types of hydraulic liquids. The refilled hydraulic systems have been maintained in use by topping off whan necessary to replace leakage losses, and in seme cases by periodic rcplacc.Tcr.t of tha fluid. As a result of the continual re.ovol of contaminated fluid, tile concentration of PCBs has been gradually reduced to lew levels, although in many cases the residual PCBs exceed the 50 pan limit proposed by the regulation. The available information on present levels of FCEs in die hydraulic systems of die casting m: chines is sunman zed m Table 10.3-1. HONS 201385 66- T\bl; ] 0.3-1 Present res levels' ii\ Die Mi-h* no ,,'dr'Lil:r' 'Vstins PC13 Lewi (p m) SO beOew detection limit (T/stc i arc: dran*, id twice: a year) 90-6000 (currently average 509) Outboard Marine Corporation owns appro*:irately 130 die castir nucatnes that at one turn us id PCS hydraulic fluid. These macm.es each Several crapcnies provided estimated costs for rcp]oeir.g hydraulic fluid, alUui.gn not all of the figures were for the perrutted chaining and flushing procedure. Outboard Marine estimated a cost of S84Q,000 to dram their rmchiras, flush then twice with minrural oil, end refill thr-m with r<'> hydra'die fluid. If hydraulic fluid were used as the flushing solution to (1) Telephone conversation, Tom Grover (Cast Forge Co.) with Bruce Woodcock (Ver.tur), September 22, 1977. (2) To.lop1 o2n*e* 5conversation, Ttsn EJarlett {Caterpillar Tractor) with Croce Woodcock (Versor), Septorber 22, 1977, U> 'Ihcrnoa, liugh (Outboard : true Corp.) , presentation at the CPA Informal Hearings on the PC3 Son Regulations, Washington, D.C., July 15, 1977 (p. 91 of transcript). (i) Telephone conversation, Hugh Thoms (Outboard Marine Corp.) with Bruce Woodcock (Vcrsar), Septm-her 23, ]9/7. (5) Ward, William (General Motors Corporation), Presentation at the EPA Hearings on tic PCB Pan tegulatuons, Chicago, Illinois, July 19, 1977, (p. 201 of transcript). -G7- MONS 201386 Solvent New Hydr-'uJ.ic rluid Dirpoc-d Tobil S. 2. 26 7.37 _0_._57 $ 9.40 Chevrolet c-.letnotei th it it lould coct $300,000 to rccrL.ce the hidrnjJic fluid in tho 25 oystrm's (20,000 gal total capacity) :n their Eoy City- (Mich.) plane. ^k Rapreecntatives of tvo ecrrpnmcn stated that if they i.cro forced to ura Ivsrona or seme similar solvent they vould Su a;vorly affactid as tile seals in Lheix radline t would have to be replaced. Also, there eas cere era among these ur.o have already flushed their machines that further flushii^g would not significantly lower the rC3 level in tiicur saenmes. All of the available industry cost esturates are sutmarired in Table 10.3-2. Table 10.3-2 Industry Ectn 'tec of the Cost of p-mining. Hushing, and Refillin'-.. Die Catting Idchune Kvcraulic Sv-.tcra Canntmy Cbe'/rolot General Motors Outboard Marine No. of Machines 25 130 HO. of Callots 29^000 05,000 Total Cost $ 500,000 840,000 S/Callon 17.24 9.40* 12.92 $/Mac mre 20,000 6,500 Material cost only. -68- MONS 201387 Hie industry cent {-t-i '.'W arc roughly cr'qmr.Jde to t!'.o coot ' estimate imde by Vtviar and pro; unt lxI in Table 10.3-3. Since the Vwrcar estimates do not include inventory costs of tr.c cost cl d.contc^acutjc.g the waste liquid truck, i figure of 51-1 per gallon might be a roue realistic ca turn to or the u'-mgc pneo of c,oonrcauj'.i rir.g iijdraalic systems. Hie eff.-etJva.-co of ydr; c'cconL--iir.it.ion pioctukrcG wdi d-pcixi on hew thOLOughly the r .ton can b^ Grained of both the cent r united liquid ord the flushing liquid .u.l alto on ice tiiOint 01 I. .i wmen .a a ubsor b _cl u~, to gaskets onl otb.or irnter:a l. .tscurveq tint the Giv. mir.g and Lle .;uc-g procedure will renavn 801, of the total PCs, a system originally contvnunatcd with FC-'O at 1000 jq-.n wall still contaminated with 200 rpm cur norths after the first flucbu'.y, tut the level of FC33 after (ha second flushing will nevor cjccrud 40 ppm. Sinea there will probably be considerable Leakage and lopping off between the Llrahungn, the concentration of ?C3s is likely to be even lower tdvm these calculations indicate. ` ' Assuming tint each cf the 1000 presently contaminated systems mast I'O f3ush'd and refilled twice, and that chemical analysis for PCTs is required six months after each flushing, the total costs involved will be: First flushing 500 gal. $14/gal Chemical analysis Second flushing . Chemical analysis Total per irachina $ 7,000 300 7,000 300 $14,GOO Total for 1000 machines $14,600,000 A major factor in tha cost of dcccnhominating hydraulic s/stcr.is is tiio cost of the uncontsminated fluid used to refill the systems. It is under stood that both Outboard Marino aid General Motors have co. rive ted : oats of meLheeJs to remove PClla fran hydraulac fluids. It is not tarwn whether these iuethnd*. involve distillation or udmiption, The feasibility of such pro cessing may have a substantial olio t cn tha costs of Groenterriaating hydraulic systems and on those carponics winch reclaim hydraulic fluid. -09- MONS 201388 TrM_2_ ).3-3 Estimated Ce-t o'* rri1- _v' t ''nui ~~Sl1 2 New hydraulic Pluid^ (ptoorh lo ostor) Id unhing 1'luid^ - 1 gal/go 1 {1(7./ vu.cos.tv no; oral oil wiur.'Jc coJiuivcis) Tranopert.'t tio'i {2) {400 i.ileo, includes flushing fluid) Incineration ~ S.lVib {includes flushing fluid) Lator {2 nun days par .Tcchuie at $15 par burdened Tan hour) Total __________Cout p-'_- ct: ?1 on 500 gallon X7(j0 gallon s.yr>tr n 7.00 7.00 1.15 1.15 .41 .41 2.85 2,85 .48 12.69 ,09 12.10 (1) TUdepiyinr conversation, John Colucci {E.F. Houghton) with Bruce Woodcock (Vtirruc). April 27, 1078. (2) Vciiar Ire., PLicrr~rrcoc In--'cto of the Proorrad i:irhir,a end Discern l Po~i)Iarocrr. fee PCs, Scrir.gcicia, Vi.: i'atlojiax Viurjncai iu.oi-.-aticn Service ll.'i'ii 833/270?), April, 1977, p. 3-20. -70- MONS 201389 Approximatoly ')r.i\ of t'o fir"3 purinet _r.g rca hydraulic fluid in 1970 and 1971 w.jre steel cr,warac" anl other i. nua :ot engaged m die casting. It jo there tore lihely that .-'0% of ti a utugc of I'd hydraulic fluid we;, m systus ol'.vr then in die casting m .chines. Althcu'h there '.a little infcrea tion available cn tho u; e of thus material, ari'-rc-.hly not old. of the r.-' -n-u are still cent,ume.ted with significant concentrations of PC-'.;. 3udd Co. state'. that th.-ir eparch.icis should roc be sic.niiicuutly affect d by the pio-~ potvd bon roguIniucriw since toe hi~L-v.ulic systems cn each of their i ulck"`s Irave been drained aid refilled on the. older of 120 tomes ever the last five ye.its.<1! The procedure of draining, ashing, and refillirg any of these other hydraulic rystEtrs to reduce the level of FC3s should cost aeprccamtsly tho same per gallon of fluid as a similar procedure perform.-! on a die casting iruddna hydraulic system. as a rough estimate fcat-d on the proportion of PC3 hiiir juIic fluid used in ouch systems, the coot of decontaminating these other hydraulic system should cost 25% as much as the coot of decontaminating the die casting mac!Lines, or a total of $3,610,000. The proposed regulations would require that the level of rCEs in these other hydraulic systuns be reduced to lose than 50 ppm by the effective date of tho regulations or liie systems removed fran service until tie rcpiuxed dccuntamiiiation is completed. Tills requirement may result in significant additional coots duo to disrupted production in steel mills, as the hydraulic syrtrnis are central to tho operation of the large equipment no-d :n t-h^sr* __ _ facilities. However, there is not sufficient information available to cst'oiish whether tJic required docontcniinntlon can be accaiplishod by7 the effective aate of the regulation, nor to estimate what the costs cue to prediction interrup tions would be.1 (1) Telectonc conversation, c.w, llbitc (Budd Co.) with Bruce I'codccck (Vercor), September 22, 1977. --71-- HONS 201390 ffcconrt i >'t7 The proposed rc ,ula(. 'o v; or'a require t.ut e^o'er?, of die ent machines having hydraulic oyster.-; cent ruinated with over 50 ppn rc2s report the idoj-ititr/ of each contaminated mchunc ard the concentration of rc3s m the fluid. This will recurve the id emeu'- cation of all nuchmec t'ut ever vised re?. Quid and tho-c that rev/ lave used LC2 -cor.temicited reel cured VvireuUc fluid end the cltmicjl anal /sis of the pvcca-ut fluid m these meclu ms for the prcrir.cc of I-C/c. 'J'.vls sir clang and-analysis progxv.r may cover- as many as 2500 mcJair.es ;jV1 must ho cconieted within DO days of the effective date of the rc-gula cion. - dvauical analysis for the quantification of PCBs m hydraulic fluid would Ls considerably more ccisolex end expensive than that remired to deterrur-e the concentration of fCsS in 10-C trartifoimiar oil. 11ns is be cause th presently used hydraulic fluids my to biml on chemicals such as phosphela esters v.inch require that the rC3s be extracted frem the sample . prior to analysis. The possible presence of fCTa in the fluid could interfere with Uic analysis for FCBs, and discrimination between these similar chemicals would require the use of a gas chrcmatcqrach/'miss spectranter rather than the simpler gee chrCT/itogreph usually uci-i for I-C3 cljteiiRir.ations. Versar estunites that the ccrpletc analysis of contaminated hydraulic fluid for rC3`i nny cost as much as $300 per sample on ties average. Review of the records'to determine which machines may be con- - taminated with PC3s and the preparation of the report to E?A would bo expected to require an average of times days for each of the 535 firms winch purchased 1X2.5 hydraulic fluid in 1970 and 1971. Tors weald result in a not c.i"lo}"cr.t: deraild of (535 ccrponies x 3 days per ccmpeny / 240 iron days per ;.an year = 7.3 man years). At a burdened rate of $30,000 per man year, this would result in total reporting costs of (7.3 x $30,000 $220,000). Ttrtal costs attributable to tin reporting rcquircuiunt would be ($300 per sanplo x 2500 machines = $750,000) t- $220,000 clerical - $970,000. Spill Pi'cvcntion cr,d Control Ftorus Each cemcony which uses or car/ices a die casting machine that is contour, uvated with PCDs will l>o required to develop and rrplcmont a nonr.il -72- MONS 201391 spill prevention and control pton. b-cauv' of the complexity of the nrr^md and the aisiraad rcquirtrun t for p__.-icd..c flu'-hirg ard ccco.it. muaiataon, tie plan will la lather complex and tuy require tie services of a registered pro fessional engineer fox one wix-h at $250 pur d.iy, Preparation of there plans by all 535 affected caiparueo could cost a total of (5G3 plans x 5 days x $250 per cl y $730,000), This cost could bo reduced by pimps one naif if a pro fours plan wux developed rider the snonsorsnip of a tirade association or major manufacturer and mode availcole to all affected firms. total c:n*cctod coot of this put of the regulation's v.ould therefore Lo expected to be $305,000 to $730,000. 10.4 Summary Xdsntif'e'r ti^n of Ca.\ta~s nc.t?d Oil Mizchircs Analysis and Sainpling Clerical - Report to EPA Spill Prevention end Control Plans Decoutara.mat.ton ol Die Casting yachir.es Decontroli.ration of Other Hydraulic Systems Cost of Production Interruptions then other HydrajIic System Removed frem Service Total $ 750,000 220,000 $365,000 to $730,000 14,600,000 3,050,000 ? (potentially large) $19,720,000 B-mlovnc'-.i Effects Libor equals (.48/12.50 = 3.31) of per gallon cost, total labor cost (.030 10,250,000 = $693,000), At $30,COO per nun year, thus is equal to 23.1 man years of labor, or 12 jcbn for 2 years. Spill prevention plans v,culd require 5 man years of effort. Reporting requirements vculd require an additional 7 man years. -73- NONS 201392 The impact OL there regulations ;ray affect alroct all die castinj and c tec-1 companies. Increased cette would there tore bri eroectcd to he pas"-cd t'llorvj to the connancrs m hior.er product prices, altliouen r.o individually signifir'iit price rrr*-cares are ergected. -71- MONS 201393 11. 0 ITU'vT TTWJiiJ'Ul SYSTEMS l- ) 1j*'\ ' r/ PC1I3 have teen irctcncr.oly used as heat traru.J'cr liquids fc.-ejuse of thnix obedient thermal stability cirri uharant fno safety. Mthougn xr.<J belt transfer arc usually quite tigrt, lsuir.c;- con occur due to msciv'tncal de:mc" of the system or bccuuea fiutxrga have Icorcrcd as a result of th.nmil cyclu.g. The Yu'ho ir'iid-nt m depart \n 19C3 causal the ?C2| poisoning of 1001 people duo to the lrthoge of TC. 3 Item a heat trsrof, system into rice oil but vus being heated Ly the syrtnu ^ A previous JVA spon'-oixd st.tly cr.t;:;ote:l that total uecce of rchg i r. heat tt,'aster systems in tl-.: Unite . a States ,1-ms ,o^an over 21 million peuedr. (^1 Most of ulus uv.tcti.il vns :..vuj<-c-l.urol by Monsanto aed distributed under the trade Thermim). Monsanto stopped producing TCD bused heat transfer liquid in 1971 and advised its cue ternars to drain and flush thsir systems before replacing the Quid with a non-S?C3 based liquid. An additional one million pounds of TC3 heat transfer liquid v ns'manufactured during the period 1971-1073 by Geneva Industries of Houston, Tcxa3. (3) There was at least one company still using FCB based heat train fee liquid as late as 1976. (i) 11.1 Fou-urC'\- its o\ the pocccr^ 1 P.-.nu1 'teens As of the effective date of the regulation, heat transfer systcua oontaimng a liquid contaminated with more than 50 pem FC2S could not be used until the concentration of PCs is redused to less than 50 ppm. - TIT biuMCCiir.e, Masonori, ct. al., "Yueho, a poisoning caused by rice oil con- tr.mi.ru too with polychlc.rire.tcd biphenyls", RhibiHA Health reports, Vol. 36, No. 12 {DcccTbsa:, 1971), up. 1033-1091. (2) Ver1 1C Ir.c. , U-,n:e of rTP? in C~m and g'rni-clnscd ^vqi-ems and the ret Tpi ft J; to Tt~ a ``r.-ire- rent, UnprcTisec-d' Druet "V'-nort, {Id'A Contract Mo. 63-01-3259, Versar Purport Mo. 474-5C), Soptmobox 30, 1976, p. 13.' ' (3) Ibid. M> Ibid, p. 26. -75- MONS 201394 II.2 Ownershio |i of tint-- vert::! ' -t- T* n There is no data available en the t^tul r.ur1;: ur of heat trmrfcr syotfMS winch have used K75 based fluji.c in the past. Px.;var, ;-. revn-w of Hnvautn1 r< ci'Ct~rror- lief- fr.1.- 1970 anl 1971 -rxliraLi'l Lh it C.2 hi: U.ion pc'se;r Of 13 oi'cd J ..t * rif If.: flu'd t a Lot, 1 of 133 d-fj-arint Ctu-vi. (1) yjld by Maiuanto dux\ny tho e ua to The present co..ccnt'\:(-.ion of FCUs in U-.a heat transfer fluid m cur/ of the syrt,;:.;; wmcU pisvioealy u --'J pcbs depends on how thoroughly inch svctcn v..s flu..!",od vheu the I Cl fluid was rrplrci.d ird chn in nun t of le-iiagc and topping off that lias occurred since then. Data on pror/mt PCD levels is avruliibic for only one syrbura a 14,000 gallon capacity FC3 heat transfer system was drained and Llmi, 4 in 1972 and refilled with <i rcn-F3 flute; tho system has been an ccrnlant use sines 1972 ard presently contains fluid pj tliat is contaruj'-Atcd with too percent i'CSs, Laclong any additional intotruiticn, it must be assur :id that most of thu 533 ccapamius which purchased. PG3 lieat transfer fluid ara still eperat: the systems airl that most of these cystans are contaminated with ICSs in excess of 50 ppm. It must further be assumed that tho use of ths.se systems is central to the rranufactru":ng procsscos in which they' ara used, whether for drying, heating, or temperature control in cxothor.mc processes. ' 11.3 Ccmplianco Costs < It is not possible to estimate the total costs of decontaminating the existing heat transfer systems to comply with the reciuremants or the pro posed regulation because neither ths total number of [,-ystems nor their capacity is known, in principle, the costs of draining, flusiiing, and re fill ir the ^>0terns should be about the soma per gallon for heat transfer systems as for hydraulic systems (see Section 10.31. `OT (2) V.avar Inc., Ucacp of FCCc in Op^n and h.-mi--clewed Svet-aer; ;"-d the ncvultirw recast of r\"3s to cm f:tror.: ont, bryauiam'-ci `.Vat P.-port, "(taV\~cxiitract Mi. uu-dl-ira9, Vi_mr r<.ajrc lo. J/!-!) , Ccptcrrhcr 30, 3 97G, p. 9, Ccmidontiol inforient :cn obtained from tho uvar of tlx- system by '.'error during a toloploivi surv.-y of major users or IC3 heat transfer v/'irma. -76- HOMS 201*95 Ihc disruption of iKc trial ; that emit unrated h 't tiansfei : i.t'j.isi !.a ) rr.on c.1 'oy tiv u 'Uijrrir.mt fren : itt.1. ',.ntcJy upon tliu effective eric? of t!'n r* elation nry result m feu: larger ce..a t-hui wjJ 1 the yuircT.ent to acacont. ,njte tie iy-ti...Ts. H^ru "gain, the . \.ail,?ljle iufoir.u ru< n .vill tot ' opoort even t guess at tv.u ircgru.tu> of tre eccrmuc nrpacts of the disrepbon on co' to, prtx'.octicvi, end employ.-znt. 11,4 fun." try Ovnr SCO Leat transfer rr/stwa iv.iy be ccntuyuinut-d, with id's in concentrations c.`<eeuhug 50 Pirn, but av,uuJ:le data is rot sufficient to support an :r.ilynm of lire coat-, of dacorumiin: ting the system or Loo eccrcrcie impacts moult mg from disruption of related industrial prcductstcn. -77- 0NS 201396 12.0 oa-a^xcccns TurhJrol 153, a I "Oca:, .-2 fluid, v.jO tried rs a tu'-bi'i.-* Jubejcj.at aid. wOik.ir.cj fluid in natural gas pip.l_r;a carprussuia by ;<.r^xal ur iuuc; during the* latu lOGCs <?rd early 197Cr. bivaanto d prcbuciucr thi" product in 1572, erd tha cc.y.jven that vvrni uurg iL switched to aJtumatr* fluids at that tiro. 12.1 Rtquit*':v~'rvc of the. rmo'^ Rix~`J?t*QT; Ilia proposed ti-gulat.ion wculd prohibit the use of any sgetiT.c s'iudi contain liquids ccnt'rumt-d with rctr, m conccjitamiLons e.:c*.`d.ir,g 50 ^pn utter the effective! dote of the regulation. 12.2 Crv] iar.r" Costs Two purchiicers of Terbinol 153, Columbia Gulf Troncmetion and Texas Eastern Transmission, ware contacted by phono. Naitdier ccrgar.y hid information available on the residual levels of PCSs in tlio turbine fluid, . but Loth indicated tint the systems wp.re relatively tight, and there was seldom the rfi-quiiL-Tiint to top off the systems - Bated on data availwolc fer hydraulic system;, arrl heat trrnr.frr systems, it must ho assumed that the cempressov fluids are probably contaminated witli PC3s in excess of 50 pen. Tlnre arc perhaps ten gas pipeline oerprerror turbines an uce that have their cil ccntriainatcd with FCBs. The proposed regulations would require that these ourbir.es Its removed frein use until the concentration of PC3s is - reduced to be lew 50 ppm. It is not kneTM that costs would be involved ror the disruption to tha delivery of natural gas that would result from removing three turbines from cue. Assuming that the complexity of the turbj-.rs is siniil.ir to that of the hydraulic rye tens discuso-cd in Chipter 1C, a coot of pet Ivys $20,000 and $10,000 par nuchinc iray lie involved in the decontamination of the oil systems. Total costs mignt ba several hunlred thcucand dollars plus tha oost of disruption ol tha gas delivery bystem. The cost of chipping gas by pipeline is established by long term contracts. Additional costs re malting from the provisions of the draft regulations eouJd hive to bo absorbed by the pi[vJ :_r.e ctiqenias. -70- MONS E01397 12.3 Sumnry Dcaontaiuination Couts ~ $200,000. -79- MOMS 201394 13.0 KDCLMMED OIL , Approximately 1.3 bill ion gallons for year of used oil is collected for use as rear! oil, fuel oil, re-- re fired hydraulic oil, .aid ic-rcfr: -_d lubnc ta.y oil. Mach of r! : unite oil previously need in applications otl.nr tun auto motive lumen tr on has been contaminated '/ilh lev levels of rc?,s, and disr,.;-'._v uses of lists conr ninated o:J. coo introduce ICTt directly into tne inviror i _r.t. A total of 2,376 million gallery of new oil uc'-o sold duri' g 1975, the major ccmsercinl us.s being automotive lubrication (50.3 percent:); induct::.al airl aidaticn lubrication (30.5 percent); and other industrial ones primarily in tmtcricils freeseeing (17.4 percent), 'die e-mount available for collection and recycle v?s cstimabrd to be 1,154 million gnllens, or 43.6 percent of total calm Data on U.S. uwaga of new (virgin) re-fined oil and. availability of used oil for recycling arc presented for the year 1975. in Table 13.0-1.^ Data generated by Keeou Dyeterns (2) for a 12-nor.ih period during 1970-7J. . indicate that, out of a total (J.S. production of 2,400 million gallons per year, upprotdr.Italy 901 million gallons, or abort 36.3 percent, were actually collected for recycling or use as fuel. An additional 601 million gallons ware os tainted to be used on roads (application for dust control and poosib) y in arpnalt) or as fuel oil; this used oil could conceivably have been col lect''d for recycle so that the maximum amount of oil available for collectscn, based on the Recon Systems estimates for 1970-71, may be as much as 60 per cent of tint produced. A flow chart shelving the distribution and utilization of waste oil m tne United states, based on the 1970-71 data of Reccn Systems, is presented on Figure 13.0-1. Summary data for disposition and usage from Figure 13.0-1 rue as follows; (1) Adapted from Table 1, page 21 of Ar--civ-nt of Itdurtfil Ihvenmis - reinM.mtct'.nent Practices, a document prey" urea'for l-A's ui:it ' of'Toli- Waste and plvt, nted with tc-otazony of H. ranic- ihc^win, Pr-ember 12, 1377. (2) U" 'in len, Worm m J., (5xon Syrio:,, Inc.), V" y to Oil t_.:.v-l:.- :u: Pi;,po-vl, nPA-6/0/fc-74-05?., Princeton, M.J.; August, 197-1. -GO - HONS 201399 K: / Qj 1 IK T-~bl n.0-1 pi ra-Kc O'l vu ilo'"!1 - v for Fr.cvcl ->.3 "i 1', ..(i; Typ' 0 l Auti'r.l'-i'/J r,Lhii Oil n&cti;*l i AvuLlcii Luho Oil* other li.ruserlal ell* Uix' Otli Pcr3tv:ad by U.5. C"u"* "1 't l. -- " f .'rvu i 5L ' Lcr i C,. n flccti fiL-W C 31 iTiC-tS Ai/eo fit _t . : tthar iLbo ol! u - SciLjlI iJ* ;;r ran- 'njrr \/U. c ' ; 3 C4r.vr'J. Hutti . i^ul/ 5tOSC3 Hjiccint rr Fartsr/ i'.li, (ji-j t farm crui-->.nt) St'-ict-xls HydrsUib c-rraiitUrj sys.i- a oil* Mittl -cro; ci--x ^vi'tic.T c c fv40 r:'?'* ftulroid cAa'.r,s ciis sub tut air CLiCtrtcjl eiii P.'XCOSj 01x5 rtirraverAS.c-1 oils Senior .iLl dViio Totals u.s. raio* 15-5 (f.-> , ;o~*i 235 Sl-JCT ,~(1 .53 725 50 103 . .SO 151 .so 95 .63 90 250 51 rroT ' 314 145 147 SO 53 isJ'T 62 340 1 ~TJ .63 .22 ,90 .42 .70 .50 .90 .53 .90 .10 .50 ___ ii. 2,3`S .50 '*7r.vri'"m ivau.*a,u :cir ; ir'tcr iot<sjj ..i u-e trA rn pimrcrawit. 0.) V-iTAtsin, `dmn J., ifacrn lyotr.-j:, Lie,). M~r Or.T^vU, E.-A-670/I~7 4-052, Tn-Tcotcn, N.J.: '-v-'-- -3"1 vri L^..' 1 iJ. Av.t j,. Jt, nm._ - i> . . i -- ISO 1.'2 93- 75 60 57 55 49 "*r 132 101 73 54 31 ~jsr 56 34 6 jio IS 1.154 -ai- HONS 201400 Figure 13,0-1.. Distribution ?rd utilization of Waste Oil m the United Sbatcs Dur:r<^ 1970-71 _________ f'nfJ*i.J Wri of Vt, jin Oil (J'nl . Hi'1 1 < fvl j ,---- -- 5*143 (J?)* * to4 c;l/vr.l l`luJui.3:11 li W"*tlUI ShIU* (246 H lo'r 'M/yr,) rwosvd (* ujiip- Pnt A(U!C 'Jr*! mi!ioS"*/in irtiwliwtM to li ttfhlntih'ntf Vtvte*. rim. -: lfl* u*1/rrl | IbVHl AM rj*l I 1K8 i 10^r>*l/yr) OsHrxUiil (or * 5C3 I'll ((/vll/,1-1 to I'm FVivJ luiffiitt (*)8 x I0%\t/yrl Afl'tlW to Dil i io`-i.i/rii Suwai frat T*Liio :i, p. 170 of tAilAiUln, :^ckm J , (Attni FnoO. K^ut OU Iwcllm mk| r<uitL B'A-f70/3'7H)l frlnoton, HJ r August, lfJ4. HONS 201401 Fate of Oil After Pi j -n .'~y Use Used nc fuel Dis:r.'>.bcl to envu r v mt Orel v : te diur-osal Ar.pl j. J to revels Re-juliu d Jobe oil picducts Prrc ''tree of K'cw Oil Vrcdueticn 12.9 3,3 100.0 tinted .i", prices of virgin lube oil and fuel oil hove varied. Tr.-i voJ.ie of fuel oil ha;; incrarr-d since 197G-71, aid virgin lube oil was scarce curing tlva period of the Arab boycott and during a portion of the per.ucd of price control:;. One result of thase fetters has been increared use of waste oil as fuel, either internally by industrial concerns which generate waste oil or via processors. The primary sources of waste oil amidrile to collectors are cervice stations and other ceborotivc-relu led facilities. Iiduotriil aid r.ve.ration facilities are also significant sources. A significantly Larger; fraction of aveilable oil is collected in urban areas than in suburban or rural areas. Eased on stuiies in tlia Pittsburgh area, spills and other wastes from product pipelines are a locally significant source of waste oil for collection. 'fhc use pattern of processed or rerefined waste oil is extremely dif fuse. Users include states anti municipalities (road application), iidustrial and commercial facilities (fuel, re-refined lube oils, read oil) , utilities (fuel), and the consuming puolic (re-refined moor oil). A small portion of the collection and processing of used hydraul is oils does not follow the general pattern of scattered sources, many re claimers, and numerous users indicated for the waste lube oils. Rr'clarmtion of used liydraulic oil, performed in most part by four companies, results m a product winch is mrrketad as hydraulic oil. -83- HONS 201402 13.1 RgouirCTXntc of t.V- P.-'r'l I'^onrs - 'Ihe disposal of oil can;.minuted v,;di roo in e:.ces3 of 500 ram is r'.guiutcd by tho 'PC3 Marking anti bi: posol Rvjuicions', ".lie propose! 'V>a3 Hm Flo julaLions' **ould change 'Jr.,- definition ojl TO Maxtuic' used m ire :'urJom . J I'j '-yosul PHLinticna to include all ..a..-tires o---.rnuju-ig no,-; than 50 ppm re" . This wilJ affect. the cUJcwble fare and di-oesaJ. of oil con taminated with Jcu-or ccrrmtrataens of PC!3. Under the fruvisions of t_v; i:repos: d ban regulations, oil cenfiminated v bh ICE:, in axecs of r'0 ppm vould h "e to bo it1 ;nti`ftc-i, c-icogartd for purpe-r,j of die; old., and burned in an approved chemical wests inch,crater. Oil contain.; r q nveucur;.blQ amounts of PCSc less then 50 ppm could ba processed for any use including as fuel or reclaimed lubi.i eating or hydraulic oil, but couJd not br used as rred oil or as a constituent of any I'Milant, costing, or dust control agent. 13.2 Pcureas art! / ro^ntr; of Contaminated t'nrta Oil _ .- Hudvcrul: a Flu.idi Oil is used as a lew visecsity fluid in hydraulic systems, end PO based hydraulic Quids Kara widely used prior to 1972. The most expensive {and pcllucing) use v.us m die casting mdch.ti.eiy. PC3 bered hydraulic fluids were also used in construction machinery, farm rrachitr^y (a source of feed contamination) ^ and in deep mining equipment whsrc* tha use of rCBs icsultod in greater fixe safety. Although hydraulic systems are narunally air-tight, leaks nviy occur at dynamic seals and major spills may occur due to hose rupture, Sonnal leakage is collected in crip pans. 1ns rupture of a hose can spray hydraulic fluid over a large area due to high operating pressures. It has been esti mated that 001 of phosphate ester hydraulic fluid losses occur duo to leakages in tiic hydraulic system* . (21 In certain inc. ustrius, operators state tint it is more efficient to continually add hydraulic fluids to the cyst ran rather than limit the system down, repair any leaks, fur', refill the system, Leakage frern these systems is often colloctid and reclamed. (1) U.S. P. inrfcr.anc, of Agraculfiru Vi i'oc Coax'; on ?C?3. Agricu 1 car -1 s T ponc-'J. 111f/ dui'C'-'Ti-j'": .'nl";!1' - ~ ' tat rv~ 'uyk'. UYT.i Lcwur. D.C. oQ~v pL tL, xu, u.j. l.. ' : ur mu ra ,* prcultura, 1972. (2) Tapn, T.I '. (Mu v t .cf'CC"! sc 'a--CM, '' `".7 \-e ,m' p- _f_lilI_7_.-3 Aiul aid Ollal gw1 : .Vi-- j_ 'y, HA . ju/u- iu-ut-j, lx. Tia, sj. /<. "Bi- HONS 201403 Motr. nUD iranuiawU.'cd aliro^i all Una iQ-oieed hyclxauj ic fluids. Uhl/i .'ians-onto dJ rrontinutd M^nu'scturir i KB-bascd hw>vulic Cluids ui 1971, they did not rcccr.Tand drainmj or flush-iirj of hydraulic systans Lut that r<_jd wr.uumt fluids should ho ciMni to the renaming IXB iluidc m the system. As a ri ail t, hyJi-ru'.ic cystoma v L:ch need PCFs in 1977 nrd prior years now cold* 1:1 rcpl(_ic".m<_ fluids eont..imatcd with .00(1 to 90", PCDs us duccusued in D.'pttr 10. 71.> total of ceil.:mm: tion is a function of Lie system lea). '<>' and dilution c'.ux'ij'.j the past five years, A portion of Lr.a air.liable u... i industrial hydraulic oil is refi c and uoJd for reuse as hydraulic oil. fus spocinlire-d raclaiurg '.-ervice is turn is hod by tha following four ccmpsuiios v rich reclaim a total of about 150,000 gallons of hydraulic fluid per year. E. F. Houghton ard Co., Philadelphia, Pennsylvania Radco Corporation, LaFox, Illinois . Findott, Inc., St. Claries, Missouri WnJ. lover corp., bast Liverpool, Ohio ' Automobile card I>j 'rtrial Lubr-'a-rtir'^ Oil 'lhe amount of used oil collc'TtT'.i for reuse in 197C-71 was about 500 million gallons per your, witn an additional GOO million gallons used intrrrnlJ y for foal or dust control . on roods. ^ Thus, .about GO poi'cnt of the amount of new oil cold 'as reused. Major uses of this oxl wore as fuel (102B million gallons), road oil (319 million gallons), and feedstock Cor re-refined lubricating oil (138 million gal]ons). The extent of rcn contamination of this oil was studied on a limited basis by the EPA National aiforccrent Investigation Centex' (tEICJ m Denver. (2) Sanplcs of oil were taken from selected tan.1:2truck lots of used oil that had been col looted in Virginia, Maryland, and North Carolina. Thin oil h ;d boon delivered to Continental Forest Industries in Hopewell, Virgjjua, (1) binstain, N.J. (Preen Systems, live.) , .`asto Oil P''c_/clx-,g ary', bivrosil, nPA-670/2-74"0f>2, Princeton, tl.J.*. Augusty 7 i (2) tiiMi'-dor, retort S. (Continental Forget Inuustries), testimony presented nt the U;5 C'A )nfor..v:l ha.vrijjga cn the KB ban rigid ations, (: (.dungeon, D.C., July )5, 1977. -85- MONS 201404 for uo: ai; supplcan.nbul fuel :n u steam lender of a paper null. Ilia oil had been cclli'ctod prop nil/ from cud: ncbile service stations, although it is por.c.'blc that rote iidustrml oil, inakJ'ng hydraulic: oil, had boon ircludcd in com of the Jot;. PCBs were found in the samples of oil at concentration! ranging f com 3.? [ r?n to 19.4 ppn, Although thr-se oil ski-pies were collected, from a re.'.trie ted an, the ext; rtt of l'C3 coni mint1 ticn is probably representataha c waste oil collected tnreugheut tea Unite 1 States. The PC'h contamination of the waste oil ccuJd come fren contaminated irdocti'J -.il hydraulic oil or Iran., former oil or Irem ty U additives ut.u in lubricating oils prior to 1973. In applications such at railxcad car 30um.nl box oils, PCBs nay ht*ve teen used as lubricant additives. ^ ECBo my also have Leal added to auberebile transmission fluids to control the swelling of oil f.osJs. It would not ba expected that FCRs would ha destroyed during re refining of westa oils. PCBs ware reported to be present m concent rations' of several parts per million in reclaimed oil used to luliricate whetstones. ^ 13.3 Cct'dI inr.cn Costs Collection of any waste oil likely to be contaminated with PCBs for a controlled use would not be attractive financially unless the oil ware known to contain PCBs at levels below the control amount. Analytical costs for determining lew levels of rCBs will be. considerably liiyher than the costs quoted for transformer oil because naturally occurring sulfur and chlorui' orarpounds in petroleum oils cause interferences in the uto of electron capture qas chraratography at concentrations of 5 ppn PCBs or hclcw. (3) These llj rtnrxrn Chemicnl Cenpany, Arcelorc grr -----, St. Louis, Mo.: undated. (2) tv.-.ats, George, {United States r>:car. >:r,.:irc. or Interior, Denver:, Colorado) , "Polychlorinated Biphenyl:,", FUu HLS 3-3-10h, .Lure 13, 1977. (3) Hofstader, R.A. (on research ard Ihginesring Co.); Link, D.J., Bacho, C.A. {Cornell University), "Interfor.roe m the Llcctxcr.-Caoture 'I'echmque for Doter.rujvticn of Polydilorir:tcd Iithrnyls by Sulfur-Conb?:rur.g Cenpeunds in Petroleum Products", lu.l!r-'i of Lnvnir.vrcoSnl Co;frmr.:'-'oi; ,~;d 3Sr. I'lLii'.bY, Vvl. 11, tie. 2, 1974. -86- HONS 201405 interfcrrncos result m feist pm it-vo ir lie: t:cns of the preserxe of <<JTs, The PG3 earpoiYunts can cnly ho resolved U rough css slur clcun-up crccofurcs or the use of gas chraratogruphy/i'ecs spectre, >:try, techniques that would cst up to several hundred dell art" per ssrpla. Road Oiliny The (root recent c1 eta indicator, that read 01' ir,g cec.rums 319 million qolJcns oi waste oil per your (Figure 13,0-1). At an application rate of 1/2 gallon per aquart? yard, this is sufficient to oil 45,000 miles of road;,ay 24 fret v/ido. 'lie prepr-ed Lm regulations vot'ld fo.bid the uce o' oil conteming detectable amounts ol PC2s for dust control. Fluids fnem trans formers are likely to have detect tele amounts Crd other industrial sources are at least sc r;; diet suspect- Currently them industrial oils are collected along with used rotor oil. Although virgin motor oil lias no PCCs, used rotor oil may have PCD;, from previous recycling which included industrial oil sources among the feedstocks or from eld tront-ruc:'.ion oils v.iiich censored rC2s as on additive. Nevertheless, used mo^or oil uiriuxed vuth imuarrial sources is unlikely to contain as much as 10 pan PCts, and ituy have PC3 concentrations that are undetectable without unusually elaborate and expensive analysis. None of the reported analyses of waste oil for PCFs was based on used rotor oil without any possibility of industrial contamination, presumably nc:,ta oil solely from automotive sources would contain fer.-or ICDs. It is doubtful that raid oiling could stand the costs, of evei "siriple" tests at S70 par sample. Prospective read oilers Iherefore would be safer using waste oil if they taka precautions to ensure tdiat it does not contain industrial oils (end certainly no electrical oils). Carpiiance with the requirements of the proposed regulations cculd be achieved by either of the following strategies: (1) Avoid Jill waste oil and substatuta virgin oil at considerable monetary and energy cost wlierc the cur,tor,or in willing to pay the mere.is ad price. At an average price c $.375 per gallon for #2 fuel oil vs $.03 par gallon collection costs for used crunk case oil, the coot of road ojlmg would incrcv ,_r' (.375 - .00) x 139 uullion gallons = $94 million per ye.-ir. -07- MOMS 201406 (2) Use synthetic read m-bili-atira crcmicaJs waicl: both rciurra dust and provide surface stabilization. Tm mere escd coat of this tyre of iiuffiml is presently of2. ot by 1c or rood mu.v ,r !rce costs on heavily traveled dirt roads at mir-a and oi1 induetriei Litres. Savings m iiumt nance c.i lightly traveled noil would ho Jo, i zignlic-nt and could only partj.'.l.'1 v offset the morcot.r.d material ccutr`. A typical synthetic material is "Cohj-tQ.':", irsresiletiirod by '.utco C-_,a<;.al Co. Tns materiel is an organic n;,in ui a tutor artuiibcn \ Inch is sold for $1.25/gtlLcn, nd applied after a 5 to 1 toiler dilution at a rata ci coo gallon per square `urd. Increased costs incurred by tha use of tins material would bo: minus: equals: Gohorex: 1/6 cullon per square yard 9 1.25 = .203 '* i U;-od Oil: 1/2 gallon per square yard 9 .08 = .04 increased material cost per square yard .168 x 14030 eq. uis. per mile of road 24 feet wide $2365 per mile - x 45,000 males $106 million per year. Those increased costs will bo ir.cvxrod until the concentration of Pens in used nrctor oil drops below detectable ] > cols. in pea`haps five \ errs, it may be possible to use waste motor oil for road oiling with little chance of telescang Pels to the environment, provided that care is taken to avoid using waste induotrial oil. The diverted indue trial oil con be made up at r.rxlcst added costs by more extensive collection efforts particularly in rural areas. ' Tlie costs uf obtaining this replacement motor oil for read oiling consists of coots: to penu. do service stations ta accept used oil from persons who citings oil theinsdvos, aid perhaps either greater storage capacity at-, stations or more frequent collections. Alternatively, collectors could travel turtnar in rural areas and Hum irisit more esnriro cl-Tl-ionis rv-rt- TW port of fch<* mcycluYj ^yvtcmn Thc-se extra costs will not be incurred unless read oilers will accept necessary prica incrcas-os to cover these cost,-,, Total ocsts ,:ught rerrnr.ably bo cg-oett-d to increase .02 par gullet: ($6.4 million per y<. rz) rd us the nr.l of incdvtir- tently using contaminated col in cccr'icnal inr.r.nctu. After :ua addificrrl ten \carn, it may no longer bo r.cces-vuy to segregate are irdusarral oii, and casts wauld- rturn to their present levels. -SB- MONS 201407 ffcgra Other tbzn pond 0.'' 'v,r About 27 million gallon, per year of transformer oil will mt bo avnilaolc to cojlcctoru, thus initially reducing the total supply. Other induutrtol oils ray or ray not be contorrvmatrd vn.uh PCSs; to be absolutely sole, tl.o recycling uuiuatry would ovoid that. Lndividual industrial :erra can piclVibly continue to too their own wasto oil as fuel oil if they tike initial end occasional Liter spot check laboratory analytes to make sura their oi-Ls continue to contain less than 50 ppn PCHs. The impact on ro-refinors (wio rake re-refired lube oil) rrd external processors (wlo process waste oil for use as fuel oil) will depend on what happens to road oiling. A strict enforcement policy with occasional all-out efforts to find ids in waste oil could prevent its use as ro:d oil. Diversion of waste oil front this use would create a large increase in supply for processors and re-refiners. Probably most of this would originally go to fuel oil usa since tha capacity of ra-refir.ars is limited and the consumer acceptance of used motor oil is limited. Later, a majority of the increase might go to re--refiners if the Frost and Sullivan market projections of 23 percent grew. par year until 1985 proves to bo even roughly accurate. ^ 'Xhis would provide an extra use as lube oil while retaining most of the heat, value for later use. - Collectors _ If collectors avoid transformer and industrial oils, their total business will decrease. However, haulage of the contaminated oils to chemical waste incinerators will bo required rrd could offer now market opportunities to the collectors. Procaeacro Waste oil for fuel use ctould becc-o more plentiful as use for road oiling is discouraged or node ut^ossible by the regulation. Hie effect of a Larger supply of waste oil on the price to processors theoretically -would ~(lj Miugfi,' T.W., "Purefined Oil; An Cotion That Saves Oil, Minjmires Pollution" Science 193, p. 1108-1110, September 17, 197G. -09- HONS 201408 be to lcwer. the,price. However, ij.xo use on coal in boilers is reJatr.oJy trouble-free ani expandable, tins use is pLcb sly very el cue tic. Ccnrccu'_u '_y ccal burning plants ccn ab-'erb tie irerear--i supply, which score: likely, the price decrease should be nog}igsole. Re-re fiTtf",`o Re-re7mars of lubricating oils should bo operated at capacity orrl thus bo more profitJjle. The recycling etnic potentially can be used to canard the market fer urod lube oil fas tor than industry capacity. Bus wi'l bo especially true for industrial and ccmrioreial fleets, but night bo extended tQ personal errs. Similarly, increases in domestic crude oil prices '.cull increase the market for all uses of waste oil. Information collected through tcleplr.Q interviews indicates that at least three of the crnspanics which, re-refine hydraulic fluid receive hydrauJ ic fluids which are contaminated with PCEs. These fluids ore sometimes contaminated to the extent of 6000 ppm. In most cares, the reclaiming prcccss rarovfis no mrc than 101 of these l"C3s. ^ It is also retorted that the con centration of PCDa in sene of the hydraulic flu.td applications encountered by these ccmganies remains at approximately 2000 ppm despite repeated flushings and drainings. In .such cares, lower PCD levels nay be achieved]o through the use of activated carbon filtration. . Those hydraulic systems contaminated with PC3s will bo identified as required by other provisions of the draft regulations. Once this is done, waste oil firm these nachir.es and fron the oil separators in plants using the irvichmes will probably have to be diverted fran fuel use to chemical waste incinerators. ' The price differential between re-refined and virgin hydraulic fluid is about four -dollars per gallon. The requirement that contaminated iiydraulic oil be incinerated may reduce the supply of re-refined oil frem 150,000 gallons per year to 50,000 gallons per year. This would result in increased costs of (S4.00 per gallon x 100.000 gallons per year = S400.000 (1) TVlupicne conversation, twain 1'awkes (RTJXQ Corp.) with 1. rcurt (Vcrtor) , Sopto.bc i' 19, 1977. -90- MOMS 201409 per ynar), urri could force the cloti-.g of three email firms with a total employment of 12 to 15 persons. Industrial 'asrs Oi1 ;?'s Thice industries v/hoc; waste oil contain:, more than 50 PCBs will have to incur disposal coots of $.0932/lb. even industrial oil con taminated with lees then 50 p;x\ PCBs rray be avoided by waste oil collectors. This will not be a big problem for cool burners. Fuel oil burning ccnmunaes can use a in.v-.tu.ro of waste irl virgin oil but. there are technical problems bo be mastered in this use. Continental Forest Industries indicated that up to 14 percent waste oil mixed with *6 residual oil is feasible. The result may ba the develc,ov.2nt of a separate market for industrial oil with lew labels of PCEs for use as fuel. Long term ccoraiuc impacts should not be fagnifleant. 13.4 Siimary Cormli-gyica Costa i Hoad Oil - increased costs of virgin or synthetic material (years 1-5) toad Oil - increased tout of obtaining adequate supplies of segregated used motor oil (years 6-i5) Lost production of re-refined hydraulic fluid $100 million/year $6.4 milllon/year $ .4 million/year Employment, Effects Throe small re-refiners may close with a loss of 12 to 15 jobs. Shifts will occur in the collection segment of the industry, but will probably have little net impact on employment. -91- MONS 201410 14. o ?C23 as LinimiTTO^L ir-cntcr cc::?rc - Although meat of the POs in use were ireduced by Monsanto os tha prune vy product of5 a reaction process, othu4 chemical reactions can produce PCt;s as by products, re-ul ting an contamination of cc.ivarcial chemicals, Sumlaxly, cona-m- ination of c/jotrig material may result in KB contamination of products made by recycling' these mitamls. Fuc/cled paper as known to be contauxr.aa.i witn PQi-s at Jew levels, but a da fail id study of this indas try jndicmd tn:t it ..cfd not bo affected by die 50 ppm limit on PQJ contamination, ^ Polychl-u'mated terphcnyJs Itivo alio been reported to be contaminated with FCBs fcured as a side reaction during manufacturing, (2) but the ro.le Q.S. d- istributer of this material ' has reportedly assured its major customer that it would warrant that future sliipinents will centron less than 50 ppm IO. The only chemicals Jcnavn to be sentooilacted with PC3& in concentrations exceeding 50 ppm are aortain phthalocyaiuuo blue and gre*_n pigments and the diaryJn.ce ye 11c./ pigments. , 14.1 Raqiiircmnn ts of td-e Preposed Pecrulations The regulations ban the continued manufacture of KBs after Deccabor 31, 1978. Tins ben also applies to mixtures containing more than 50 ppm POJ3 regardless of whether tr.o PCBs w^re added intentionally or fonred during in nu faction? as an unintentional by products. 14.2 Compliance Costs Phthaloc'Jc.'lino PfCjCnt^ KithaLocyonir.a pigments are major sources of heat- and lightstable blue and green colors in the plastics and printing inks industries. In the monuCr.cture of copper phthalocyonine blue pigment (phthalo blue) , the TO Vtcrsag Inc., Involvement of iC3r> in the Polo and PnxT Industry, UFA 560/6--77-005, iVwruary 2j, 1 07 7. (2) Vi rs/ur Inc., Ar_ err.ront of luc .`brurcvrnt^l and__rceramic Lumets of the U,in a:i Lrccrtu o:`.'bs, tr.\ 'ouu/o-/, -Jj^T^dconraiy lid 7. " {3) i'-'".~i-`7l co luiucauLon, L.ll. Arguoso (M. Argvcso end Go., Mcuri.orcrcck, V1.Y.), August 30, 197). -9?.- MONS 201411 copper used in the reaction apr-'rcntJy cutalyv' : tho djdiydiod'Iorinaticn cf the tridilorobcncene (TO) solvent coed in the proutes to om varying amounts of trichloro and pentachlcro biphenyl rceidua in the product. rurther c.i!ormaticn of phtJmlo bite to make phLhalo gvacn picr.unt results m the formation of PGJj residues in tV jim product. Domescic and fcroign nanufretur-ert of vr.tr.nlo p'.greets, using tiio TC3 solvent proceed, lava tinted these pigr.cnts for PCs level. Results indicata tn*.t this process ccnorotcntly produces preprints with redo residues in the 100-300 ppm rerg-*. Cno analysis from a domestic mrui'lecturer reported ccnco.nirntions as high as J000-2000 ppm, Several U.S, companies manu facture the ththalo picuents from the basic re/ materials, while the other U.3. > oorparuts maik_txng theca pigments import foreign TC2--bescd crude pic-wntn end purify them for sale in die United St-, tee. Under the proposed PCS ban repulamom, all of, these manufacturers ore in effect producing a PCD mextuxo* which could cot ` ba sold or distributed in ccrrmerco effective 30 days after- promulgation of tha draft regulations. __ _ Discussions With the dansstic ph thilo pigment manufacturers have disclosed that cnly ona manufacturer does net use the rrCQ solvent process (Jtcroccne is used es the solvent in a proprietary process and the pigment pro duced has essentially zero PCBs) . All other loreotic and foreign manufacturers use TCB solvia-it, and are accordingly faced with mayor process revision/; to ocrrply with tha proposed 50 ppm PCBs limit in their product. Tlis ccncentraticTi of PCBs in the phthalocyanins blue and green pigments can reportedly be roduced to to lew 50 ppm by a change in the solvent used in the manufacturing process. Such a change will require modifies tier; of 'die process and quality control procedures, end may cost 5100,000 for each of the five or so manufacturers and importers of the material. Since unccntirum ted pigment is available from ona U.S. nnnufacturcr, there is sufficient price com petition to prevent these increased costs from being passed along in higher prcduct prices. The effect would therefore be- a decrease in corporate profits. -9J-- HONS 201*1* D'Ccrulid'' 'IcIIcj P'J/i.-.ttj . Diary! ice pigrints .m tto nnjor yelled pir-v-nts used in printing iniis. These pigments are ranch by reaction- cf picc j.-sors which indue2 dichloECi-i--izdinG. \ muior side roue ur,n resells in the due nmaticn of the b.'Jizidi.'j'<a reuniting m the ioouticn of 3,3'aidiJombipi.myl. According to Dun Morgan of the Dry Color :tinuf returers Assncitation, ^ rrort diiry1 i'u yellow pigments age ocrtsmir.itrgi with PC13 ft concentrations of rcvvral hundred carts par million. Although a few batchra of pigment hive Leon found to cert urn leas tiion bO ppm PCIs, the industry is not yet cbJo to control the irjuiufoctvrirg process to reliably achieve this lav level of 1C3 contminction. 1 Sales of diarylrds* yellow pigment in 1976 wore about 12.66 million pounds having a vdue in ci;ccts of $52 Million. ^ Hun pigro-rt was ccntcjunatod v/ith perhaps several theuemd. pounds of 3,3'dichlcrcruph_nyl, wiuch is a relatively biodogradible iscuor of PQJ. If the proposed PCS ban regulations result in an effective ban on the manufacture of this yalluv eye, most colored ' ` printing :r.hs will have to bo reformulated, resulting m come lest production whj-le technical changes ane made in the $690 miUion/yaar ink industry and the $43 billion poo: year graphic arts ii-dustry. There is no technology avail;bio that can reliably reduce mo concentration of PC3s in diarylie! a yellow pigments to below 30 ppm. If the ben on the manufacture of FCSs after December 31, 1078, results in an affective ban on the nvmufoccurs of this pigment, lost sales of ttiis material wall be aoout $52 million per year. Alternative pigments are available, but their use results in higher ink costs ns the alternative materials ;ire less effective and/or mere expensive. Increased costs due to the conversion to substitute materials may equal 20 percent to 50 percent of the value of the discontinued yellow/ pigments, or $10 million to $25 million per year. There stiould to no net erplcymsnt effects as tho production of substitute materials will offset the louses from the discon tinuation: of manufacture of the diurylica yellow. ilewevar, several hundred ;cbs nuy to affected at the impacted m-nufre hiring facilities, and an unkr.evn amount of production cquiprent vo.ild lose scenario value. Til 'ivjit-i..j_io"<joh'wji.Con Morgan (Attorney for tile Dry Color Manufacturers Association) wiUi R. Westin (Vi_rsar), Shyi-ubcr 22, 1977. -91- KONS 201413 14.3 StHiniry ` - Com-rUcnc? Phthaloc/.-muxs aJuc - Production changes Diarylido. Yellow - IncT'ored ccct-; of subctutviic pj.c-v.nL3 5500,000 - 107S $10 nu.l_li.on to $2!) million p'r ^ir writ Several honored jcbu \ould bs affected if the :nuf.icruru cf diaxylodc ye lie.: pignvontc banned, Theno oculd ba offeat by Giro lev,rent increases in th.i segiuintc of the pignout industry ;tvplying too oucstitutc materials. -55 HONS 201414 i5.o oilmen 'i\nup'ctctlC:xj - The use of PCBs m tho uanufactrLirc of nev copaci'ors is cmpcctud to t id by mid 197U due to a number of factors including tho aiding of production of lMltn by .'Jonsanto in October, 1977 and Liio zero IXb3 diocliargc ixouirisreritr inipi'-C'd on the nvnuLncourirj plants by tho n?.\ undor authority of thi recatal Water Pollution Control Act. ^ iiowever, the decision of tho capacitor roanu- factiu exs to discontlrjue the use of PC3s without attempting to develop ad ter:a to scurcar. of supply after Monsanto stepped production vos trade in anticipation of the implementation of tho Eon Regulations of Sd,,ticn 6(e) of the Toxic Subcburccs Control hot. Although the ETA apparently has no dis cretion in the urn]tenanting the ban on the use of PCDs in the morvOcture of capacitors, tho ecciraiic impact of the change to al tamale material a and designs is undoubtedly the result of the provisions of the Act as urolenvantod by the proposed regulations. The proposed regulations would ban the manufacture of catacitors containing PCEs after December 31, 3978 as the ERA has determined that the ben in To:tic Subs tineas Control Act on tiie manufacture of iOa applied also to the nvu-iiifacture of items which are considered to be 'TC3 Articles'1 or "PCB Eguiuniont." ' 15.2 Capacitor Production irH Sales " PCBs have been used as a dielectric Liquid in most of tiie alternating current capacitorn rrnnufacturod since 1930, PC3s provided tiie advantage of non-flairiaoility winch is not available with electrically suitable alternative liquids. The development and ccni.ercial introduction of nor.-fCJ capacitors started in 1975 in response to growing concern over tho environmental effects of PCTis. The time required to develop various types of ncn-PCj capacitors (1) KPA, "Final Decision," rcdciral Register, February 2, 1977, pp. 6531-6555 -96- MONS 201%i5 has boe-r'a functi.cn of the fir;; hazard wuch would rcsuJt from the i.niure of each type of capacitor- Segmentation of this industry by type of capacitor is required to calculate the impacts of the draft regulations. . PC3 capacitors inve been nude in irony different uses and in designs suitable for irony different voltages and applications. Ter the puiyosa of this analysis, all cf the various tyyos of PCD cr.rucitcrs vail be class if", id as either ocv/ar factor r-.pacitocs or industrial capacitors, rewsr factor c.ipacioui; are those Jorge high voltage units used by utilities to correct for 1: going power factor in electric tranciir.oion and distribution systems. Indus trial capacitors include all other types of FCB units which oro uwod in an:ociat:on , with specific type3 of equipment such as electric motors,, fluorescent light ballasts, and electronic circuitry. Census figures for capacitors ore collected by the U.S. L'esertment of Canrurce on the basis of seven digit SIC codes. The most recent data at thus level of disaggregation was obtained in 1972 and is sunmarized in Table 15.2-1 . below. More information at this level will be obtained in 1378, but vail not be available for several years. . Table 15,2-1 FCB Capacitor Production arri Solos: 197? ^ -- TyFe * Shunt and Scries Bower Factor Correction General rurpooe Motor Control Fluo"escunt. Light Bed. last Caracitors and other capacitors except electronic Product; on-Uru ts 192,700 22,100,000 rot available SaJos-'-tillion 5 4 1 41.1 39 32.3 (1) Source: U.S. Department of Ccrr'rrcc, nVctrieal Miaonrrmcnt and Distribu tion* Fcuianent, Publication MCd-j&V). -97- MONS 201416 Annual estimates of c'.pncitor solus volume ore iviiJoble c-a cm aggregate basis Crcm a 20T curvcv of. .ron'i-'acnurc--j at the five digit 5TC code level. The recent information available from this source us sun-crircd in Tfcblc 15.2-2. Table 15,2-2;1) PCB Cac^citor Si'es - by Year Year Sales - filllien Dollars 1972 1973 1974 1975 1976 112.4 143.1 157.3 119.3 149.0 (1) Source: U.S. Department of Cunncrce .' IS.3 Coroliar.ee Costs There are two basic techno logical alternatives available to capac itor manufacturers who nurt develop norr-DCB capacitor product lines. The direct, and probably siiort term, solution to the problem is to develop a di electric liquid which can be used as a direct replacerrsnt for PCBs within the presently used technology of capacitor production involving aluminum foil and paper as a solid dielectric. This type of construction has been developed to maximice the advantages achievable using PCEs as a liquid dieJ.ectrie. An alternative approach would be to develop a new technology which rakes optimum use of the materials remaining available to product designers. Much effort has been spent in evaluating materials for use as PCB substitutes in I both .the (J.S. and in foreign countries. No substitute liquid has been developed which equals PCB in dielectric properties, fire resistance, and stability. Any trrdo-off entails enhancing electrical per formance^ at the expense of environment!] or safety considerations. impregnating capacitors with alternative dielectric fluids and/or redesigning than may -9R- MONS 201417 result In substantial retooling, ru-.c-aren a:'i development, and otirv- product- icn related coots. Such costs are normally hue;!'. ,;t first, since the m jo* try 13 essentially characl;''e'irod as infant; i.c., it is facing a ru?w learning came due to the production of technologic illy r.av capacitors. IJcwever, runce all manufacturers are developing ron-,-C3 carr.ciuc rr, and circs those r.tv preducts will be introduced <-r->:nfcially su. ultur.eousl/, there i,:JL ho substantial cenpotation which will prevent the rjoid recovery of develop!'"it and tooling costs through market skinning. Therefore, it 13 ei.poctcd that this initial product prices will closely approximate the long term ranpetitive price sfreture cf the capacitor industry. A review of the present statue of each of 'd > na^or segments of the cr.ro.citor industry should provide an accurate picture of the response of this industry to the FC3 ban regulations. Power Fcctc* Cj-cc ion? large pewar factor correction capacitors wlucr. operate at voltages above 2000 volts are uoed by electric utilities to compensate for irductivecurxent lags caused by inductive. rotors and odor similar machinery. These capacitors are usually mounted oat of doors m substations or on pew or poles, and little risk of significant fire losses is incurred by the use of a flanruble dielectric liquid in these units. ' Prior to 1977, there were four manufacturers of PC3 power factor capacitors. All four of these manufacturers discontinued the use of fC2s duung 1977 and introduced non-PCB capacitors having the same functional specifica tions as replacement products. Table 15.3-1 lists the manufacturers of these largo capacitors and smmanzes the technology used in the now products introduced by each manufacturer. The soiling prices of these largo cv.pcc- itors arc negotiated on the basis of large orders, and no published price lists are available, liowever, Versar estimates that tiie prices of tho capac itors manufactured by Uestinghov.'.o, General Electric, and Sangamo increased lOt to 15% following tl:a introduction of non-FCB ujiits, and the price of the McGrow Kliuon capacitors lucres; -J to 20^. McGrow Edison clauivs exceptional product life and efficiency for tlieir product, and the higher price has apparently not had a significant r.gact on their share of the market. -y SI MONS 201*1 Soltis of FC3 tXT'A-ur facto:.* cc'crctaci carcciters ::i 1976 arc erta- nuted to have been approrurntely $5 1.5 million, Assuming relatively corn tant cut: uo and demand, a ten to twenty percent price increase of ccivrpornblc rou-rC3 power factor correct 'on cr.cc cituLS will rcodt, in sales of a^roxaratcJ / f>G0.0 to 565.4 million (using existent dollarj). Hence, utilities and othrr uixrs cf power footer capec_tors are expected to fey approJtiriiotely 55.5 to 510.5 rralli.cn iruce. Utilities ctrolcy npproxirvitcly ninety-fjvo percent of all po or factor corrtcUcn capacitoro. The ability of utilities to pas3 all of The additional costs associated with r.on-PC3 capaci tors cn to residential and caTtttrci.nl users in terms of higher prices will depend upon : tote regulatory crwmssions' attitudes toward rate strictures. Total revenue for all electric utilities '.-as $46.2 billion in 1975. It is estimated that total revenue tor all utilities in 1976 will have been approximately $50.0 .million. If al.l the utilities additional costs associated with using nen-PCB capacitors i3 pasted on to residential consumers, end tint their average monthly electric bill is fifty dollars, it is estimated that residential cor.tcrers will incur an increase in their electric bills of approximately .02 percent, or one cent per month. [Note that this is the long run effect? in the short run tr.s extra costs of ncn-FC3 capacitors will appear as a capital item in the rate base. If depreciation and replacement are both straight-Line functions, ever a ten year period, the rats base and the return on it will rise until the tenth year at which point a snail return on capital will be obtained as well as capital replacement costs.] Since part of the costs will os passed un 10 industrial u:crs, the relative price impacts 'will ba even less, and are not expected to significantly impact either the price or demand for electricity. -100- MONS 20I4I9 Trh]c 15, 3-1 Currently /''ail -L'lc ;'oh-a3 P-aOT Factor CO'- .ri'.m C' v.oi''Oi"3 Monufr.ctui Sol:d Dielectric laauid Dielectric* Vfc stinghouse General Electric Sangamo f-lectric Co. McGraw Edison Pepm and plastic film orrtaii >otion Paper Paper Plastic film Isopropyl aiphenyl Phtholatc ester** Phtiialate ester'* Dutylated monocnlorodtpnanyi ether * All of the li<nud dielectric materials contain stall amounts of additives as free rediem scavengers, etc. The identity of there minor constituents is proprietary miomation. ** The iJhtjkilafe ester baced liquids reportedly contain a significant .mount of trichlorcfccnzcne as an additive to raiia the corona extinction voltage. Industrial Cetzeitors PCB capacitors have teen used in a number of diverse industrial, appliance, and lighting applications incJuding arc welders, induction heatii.g furnaces, fluorescent light ballasts, and television sets. Table 15.3-2 Lists die manufacturing plants known to have used rCBs in the manufacture of this type of capacitor in the early 1970s. Versar contacted these manu facturers in September, 1977 to determine whether they were still using FCBs, and if so, when they anticipated ending their use of PCBs. The results of these contacts are sumorized in Table 15.3-3. Ml of these manufacturers plan to introduce non-FCB capacitors to replace the discontinued PCB products. In all cares, the new capacitors will usq liquid phthalic acid esters (phtivilatos) as a direct substitute Cor PCBs. As a result of Lius material cliange, an increase of 6% in the size of the -101- MONS 201420 Manufacture*"*: of PCS Tatar. "a `1 Cr'C'-i te-c in 1976 O-trpnny N p-a General Electric Cfcu'jxny Asrovox Universal Manufacturing Corp Cornell Cobilicr P. R. Mallory & Co., Inc. Sprague Electric Co. Electric utility CD. Copccit-or Specialists Ir.c. Jard Corp, York Electronics KF Intcrcnics Axel Electronic, Inc. Tfebe teutson,Tonn labs. Electro Magnetic Filter Co. location of tin p? ~_nt Hudson Fells, ff.Y. St. Edvard, N. Y. New tecford, Mars. Bric'r.r-ort, Conn, lbto/a, W.J. New o.'ICord, Vfayr.estoro, TVnn, North Arams, Mass. LaSalle, 111. Escondido, Calif. Bennington, Vt. Brooklyn, N.Y, Baynhora, L. I., N, Y, Jamaica, N.Y. Canton, i*b.ss. Sunnyvale, Calif. Source: Versax Inc., PCSs in the United States: Industrial use end L*'ivi.rc "i1*" ratal Districntacn, upri r.~rre. d, 7a.: National ICcnriLcal Infcrraticn Service, (MIS 73 751 rt02/lW?) February 25, 1976, p. 39. Updated by Verstur in later studies, Contract 68-01-3259. -102- HONS 201*2* TlMr* 1 r 3-3 Minufrrtr cars of tr-p1 Ercuid p; electric rar.'citm-r ' Small C'prcitor 5,Jcc (1975) * Mill1 on 5/_, ar Statue of rC3 Use as of late lft77 Gener a I r.'Jcctnc Aerovox UiivoirrU Mfg. P, R. Mallory Cbmeil Eubilier Jard corporation Electric Utility Co. Others 30 24 13 10 7 4 3 3 NO PCHb used PCEs inv";itory sufficient until June 1978 - Will end 1;CB use by mid 1973 PCEs inventory sufficient tlirouch March 1978 '" No inforrution available Will end vo of PTEs during first quarter, 1978 PCEs inti=nuory sufficient through mid 1978 '' Ho use of PCBs after 1977 * Source: Office of Enviiorarental Affairs, U.S. Dept, of Ccrrmarce 103- HONS 201422 capacity T5~fnu.ied to provjde tiie sore ul.ctricJ fun-ifon, ^ a ictu.lt of the 3 iso increase, C`OTO tranufacUirci:; who '.e? apJcucn in tha.tr rreducto "ill hfivc to redesign to allow loom lot Lire larger come i tore. Capacitors using metallised plastic film and pU'p.Uc acid r -ter liquid dielectrics are being tor.ted; if successful, such univs vrould be Lhe soma imu as equivalent ?Ch capacitors. The phUnlatcs arc ::ore firmruble than rCl's, and situ.factory fixe s. 'Ci.cy can on achieved only by incorporation of adequate circuit bleaker(prcs-uic or thermal typos) which will prevent rupture of the capccitcr case following electrical Ciilure of tho capacitor. Substont ;al testing `-as him requamd \o prove the adequacy of these circuit breaker devices to the satis faction of flic users of the capacitors because of the possibility of sub stantial j'loduct lj.aoi.lity claiais should a me problem develop with the nonPCD units. The development and testing requnttunts tvivo delayed the intro duction of the non-rC3 capacitors, however, none of the imnufaotuters of " small curacitors contacted anticipate using pets after mid 1973. Use of pC3s until chan will he bat'd on enistir.g inventories, as f'ensanto stove id shipping PCBs iji October, 1977, and no iiiiportation of ?CBs is planned by any capacitor manufacturer. The switch to phthalic acid esters will increase the demand for 1 tliis class of chemical by approwu:rataJy twenty million lb/year, compared to a total production of clout one billion lb/ycur. This tv.o percent increase in destand will rot significantly affect either the availability or price of this material. . Est-mutim of the unit coot impacts of the FQ3 ban regulations on tiie indue trial capacitor segment of the market is difficult for several reasons. First, Monsanto significantly increased the price of FCh3 during 1976 end 1977. These price increases reflected greater production costs due to envirwr-Tcniril pore.'.unions in handling and shipping the material, plus coots incurred through Monsanto participation in the regulatory pcccess. Monsanto 'van also in the -104- HONS 201421 position of supplying a uricya : "duct iuvr'i.i a lew p.-jcj elasticity cf dorand. The anticipated reguirticnt prcur.iod a high Lvafier to cn'rry into this rr.-irket for other possible jiufacturcrs of PCEs, go boncanto was :ji a ironofoly position, .ad their pricing may have reflected tins mar'iot condition in addition to germl inflaticrary pressure on all ccrTTodto/ prices curing this [/arted. The ret effect vuu to snerem the price of FCS ct .ncitors above went would 1. .ve toon a~:u'. ed micor lC'-g tens c:.;; iticavo ccr.datacna Slid there rot boon U\i threat of regulator/ action on the manui:actu\vj end use of PC.'o, At present, loth CO', capacitors ord non-FCB capacitors era available, although from different iRanuiac-turers. The r.cn-PCD industrial capacito'-s ace tolling for rboju ten percent core than the ?C3 units Jawing ' the earn functional choreetaristicu. Sinco tha tranufactircrs of ncn-.rC3 capacitors do not hove tho option of producing TC3 units, this price in crease may reflect tho premium vhich users ere willing to pay for avoiding any possible impacts of the ban rsgulaticns on their ere rations and inven tory roiner than reflecting increases in rajn>'Cncturing costs. Ecui iibrhm pricing wuld not b' e:.recced to result until IC3 capacitors were no longer available. Tha demand for capacitors is highly inelastic, because close sub stitutes are not available arid the number of uses to which capacitors cay be put are limited. Consequently, capacitor users will re confronted with prices for non-PCS uruts which reflect tho additional cost3 of production of such units due to the proposed regulation. The. increased price of rCb capacitors and the present caipetitive pressure on the price of rscrrfCB capacitors suggests that tho long term price increase dve to the banning of PCBs will bo more than tha present differential of 10 percent. A total t price increase of 50 to 20 percent is perhaps a more reasonable estoreto of the price increase for non-PCD capacitors. -105- KONS 201424 Sales of PC3 industrial enoactLeis L-i 1976 arc estimated to have been approximately SC] *7 million, n'lsuirumg relatively constant cutout ard demand, a fifteen to twenty percent price increase fer csnpomble non-FC3 industrial <c-g.ertors will result in said of from $59.5 lo $62.0 million (using con ii_ fit collars), Tlur. suggests that users ol inJuatr ie.1 capacitors will pay approximately $7.3 to $10.3 million mono for non-IMS units. Manufacturers of electrical aqua um?. it wntch will urna non-IMS inductrJel capacitors may face vrorioun redesign problems. For nramlo, manu facturers of miniature electrical ecuicr-int, who speci.U ize in optimising space in the construction of their products, may find that the production of a new, lireor capacitor makes too ccntin.uaticn of their miniatu.fi cr.d product line liniaC-run. Apart fro a the market for miniature equipment, most electrical equipment can to redesigned to accarodato the. semswnat Larger non-PCB capacitors at relatively little cost. Capacitors represent a very small fraction of the total production (i.e,, input) cost of a given appliance. Any price increases in final prod ucts due to employing ncn-FCD capacitors will be ir.pcrcoptable to ccnsi mars i.e., tlie increase in price par unit will he so small that the percentage change in quantity demanded will be very close to zero. It is expected that sales of electrical appliances will not be alf'rcted appreciably nor 'will' there be any dramatic effects oa,,employment in the capacitor production uv . dustray nor in the electrical appliance manufacturing industry. ' Users of ron-PO industrial capacitors may face creator risks of fire ns they :-.otch to suen units. Insurance rataa will increase to reflect any increased fire losses, but cnly after a time lag sufficient for naw risks to be incorporated into the experience record. Any decrease in the cr peered service life of industrial capacitors will hove a disproportionate effect cn economic impacts due to die prepared regulations. It is estimated th it fewer th.n two percent of all srnll capacitors fail before the equipment is scrapped due to obsolescence. The -106- HONS 201425 cost of replacing these ccpicitora includes cat of service Uu and high labor coots, and nay total ten tines tie retail price of the ropLicerent capacitor. the cost of replacing fail cl capccito. 5 nay therefore be equal to 20 p:"ccnt of Annual industrial crpacitor n^lag. if shortened service Life results in an increase of the rate of failure to 5 percent of the r.cn-FCn units prior to obsolescence, the increased roplaccront coats could be 50 percent of the value of Cm total stall captcilcr .Tirheb. -107- HONS 201426 15.4 Sufuturv Rcd^Giqn of eoairtont to <r,cccrrcd''ri3 larger crptcitors Long 7?}'r', Cnsti: ' Pa .'or factor capacitors Price incrt'ciiy for non-PC3 capacitors S5.b to 10.9 million pji" year Industrial capacitors: Price increase for ncn~.-C3 caoacitors Increased fire risk Decreased service life $7.8 to >0.3 million per year * * Bmlo'tnr"t zs: Kot ercccted to be significant Insufficient data available to support esturate of xr.pact. -108- MONS 20142? ig.o TiyvNSrcrcicu whbTACOxirhG Liquid filled transform-re containing a PQ hared liquid known generic-dly as 'asknrol' tove Lean used for '-any years in these installations mere the risk of fire justii cd the use of a fire resistant fluid. Askarel traiioformo: s have been ullcwod to to metal 1l ;i in hazardous locations such as m building:; without the rcquiiu-int far a fire proof vault or fire npnnklcrs. la sub stitute tran:former liquids h_vo yet been developed which have fire resistant properties equal to the 1X3 fcesed askarel. 16.1 Recninr'-nts of th~ Pro cocci RtonlahJcns ' Hie proposed regulations would prchtbit the manufacture of nw r rCB trrnfonners after December 31, 1970, but classify continued use of existing FC3 transformers ext ept these used in railroad locomotives as use an a totally enclosed manner. Tiro regulations would authorize certain minor .Ti'.intcnance of existing fan a former r for five years after the effective date of the regulation but would prohibit mi]or rebuilding of failed units. It is assumed that ' _ authorisation for rruror mamter-ujig would bo granted o:i request after the five year servicing autbcricatu.cn has expired as such maintenance decreases the risk of catastrophic failure of cisnnforr cis .sod minxaises the risk, of Iocs of PCDs to the envirormont. Disposal requirements for failed askarel transformirs are specified by the FC3 Marking and Disposal Regulations, and those require ments mcald not be clanged by the proposed PC3 Ban Regulations. _ A review of Monsanto's customer list for PCEs in the early 1970s indicated thirteen cempanrec torch used FCDs to manufacture a shard trans formers. These companies and the location of their transformer nunufr.cturirg plants are listed in Table 16.2-1. Production of askarel transformers averaged 5000 unite per year in the early 197Cs. lihen these companies were contacted by Vcrcor in September, 1977, only ore manufacturer was still producing asdrcl transfosnors, and it anticipate . ceusn j production of this type of urut prior to tile end of 1977. All of tinea uanufjctuivru produced Loth oil filled cud askarel transformers in the ruro yl.-nts, Oil filled trans formers or^* inter- -109- MONS 201428 U.S. Transformr Table IG.2-1 ` . i 11 L'--d igi, ailcx ] ?70 Co~;-ny Hrxn VJesLincjACuLO electric Coj.p. General Electric Cenrany Helena Corp. Hcvi-Duty Electric KuhLiUn Electric Co. Electro Engineering works Cnvirotech Duoll R.E, CJptegraff 'Lfg. Co. H,K. Porter . Van Tran Electric Co. South Docten, Yu. Sl-aron, Ta. Pori.a, Ca. PirtsfiolA, Findsme, N.J. Buffalo, ;i,Y. warren, Ohio f'jedtcrd, Oregon Helena, Alabrxa Goldsboro, N.C. Crystal Springe, :Liss. San Leandro, Calif. Lebanon, Pa. Scottsdale, Pa. - BeLvont, Galif. Lynchburg, Va. Vondalie, 111. Waco, Texas Source: Vercar Inc., PCHe in tlie Cm ted States.' Industrml u 5 and Fiiviror.it:v--J. luif.lireti.cn, =prir.gfield', Va. "halrdhiil Tccnmcal inrorr.i^ion ^arvica (NTIS P3 251 402/2KP), February 25, 1976, p. 89. -1L0- MQNS 201429 chuicabio with amltarel Lr..ay.for..i a<i .ii iii-'/ applications provided t-h-1- p instillation 15 properly c iqiro: rad Other substitute-- for ts'aarcl. tr r arc also avail.ible. Ito HO, COO a: toted triwforajs presently m ravico total only t..o percent of the total mx oar of pewur and cUitr notion transforms tn u: 16.3 .Out witQtn- f-r PIT Trrnrfrr nryi Tto uctorcl transforms ptc?r.ontly in scxv3.cn specified because Lius type of liquid filled unne former offered advantages tn ciro, reliability, e,J fire safety Cut \.ere r.ot available with other tyres of tinns- fornurs. Alternatives to rca tr-uvafoiTrcrs have always hoen available, eichouqn all of tho ether types of tren=iorxers havo different design characteristics 1 and none arc direct substitutes for tha PCS units. Therefore, ewitnil re pine. r>nt of th 1 existing PC3 transformers veil n'onre that each of the p"e- cent installations to rc-evaluatcd and that the necessary engineering changes to mode to ailcrv use of the test available replacement unit. Pew transformer installations vnll to desicr.ed to rahe optimum use of the available r.or.-fCSs' - transfor.rcr s. The choice among the available alternate transformer types and nutnrials depends on tha requirements of each specific application and the characteristics of the available non-PCS units. A number of alternatives to the use of PCBs in fire resistant liquid filled transformers and to the usa of transformers which contain any dielectric liquid have loan developed and are ccrrrrercially available. These substitutes for res transformers differ in thoix pcrfonrancc characteristics, applicable firs cede installation requirements, and cost. The following sections discuss die major types of substitute units which arc available. High Pars Pi-Cnt Liquid r1 sulcitad The 1975 National Electrical Code and previous issues alleged only Mi.i use of askarel and dry typo transformsrs in hazardous locations with out vault protection. Askarel was essentially defined as PCD based liquid. The 1978 NEC has added a specification (Article 450-73) for 'High Eire Point Liquid Insulated Transformers' vhich can be used under these tore cor-diticns. Tlx* 'High Hie Tomb Liquid' must luve a fixe point of at least JOO'C, end nunc not pnaccg.ite fluinss. -111- HONS 201430 Underwriters h .curatory os. e^nuiy lit It three lieu vis at meeting the. 'High Tin roint1 piroiaitty recui;\-:,:nts for transform-uu cpiratarg at voltages below 600V-. Dow Cor:iing 561 General electric SF-97 (50) SW5 Silicones Ccrp. r-130 Fcctnry Mutual Rettorch has not yet ccM-plctcd developing formal approval requires mts and procedures for 1 High Fire Point Trarmforr.er liquids' . Uotuvor, brood on preliminary tests, Factory Mutual h s iiaucd interim guidelines to its field offices that six silicone liquids and three hydrosjebon liquids could to accepted at Factory Mutual insured locations without special fire protection. Tlis list or Factory Ritual accepted liquid includes: Supplier Desir-ation Tyro of Flu Pew Corning Dow Coming Genuiol ilcwtric Union Curbide SIS Silicones Sh'S Silicones RFC Corporation Gulf Oil Chemicals Co. . Uniroval DC 561 DC 200 SF-97 L-305 F-101 F-190 * RIEmp EF Dielectric Fluid PAO-20E Mineral Oil-Billed Trine-'orders Silicone Silicone Silicone Silicone Silicone Silicone Hyclroca ebon Hydrocarbon Hydrocarbon If fire safety ware not a consideration, there would bo no rea son why oil-filled transformers could not be used in all explications. In the put LX's-filled transformers have cost about 1.3 tiros as nuch os oil-filled units of the sero capacity, and thus most users preferred the oil-type wnere possible. Thu oil-filltd transfortvirs are the see sura as the unlnral units, and arc considerably lighter in weight. Alio, nmcial oil has setnewhat setter heat -112- MONS 201431 transfer ciierectmeeicC then ar-Lxal, e-:.d on electrical arc in mirural oil results in breakdov'n products that ere norv-cuL-rosi.e. ' The major disadvantage to mineral oil is flannubdity; trans former mineral oil h-a; a 11a;h pomt of l-S5nC. If an arc occurs wvth the trtuvdoL ...r, the bred-down p'ocucU. will ho Jjjdrcgan and methane, both o whiten are fJcrrnnblo- Defiled aenti; of such failures cure rvirntair od fcv tie electrical industry, lire Underwriters decs no1,; approve of the vice of oils and o tiler flcamde liqueds for* indoor replications. Where oil-rilled iransicr'.ors arc not epacifically prohibited -at ou-sits replnc-meits for PCI*filled units, the National Electrical Cede reposes certain restrictions upon their a ode of installation. Oil.-filled transformers are used in almost all power trans former applications and foe most substation distribution ^plications /.here the trurocssion lire high voltage is reduced to 12.9 lev for local d:stribation. Most rural pole-mounted traits formers which reduce thn voltage to 220 volts are also oil-filled. The issue of fl.-aiTabi.lity only becomes important vhers the distribution transformer must be buried, as in many urban applications, cr located clo-iO to, widuoi, or on tin roof of the building it serves. FCB-filled transferrors have, in the part, been used in most ouch applications. Cii-filied tranefomrs can be used in these applications only if they are suitably ire lated fren flatimble structures or if there structures are suitably safeguarded against fires. Wien transformers'"ora located outside the building tny service, the lew-voltage power must be brought into the building via cables or insulated buses. Tlus causes additional energy losses duo to heating in the lew-voltage tranmiiosicn lines from tie tmiccur to the point of uec. Oycn AiV'Coolad Tivmsthr*,<ts Transformers can bn built without the use of a lie rued cooling medium. Cno type of dry tranofon.or that is quite successful, uijJer limited conditions, is the open air-cooled transformer. In this design, ceding air 13 driven through the transformer by either natural convection or forced circu lation. In those sizes wi-jero air-cooled trannfoninrs are available, they are -113* HONS 201432 about equal in pn.cc to a-karel-filicd tran:.forT;r>'H of the sam 1 k\a rati.''?. Ilowavu::, the toLie /eng liml-avicm pi event ceen-aar-ozeled tran*' foiTiers irem being considered tor many appl rcitaons using atkoxel-fillcd trm -.tonrers. H'vit car-mity: TIto pa.er drawn tre.n a transfoi.-.ur usually varies over a vide range. The rating of a tronnfor.. ar is est.-ib11 led by the power it can Ivr.ila continuer by without ovcr-ncatirq. If a liqn d-fillcU UrauufoLinnr is ceoratcd it overload ccndivioro for a chert period of tune, h > liquid wjLI act an a heat rink, absorbing the forcccs beat produced un the tin sfemer without a rapid inc tare- in temperaCure. The r.ecult of t'.is c1* erred, inertia is tint liquid-fi] led tinnsiormors can operate at outturn cf up to ?t0 percent of rated capacity tor a parted of cat to two hours without do,7003. Air-ccolol transformers do not have this heat sink of feet and are limbed to operating at a maximum service racing not rrh higher tlian the continuous rating. Where tlio current draw on the transformer does not vary greatly during the day, this limitation so not a problem. However, in most caco.'i the vari.-.p . tioji 111 load requires dry transformer to have a 20 to 30 percent greator capac ity than liquid-filled transformers in the srre application. Diclcctric tr:.noth; Hie liquid coolant in s. liquid-filled trnnufoiroar also provides a significant level of elec meal insulation hetic n tlie venous current carrying components within the transformer. ,\ur has a much lower dielectric strength, and open-a 11--cooled transfonners are limited to a maximum voltage of 25 to 40 kv. - The problem of electrical insulation is even more severe if the opon-air-ccoled transformer only operates intermittently. When the transformer is operating, the heat generated within the winding: keeps the insulation dry, and maintains a high dielectric strength of this colid insula ting material. Hoover, when the tranorerror is not operating, the coils ccol to ambient testperatures and the insulation con absorb moisture iron the air which reduces its dielectric strength. Cyan nir-cooled tronsfe-.i errs mst he tlxsroughly dried before being put into service after each ccol period. -114- HOMS 201433 One other ;uvhi. n with ' `er-.oclc-d transformers re tue tcrbc^cy of duct to Ysz. attracted fron the err to the coils by electrostatic fences. Duct can build up in the colic, ard blush the flew of air, or it can form conductive paths an! cocoa short circuits. O'cii-air-cooLol transfor:ii''rc are centra1 ly limited to dry, clean locations wears the lead requarenents are fairly even and court mt, and where the nexuntn volume docs not exceed 30 bv. Such trme former s ,,ta hem; successfully used m large office buildings, particularly tall- build,_oyi whore the lion: reivers are located ever/ few floors. Keen in this mpplid'.i-'cn, th.ocjn, conditions arise that evened the capabilities of the transformer; for instance, in the Crara TCwor in Gicago, which is over It CO feet tall, the clcccr'.c pewtr is brought into the building and up bo the distribution tiarnfocrcrp at 108 V/, which is buyend ti'.a voltage limitations of cycn-aar-ccoled transform ars. Closed Gc~~?illsd Tr">--'orders Trans forme ro can ba built -with dry inert gas (usually at an elevated pres.rare) as a heat transfer medi-jin. These transferrers avoid the treuntenoncc problm-; caused by moisture erd dust in open air-coded "v-ir.'-fcrr- r;, but they are similarly limited in overlord capacity because of reduced therad inertia otvparcd to liquid-filled transformers. Closed gas-filled transformers irust be installed in pressuretight containers due to the changes in gas pressure caused by chances in temper ature. However, the rvucinum voltage ratings of gas-filled transfomrs can be'equal to that of liquid-filled units. A number of different gases have been used as heat transfer nodia in closed gas-filled transferrers. The mast commen gas used in die U.S. is the fluorocarbon hexafluorocthone (C?t`c). Nitrogen and sulfiir hexafluoride lvavu also bean used successfully in certain applications. Helium lias not been found to bo a satisfactory gas fo1' this application bccauic its lew die Icctric strength revolts in corona discharges within the transformer. Hydrogen is ansati.cf.'cto'y tls any losh in the tinea formal would result in a severe fire h izard. -13 5- MONS 201*3* Because cf ilv r.e^~-y,\for a p: caearc vessel container, gns-ccoled transferrers arc 30 to 40 p-rc-cnt heaver": Uun PCD-filled trrraic: xirr,, ar.cl cost Uo-thirds more (and ~-n.ee as ru:ch as oil filled trar. si covers) . In ad dition, tha gas-filled trnnsformers must be sued larger tiun oil-filled units to allow for tlr: expected heavy load punJji of prur consumption. 1G. 4 Relative rric^s of b n-rC3 Tran:;tei-->rs The relative prices of distribution transform irs of the si.e and typo ccmtenly installed Li offieo buildings aro vnvnarized in Tables 1G.4-1, If the KTBrp high fire point liquid filled transfoi" .r proves to be accopU-hle for installation without aicnliary fire protection, thors should be no cost increases for ncr.7 transferror installations resulting from the ban on the nunufee tore of RGB transforrers. The cpn dry type transfoircrr ora also quite cost ccocetitive with the K3 units for irost applications. Table 1G.t-1 fl) Relative Tmv: former Prices T/r--> of Unit Oil filled PCB KTHnp Silicone Open air cooled Sealed gas cooled Price: 1000 KVA Unit* * $ 15,300 19,900 _ 18,400 * 22,300 20,700 30,600 Prirai 2000 .VA L'-mt $ 23,300 30,300 28,000 34,500 35,000 46,600 Source: MX Engineers, ''Distribution Transferrer Status - >7TI Pro^tct", Memorandum to U.S. General Services fdnuni,>t ration, Jvme 1, 1977, -116- MONS 201435 Clcmi-HD dlCT-fi!. The only ctcfs incurred by trnn.' or*-or mortifr stirrers due to to.e ton on the use of FCto will bo o3 r >,i up and <bryc<, al cento u-rjxrcd n flush-erg i'CP.u fi'cn sloir.ge and ...'tonal h. .riling c-yui'-i, _nt prior bo using thir> ccuipn:unt to store high f:i: point liry^de. Than <-ru iprent ce- .acts prnT rilv o storage trike, filters, pumps, aid piping. Clean up cn; t:t, melding disposal of ccntarnr it'.d solve '.o', sneuid lot exceed CIO, 000 per pJiuk, or a to oil cne tura coot u'-'.etof rt:I':pa 5100,000 in 1977 ar 1 1973. Hie 'high fire point liquid ccclcd transfcrrcrc' and air cooled tmnr.fonrero will cost .lhout the <v to to 101 nore than ankarai units tic good'.eg on the accept: bilaty of hydrocarbon base high fire point thin:-.;oreer liquids. Breed on revet sales of 5000 askacei units par year at an average price of C20,OC0, a 10C, cost increase would increase to files and cents to the oners by (5000 x 520,000 x 10% - 530,000,000 per year). There should be no efrect on total denind for trorrfenters for new applications. The bon on rebuilding askarel (rnnsf oKTcrn may increase the demand for r -w tnuEforrers by 1000 to 2OC0 amto per year. This additional demand should be easily supplied as ton transferrer manufacturing industry as it has recently been operating at only about 00% of capacity. Market structure should not be sigmficantly affected as all of the ferrox manufacturers of astard transferrers will have equal access to the 'high fire point transformer liquid' materials aid teclnolocy. Access to this racket ncptmib will open to tiose transformer nanufaccarers woo aid not offer askarel js an alternative to oil. lliis will primarily afford a marketing opportunity to PTE Corporation which lus never supplied atourel 'amts tut wruch lias a strong market position in the high fire point liquid trarsfoinvcr nv>rket scgmir.t- The increased sales by R12 will probably be lees then the total increase in trans/oratar sales, so this small sluft in inarkcc. structure utould not result in a net decrease in the sales by any of the other manuf.ictuicis. -117- MONS 201436 Incrcur,,' It was implicitly uriur-d above Uhl the high fare point liquids arc snrdsfoctory replucuiir.rvts for Ul.'s in terms of perlor.ivincc ard lire saftey. In fact, the high fue pouit liquid - can bum under certain co:diticnt including Safety Division of the EucioraJ Bureau of Standards under a research project currently being faixicd Ly the U.s. iiopartnent of Energy. the work of U`.3 Curuti of Standards is cornel etc. Any estimates mebs at thi3 tiia-s must nc.o'scarily be based on rather crude o crumptoons. It could be assumed, for example, that the 2G1 price pruTucn for asknrel transfoc-ers vs oil filled point train teemor liquid r.aght achieve 95% of the additional fire safety tmt would otherwise be achievable by usir.q aslicrcl. The increased fire leases re sulting ftait the use of the high fire point liquid filled units would then f-e one percent of the cost of the units. Bated cn a production of 7000 new and replacement units par yn.tr at an average price of $20,000 each, this loss would bo $1, '100,000 per year. 16.G Summary Trans it:1 ore? Casts Clean up costs for manufacturers $100,000 1973 only Lang Term Casts Increased cost of rjon-PCa transformers Additional fire lottos from use of non-PCB transformers $0 to $10 million per year $1,^00,000 per vrar (very rough v.ctituita) -118- MONS 201437 riVTTP '>1 t * ** Increased dunend for ripjiccrrpnt transfer'', or a :J'Culd 'TejV'mtc crploy,Tent equal to tliat loot m the t'-rsussacnr _r reL'ui.'dar.q' saprent of the ir Justly (see Chapter 5). An additional /3 jcoo v.ould fce expect'd in 1579. _llo_ HONS 201*3 17.0 tc/m, ^C3T fro; rj nc li\l ^ Lo The preceding chapters have discussed the various costs a hue!: will result from carpiunco with the proposed regulations. Costs of decon triturating or scrapping existing equipment, prep'.ration of 51.' ill control plans, and the costs associau-d with tire bon on rebuilding asi.arel transformers arc all transitional certs -- the annual cents will eventually decrease to -cro, though tills may require 20 years or more. Cent increases due to the increased prices for ncn-FC3 capacitors ij'.d trails foe.'.us will be long term costs -- they will to expected to continue indefinitely. Economic impacts, as distinct front cost impacts, include employ:ant effects, changes in market structure, and inpoets on energy demand and the international balance of trade. Those impacts, boo, can be both transitional and long term. 17.1 Transitional Coot Impacts See Table 17.1-1. -120- MONS 201439 Table 17.1-1 Transitional Cost impacts S KlUlm Erf Vcor 1979 Z>> JCi> TtftAoftirmtsr*! Hucuttyrcj dun up coat* 116) tan on ncLr<Mdtpr) 14| Itorc^urn Savings Ut Uevlcfl Tim , Trnsfuititer Service IS) j -i tu 2*4 0 1.41 lSfl per yoer 3.<t less Ikx year t/Mt Vbgc Spill Prevention plan > Uxo-oilve Tra3fonnarr (6) i i 0 0 fttrljrotlll ProtjTJrt 70 Prxdiali^ 0 2*7 12 years) llntl fetUyaiit tor CCB r<cfoi lirvj 0 *001 *1 (1911) 0 Spill 1 invention PIAn rco Cijxici Uif *02 " 0 L4piJ[nunt r%jLkil0n 415) i lnvw^LiJiy ctooleucunce O) 1 0 Oil Ffllul Tr<msion<ur* (7) idi ;^lyil* art Disposal Ml/llnr/ r**! 19) 34 ' ).<i leas per yodt ilhijulld Uxvk.fU Qvplcu Oj Doc. ji, mi Svtop CMtlrvnui Miners Oavlit* tif oac. n, mi iv-pori iij Custs >illl I ruvoikiUm Plan* .02 .04 ' 0 0 `LMt* mit iVaJlflWo to |u|^0(t ttUnpU) iWOb^ly pull coil IrrpOCt, $ Million TOLrl i .1 430 7S L l 7 5.4 .1 .005 .02 L 700 2 6 02 .04 tatL-u'.od Aeilobil'ty ot Tll 1 -901 Srwi ?0l 1 jOl l00t tim tin lln\ ilOOl ;:oi ncov ilc\ 1201 I5CI 11004 'r '' i HONS 201440 122- Table 17,1-1 (Con1t) Trarisit-icnal Cost Irrmcts Ita* (Chapter) ID 79 5 Million i er Ygar Huvi.oling toira $ Million tom; Et Jr-ctel n. ] Lu I Illy <t 'tjiji LI uctzoM^noL* if) Replacement Coot InciUMl IaLoc Omu j.j ,1 0 sis 0 .3 1201 -1901 i900% jr^wlic Syitaa (10) Oio Costing Machine* Amlytl* nJ Suvling OciMtUfJ Spill pravcmlon Mono itoccuHLinajirtUon qvIkj >tfiU.sin 1c Syjtano txrrwit.'* Jituion rrukivt-tloo interruptlefts 1 .a .2 7.1 J.6 A* a 0 a 7,J (1910) -0 0* .9 & M.S 1$ A* . 1501 1501 1104 -30$ *2001 -304 io:i ** iiuot IVjuafcr Sy.Uw (111 Qj^ireHtoro (12) norlairLd UIL 1121 IniicnscJ (Just of Synth*tie Rood Oil Ktlcilol lnui>isuJ Uic,t of ftttd OIL l/s 1 Ml turtlon of Facldlm) l!,JrtKkllc t-luld rilLkillvyoiilii' I1! *niU (Ml OdlVjC* II* .1 100 '4 .j $160 1 ndllldtt 0 0 .2 100 (*W1 2-S)**" SCO ii4 lyjMira $*131 .4 (1900) .1 0 .3 51,002 mill Ion Sl soi tiooi -eJt uoi -$ai +:oot 1201 -50t *2004 -004 H04 `Hits ir>t .nMijuMo 1? estimate. rotcrit'al I* largo coat i\Jact, "**Oa^U to cnillikie liJ4j(inUcly ly.tll wuta ini oil no loirjcr contains mm traiila wountl of rCSd. bu*d cnU*tldi OwroiMJtl da**rU my result in jlijuidcanUy culucoJ InpacLfl. HONS 201441 17."2 Lend' Ta'aa Cost T.rr'^t- Trane formara: (Qinptsr 16) Incrcn+ed cost of non-PCS tiansfotTn.-r-: Inc'Marcd fuc losses Capacitor".; (Cn-ptar 15) $0 to 10 mxlJ ion/year Data not available Inoroasad coat of non-PCa re-;.or factor cap lcitOLt; Iiurrased cost of non-lCB capacitors Increased fire )or,sis Decreased service life $5.5 to 10.9 nUiciv'y.^r $7.2 to 10.3 iiC.llion/y;.x { 50*5) Data r.o c av.'tie) lo Data not available Diarylxi? Yellcw Piement (Giaptmr 14) Increased cost of substitute pigments $10 to 35 iiu] J-rn/ycor Total $23 to SC million par year Present volte of long term cost impacts assuiung 10% discount rate $230 to 560 million 17.3 Bum]o\iv'_nt Imosets - Item (C-enter) PCB transformers Rebu aiding Railroad transformers (6) " Retrofill and decontamination program Oil rilJod Transformers (7) Aivilysis Disposal services Mining Machines (0) Spill Prevention Plans Elcctremagnsts (9) Increased demand Additional Labor for Operation: without Magnets Hydraulic Systems (10) - rV'non(r>|''.ination Program NO. of Jobs (3 979) Total Man Ycts -50 -1470 +55 +42 to 106 +69 jto 110 +2 +50 +50 +12 + 165 +1235 to 3113 +2029 to 3235 +2 +25 to 32 + 17 + 24 -123- HONS 201442 Lost Prediction frem closing or CacilJtie:; during decent am mat: oil Spill prevention plans !' 'porti,'7 require srr nts licit Trunaur System-, (11) Decontu.un.iticn proy/an Ccuptessors 0.2) Decontamination program potent i'] Cor treuSi'jrlo oC Joyed fr early m 19 7 9 i_n tV steel ojrluttxy for re/oral irontiij +5 +7 +1 -500? +5 +7 j +1 I nt'c.lcimud 01 (13) Dan on reel nTUtion of coatcmiriatcd hydraulic fluid -12 to 15 -24 to 30 Diary Lido Yellow rig.Tc.nts (14) Loss of jobs m manufacture of pigments -200 Capacitor Manufacturing (15) 'Item;former Manufacturing (16) 0 +15 Job losses offset by` ir.crc isct ample y- Trent m .'oMr:' of i ubntit ~.c materials. 0. +1470 17.4 Other Foorcnuc Impacts No significant market shifts are anticipated to result from the bin on the use of lCPs in the manufacture of capacitors or transformers. The only significant impact on energy demand will be for the oil required to replace the contaminated tr-rsLormr oil, hydraulic fluid, heat transfer fluid, and compressor fluid which mist be drained and inciteraced as port of the decontamination program. Thus requarurent './ill bo insignia icint wlK'n careered with total Oil consumption, particularly since the incr^.-ised demand for transformer oil will lie spread over 20 yoiurs or ncre. -124- MONS 201443 A nirrijcr of morcr _ls cu tho balance of trade r..iy be anti ci pited. The bon on the n 1 . Linen of red cauaciuo'"". in feere cn node electrical equipment night dccrc.v-"o tha avai_h Jollity cr slightly increase the price of reported opulianccn. The metrics ren cn the PCS contmimtion of diary lido yellc : ph-rronts micd end the u:portat: c.n of this Mtcrnl, However, the bin cn re cycling ccn.-cairvited tri'icfonrcr oil world Ire onpoetud to result m r.n inetcamd d errand for rev oil, ar.d the bon on the red' Hiding of trnneiiu.nccc will release the nci'-bcr of nc.v trarsicm 5 Ucr.g n, `nufccturcd resulting in an incm:'r.d drTend for baitd-to to make the <dcrdn'.Tn wire used in their cci emit iron. Cuificic.it data in not available to support a crusutib'.- tiVG analysis of there effects, and the total motet on tha balance of trade is not eip.cfod to be significant. No significant urpacos on supplies of strategic materials. were identified r.n the courts of tins study. -125- MQNS 201444 APrcKoix a TOXIC SUCSTTOOES CC:'.':'C!, ACT Public Lav/ 94-469 90 Stat. 2003 et scq Page A-2: Section 6(e): Polychlorinated Biphenyls Page A-3: Section 6(a): Scope of Regulation A-l HONS 201445 1`IJULIC LAW 94- >v3 --OCI 1!, L'Vf. 90 5 rAT. 2023 (o) Poi,TC)aO*UL'l.\r !> - (l) VlruhlU ;it '!IOli*h_, afttr tin* till Use iljto nC tluj Act tho Ailmi u* tr.itoi .lull luoinulitaio rule:, ta-- (\) mcrciibc nit thuds foe tL-> di^po-jd o{ p,,lychlorinated Lipl " \ ` , and (11) -* i oi\lh'utmlted hud m Is to bu mm Ltd ..thcli--r and nnnniii' v Li.i'ir >, wij m 'tut ntia with i.'/.w t to their pivti a nv;, di iu iini:,i .ii m kDiiin 11 iv, .i * oi ,.i.pi"il or with icopetl to ,tni edii'niiuii'iu ofuii. i atci. riu, RtTpniun *. i , p i am r iv i me nrm . ,iiui',iii i di.'R lu con sist' nt uit l ihr in'li.it.. cu oii'U i f-i * j 5,'ii !). (3)(.\) I.-vctiit cs [ii ). nttil iliiOli iiihp i| i-jr-ipd l J3 I, ef.rrcfi vp one ye.u litre the ci'Miic 'Lie o this, \st u> pn on inn' i.i.inul ttiiK, jiioci--' oi th.u uiuil- in i n iiinvu i* o> i. ,* :nv[i'l onJoii i.iistl 'npnciyl in .iti) i.MiH'cr oi her tli i m i totally t iioh,.,',, " inner 11) l'lio Auinmi',1 i"n inj,v by i ih- in'hoiiw the m mufneture, pro.' oil!", distribution ri cu'iimcicr of n a (dt any co.iibn.utiou of ilich .-divide-,} oceny ,.,'iy dji [) ifiv hi./"-i:y t :U : ,'t: ini'-oflici than ill A total!/ rinlo .iti m n. ir i u dm Vo'mii i iiorli'u1, ..i it n.ii i.mnu* f.itluu*, p'iti. v*iin'll :i[lnit..m in i jiti.'ii-i oi u`0 (it cunibm.ition ofsucii jell-, sties) iv'll lot [in-cist ui urn Cu-on-mle nA o( injury lo health ot tin* rut iroiKiu'iit. (C) fc'ui the puipi'ita of this pjuarr*[.li, the turn fotr'K uu-loscd niuimti ' iiiiMti!, jay in nine winch 'i'll e fme that piiv t.-oonure of hiinno h"iti"s or tie enui'.iMisi'wt to i jultciloi mated 1 * I * nit. 'is 1 will be iriaiytiiii ant us cicli-ii ini si by the Annum..ratoi by iu'c (3){A) !'\ci*pt jiioi lusl m Aubpai .i-i S (13) i.nl (L)-- (i) no porfoit may n..imiiat tin t ir.y -oly r'llvi i.i -{fd biphenyl iftei two y e-irs .ifto: ih. c-dectu c J tie of t m Att. a,id (it) no pciv>n t'<-'y (' or d:-.,mo ue ,n 1*0111:1""lp any poly, cliloi 111 tied bipiien. I 1 .ft 1 m ij ; 1 J u'K - 1 *' f ; * 11 = ' ' ter men date. (13) .Vjiy* |H.D11 limy peut-on i:ie Viluiuu n itor for in c"<*inptiori from the i't"|is.r-.int'nta of subbumjn bh (A), wd Ifi* Vd uniituwr iii.iy gi nit by mi* suili m rtrniptiou if il.e Adini'uitiator finda that -- (1) .an uJirtMionuble nat: of nijutv to health or enntonmont would not remit md * (n) "ood f.ulii eifotts h.ue been inatie to dctcloj' a cltcmicil snhstiiiiB winch dura not pnijcnt an un'e tsonuble it*.l. of injury to hoiSth or dm envircmincnt and which may bo substituted for such (lolyehlorinarrd biphrtiy I. An rtri.t[Hio'n granted under rhis mhn.ua;rjph shall h* subject to such trim, usd con`ln,on,> is tnw Ariimniitraior .nr.; ptescriue mid shall he m cifeet Cor mil* period t taut not nioic t'l.sn one year from tile dale it is granted) aa rite Adnim'-ti ttor may pre enne. (C) Siibparagrtij'h (A) slinll not ippiy to 'ho do.. A in.on in com- metca of any polychlorinated b 1 ys`11 v 1 if stiiS poi; rhlorinated biphenyl was sold for pur!'o*eii otliei tii,m rreaie befoie two and ono hlty*am.ftertiicdatcnf enactment or mis t. (4) Any ruin under parajr',iph (1), 1-3)133), or (.3)(B) shall ho promulgated in accoi-dante with pai,i_:t 'pii- yd), (3), ami (i) of sub- swtion ic), . ,, , (5) Th`5 subvciion does not 1 nut tlT luthorty of thr Atltninis. trator. imtlrrany'othei protir.on 1. um Vet or any other I'cdeial law, to take action 1 expectnif any policldoi iate.1 oiohcnyS, ,rrow(lr eaclcwd n'^micr,'* * Kcinoo Tur i*rnjir.oc. T<rn* 1 ml A-2 MONS 201446 IS OSC ?60S, svc. o. Jtkf ur atidn or rczuiDtHi ciumjcu. sorm wees A\n Mixu i.::, (a) fx-ont or 111 ri i \ ins ~-"Tf (l - ' 11.11 '..ill itnr 'iiul, >) jt "here i~ & in ii'nlilc In ..`i I., i .ii. luii' 'liu I i .i ii". -1: 3ct .iio I' i \ inrf, c|is tldiutnii in 'nmnnii............... I ill [. i! oi i oii'iiiii 'i.l -I mcc or nil (tui o, or tint mu 11 iiliin.ii. tin ni i i !i ti i'ric or u 111 piv "lit m iimea'iv d>.e n of .nju to health nr tii. "-n iromncnt. the Atli.nut Uator'n.il lc ,n|e .i i>pi \ < >o or more of Mi. ;oilo"t'v' i cqu11^ 111111=1 to 'iTr 11 Mil' : nee or nn \ (i: r to 1 he < i. i"if '.m -;,u v to protect adequately t.ihu 'iicli n I. n m- the h> t, I nrdcii-oi.'.e I rquii ciin ills (1) A i cun it 111. nt (A) pi-olnbi. ivF the iramif ict n.', procc-, m;'. ci ill mini' mi i.i curium'rr' of si < h jubilance m miU ire, or (1,} 1 triitm t t1 k ,. no.i.it of Mien -i i m . itc,' oi int\t nr i men in iy brill nili.ict.in-,! p,im' ,ed, or ci.Ui d ntert in ecm.imu" (1!) A icrpii nm or -- (A) pi iiliil'.! i i * * i in' tnJ.ui. i ntlutv, proctSMU'- or rbitribn* tw;i irt cot mi "1 to of ,uch mi1 hi' u or instln" [rr (i) a pai!itii!.ir i,-o r,r fit) a pirn ui.n use :n a tin. intnt'on in ruen of a Imcl specified by tl.ii Admmi'tiator m the rule imposing the i npiiicm:lit, or (HI li.'intiri'r tlie .amount of siir.li <iilj-.:ince or mixture winch may bo m.imif'ctnrt i. p.Ott'.vnj. or i.i.cnbutcd m commuice fin (J1 a pjrticnl.ir u's' or (it) a p lucular u- in ft coin/c.i r. non tu e\cf'j c-t i lea cl s'.'c.,,'d by the Administrator in (be mlc* imponii" (he reqimn . >j,t, ' (3) A roquirom.'iil. that inch '.Astana, or nmtutr or any article cutilftinin ' inch sob"anee oi mixture b-> marl ed w.th or accompanied by c'rr.r and adequate 'xarninjrs and instruct,or,s witJi tespict to its u-c, distribution i.i commerce, or dfioosal or with respect (o any combination of sum acuuties 71,form and content of rucli iuiiiii'l') and m'trurfuns snail be pre-c.ioed by lire Administrator. ' (1) A lequireineut that manufactureri and proct'mjrs of such Sub-taiicy or nmiiwr tr.alte and retain records of the rj'occs.u U'-eii to mamif-ietiHc oi pincess sucti subst.aticft or mixture anti monitor or conduct tests which are reasonable and nece^arv to assuic com pi to nee with the letpniemints of any rule lpphcable under (lus subsection, (5) A requiiement piohibiling or otherwise rcqiihatinij any manner or method of comruerciai use of such substance or mixture. '* (b) (A) A requirement prollibit 1115 or otherwise remilating anv manner or method of disposal of such substance or mixture, or of any a 1 tide coutniiiuijr such subMmtce 01 mixture. by its manu facturer or processor or by any other perron who uses. or disposes of, it fer eornmctcr.l purpssss. (B) A requirei,.i.nt under subpiraq.aph (A) may not rcquuc any person to tale ary aciion ohm would bo in v'oiauou of any law or rcqmr-mriu of. or in .'dret for, a Statu or poilticil subtlivioion. and shill lOmnre each o''"'on subject lo it to i-etitT each Plate and politic il subdtvitnuu m which a rcquiivd disposal 1 may occur of jiich 'ir.nir.el (7) A requiiement aucctin;; m nvufarturtr3 or prucvsaor; of Such anlist.nice or irr nr" { VI to ;i .e notice of stii'li t ni 'a-O'iahle risk of injure tn .li tnbmom in ../nH'ierca of in.1! .-ubsti.ice or unxtnru and, lo l!..' e .tciU :eason,ibl_, ajcortain ibln, In mV? per sons in po-,.,e*3!on of siitli -.iljst.ui.'e nr mixture or extiri.e-J to inch jtib'.nmc ot iiuxL'H'', 1 il) to yrno .miilio jintire of sur|, risk of mpuv, ,utd (Cj to uplace or r<'iHrcdn- ^uch -ubstanca or 1111.lure 15 cltfcteil bj (lie pcr.ou (') whu.li the M')`iifinenc is directed. Any rr'iinlri'H'lit (or ri'iiibiiiation of tcupiiremenii) ini|n>-eil mvlor this iiib.,etlou nmy U limited tn ippl'c .nan to spin.Hied ^eugi iplim aii as A-3 MONS 201447 EETEFJSXSS HONS 201448 A-^ocrny-'it of IrcV'*i~ri-it Vi, -''-.ipoiua lot L-A1 b tj'lieo or sJijd*.. : Lamer Hicfcn-in, DoccitJjcj: 12, 1977, a ccci-rr'nt pix- ru ^c^num man t-jjailuncny el !l. Antr-rc, 177G Ann1 ill Korcrt. AintniJ:, l'r.c-Ynr Cnna-inA e 3T.-n, 1977. I3i.urc.vi o the Ccmun, E.l.-.cirrj'-g1 ft:yore No. AC.'2 (2)-3GA,''i.i:;l.l~on. cm 'Jt-i.cn &'j]D nt, tD: 1377. . ENSCO, (.`t-ncial I-nCormnt3on E7'?Q>-FC3-001 P.cv. 3-73, El Dorado, Arkansas; March lsf/. , CPA, `'rm.il Decision", Federal Rojirter, February 2, 1977, pp. 6531-G535. Hofstader, R.A. (Dexcn Rosoarch end Erqincsrirg Co.); lack, D, J., Beebe, c,A. {Cornell University) , "Interfrrcnce in th; Electron-Ciptura 'Technique ror DtU;i-njjiati.cn ol PolydilcrmaUad Clprenyls by Sullur-Contoimng Cncpoerds in Petroleum Product a", Bulletin of 'dnv; roimntaj Contmn nation cirl Tonce) toy, Vol. 11, No. 2, 1974. , Kuratcone, Masanori, at. al., "Vusho, a yovjorurq caused by rice oil ccn~ tmuiotcU with polyciilorinateri bipnenyls1', rrc "1A Health A. sorts, Vol. CG, No. 12 {December 1971), pp, 1083-1091. Lapp, T.W. (Midwest (Search institute), `lbo .''.`'rufccto-'o U:e of Ol reted Ary) unrl Alkyl Aryl piiocphato raters, aT\"5u~o7iW<j-tH)'j/ rebruoiy J9/G, ' MOHS 20i*** REFET.ENCE3, canTN'LTD togruder, Robert S. (Continental E'ore-.t Industries) , testinony presented at the U.S. EPA informal hearings on th<* PC3 ban roguJations, Washington, D.C., JUly 15, 1977. touch, T.W., "Reroxinud Oil: An Option Tliat Saves Oil, Minimizes Pollu+j.cn", Science 193, p. 1108-1110, September 17, 1976. Metropolitan Transit Authority, Annual Report, 1976. Michigan Department of Natural Resources, File Memo, undated. * Monsanto Chemical Ccrrpony, Aroclors for -----, St. Icais, MO.: undated. ' NJ Department of Transportation, Higrilichta of Activities, 1976. ' Rouse, T.; P-aab, E. (General Electric Co.), U.S. Traasfcnr.*r Oil Supply and ' Petard, 1975--1 DflS, Interin Retort, Palo Alto, "CalLf.i Blccuric Per.Air Research Institute ("w-port >to. EH--303), Nov. 1976. * SEPTA, Report to the Public and Financial Statgr.vnts for 1974 and 1975 Staftrcne ot C.cjationsT* "' Uvsnas, Hugh (Outboard Marine Corp.), Presentation at the EPA Infomal Hearings on the PCB Ban Regulations, Washington, D.C., July 15, 1977. U.S. Department of Agriculture Ad. Hoc Group on FCSs. Aaricjlturo1 s Pesronsi- bility Concerning PolychJoEinatndiiBii'isnyl3 (PCJs) Wos'rungCcn, D.C.: O-iica of'science and Education, U.S. Department' of" Agriculture, 1972, '' U.S. Department of ctirroarce, Eioctrlcs.1 Maasurenent and Distribution Erv.vraont,- Publication MS(2-36A), " *' Versar Inc., Assessment of the Envircmnntal ard Erencmic Inrsacts of the Ban on Lnpdrts of FC'o, EPA 560/6-/7-007, February 22, 1977" " Versar Inc., Involvement of PCBs in the PuId ard Paocr Industry, EPA 550/6-77-005, February 25, 19'77. Versar Inc., Microeconomic Lrructs of the Prooosod Marking ard Disposal Pecu lations for PCPs, (EPA Report No, 5Vu7U-T/-UiJT, iij ringncld, Va.; wauiorZI"' Technical Information Service (NTTS No. fb-267 S33/2WP), April 26, 1977, Versar Inc., PCS Activity Analysis pj-qjs, special Report, EPA/CTS, July 11, 1977. Versar Inc., rG3s in the United Stains: Industrial l:so tud _Eiwtrorrjintal Distribu tion. spriiWL'.'o Ld, Va.: "Mr--orvti .Cu.uucal Lr--cMacian ;>_ivico im'is t-B 25.1 -102/jwp). February 1976. ' HONS 201*50 RLFCn-KCCS, OCOTEJUFD Versar Inc., Price Schedule - Quantitative Analysis of PCS'; in 10-C Transformer Oil (Price Sheet 100), Springfield, Va.: f:iy~l, 1978!, "' Vorcar Inc., U.'-.gs of PCPs in Opon and Stici-Clor?d System; and the Resulting Locs.ep o PCS' Tn ch Ltwcovt ~nc. tPA 560/0- i '-009 (uupuu.Ln.iou /oport), ScpccTibar "l, iV5'. ' VMrh, E.J. s Voytih, D.S.; Pearce, H.A. (wsstinghousa Electric Corp.) 3XaJ.uau.cn of Silicono Tl^id for R-= ulcer i~iont of PCD Coolants in Kailssiy Industry, Drurc Final !u;fort, import t'o. cclmuc-*12'J4, uuly, 19/7. Ward, Williem (General Motors Corporation), Presentation at the EPA Hearings cn the PC3 Dan Regulations, Chicago, Illinois, July.19, 1977. t'Jbsro, Ceorga (United States Department of Interior, Denver, Colorado), , "Polychlorinated Biphenyls", File KZS 3-3-lCh, Juno 13, 1977. . Weinstein, N.J, (Feocn Systems, Inc.), Waste Oil Recycling and Disposal, EPA- 670/2-74-052, Princeton, N.J. i August, 1974. 1 * T" . - - HONS 201451 fliUUOGJtAPWtC DATA I. ilcporr ,Nrt. JMfcGT 4, n<l AL.ii VtlMltU Microeconomic Impacts of the Pressed 'PCB Ban Regulations; 7. Audioc(s) Robert W-.-stin, Louis Feurt, David Eerhey, nrvce Wccdccck ^9 Pe/<o/rrir. Name and Addfou Versar Inc. 6621 blrctronic Drive Spriinfi eld, V'-rtTinM ?21S] lj. ?pon*oiirt^ Or* jaiZmon Nm and Addre-i# Offlco of Planning and Mamgemcsnt: '' U.S. environmental Protection Agency Washington, D.c. 20460 <> /IS. Supp(ttnfttif Notes EPA Project Officer; Mr. Steven B. MaDcsnson U Abuaetv J. fUcjpienc't Act*S5<on No, 5i hr port Unt Kay 16. 3 0 73 6. 0. fN'eorfornm5^3O5rgani^ingA r.eft It), -CCK Ln it No fid CoocfictyG^ar.*, No. 68-01-4771 13 V>pg oi Repo<c Period Coveted Final Tas^ P-rxa't 14, *1 . This report sirmarizes the estimated economic impacts of the PCB Ban Regulations which axe being propeced to iinplerajnt Section .6(e) of the Toxic Substances - Control Act. * 17. Key ford. ">d Docimm Anily.u. 17*. Ue.cnptor. PCBS Polychlorinated Biphenyls Capacitors Transformers Coal Mining Wests Oils Phthalatca Silicons* concn%B. 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