Document pB9EDrZG21EVb6epdNVXEEXXw

Last of all line the ilsoovery of highly-chlorinated diphenyls in the environment .the cosp&nies in question are organizing them*elves in such a way that, the part vhich cannot he regenerated la systematically destroyed by pyrolysis. NPC00007251 769890 / f,an m Oats Scotsc Sharon Works, KL-017 224-4295 June 4, 1971 1 .3 . 45-063-99B Instructions for Handling Inerteen and Installation and Maintenance of Inerteer Transformers. Sharon Works, ML-381 Mr. R. L. Schwab Sharon Works, ML-384 Mr. R. B. Pherson South Boston Works Mr. G. C. Wilburn cc: Sharon Works - ML-017 - Mr. n. R. Sbcppari Sharon Works - ML-017 - Or. 7. K. Bloat We have revised I.B. 45-063-99B to include precautions ar.c ins true t i m s for handling Inert fen ar.d Inerteer rcntariir.atec materials and containers. In making this revision we have completely rewritten the brochure to up-date it in all area:,. A copy zi the tentative revision is attached. May we have your comment-:, prior to making arrangements tor printing. ML-017 - Matls. Eng. Dept. - Fluid Insulation Section - H. A. Pearce, Jr. /bih Attachment NPC00007252 769891 MINUTES OP MEETING ON PROPOSED PCB EFFLUENT STANDARDS February 28, 197** Monsanto Company St. Louis, Mo. PC00007253 769892 Chairman: Mr. W. B. Papageorge Manager, Product Acceptability Monsanto Industrial Chemicals Co. Objective: The purpose of the meeting was to share Information, experiences and Impressions .to help each of the participating companies In talcing appropriate actions which are mutually supportive and effective in persuading the Administration of EPA to modify the proposed PCB Effluent Standard. NPC00007254 769893 PARTICIPANTS PCB STANDARDS MEETING Februar? 28, 1974 CERTIFIED BALLAST MANUFACTURERS Mr. N. R. Clark Universal Manufacturing Co. E.I.A. Mr. Arnold S . Doty Dr. E. M. Moore Mr. Rudy Carlson P. R. Mallory & Co., Inc. Electrical Utilities C o . Electrical Utilities Co. GENERAL ELECTRIC COMPANY Mr. James 5. Nelson Mr. Stuart Rlchel Dr. Edward L. Simons JARD COMPANY, INC. Mr. Richard Rollins NATIONAL ELECTRICAL MANUFACTURERS ASSOCIATION 'REMA ` Mr. A. M. 3ala~ WEI .'INOEOUSE ' Mr. H. Shett'-rr, Mr uftLtn NPC00007255 769894 MONSANTO COMPANY P. 0. Benignus H. S. Bergen D. B. Hosmer. R. H. Munch W. B. Papageorge W. W. Withers C. Paeon W. R. Richard J. R. Savage E, S. Tucker P. L. Wright 2- Market Manager Business Director Utilities and Environmental Protection Director Senior Science Fellow Manager, Product Acceptability Attorney Product Manager Manager, Research and Development Manager, Manufacturing Research Group Leader Manager, Toxicology NPC00007256 769895 AGENDA PCB EFFLUENT STANDARDS MEETING February 28, 1974 9:00 AM 1. Welcome - H. S. Bergen 9:10 AM 2. Introductory Remarks - W. B. Papageorge a. Brief Review of Proposed Standard b. Critical Action Dates c. Objectives of Meeting 9:15 AM 9:45 AM 10:15 AM 10:30 AM 11:30 AM 12:00 Noon 12:30 PM 1:15 PM 2:00 PM 2:45 PM 3: OC PM 3:30 PM 4:00 PM 3. Discussion Topics a. PCB Characteristics - Realistic Definition chemical, physical, biodegradation b. Sampling and Analytical Methodology Break * c . Toxicity Acute Chronic d. Bloaccumulatlon - BlomagnlfLestion e . Dilution - Stream Size lunch f- Proposed Effluent Stand S Control at Manufact* r'r Current losses Background 3 reek h. SconoT.i: 'oi; ; * i. Action Plans Adjourn NFC00007257 769896 MINUTES OF PCB EFFLUENT STANDARDS MEETING i. Mr. Howard S. Bergen, Jr., Director, Specialty Products Business Group of Monsanto Industrial Chemicals Company, welcomed the participants. 2. Introduction - W. B. Fapageorge Mr. Papageorge summarized the timetable past and future on toxic pollutants: July 6, 1973 Toxic Pollutants list published September 7, 1973 - Final toxic pollutants list pub lished Including PCBs and 8 other chemical classes (e.g. cyanide, mercury, DDT, cadmium, etc.) December 27, 1973 - Proposed Effluent Standards published January 13, 197* - Filing date for status as participant at proposed EPA Hear ing on Standards 'anuary 25, 197i - (i) Prshearine Conference with SPA ( u ) NEMA, Monsanto, G.E. and Westinghouse recognized as participants. (m) (IV ) A total of objectors ex pressed ar. ir.rerest. Thv represente:' industry-o. :-.a. associations with the exception of the Michigan Water Research Comml33lon and two powerful environmental groups (Environmental Defense Fund and National Resources Defense Coune i*I;. Pres 1cir.~ c f ic_sr 1 - cnac Hs"*.rings *-'iit te strie sly Je. cross -examint 1er,"of participants ' testimonies in affidavit form only NPC00007258 769897 -2- March 15, 197** - Written testimony by 38 objectors to be submitted In affidavit form.- April 6, 197** - Hearings open for cross-examination and rebuttal evidence. CN"/Cd/Hg first three. PCBs are 7th (third from last), Mid-May, 197** - Hearings completed. (Evenings/week ends may be used.) June 25, 197** - Pinal standards published - effective In one year. It should be noted that others who are affected by these standards can still comment by March 25 to: Dr. 2. Hugh Thompson, Chairman-Hazardous and Toxic Substances Regulation Task Force Office of Water' Protection Agency,. Environmental Protection Agency Washington D. C. 20**60 Industry representatives still wishing to comment and who need more background information can contact any of the* Industry participants (see attached list) or Mr. W, B. Ps^ageorge of Monsanto (31^-^94-^051). Mr. Richel (C-.S.): (1) Made a olea for greater Industry participation. Comments can still be made up to March 25 with sound excuse for tardiness. (li) EPA at January 25 prehearing Conference were reluctant to expose themselves to cross-examination. Dr. Hugh Thompson to be available for cross-examination at Hearings. (ill) Many objectors had common Interest (e.g, environments'1.1' EPA suggested a common counsel for this group. (iv) On each of first l pollutants, EPA would offer 2 w Mr. Dot-' (?.R. Ms:j-cr on starnarli. : w**v VJ*-- -ir.9. *- '--,* ,,V n--.; Mr. Richel (G.E.; stated: (l) Law is clear-economic factors are not relevant in establishing standards. (li) EPA Is somewhat of a spilt personality on this. The1 NPC00007259 769898 Presiding Officer at the Prehearing Conference ruled that economics are relevant. NRDC (National Resources Defense Council) objected and was over-ruled. (iii) Industry can and should therefore introduce relevant economic data. EPA would be wise not to expressly refer to such date in the published standard otherwise NRDC could go to court and EPA over-rulea. Department of Commerce It was pointed out that Sidney R. Gallier, Deputy Assistant Secretary for Environmental Affairs at the Department of Commerce wrote Monsanto on January 15 asking their views on the proposed effluent standards. Copies of Dr. Gallier's letter and Monsanto's response were circulated at the meeting. Industry should contact the Dept, of Commerce. Their legal counsel (Mr. Morland) has been active- on the side of industry in other environmental hearings. Mr. Salazar (NEMA) pointed out that the PCB Task Force had recommended a standard for PCBs of 0.01 ppb in the main body of water. (EPA was a member of that task force). ANSI C-119 proposes to use this Task Force recommendation and print this as a standard of 0.01 ppb in main body of water. Mr. Sheppard fWastlnghousg) queried if plant effluent standards could be setto meet"0.01 ppb. Dr. Simons fG.E.) said this implied an acceptance of ANSI C-119 by industry. There seemed to be some doubt on this. PCB Characteristics Dr. Tucker (Monsanto) presented hand-outs on: (a) Monsanto's proposed definition of PCBs . (b) Comments on EPA's proposed analytical methodology (c) Monsanto's pre-publication paper on biodegradation ` fa) Definition c. ?CEs 1-- c h lo r o b lp h e r .y ls co t.ot v *2 I-n g r * FC3s up cc tecraohlorobipr.enyl are no of concern or. environmental persistence or biomagnl.ication. Dr. Tucker proposed the following definition: NPC00007260 769699 -it- "Polychlorinated biphenyls (PCBs) means materials containing the biphenyl group which is chlorinated and which have been shown to persist and rapidly bioaccumulate in the aquatic environment. These chlorinated biphenyls are Identified as those components having gas chromatographic retention times greater than 5^, relative to p, p-DDE - 100, under the standard con ditions recommended in the EPA PCB test method." Mr. Sheppard (Westlnghouse) said Monsanto's proposed definition was relevant to persistence but was it relevant for standards directed toward toxic materials? Are persistent materials non toxic? Mr. Wright (Monsanto) stated the proposed effluent standard had two parts: (i) acute limits directed to toxicity of materials and specifically limits PCB concentrations on that basis. (ii) daily load in effluent - based solely on biomagnifloation (relevant tc persistence).- Dr. Simons fG .E .) pointed out that section 307-A of the proposed standard refers to persistence as being a critical factor to be considered. Dr, Tucke * (`-Ton?artto) stated we were badly hurt if regaraed as persistent ana if biomagnificat lor. fac 200,000 ar? used. ?.esearcner3 ether than Monsar.to have foi bacterial degradation of ?C3s and that ?C3s nave o< an fourr: undergo metabolism in both avlarlan and mammalian nim*!s. ;v Mr, Nelson (G.5.) asked if proposed' PCB definition wou] * exclude Aroclor 10i6. Dr, Tucker (Monsanto) Aroclor 1016 would be excluded part f$o.9$ is lower than centachlorobiphenyl). Arc-: would be excluded to or better. Aroclor 125^ nov not be excluded. vr. ?acarecrTMe Mensent *-! rtIntel w - v is" bVir.g zr iTicI T 'IrT ie zermir.ir.g U J^ list of 9/7/71 only bior.arr.i.icac olluta::. eared re Dr. Simone {G.E.) agreed. NPC00007261 769900 -5- Mr. Wright (Monsanto) stated that an acute toxicological level Is defined in the" PA Basis & Purpose document as s 10 ppm (96 hour LC-50). He also believes that differences In toxicity among PCBs are minor until chlorinated as high as Aroclor 1200. Mr. Kelson (G.E.) stated that words should be used In a dis course on definition to properly screen us on acute toxicity. In reference to a comment that Aroclor 125^ would not be excluded by the proposed definition, Dr. Tucker (Monsanto) offered the opinion that transformer fluids were easier "to re cover than capacitors. (b) Analytical Methodology Dr. Tucker (Monsanto) stated the EPA's proposed method for ?CB analysis was being submitted to ASTM. He thought the method was well written and capable of detection to ppt (parts per trillion) but it was untried and the quantitative accuracy Is in question. The method was not submitted for round-robin testing before SPA adopted It. Monsanto has found that by spiking distilled water with 500,000 ppt or 500 ppb of PCBs we get values for rCB that vary by 5556. The EPA, however, claims a capability of detecting absolute values at 50 ppt. The EPA method ignores interfering substances. Mr. Clark (Universal Manufacturing) said that with a proposed upper limit for ?CB discharge of C.06^8 lb*/day the sensitivity of 'analytical method would vary_ "all over the lot" depending cn rife- size of the water "reservoir'1 into which the PCBs dis charge . Mr. Sheppard (Westinghsuse ; commented that if the analytical techniques on determining ?C3 levels are so difficult, hew v 4.4 are the determination of toxic values for ?C3s. Mr. Clark (Universal Manufacturing) asked If analytical technlqu differentiate between different chlorine levels. Dr. T u c k s r (Monsanto) said it would depend on the PCB mixture! Aroclor 1242 could probably be Identified quantitatively In a mixture with Aroclor 1260 but addition of Aroclor 125** to the mixture would prevent identification because Aroclor 1254 contains PCB homologs that overlap both Aroclor 1242 and 1260, Dr. Munch (Monsanto'said that the use nigh resolution and hence hand individual ~eak3. sei SPA loan:i Dr. Simons (G.E.) mentioned that after EPA set automotive emission standards (NIOX) the analytical methodology was found faulty and the standards were delayed. In this case, SPA is not setting the effluent standard on analytical methodology but NPC00007262 769901 f -6 - on factors such as toxicity and persistence. The methodology is relevant in enforcement and monitoring. This then leads to the possible argument that the effluent standard is correct and Justified on the basis of toxicology et ai# but is not enforceable due to lack of an accurate method for absolute value deter mination of PCS discharge. Mr, Richel (G.E.) pointed out that SPA won't buy an answer to that argument which seeks to raise the effluent standard to a level that can be accurately measured. Mr, Savage {Monsanto} felt strongly, however, that this dilemma needed to be in the record. Others agreed. Dr. Tucker {Monsanto) said ASTM would hold a round-robin*cn the EPA method and that Monsanto would participate. He will send the name of the ASTM contact to the participants so that they can decide if they want to Join the round-robin test. Mr Sheppard fWes11nghouse ) said he was not prepared to accept that the proposed E:Jn method for determining quantities and types of ?CB in samples and animals was accurate enough so that toxic limits could be defined on the basis of PCB levels of question able accuracy. Toxicity Mr. HD5rr.gr (Monsanto? stated that the original EPA publication cn Water duality Jrlteria came from a publication by McKee and Wolfe for the .State of California. The MeKee/WcIfe volume was well done and EPA aid not change much of it. There is now a new 2-volume EPA edition extracted from the work of 10 committees of the National Academy of Sciences. The toxicity of ?C3g is related to .salmon egg stud .55 and Monsanto doubts the validity of this. Monsanto has made their feelings known to Dr. Thompson of EPA but he thought the criteria were sound. Since then Russell Train has been sued by HRDC and other groups on the grounds that the toxic polluter.list is not long enough and the proposed standards are too len ient . Mr. Wright {Monsanto} went through the rationale used by EFA arriving at a PCB discharge maximum cf 0.06^8 lb./day. He t showed how the standard could be changed and -et be cor.?'.*:_ with published data cn PCSs . De ta Lis folle-- 5 ppm in fish for human consumption 5 ppm in components for animal feed 0.5 ppm In complete animal feed NPC00007263 769902 7 (b) Monsanto would not disagree with these tolerances. (c) FDA has presented - acute toxicity limits {point sources) - chronic toxicity limits (daily load) Acute toxicity limits: 96 hour LC-50 studies for FCBs show: ~280 ppb in fresh water (bluegill) ~ 1 0 ppb in coastal or seawater (pink shrimp/oysters) Published data based on materials leaving an outlet and going into a body of water. Acute limits have no direct relation to chronic limits. Chronic toxicity limits: The EPA equation is: Chronic limit X water flow rate X safety factor gm/day discharge In Marine organisms the chronic limit is set as 0.S pom ^ ,-11** 537c " - 0<01q' p? In fresh water the chronic limit has been determined by using G o ?pm as toxic limit for salmon eggs and a 200.000 bio- magnification factor. This gives a chronic limit of i s i r t s --.2-5 m The biomagnlficatlon level of 200,000 is based on unpublished data from Stalling & Meyer (Fish Pesticide Lab, U. i. Dept, of Interior, Colombia, Mo.). Dr. Simons said that in response to repeated requests by G.E. to the Columbia Lab the only referenc they have been given is a Stalling & Meyer paper presented in Carolina in 1971 and which contains no mention of a 200,000 fac Mr, Wright ^Monsanto) stated he has seen only one literature reference to an accumulation factor of -- 200/000 ar.d that was in the hepato pancreas of a pink shrimp. If'the FIB .v` calculated on :r.e basis of the total sr.rimp then "ns accumulation fa:tcr was tr.ly 22770c. 'than r e f e I v r accumulation factors of i!00-`T5 ,000 for wncle tissues of vsritu fresh water organisms. Accordingly, Mr. bright proposes that a biomagnlf Icatlon factor oi1 30,000 and not Sou.QQU Reused, He also proposes that we retain the chronic limit of1 b .5 ppm wltF- out debating the salmon egg issue. ****000007264 769903 -8 - Thls would lead to a discharge level for PCBs: 0.5 * x 10,000 x 3O,0o 5 (flow rate) 0.5 X (safety factor) 5.** (conversion Into lb./' day) - 0.459 lb./day This compares to the proposed standard of 0.0648 lb,/day. The safety factor comes from the HPArs Basis and Purpose document supporting the proposed effluent standards. It Is supposed to take account of non-point sources of PCBs and is the same as 5 of the 9 toxic pollutants proposed for EPA standards. Monsanto's Medical Department feels this safety factor is arbitrary and confers no real toxicological benefit. If deleted, the revised Wright PCB discharge level would be 0.91o lb./day. One of the most critical parts of the discharge equation Is the water flow rateT A significant number of dielectric PCB manufacturers have plants on rivers where the flow rate is under 100 cfs or 1# of the EPA cut-off flow of 10,000 cfs. Several plants discharge into sewage plants which in turn have treated liquid flowing into rivers or streams with very low flow rates. For a river with 100 cfs flow the EPA maximum discharge would drop to 0,000648 lb./day or 0.162 lb. in a 50 work-day year. Even a revised standard of O.-id lb./day at lj,u06 cfs would only be 0.00913 lb./day at 100 cfs or ~ 2.3 lb. per 250 work-day year. Clearly this is a staggering target to nave to meet. Mr. Doty >Maiitry) po'nted out that in the presen' language of the EPn standards municipal sewage systems are no cons Ldere-d point sources. Mr. Riche1 (G.E.) was of the opinion that where a plant dis charged into a sewage system without treatment and hence into navigable waters the plant could have to comply with `effluent standards on toxic pollutants, Mr. Papageorge (Monsantej felt we should not be complacent and regard* discharge to sewage plants being the answer to problems. Mr. Hosmer (Monsanto) stated that 10,000 cfs represents the largest flow the z,PK wi : consider on the grounds thic all Industry would move to the largest river. The opposite of that argument is that it encourages small plants or. ever"/ stream in the country. Mr. Sheppard Vest lr rr.cuse ) raised the issue of Ta-**--*'ifr1--. Since if aVcearj that TTT the experiments to establish toxic value3 were run without edi er.c effects being considered, the real-life values were quest1 ned. PCBs attach themselves to sediment. Furthermore the sediment moves down river and so PCB would'be dispersed from the point source. It was pointed out by Dr. Richard (Monsanto) that Aroclor 1254 is soluble in water up to 50 ppb and that in time partitioning between sediment and NPcooooyaes 769904 -9- water could take place, Wr. Wright (Monsanto) agreed that the discharge limits were extreme cases in the absence of sediment considerations and this was worth study and incorporation Into arguments against the proposed levels. Dr. Simons fO.S.) queried whether we were correct in concentratlng our attacks on the criterion of toxic effects of mammals eating fish and Ignoring the possible argument that fish per ae must be protected. Mr. Wright (MonsantoJ said the proposed standard says both, in salt water, standards are proposed that would protect the species that eat organisms containing ?CB. In fresh water, if 0.5 ppm In salmon eggs correlates with < 5 ppm in salmon then we are protecting salmon. He also said that the chronic limits and biomagnlflcation limits he was proposing would protect the species themselves. We should, however, beware of arguing for higher levels in fish because we could draw EPA an" PDA Intoconflict. The FDA levels in food, fish etc., are temporary tolerances and any arguments against their validity could lead to a reduction in these tolerances. Mr. Savage (Monsanto) queried whether raising the level in organisms could cause possible danger to predators. Dr. Simons fO.S.) quoted from page 39 of the Basis & Purposes document which states shat the body burdens cf birds and mammals should not increase over present levels. Page 51 of the same document cites a Nat. Acad. 3ci. report which gives 2,0 ppm ?CB as tolerable level in flesh of whole fish. 2.0 - 0.1 com PCS 200,000 is given as tolerable level in water divided by a safety factor of 5 to give a maximum ?C3 concentration in water of C.0C2 ppm. Thus EPA accepted 2 per. PC3 level in fish but get to w cer concentrati a of 0.C02 ppm by using a high level of 200,000 for biomagnifi-.: cion and an arbitrary factor of 5 . If we were to revise the proposed EPA standard by: (l) using 2.0 ppm as chronic limit in fresh water species instead of 0.5 ppm; (li) substituting 30,000 instead of 200,000 for biomagnification factor; and (ill; lgne ring safety f a c c o o f C .5 cnen the maximum perr. .-si-ie discharge i be: v;__ 2.0 y 10,000 y 5-4 -- 3.6 lb. 307060 NPC00007266 769905 -1 0 - For the plant situation on a river with a flow of only 100 cfs the discharge would be 0.036 Ib/day or 9.0 lb. per 250 work-day year. These levels are still far below'"the 5 lb./day given In AtfSf c-107. It Is therefore apparent that other aspects of PC3s must be highlighted In order to get away from FCB discharge levels as low as even our "revised" proposals. Aspects to concentrate on are: (1) Definition of PCBs that excludes biodegradable homologs. This could exclude 90% or better of Aroclor 1016 and 6 3 % or better of Aroclor 1242. On that basis, discharge levels would be as follows: PC3 Type Stream Flow (cfs) Any PCB Any PCB Aroclor IClo Aroclor 1016 Aroclor 12^2 Aroclor 1242 10,000 100 107530 100 1,OoO 100 Discharge (lb.PCB equivalent/day) S H ^ Wright oimons/^iright 0.0648 0.000648 0.040 0.00648 o.if 0.001Q O .918 0.00918 9 .1d 0.0918 "5773 0.027 3.6 0.036 36.0 _ O06 10.d 0.10 _ _ f2) Try to change stream flows from the present value of the flow rate In cubic feet per 3eccr.d (cfs; expressed as the procable low rate occurring during a " * consecutive day period once in 10~years at tne effluent point. If the average flow rate over a period of time (to be agreed on) was used, the lowest flow rate in the equation could conceivably be raised by a factor of 10 from 100 to 1000. In the Simons/"Wright version for a standard the Aroclor 1016 discharge could' be raised to 3.5 lb./day at 1000 cfs flow and Aroclor 1242 to 1.0 lb, day at 1000 cfs flow. Magnitude cf ?!? Point-lour''=3 It is possible that I?-, and nvirorwisnca misinformed on the nuncar c clants 3til In-the U.S. today there are NPC00007267 769906 1 PCB manufacturing plant ~ 1 8 capacitor plants using PCB -'-27 transformer manufacturing plants using PCB In the past there were probably 1500-2500* plants using PCBs Only 2-3# of these plants continue to use PCB today * (Subject to closer checking if necessary) In the past -- 97^ of plants using PCBs purchased~40 million pounds.of PCB per year. Monsanto's PCB sales policy has therefore - reduced number of using plants to <~ 2-3# of previous total. - eliminated lbs. PCB sales per year. The EPA standard would limit PCB discharge per plant to 0.0648 lb./day or -- 3.2 lb./day across the U.S. ,(-- 50 plants). This equates to ~SCO pounds in a 250. work-day year. Since fish have survived throughout the 40+ years that PC3s have been produced and widely used, the standard proposed by SPA seems far too drastic. Turning again to the $ imcns./Vright proposal we can estimate the effect in terms of annual PCB discharge into water across the U.3. at 1C0C cfs: Discharge h a Discharge (lb./da_y) T~-US Total per No. 250 days Plants (pounds) A3 Pers istent PCBs ! Discharge .No. US (lb./day) Plants ' Total! Any PCB Aroclor 1016 Aroclor 12d2 Aroclor 1254 3.6 3.6 1.08 0.36 *1 900 18 16200 4 1080 23 2070 1.2 O .36 0.3b O .36 1 IS a 23 -CO ` 20,250 u Plant is or. river 1:* sheets 0 * . .J , V w - _ - Using this technique an argument can be made m favor of the ANSI C-107 proposal of 5.0 lb./uay. NPC00007268 769907 -12- Proposed Effluent Standards Dr. Simons (Q.E.) summarized the points he felt had to be dealt with in trying to change the proposed standard: 1. Higher persistence of higher PCBs versus alleged lower acute toxicity 2. Background levels of PCBs 3. Written testimony of participants and correlation Toxicity EPA Basis .v Purpose document (page 50) states that 96 hour LC-50 to fish cannot adequately measure toxicity of PCB. Where is time demarcation between acute and chronic. Chronic effects can be either lethal or non-lethal. Why are PCBs on the list on toxic grounds? LD-50 for PCB Is such that it Is not considered toxic to humans. For protection of aquatic life the Nat. Aca. Scl. set a 96 hour LC-50 of 10 ppm or less. In proposing a definition for PCBs, 2:'. Simons (G.E.) felt we . should stress: (a) lack of persistence 0f homologs below tetra- :hlorobiphsnyl. (b) chronic toxicity does not arise for the lower I'Omologs because they are"non-persistent. (c) Ignore acute toxicity - no real difference;: between Aroclor 1015, 1242 and 125". Participants need to consideri Do we have the best definition? In the tentative EFA analytical method we should take note that in the table on p.3-22, the percentage of PC'fi was not controlled. Mr, Carlson fE.U.C.) printed out that in its present form standard could saddle present PCB user: with-ail ot.er .11 continued uses. Dr. Plenari "'Monsanto - pointed t :t that Boxboard Manufacturer's AsstcVition nal rraei :n a : r r : protected recycle carer users fror, just such a situaci.:;.. Mr. 3ergen (Monsanto) asxad that copies be circulated to participants. A Npcoooopass 769908 -13- We need to word our definitions to exclude residuals. Participants should exchange proposed drafts on wording re garding residuals by March 7. G. E. stated we should not approach the hearing on the basis that things can't be done. Rather take the proposed standard and point out what It means in real"life. In u^E^'s case they use R ff~lb./year and yet can't lost 0.5 drops per day. Stream flow rates make the matter worse." This Is a point on which Dr. Thompson should be cross-examined. Of the participants present, 5 plants discharge Into sewers with outlets into rivers (very small except In 2 cases). Three plants discharge into small rivers. Wo one at the meeting could cope with the EPA standard as it is proposedT Only Jard expressed an opinion on what level they could!lve with. {Jard stated 27 lb. Aroclor 1016 per day. This would be 2.7 lb. PCB by our proposed definition.) I NPC00007270 769909 -14- Partlclpation at EPA Hearing Definite participation: Monsanto G. E. Westinghouse UndecIded; Electrical Utilities Jard NEMA No participation: Electronic Components Mallory Objectors of record could adopt non-responding company as witness. G.E.'s testimony will fall into the following areas: - Explanation of why PCBs are used - Consequences of ban on customers - Inadequacy of EPA/Nat. Acad. Scl. statements - How standards would apply to G.E. - Inadequacies of the Standard definition methodology logic behind the standard Other contributory actions: Involve Federal Energy Office (e.g. Aerovox letter or. motor-run capacitor contribution to ease energy crisis.) petrochemical producers1 PEG retort. Power Systems Group of IEEE will circula* tlon paper on PCBs (technical aspects) it dielectric industry to Congress, EPA, ?' Dept, of Commerce (target date: April) NPC00007271 769910 -15' Action Plans 1. (W. B. Papageorge) Circulate to participants copies of FDA/Boxboard Manufacturers protocol on PCBs in recycle paper. 2. (Participants) Exchange drafts on testimony regarding PCB reslduals/background levels with each other by March 7. (Monsanto contact should be W. 5. Papageorge.) 3. (Participants) Submit to V. 3. Papageorge their thoughts on proposed PCB definition (to exclude 1-4 chlorine homologs). (Participants) Communicate with each other on how best to handle sedimentation phenomenon (as raised by Mr. Sheppard of Westlnghouse). 5. (E. S. Tucker) Send out name of ASTM contact for participation in rovnd-robln on proposed EPA analytical method. 6. (Participants) Write to Dr. Caller of Commerce Dept, opposing EPA standards. (See Gailer letter to Monsanto and Monsanto response.) 7. (Participants) These who have not responded to SPA can still write Dr. Thompson by March 25. 3. (A. Salazar, N E M O (a) Get feedback f . Edison on the- 3.r.*;r v '`i (b) Determine ro. affldavlta/tz hearing. 9. (W. B. Papageorge) Obtain PEG report Mr. Nelson (C-.E .' ,2. (Partie leant3' Involve ?.E.?-. :.n lines tf Aert-vo.; ..... v Simon. NPC00G07272 769911 tf MAH 2 i) 1974 NaDonat Electrical Ijnutaeturerj Association 155 casi t n Street New York. N. Y. 10017 - 212-682-15G0 Bernard H. Flk Prnitianl March 25, 1974 Dr. C. Much Thompson, Chairman Hazardous and Toxic Substance Regulation Task Force Office of Water Program Operations Environmental Protection Acrencv Washington, D. C. 20460 SUBJECT: PROPOSED TOXIC POLLUTANT EFFLUENT STANDARDS - PC3 *S Dear Dr. Thompson: I am Bernard ", ralk, President of the National Electrical Manufacturers Association. I am writing in behalf of the Power Enuioment Division cf NEMA, which represents companies responsible for over 95% of tne domestic production of liauid-filled trans formers and canacitors for both domestic and foreign use. A list of these companies is attached as EXHIBIT "A". Our ourccso in writing is to object to the orooosed Toxic Pollutant Efflue nt Standards for A.Icrin/Dieldrin et al, FW?CA. (307) Docket No. 1 , particularlv in recard to the proposed star, dard for Polvchl er m a t e d 3ioher.v ln - *iC CFP 129. This c o m inication will serv;o to endorse and supplement the formal tastir.on alreadv filed hy individual companies before the Administrator in the current :iuarmes - namely, Cenerai Electric, Monsanto and Westinghouse Conies of tnis letter are beino s-sr.t to all objectors on the service list for the.Hearings. In the remarks which follow *.;e shall stress our or that the definition of PCB's employed is* too loose art toxicitv of PCB's has been misrepresented; that oreviou efforts have brouaht the problem well in hand; and that it safety and economic values are threatened bv the unjust if led extreme proposals for effluent limitation, which would alr;c e::a- cerbate materials shortaces and the ene rev crisis. We shail urea tuat tr.e E? A limit its control efforts to the .setters four.d in the environment ar.d establish limits attainable ;/ m d u * in.v consistent w itr. -c1ur.tary measures sire acy ado tied, n ion .: : been shown to oe rar.ir'ly red1: cme t:;e environments;, ur..-r -L cvor. in the aoser.or- cf reTuiaci :ns. Our first cosorvation is that the CPA has classified a wide range of different compounds with differing potentials for environ- C o n t 'd NPC00007273 769912 National Electrical Manufacturers Association Dr. C. Hugh Thompson 2- March 25, 1974 mental impact into one general definition of "PCB's". We urge that the Administrator establish a definition of PCB's consistent with the objective of protecting the environment against onl v those isomers found to be persistent in the environment. Excellent sugqestions for accomplishing this purpose are to be found in the testimony referred to above. We note also that a serious question remains as to the appro priateness of including any form of PCB on a list of toxic pollu tants. Certainly PCS's are not "highly toxic to man" as charac terized in the document promulgating the list of toxic pollutants (38FR21342). The toxicitv of the industrial formulations has been shown bv the reoort of the Interdepartmental Task Force to be many times less than the criterion referenced by EPA for such classification. EXHIBIT "B" is a chronological history of key actions by Government and industry in response to the crowing awareness in the past 4 or 5 vears of the possible adverse effects of PCB's upon the environment. An analvsis of this list indicates that industrv was oremot in respondincT to this environmental concern and took steos to bring the potential pollution problem under control even oricr to oassacc bv the Congress of the Act (PL 92-500) which authorizes the suaoested orccosed effluent standards The unilateral lotion of the Monsanto ComDanv in withdrawinn PCB's from all coen and semi-coen applications, such as olasticize r for paints ar.d varnishes, carbonless carbon paper, hvdraulic ar.d heat transfer systems, etc., acctr.oiished a major reduction in the total use of PCB's and in the total amount which could possibl reach the environment (entirelv apart- from any disposal centre', efforts). The only remaining applications countenanced by Mon santo's sales policy are in transformers and capacitors. 1-> order to minimize any entrv into the environment from tn mairiing applications, the electrical industrv through NE:-'. standards for handling these materials and controlling the . charge of wastes. These standards have since been adooted -an American National Standard, ANSI C107.1-(1974), Inasmuch* as Monsanto is the sole U. S. Supplier, the?a *' t'ary actions bv industry have crearlv reduced t.v- thro.-." ./ serious environmental contamination. - Cont'd- - - NPC00007274 769913 National Electrical Manufacturers Association Dr. C. Hugh Thompson 3- March 25, 1974 Another observation which can be drawn from the chronology of events is that previous studies of the values involved on the part of Government Agencies have resulted in the conclusion that continued use of PCB's in transformers and capacitors is currently warranted because of the public safetv and economic importance on the one hand and the lack of serious environmental threat on the other. ' Vie cite the Interdepartmental Task Force Peoort and the Food and Druo Administration roculation with reaard to food and food packaging materials and, on an international basis, the OECD decision. Within the electrical industry, the development by Monsanto and the DromDt adoDticn bv the manufacturers of Aroclor 1016 as a capacitor impreqnant substantially reduced the potential environ mental imoact. This new dielectric, it should be observed, is virtually free of the hicher chlorinated isomers which alone have been found to be persistent in the environment. The resultina effect of these voluntary actions on the oart of industry are already measurable in the environment. We quote from a paragraph in the Monsanto testimony: "Thus the situation today is drastically different from conditions which existed cniv three years ago. Today about 40 million pounds ner vear are being carefully used in the United States bv less than 50 Monsanto customers ir. the manufacture of sealed electrical couipraent. Prior to 1971, close to 30 million rounds per year were used by thousands of customers." Monsanto -Iso auoted in their resrimony the followlna scsrem.or.r bv Dr. George Karvev of the Weeds Hole Oceanocrapr.ic Institute: "In the summer and fall of 1972, the surface waters' ef t ' ' Eastern and Western North Atlantic Ocean had an averaae concentration of 30 oarts oer trillion. Bv the summer and fall of 197 3, the averaac PCR concentration in the same ar-1 had decreased to abour 1 oart per trillion. "Since the suspended solids fall out and mixi r.c rates the ocean are constant, r.he observed reduction n sur laver concentrations indicate a reduced '*C3 ir.c Aaain, in its last: 10 rarest basket surveys, the % e failed to find anv ccar.ui fiable rssiuos of PCB's. ;3ee rpcc Chemical News, October 1, 1373). Thus entirely apart from an*/ question as to the toxicity of PCD or appropriateness of the C o n t 'd- NPC00007275 769914 National Electrical Manufacturers Association Dr. C. Huoh Thompson 4- March 25, 1974 definition adopted by the DroDosed regulations, PCB's are diminish ing sianificantlv and raoidlv in the U. S. environment. Our member companies arc concerned that the extreme nature of the proposed regulations will make it imoossible for them to continue the manufacture of PCB transformers and capacitors. Should this happen, we recognize a significant increase in the risk of fire and explosion on premises where alternatives to PCB's are used. Wherever flammable liquids are substituted, there is introduced a higher risk factor. This would be of primary imDortance in such installations as schools, apartment houses, shopping centers and commuter mass transit vehicles. At the Present time, insurance regulations and cede requirements are built around the availability of ?C2's. There is no substitute available with a comparable degree of orotection acainst fire and exnlosion. As pointed out in the testimony submitted by the Westinghouse Electric Corporation, any regulations which would have the effect of banning PCB's or causing major relocations within the PCBusi.ng industry would impact on the livelihood of as manv as 34,000 Deoole {including workers and their families). The proposed re gulations micht *well encourage off-shore manufacture'of PC3's and PCB equipment, with a resulting unfavorable affect on the balance of payments amounting to as much as S150 to S20C million annually and the loss of ^obs for V, S. workers. As pointed out in the General electric testimony, there '.'ill be serious consequential effects cr. the industries that use PCS transformers and capacitors. G. t. has estimated that an inter ruption in the availability of PC3 trar.sionuers would cause seriou." delavs involving "as much as 31 billion cf construction projects ...involvino schools, factories, of fice- buildir.es, apartment houses and commuter trains." Similarly, if PCB capacitors should bo withdrawn from the market, the industry would be unable to supply the needs of electric utilities for power factor correction capacitors. "If none of these capacitors were available, the in creased cost of Generators and transformers and other equipment ...would amount to approximately 31 billion ter year." The G. Z . testimony contains data concerning consequential energy losses amounting to man" millions of barrels of oil and cites serious resulting dislocations in the lighting and air conditioning in dustries . Cont'd- - - NPC00007276 769915 National Electrical Manufacturers Association Dr- C. Hugh Thompson 5 - March 25, 1974 As a result of the industry actions described herein, there remain onlv a few manufacturers who use PCB's. These manufacturers are entirely within the electrical industry and subject to the disciplines of the American National Standard C-107.1. The capa citor manufacturers are the bicrgest users of PCB's and have been able to switch entirely to a new formulation which is biodegrad able. We can see no pressing need or urgent public necessity for the EPA to take any action with respect to PCB's beyond giving the regulatory support of the Government to the voluntary programs already established. This could be accomplished by redefining PCB's along the lines suggested above and adopting discharge limi tations consistent with current best practices. Sincsrsly yours f B H F :dk Aits; Exhibits "A" and "B" Service List CC: All Objectors on the Service List NPC00007277 769916 LIST OF CUPPENT AND PAST MANUFACTURERS OF ASKAPEL-FILLED ELECTRICAL EQUIPMENT TRANSFORMERS Allis-Chalmers Comoration Central Moloney Transformer Division Colt Industries Federal Pacific Electric Co. General Electric Comnany I-T-E Imperial Coro. McGraw-Edison Power Svstens Division Niagara Transformer Coro. Standard Transformer Co. Div. of American Oaoe and Machine Co. Wagner Electric Coro. Westincr.ouse Electric Coro, Past manufacturers POWER CAPACITO?.? Federal Pacific Electric Cor oar.y General Electric Ccmp.w.McGraw-Edison Power Svstj.ms .. Sanciamo Electric Comoanv SDraguo Electric ComDar.v a Wes tinchetse Electric 1. . EXHIBIT UPC000072'78 769917 Chronologyof Events During She years 1968 and 1969 there emerged a view, based on new scier. Cifie findings, of PCBs as widely dispersed in the environment and capable of certain adverse effects on various organisms. The following chronicle lists the major industry and government actions in response to this recognition, or having a bearing upon it. February, 1970 Monsanto, th only manufacturer of PCBs in the United States, alerted its customers to the potential problem of environ mental contamination. Major electrical equipment manufacturers relayed this information to end-use customers for electrical apparatus, with advice as to proper destruction of waste PCBs. June-August, 1970 Heretofore, PC3 formulations had been used in a vide variety of applications open to the environment, such as plasticizers for plastics, coatings, and adhesives; in semi-open applications, such as hydraulic and heat-transfer fluids; and in sealed electrical apparatus, namely transformers and capacitors (also termer condensers). During this period, Monsanto initiated the withdrawal of ?C3S from all markets except the closed application in transformers and capacitors. October 29, 1970 The Pesticides Regulation Division (then in the Department ol Agriculture) issued PH Notice 70-25 to the effect that "Formulaiors and manufacturers of economic poisons containing polychlorinated biphenyls ar.d polychlorinated ternher.yls sh.-ld change their formulations to eliminate such chemicals either as active or inactive ingredients. June, 1971 The National Indus trial Pollution Control Council .(Electric and Nuclear Sub-Council) published `"The Use and Dir;-:--;', of Electrical Insulating Liquids" and included in their rsport rcccraiendations to minimize the possibility of entry into th environment of PCBs used in capacitors and transformers* 7h* regulations were later developed by a coazittae of ANSI. August, 1971 Monsanto announced the commercial availability of Aroclor ' c new PC3 far~t.ilstint to meet the requirements at the caa-j industry. This nov materia', is substantially fees -f m o higher-chlorinated isomers tha: have teen to:'no m r;a environment, <tr~- has a r.igher rate of bio-da_ ad:non than ocher com .arctally available PCBs. The capac.ccr industry promptly completed conversion to the new material. May, 1972 The Interdepartmental Task Force on PCBs, representing five Federal Agencies, issued its final report, "Polychlorinated Biphenyls and t.ie Environment". Among other conclusions, the report found justification, for continued use of ?C3s in transformers and capacitors. " EXl.*ui* s HPC00007279 769918 Chronology.of Events October 28 1972 The Federal Hater Pollution Control Act Amendments of 1972, PL 92-500, became law. December 18 1972 The Food and Drug Administration announced (in an environmental impact statement) temporary tolerances for PCBs in food (to become part of a new "Part 122"). February 14, 1973 The Organization for Economic Co-operation and Development (OECD) announced a decision of member countries to control the manufacture and trade of PCBs, stating: "The decision allows for production of PCBs for use in closed systems, such as condensers and transformers in large electrical equipment, which present minimal risks for the environment",* July G, 1973 The Food and Drug Administration issued rules limiting the sources by which PCBs may contaminate animal feed, food, and food packaging materials. Transformers and condensers (capacitors) were specifically exempted from the restrictions. December 27, 19?3 The EPA proposed effluent standards for variou; toxic pollutant Proposed standards for PC3a were included. January 9, 1*74 The American lational Standard Guidelines for Handling and Disposal of Capacitor- and Transfcrmar-Grade 4skarsl3 C tair.ing Polychlorinated 3i .her.yIs, C107. i-(1974) was * c:..'vsd. -- EXII NPC00007280 769919 ENVIRONMENTAL PROTECTION AGENCY BEFORE THE ADMINISTRATOR In re: Proposed Toxic Pollutant Effluent Standards for Aldrin/Dieldrin, et al ). ) FWPCA (307) Docket No. 1 ) ) SERVICE LIST AmerJ can Cyanarsid Company Robert B. Owens, Esq. Theodore L. Garrett, Esq. Covington i Burling 888-ibth Street, N.W. Washington, D.C. 20006 American Iron and Steel Institute Max N. Edwards, Esq. F.i:hard E . Schwar iz, Esq. 1586 Y. Street, N.W. Washington, D.C. 20C05 American Mining Congress David W. Miller, Esq, Shea & Gardner 734 Fifteenth Street, N.W. Washington, D.C. 20005 American Petroleum Institute Edward V, Warren, Esq. Kirkland, EI'li3, Hod son, Chaffeez, Masters ar.-i P.c-we 1776 X Street. N.W. Was hin5c0r., D.C. 20C06 American Smelting and Refining Company R. Klrman Goleman, Esq. Brown, Moroney, Rose, Baker & Barber 900 Brow-Building Austin, "Texas 78701 Anaconda Company George K. McArthur Box 27007 Highway 10 East and Kell Tucson, Arizona 85726 Benzidine Task Force of ti Synthetic Organic Cherzica Manufacturers Association Glenn Nelson, E3q. Cleary, Gottlieb, Steen Suite O O 1250 Connecticut Avenue Washington, D.C. :U2t Steel Cor, . . :avid Shultc;. ?.0. Box 316 Pueblo, Colorado :11 `-2 Diamond Shamrock Corpora*; Joseph Emerald!, Esc. 1100 Superior Avi.-.u-? Clove*.and, Ini. -- 11- c *j rone le ..er.curs * Come -- ames C. tliidrew Wilmington, Delaware 19093 NPC00007281 769920 Electronic Industries Association Donald Wilson Panel on Environmental Qualities for the Electronic Industries Association 2001 I Street, N.W. Washington, D.C. 20006 Environmental Defense Fund Jacqueline M. Warren 1525-lflth Street, N.W. Washington, D.C. 20036 General Electric Company Stuart Richel Dr. E, L. Simons James S. Nelson 1 River Road Schenectady, New York 123^5 -Hercules Incorporated Edward Wolper, Esq. Legal Department 910 Market Street Wilmington, Delaware 15879 Inland Steel Company Prank ?. Cihlar, Esq. Mayer, Brown i Platt 988-17th Street, ::.W. Washington, D.C. 20005 Kaiser Aluminum and Chemical Corporation Daniel Marcus, Esq. 1665 K Street, N.W, Washington, D.C, 20006 and R. W. Turner Kaiser Aluminum and Chemica. Corporation Kaiser Center Oakland, California Ker.necott Copper Corporation Edwin H. Reefer 1101-Ioth Street, M.V,*. Washington, D.C. 20'*5 Michigan Water Resources Commission Michigan Department c:' Natural Resources. Carlos Pederov Mason Building Lansing. Michigan ^392 2- Monsanto Company Phocion S. Park W. B. Papageorge 800 North Lindbergh Boulevard St. Louis, Missouri 63166 National Association of Metal Finishers Peter Kovatls 248 Lorraine Avenue Upper Montclair, New Jersey 070^3 National Association of Photographic Manufacturers, Inc. Thomas J. Dufficy 600 Mamaroneck Avenue Harrison, New York 10528 National Coal Association James ?. Boyer Bituminous Coal Research, Inc. 350 Hochberg Road Monroeville, Pennsylvania 151^6 National Electrical Manufacturers Association William E. Heifner 1211 Gonne Af" lout Ave 4Jw 1 .11 11 Was hington 9 *\_ 20rwvq3^jT Natlor.a 1j. Or*-1.2n John Suthl es Grant Bull di Pittsburgh 4 pera tion 5 y1y ar.ia 15219 Natural ur pQ Ds V2r.se Council J, G. Spec R 1710 ll Str 96 * > New Jersey .7in . Jerome ?. omit; 20^5 City Line Ro-iu Bethlehem, Pennsylvania Olir. Corner Walter' J*. "hemic ais 'o' os J f> '* iu -* Reynolds Metals Company Mark 0. Tropea, Jr. 6601 West Broad Street Richmond, Virginia 23261 NPC00007282 7S 9 9 ^ St. Joe Minerals Corp. Balraot-Sdwards Division John McN. Cramer, Esq. Reed, Smith, Shaw & McClay P. 0. Box 2009 Pittsburgh, Pennsylvania 15230 St. Joe Minerals Corp. Zinc Smelting Division John KcN. Cramer, Esq. Reed, Smith, Shaw & McClay P.0. Box 2009 Pittsburgh, Pennsylvania 15230 Scott Paper Company . Roberts 5. Owen, Esq. Covington & Burling 888-l6th Street, N.W. Washington, D.C. 20006 Shell Chemical Company Andrew Krulwi3h, Esq, Arnold and Porter 1229-19th Street, N.W. Washington, D.C. 20036 Sun Oil Company Charles 1. Spann 160S Walnut Street Philadelpnia, Pennsylvania 19103 Texaco, Inc. AT. art H. Lasdav ?. Box 509 Beacon, New York 12508 Union Oil Company of California Edwin D. Blum Union Oil Center Los Angeles, California 90017 Velsicol Chemical Corporation Nell R. Mitchell 3`11 East Oh^o Street Chicago, m i n d s 5oll and Bernard H. lorant F.C. ox 858 Highland Park, Illinois 50034 Westinghouse Electric Corporation Norman -William Smith, Jr. Gateway Center Pittsburgh, Pennsylvania 15222 Wheeling Pittsburgh Steel Corporation Dr. William R. Samples Duval Center Wheeling, West Virginia 26003 United States Environmental Protection Agency Office of Enforcement and General Counsel Allen W. Eckert, Esq. James A. Rogers 401 M Street, S.W. Waterside Mall, West Town . Washington, D.C. 20460 -3 NPC00007283 769922 An Environm entally A cceptable Liquid D ielectric or Dc w e r C apacitors e _ o- M cG R A W -SD ISQ N C O M P A N Y P o w e r S y s te m s Division NPC00007284 769923 Page 2 li ts apparent from these actions that there is a possibility that there will he a total ban un the use of PCBi ir. the United States in the near future Tfu situation is of maior concern to manufacturers of power capacitors a: J to maior users of these electrical devices. McGRAW-EDISON RECOMMENDATION Over the pas: several years. McGraiv-Edison ha* beer, en gaged in inumber of testing activities with nve* 30 liquids aimed at the development of a replacement dielectric fluid for power capacitors. One of these fluids, called EdisolTM fluid by McGraw*Edison Company, was found to possess the required electrical, physical, and environmental Diaperties specified in the testing program voais. Edtsoi fluid is a diphenyl oxide (DPO)-based fluid and wjsdeioloped loiutly with Dow Chemical Company. Ooeraring efficiency of caoaorcrs impregnated with the new environmentally *afe insulating fluid is eaual to --or better than-uniu using PCB. And. sue '.s net affected. INTRODUCTION The history of developments in the power capacitor in dustry has been quite dramatic over the la.it 30 years. Through material and design improvements, power capaci tors have had site reductions from $0 to 10 cubic inches per kvar anti puces have dropped from S5.QC per kvar tu the current low of SI.50 per kva:. making capacitors arte cf the best buys in the elsctncs! moustry. A major contributor to 'jus dramatic product jmprcvemsn has been the liauic die.ectnc Ajocior.* a capacitor-grass askarel containing polychlorinated btohenyl iPCBi. But toJr*, tanaciior u-ers and manufacture's are faced with a mil or problem. Table 1 is a bnef account z: industry and jovernmniui activities regarding ?C3 *,:qu.a over ais p-it ten years. Table 1 Industryand Gawnnumt Activitiesan PCBi 1966 PCB O ta c te S in in* a rwt roomer.-.. 1971 Federa. gov**nm rm tK i& i i n n m i' fo rc e io c o o rd i nate governm ent effort mvaitigating PCB h ouidi: FDA i i ta m o cra'v PCB to U ra rtu ;eve'l 1972 M onunio v o lu n ta ry resin c u a il of PCB iiauid to elctr>;3i jo s 'iu tio - u . 1972-3 EPA i n . i i j t new t e e r s a c " to :o i.i- o o ilw :a r i- e t* lje --. n e n e rd . 1974 ? A c e v e io s t !>! Cticunie-.t i,an m a 'er i t e r o - #r<J .1airtSt't*on ItS?5 i ! GOoCvipi'"n*fn.lr;.iV.u-Jn.i-.SrJs".-e>s:*?ir-S^hvkt-*;a;C*'c\Jtu-'*1 sa j I "ifet.*e;*i*#ra*2 PCSuie-tc-- n-cs'cs--ourv-s. j i I EPAsnfllie:eft.amt;:cnet'o'obomii s n (unaoie 'toiacement(touts;rotPCBi aoconvene;n.cni eonfner.eeonPCSiiodiicuiienccentvluuo'luvof furtheritesitonrpreduceenvironment!conierm- nationDvPCBi 1976 EPAmettimiinmanuiae-viieriumqPC3iandeau'Omenijieninfliicuii:ecnno>(M.cal,tn*ironmomoand0911MMC11OlOSIHD-eMllilum Jv'V 1 EpAAtlreguircjrrod<EC*Vd'9VO1 1977 .*bf*S** *1 efleetisrvcani;n.,-:uv HEALTH AND ENVIRONMENTAL EVALUATION Dow Chemical Company conducted an extensive and com prehensive evaluation of the impact of Edisol fluid on the environment. Their evaluation was based on. 1. Persistence in the environment (hiodegudability) 2. ToXicity in mammals. 3. Toxicity in fun. 4. Bioconcentrail on in fish. Dew Chemical Company* health and environmental test procedures have evolved over :hs pasi 40 vmts. These procedures are based .n. extensive experience in 'sting and marketing a wide variety ct chemical product: aiour.d x.e world: experience with go \T.men:si regulating agen cies, participation on mdust: ai standards committees, particle un :n acaucm..* cjusiocrc.'icns of questions of hcaiiii ar.d ftivircnmcrtal impac: PERSISTENCE IN THE E N V IR O N S l *.BIODEGRADABILITY! The rate ef fei.njsstadibfi'; depends or, three maior a :;. -- - 1. Type of water samp.;. ;.e., se-* . . nver, etc. 2. Type of bacteria presen;, dim mired as found i chemical plant sewage or noiwccJimaied as found in ci: sewage. 3. Concentration of bacteria. T.*.: maior hemic:*! : j in rn n i'1- ' f.,:o :j "1 Ti'.'cicrsc.' a rate -if t.irei ias'rr t ** -v.-: cnemicd c-j.noo.-iir: -:*PCB ::ta; sees *-,c . s;:ow; tnat the rare of riudeg:adcr -. me .owe; cr.u-r.r.- ated fractions of PCB is fixitem;.1. dew. "r nor.dctcctabie. which is atinbuted to the higher dr?-;-: -v' cmonnaiion of PCB. The rate of biodigradabiinv of t-Jis;.; fluid is com parable to those of common itidu<i:;u; chrmiwals Exomules of these would be nanthaienc moth balls and dtcjiloo - henitfiie used to deodonre Ijvjturifi Neither of these industrial euruiu.'ls is known t.i present e:::fieai't sihiumi- mental problem*. NPC00007285 769924 Figure 1 Guidelines available an hazardous substances such as PCBs requite disposal o f liuuid wastes in men-temperature uicnieiaturf and solid wastes in specially designated dry landAils The recommended disposal o f Edisol fluid is by conventional incinerator or a proper!*, designed landfill :n accordance wt:li sute j>ic local regulations. This teceminencjuon <s based on the uvrai! interpretation o f the Iieatm jitd cn%ii eminent ai `cro pert res of' Edisoi fluid. TOXICITY IN MAMMALS Edisol fluid is less toxic to animals than capacito1grade Pfbs. Tests pc; funned inciuasd tuxietty rr.r.i oral feeding, slim adswpuur.. and vapor innalation. pius irrita tion lo eyes and vkin. Based on tins tm'oniuuur,, ntminul prutscturn measures for workers handling chemicals arc recommended m acLoidancc wuh the Occupational Safe tv and Hejiih Act o f l*J70. This recommendation applies :u chemicals with the least potential handling hazards. In tests regarding oral acme toxicity to mammals, results showed that the highest practical dosage o f Edisol fluid did nut kill rats. Evaluated during ,> ''M-day dietary feeding titidy. no significant differences resulted :n crnirol rais ami rats fed up to ! i mgikc -ias in . j .mT-<e person i l l ' , sounds;, this dese would re e^ysaJen; *c 750 me. Jay or j$0C parts per miihcn n consumed :r* a : . k ;;ih z h i;y ni.ne mar. a p-vand| d :ry r<v:!>-, of meat :: F.jh. Accumu lation studies ihow \r.y E iu ri fluid accjr.a .ite : .: least TOO limes less in jn n i.it :'ji than capacityr-gr-ics 1*. j. TOXICITY IS FISH The toxicity o f Edisol fluid to fish is significantly less than ttic toxicuy of capacitor-grade PCBs. Table 2 shows the conccmu' !'!*, t-jcvc/sil common samples that isTeilul to in percent of loTfisii I LC'50*- Page 3 : Tosicity Low Mostrate Toxic Exirtm Table 2 Toxicity Classification far Fist1 Ejurn&l* Emvi rf'co- Qrv ciaanmasoi*r"t XiaD'itnjicnt (mombs'l>; ODT 1l i j 1 ! IpLCpmso) ICO 10-100 1-10 1 jj i : ; j Table 3 shows the results o f the conventional datic-uater test on fish. In this test, fathead minnows were used to compare the toxicity o f Edisol fluid with capacitor-grade PCB. Edisol fluid is moderately toxic to the fish wlule PCB is extremely toxic. Table3 Tbxicilv in Fish LCS0 (m q'liter: ppml T1 96-bour auc-watt! (EPA rxcommendod pro* cedure) Edaol Fluid 15 | PCB j 0.76 For a volumetric petspeclive o f tnis contamination, the 0.7b mg/Iiter 1 equivalent to approximately -45 drops o f PCB (from an eye dropper 1:n ,1000 eaiioas o f water. This is the amount that will kill 50 percent o f the fish in % ivuurs. In order :-j kilt no fish m this psr.cd or time, tnc laminates wsier would have :o be dilu' rd to t'j.oC'C c-i.jr.s. Farciicr r:s ir*. this iOme senes radicates a:: greater differene.* in toxicity for icncw exposures. BI0C0NCIN7RATI0N IN FISH Tests to evaiua'? cherr.:.:,; bioccr..vr.::j;ltVt> r sir-.nv trout showed that Edisoi fluid has a i ** mocoiice.itra ion potential as opposed to a very nigh :v te r,:u i c a r.. grade PCBs. it is tins bioconcaiiua;.or. P C B s \ _ is one o f the must detrimental error. j. - and gives rise to the FDA iinut o f five *:.*- fish, For example, compcrmn; .*: * .; > significant components of Edisol fluid K b .. grade fluids siiows that tne PCB tuocoitccmiaiioi. r>-=......... is 30 limes greater than that >; Edisoi fluid U re jn u cnemicais that have low water solubility are easily oil.^cJ up and stored by fish, opecict!*. in :iv at Tins kct'isens whether *;ie chenue-i:. arc .'.'fsent :: e.t -oa : ::iv vctsi. ENVIRONMENTAL EVxLU \TiCV Si.".*.! Aii V Table -i summarizes flv: cr s-vwcnit.enii. evaic. r. tests. Capacitor-grade PCB. transfi'rmr'-cridi.' mue::. and Edisol fluid are lined in a forced ranking cased on t.^ ir degree of environmental hazardousr.es To make a totally valid evaluation, these four tests must be considered col lectively, not individually. NPC00007286 769925 Table4 Rilllive Environmental Haji'tfi 1 1- Forced ,`tlo5! lcK*(T)ti' !f . ! Toiisnv IMjmmjl.f \ t h Btaeoneentrn.oni!Totai* f PCS i 5 f 3 |5 S !8 Miner* , . | on 30,4 lL 11EFdi,er*i`! 3 1t 17 3or4 t t3o i 10 2 j 8` *A tom of 20 ii tn> matt njiargovit 'nkino pombte <nd 4 n the lisit haurdout rj"kt''5 electrical test p r o g r a m Since lc>', l. McGraw-Edison has been cmiGUctuts an active electrical test program ui: nuih sniad and lull-size cjpacmir* using various liou: a uisiectrKs Over 1000 small capacitor units were tested and over 400 of these were tmpiegnated with Edisol. During inis testing phase, units were subiectcd to voltage stresses at 125T to 20Q,ii or' rated voitjee and at temperatures ranging from 6UC to t0C Switching surgeMasts iwere performed ai 1SO' i of rated voltage for Si)Q0 hours. During this penud. 65.000 switching operations were performed at 2500 rated stress. No capacitor units fjiied. During another phase of this resear';!; program which spanned a n-cned r.f 2-1 ` Z years- i00- arc fCO-k.-ji full-ticc capacitor units were cre.sied :r. ev^s-v it rated vatacc. 1. 200-kvar units eitviicec -,xnii"uyus!;. lor over one sear at i301" wf rated voi;ae;. 2. lOO-kvar units tested continuously for 2-1/2 years at i lO'- of rated voh-acs. 3. 00- and 200-kvar units energized tnienr.v.ttently for 2-1/2 years at up to 160" of rated voltage. 4. Over 20 million kvar-huurs of operation ineged. And still no capacitor unit failed. Edisol fluid works satisfactorily in both paper/film and all-film capacitors. However, since it was evaluated primar ily for use with an all-film dielectric as opposed to i paper/film dielectric, it is necessary to review the major electrical features of. McGraw--Edison'; all-film capacitor which are directly affected by the use o*' this new fluid. 1. Avera* dic'.ev'. i : .'"SSe; citde: -rp-.-rj:---; . \ r * e : e 's:uced fruui -! f ipiicc.-.:V '* d ,,..i-vir re kvjt. Welts losses w:il oc r;di.L-J c-i:t t::-.,;: w..: Edisol lluid-insuLted all-ftln: capacitors :::a;i - :t.\ all-film capacitors (Figure 2). 2. Low temperaiuie rises Juritig operation provide for greater kiiovar suniluy 3. Operating costs are reduced since less total system capacity is required plus a savings .if kilowatt hums during operation. 4. Highei ievd of reliability due to the ereaier ratio of discharge inception voltage fDIVl to operating voltage thereby reducing the possibility of corona damage to the dielectric. 5. Greatly reduced tank rupture hazard due to the absence of paper ir. the dielectric. DIV VERSUS T E M P E R A T U R E rtzure 3 it a compattsor. divenarge inception voltage (DIV) var- :a ie:nverature. Cipacnor units impregnated with EJisoi f.j;d show an reciabi.' -iivantage over those impregnated with PCD. _ 3- & \ -CC -25 C * 20 D nre;tr.3 Trr;o*ri:t.-i Figure 3 rtcu'C ' siitiws :Uai, with Emvit iL c i - *. tr.auges ui DiV .>er ::;c nor--.: .-rtr; . . * 7-us -ncji-i *:;*i :T:c ..Pact".." -ll,;; .t ' ... - . .4 ir-- c:* .-jictv r - . ' v . * r e : 'I 'c ... ; _\\Z - v Div ha. - better ' s:v5e ": : r - A.'.2*: c.._-f-Ctcr!l t :- Tinj - e ijit ; ;;i __ ;r reliability and .peer l.-re.The resaits These c_.^ -If-' that, through tiw use o! EJisu! I'uid * a dieiecir e. users cm be assured of having b-pacuoi units mat vii! injiniam ot improve on the present available eleermai ratings arid physical sizes. NPC00007287 769926 flammability characteristics Jl i5 desirable that capacitors ni't cause a fire hazard t>i the surrounding environment. This hazard sxws uniy when a capacitor fails and us tank, is ruptured. PCBs. due to their relative nonflammability. jive proieaiui: against this hazard. When a wick such as paper or wu.id is present, however, a fire hazard could exist. Edisol fluid is classified aj flammable using a standard flammability test, by defirmun (Underwriters Labora tories). a nonflammable liquid will boil before the i;re point is reached. Table 5 compares the flammability of three dielectric fluids. Note that Edisol fluid is nm as great a rue haziud as transformer-type mineral oil. Tiblr S FbrmnabilrtvCtiiricrerinici D tt'K iric Liquid PCS Floah Point tC; 166 Fir* Point tCI No io 3 t5 * Eoitoi liaid Mineral o ' 7S .55 200 170 *Bruiva ai300 C. . Distribution transformers ottin operate a: Temperatures approaching the flash and Are ; m i i of rhe transformer oil, at which temperature iimos; ar. 'vpc of arc cou;d produce a fire. Cunveisely. capacnorv `pirate at temperatures well below flash or fire points of tr.; cieiectr.c fluid, such that a rather large arc would ne <ecu red :.i produce a fire in the event of tank rupture. W::h ir.c introduction of the all-film capacitor, paper rus been r:mo*fi from the active dielec tric. virtually ilinunaiin;: gassing. :he primary cause of tank rupture And. sine: the capacitor operates at a lower temperature than pipe: z: paper.iiir.i iesicns. the tire hazard is substantial!;- reduced These Highly desirable characteristics arc maintain:.: w:;h tr.e use of the Edisol fluid, the result bcir.c j reiat.veiy safe capacitor. TANK-RUPTURE CHARACTERISTICS Figure 4 shows the comparison of the ail-film Type S capacitor tank-rupture characteristic wnh that of the Type R paper:film design. There is a definite improvement in the safe zone of fitting tlm can be obtained by using all-film capacitors and also allows application of capacitors m higher fault-current area* McGraw-Edison has found, through extensive testing. that virtually no internal eases are generated during an all-film capacitor failure mode. This is because of the absence ot paper m :he active all-film dielectric, and is in contra:: u the gases which aie generaied during a pape: film capacitor failure mode-cases which would. ;n turn, rupture :i:c la/.k Page 5 10000---------------------------- 1 CURPSMT -'-msii Figure 4 Comparison o ' ail-fiim versus cspcr'fiim c?.oncstc rankrupture curves. CONCLUSION With Edisoi fluid, VcO.'aw*Eifci'n brings in T.c car:ci:.r meustry x dielfctricaif suuabii and er.vinmr.e.vuiiy accepuble alternative : einacitOi-eradc PCE Tills .lew- fluid is significant^ less ;:\ic and accumulative fish aid mammals and biodeura :es it a rruen 'isier rate ma n PC 3. Alt of the superior ciec:r:cai cniiracterisi::* loday's capacitors are maintained ar.c. m Physical size of the ca?a:ii ?'rs ins'sr.cfr. iT.rr-. v:d. -mi* .r. :r.y*, pieteiy compatible with pr:vr> r . H: being made available at a reiser..evar.jtec : ciaily when cost consider;!ion> for aispou. jf capacitors or accidental spillj involving PCbs are made, "he use of Edisoi fluid in an oil-film capacitor irrobabiv wil! produce no greater fire hazard titan ptcscnt<L> PCB capacitors. C!:arl>. "disc! fluid proncc; ccpa.:tor-:rade ?Cii'. xue. :r.: j,' :--.r.:v: NPC00007288 769927 HER-J'IG W I T H WKSTlHCiOUKB SEPTEMBER 4, 19 75 9:30 A.H. A-303 PROPOSED AGENDA 1) Introductory Remarks - T. L* Gossage 2) Monsanto data on biodegradation and tissue residue studies MCS-1238. 3) Monsanto data on toxicological studies development capacitor dielectrics. 4) Westinghouse concern related to environmental impact of PCD replacement. 5) Industry status r.on-PC3 capacitor dielectrics.(`-f . 6) Status Westinghouse contingency planning, 7) Definition of fucure programs, 8} Summary. Lunch at 12:30 ?.>!. - C00007289 769928 MONSANTO TRIP Sep tomiK.-;' 4, 1975 Westinghouse Personnel: R. Sawvvr K. Kelly L. ShoaL' G. M o r d e r L. MandeIcorn Monsanto Personnel: Tom Gossage, Dir. Marketing David Wood, Marketing Manager dielectrics Bill Moore, Marketing Representative Dr. Ralph Munch, Distinguished Science Fellow Jim Bryant, Senior Research Specialist Dr. Jim Kieure, Group Leader Applied Science Vic Saeger, Applied Science Dr. George Levinskas, Medical Dept, Representative 1238 Price and Availability A. Test quantities, We estimate a requirement of 500 gallons in drums over the next six months. Price until 10/1/76 $.71/lb. LTL Drums (8.4#/gal. est.) Price after 10/1/76 Si.05/lb. TL Drums $1.07/16. LTL Drums Availability Two drums are or. order. Will snip by 9/15/73. Present capacity 2-400 gal./day. 3. Production Quantities. We estimate 1 tank car/mcnth (3,000 gal.) 1st year. We estimate 2 tank cars/month (16,000 gal. 2nd year. To achieve production quantities in 6-9 m o n t h s t e m p o r a r y facilities would be required. These would be used until a new plant could be built in 18-24 months. (For l-l-:f years. Price first 1 -1-2 years of production: est. SI.00/lb.-S, 35/13 . In new plant: Objective price $.63/lb. ^at today's cos C. Monsanto's Market Position Monsanto may terminate product 1er oc .'23. Thei* prosr;." t are structured or. tne dsi.; m a c ?CB well bo ciscontir.uji. _. Gossa c estimates that ?C!J will ne climinacec t.trougn governinent edict, Monsanto decision, or utility industry decision, within six months to one year. Monsanto is offering only 1238 as a substitute ter Aroclor . for the total capacitor Industry. They will not offer etcher or both components of 1238 to the industry. Developmental costs of 1238 will be borne by Aroclor buyers. A 3c/lb. increase across the board on Aroclor will be effective on NFC00007290 769929 on 10/1/76. Another lari'/1 increase is predicted for 1977. (Settlements of l;:w suits do not represent a portion of the 1016 cost. The. amounts are "not significant".) D. Monsanto's Decision to Invest $10,000,000 capital investment will be required to build a plant to produce 123S. This decision will ninge on: a) Continued favorable reports from the, Medical Department. b) Acceptance by ir.ost of the industry of 1238, They need a volume of 10-15 million lbs./year. c) An estimated life of 1238 of 10 years. E. Affect on Transformer Aroclor To achieve production within 6-9 months in temporary facilities, one of the two transformer fluids now used by Westinghouse, PDS 54201KA or 54201CM, would be discontinued. A decision to discontinue should probably be made four months ahead of beginning production of 1238 (two months for physical changes, two months to announce to the trade). The transformer divisions have not been advisee cf this possibility. Monsanto would like guidance from this division on how to go about this. 1383 1588, whi h ::as been tested by R. & 0, will be wicncrvvn by Mu nsar. c. At this time tr.e price is raised to fl,17/lh. LTL drua.5 Monsanto recommends m a c tests be discontinued. G. Contracting for 1233 Monsanto expects to sell 1233 under the terms of Cheli standard sales agreement. No indemnity agreement is planned. Such an agreement is considered undesirable since it would imply that the material is hazardous. 3ecause of frequent changes in railroad polity, Mor does not know whether or not a crip lease arreemer.r will be returned ter rail selement. Monsanto inte- is to rescr" 1 the with 15 days written r.otire. tc Lr.cceass NPC00007291 769930 Monsanto Meeting - September 4, 1975 1. Monsanto has been working with s u b s titu te flu id since 1969. 2. With pressure on PCB's, Monsanto sees very possible term ination of continued use of PCB as fa r as Monsanto's continued supply of tne m a te ria l. 3. D ie le c tric Research Groups: D ie le c tric s (Munch & Bryant) A n alytic al (Mieure, Seeger) Medical (Levinskas) 4. Environmental Impact: a. Biodegradation b. Accumulation in animal tissue. Biodegradation studies: Main emphasis in activated sludge tests. Described d e ta ils of tests. Monsanto feels comfortable w ith MCS 1238 degradation because ` a ll components (hydrocarbon & sultone portion) biodegrade even though the biodegradation rates are not s ig n ific a n tly higher than for MCS 1016. Accumulation studies on ra ts : 30 day feed + 75 day recovery period. Curve comparing 1242 and 1238 presented shows 1238 accumulation to be in s ig n ific a n t compared to 1242. 1016 accum. has also teen measured and is aoout r.a if that o f 1242. J icher chlorinated types such as 125-i or 1260 accumulate than 1242 and recovery is also much 'ess. T o xic ity data (Levinskas) Have smarted '"h a la tio n studies on one-month exposures on various animals -nd w*' 1 check for li v e r anc other organ damage. -This w ill !: complete at scout the end o f the year. Acute to x ic ity (LD50 value) fo r 123*3 discusses. Skin ir r i t a t i o n is less fo r 1238 wan *or 1015. Vase- ihal-jticn i t not-strongly cbjectionaole. New m aterials 2 - stage review: {presently between le t i 3rd st-ge'" ( 1) continued inh alatio n studies (2) carcenogenic studies: now running p ilo t study. Complete study w ill b e a t end of 1977 or f i r s t of 1978. ' Reasonably confident that this m aterial w i l l not be carcer.cgenic. (3) Acute fis h to x ic ity to also be complete at end o f 1977. Disposal o f 1238 would have to be handled s im ila r to mine-a! o il. Could be 'ncinaroted as is motor o il or fuel o il. Industry status of non-.-23 cao. d ia le c t ic : a) Monsanto has made cecision to o ffe r or. \ j 1233 to cao. industry. No other m aterial is planned to be offered a t th is time, nor are the 1238 components to be offered separately. b) Use of esters: reprocessing causes gradual degradation and also a hydrolysis problem e xists . NPC00007292 i 769931 7. Properties: a) auto ig n itio n temp is 335"? (445',C) b) re fra c tiv e index: Monsanto w ill get. c) ' Monsanto to check s a le a b ility of 1238 vs. temp, down to -40aC. d) W ill get absor. of PP ano 1232. e) Additives: Unox 1221 has been found to give b e tte r re s u lts than other epoxides on other hydrocarbons, but 1238 has only been testeo with 4Z21 fo r ac capacitors. For dc capacitors, Monsanto has tested guiones and they ennance l i f e on dc. f) E le c tric a l breakdown of f lu id w ill generate no strong acid by products H2S and HgO plus some sulphorated compounds). g) Life Test; B a lla s t capacitors impreg. by preheat fo r 2 nours in a ir aven 125"C, vacuum dry at 125cC, impreg. with de-gassed f lu id heated to 95aC, cap. at 1-5^ before flooding a t 125C cap. temo, then vacuum is broken, cool to room temperature and then solder sealed. Accel, l i f e te s t 9QC oven temperature, 1000 vo lts rms 60 Hertz on 2 sheets of .00066 (.9 den) 1233 units nave run more than 1000 hours. Measure P.F. p e rio d ic a lly {^-each week). 8. No need fo r antioxidant w ith 1238 even fo r long time storage. 9. Avoid use of epoxy-type sealants fo r b a lla s t type ,'cap. cans. DC S2348 (Dow Corning) - O.K. 3M EC1447 {Phenolic Type) - O.K. 0. Westinahcuse to supply Monsanto w ith FPF units (75-50-76; fo** l i f e tests (process 3 at a time) - need 100 to 200 un its. George E. Msrc'e** 2 NPC00007293 769932 769933 t 3 3 3 3 3 3 3 3 3; 3 i i i i -1 ; 3 3 3 SaEDWTT2S Ufi CAPACITOR DIELECTRICS DEVEl ` ":CN'7 R. D. McClain, Manager Capacitor Unit Engineering G. E. Mercier Senior Engineer * Capacitor Unit Engineering NPC00007295 fyyr. Jinm. .i t --r- --t* 769934 1972 aECTRIC UTILITY ENGINEERIWG CONFERENCE A p ril 9-21, 1972 SUBJECT HO, 41 CAPACITOR DIELECTRICS DEVELOPMENT Robert D. McClain Manager Capacitor Unit Engineering George E. Mercier Senior Engineer Capacitor Unit Engineering INTRODUCTION E le c tric u t i l i t y application of capacitors w ill change during the 1970's because of the economics in using big capacitor un its, and because of the environmental pressures to police the use and disposal o f PCB's and to move d is trib u tio n c irc u its underground. THE SWITCH TO BIG CAPACITOR UNITS Although 100 kvac and 1 50 kvac capacitors retained considerable po p ularity throu^i 1971, use of 200 kvac, 300 kvac, and 400 kvac capacitors showed a marked increase. Improvements in polypropylene film , kraft*paper, impregrat fng flu id s and knowledge o f processing constraints led to the introduction o f :he sing*e-phase 200 kvac and the three-phase 300 kvac capacitor in 1970, followed by the three-phase 400 kvac capacitor in 1971. {See Figure 1, 2, and 3.) fie ld experience with the f i r s t increment of 3,000,000 kvac of three-phase units in Tri-Vac equipments vindicated the design change: f a i l ure rates were as low as fo r the sm aller, single-phase capacitor equipments, and users benefited from-lower coses. Additional improve-ients in the techniques o f applying the 3yna-Vac d le 'e c tri system to capacitor design have led to big u n it designs with losses held to even lower le ve ls and designed with overload c a p a b ility s u ffic ie n t fo r . successful application in very small substation banks. A comparison be tween minimum bank sizes th a t may be constructed using standard 100 kvac capacitors (with rated voltages from 2400 vo lts to 14,400 vo lts and capable of sustained operation at 110% o f rated voltage), and minimum bank sizes that may be constructed with 200 kvac capacitors (w ith rated voltages from 4160 to 19.920 volts and capable of sustained operation a t 120% of rated voltage) snows the way to potential savings from reduced nunfcers of fuses, smaller mounting frames, 'educed in s ta lla tio n costs, reduced real estate `equir is n ts , and lower cost :e r kvac for th e 'capacitor un its. See Table I. Minimum bank s-.zes have cee established on the basis that the bank w M l remain in service with one u.own fuse 1n any (or 1n each) p a ra lle l connect ed group o f capacitor u n its. In the case o f 100 kvac u n its , the re s u lta n t Subject 41 - Page 1 la r e : NPC00007296 769935 uar 1 1 ] i # if overvoltage permitted w ill be 10?! of rated voltage, maximum. In the case of 200 kvac caoadtors, the permitted overvoltage w ill be 20X of rated voltage* or le ss. L ife expectancy, in both cases, exceeds normal conmerc ia l stated expectancies of 20 - 30 years. Only wye and grounded-wye applications have been considered. (Delta-connected banks are om itted.) Table I shows the range o f 1ine-to-11ne voltages that may be served by Increasing numbers o f series-connected groups per phase, and compares the minimum bank ra tin g (kvac) that may be achieved in wye and In grounded-wye applications, using 100 kvac capacitors (as stated above) and 200 kvac capacitors. P lo ttin g th is information as shown on Figure 4 reveals the broad opportunity fo r savings by use o f big units in small banks. r Failure rates fo r 200 kvac capacitors, for the illu s t r a tio n above, may be taken to be the same as fo r the 100 kvac capacitors. Assuming a very pessimistic rate o f 1/25! per year (a rate at le ast three times greater than recent experience), the p ro b a b ility that any given 200 kvac capacitor w ill experience an exposure to overvoltage due to fuse operation during the course o f a year, has been plotted on Figure 5. Because 200 kvac capacitors b u ilt fo r the application cited above must have very low operating losses, the user reaps another b enefit in terms of better operating efficiency. In sunmary, the move to big capacitors can be seen to extend over the f u ll range of capacitor bank sizes because of greater overload.capability, greater range of available voltage rating s, low fa ilu re rates and lew risks of exposure. Savings in f i r s t costs and operating costs re s u lt. USE AND DI?o0S.AL OF PCS'S Discovery in the 1360'3 that polychlorinated biorenyls. ftermed "askarsls" and used extensively as in s u la tin g flu id s in C3oacitors and transformers) tended to p e rs is t *i the environment, and might be factors in environ-ner.tal p o llu tio n , led to a widespread e ffo rt to bring them under control. Monsanto, U.S. s up p lie r of PCB's, has stooped sales of the material to a ll users, e s s e n tia lly , save manufacturers o f transformers and capacitors. Because no suitab le replacement f lu id has been found w ith the properties of non flam m ability, wide operating temperature range, excellent c haracteristics in the face of internal io n iz a tio n , desireable d ie le c tric constant and c o m p atib ility w ith other d ie le c tric m aterials, and because use o f PCB's is re s tric te d to closed containers, use in capacitors and transformers is continuing. In Septe.iter, 1971, a ll askarel d e lJ,.5" 2d to U.5. capacitor manufacturers was cnanged by Monse-tc :o oe c- 1016, a mix of lower-c.il orinats:; PC8 homologues and isomers ce-Tted mora blcJ^grad-ia:'a ard p o te n tia lly less persistent in the environmer.: than crevicus asxarels, in the event of t h e ir Inadvertent loss. This change provided no r e li e f from the need to exercise caution in the use and disposal of PCB's. Manufacturers have taken strong Subject 41 - Page 2 769936 1 1 ! } ! I I measures to assure against loss o f PCB's to the open environment: surplus waste flu id s are returned to Monsanto fo r sDecial incineration at high tenperature in equipment with an exhaust-gas scrubber. Saturated solids are disposed o f in s u itab le la n d f ills , or are held in containers fo r future incineration. Standardized procedures are being developed by ANSI C-107, a national standards committee concerned w ith the methods for use, and disposal o f PCB's. Working groups, established by the principal corrmittee, are ac tive l y producing the f i r s t drafts o f procedures fo r use byimanufacturers, users, and scrap dealers involved in the problem. CAPACITORS FOR UNDERGROUND DISTRIBITTIOH Vault application o f low voltage capacitors on concentrated, urban networks has been a common practice. As suburban and ru ra l load growth has been accompanied by increasing pressure to place the d is trib u tio n c irc u its underground, several approaches to the capacitor in s ta lla tio n problem have been made: - Low p ro file , pad-mounted, housed equipment. - Submersible c lu s te r equipment for in s ta lla tio n in subsurface, 36 inch diameter va u lt. I - Direct b u rial. Of these, d ire c t b u rial commands greatest interest at th is time. In tro duction o f Dyna-Vac capacitors w ith exceedingly low losses offered the oo- p o rtun ity fo r re-in ve s ti gating the p o s s ib ility o f d ire c t b u rial on the basis that derating factors previously encountered .r-ight be avoided. In 1965 Westinghouse joined a customer's evaluation of d ire c t b u ria l, supplying caoacitors w ith a special protective fin is h . Connection to the terminals was through removable, submersible URD term inals. Thermocouples connected to the capacitors a t too, center and on the ca nt er of one side, and thermocouples located in the-surrounding earth provided thermal per formance data. The capacitors were placed in lin e in a trench 50 inches deep with separation of 36 Inches between one capacitor and the next in lin e , see Figure 6. B a c k fill fo r three units consisted o f tamped pea gravel to an extent o f approximately 4 inches on each side of each u n it. The. other three units were b a c k fille d with native s o il from which large stones and major debris was removed and then well packed and tamtad, see Figure 5. In a subseqcs".- in s ta ll at ion, :r its w=-e '.-.stalled w ith i snecial fin'.s.: applied by tne u t i l i t y , in a trench approximately 3 inches deep. In both in s ta lla tio n s , the capacitors were switched "on" from 8:00 a.m. to 4:00 p.m. d a ily , for a t le ast one season. Then banks were operated 12 hours Subject 41 - Rage 3 I IIP NPC0000729B 769937 "on", 12 hours "o ff" for one season; and f in a lly they were placed on con tinuous operating duty. Although the te s t program is not complete, status of the program has been reported.' Continuous ooeration of 150 kvac capacitor units produced no case temperatures above 43C w ith ambient s o il temperatures of 25aC. (A lim itin g case temperature was considered to be 70C fo r1the designs under test.) Because the f ie ld tests involved te s t sites receiving 30 inches o f -ain f a ll or more, per year, a comparable te s t program was in itia te d at the D is t r i bution Apparatus 01visio n , where moisture conditions could be controlled and the ambient kept close to 25*C, year-around. Again, these tests are incomplete, but tend to support the conclusions being reached by those conducting the f ie ld te s t c ited above. S u rp ris in g ly, capacitors b a c kfille d with pea gravel have tended to run at higher temperatures under the dry conditions of the laboratory te s t, than have capacitors b a c kfille d with native clay. In sunmary, tests conducted so fa r support the f e a s ib ilit y o f d ire c t b u ria l o f Dyna-Vac capacitors, without requiring serious derating. CONCLUSION 1 pyna-Vac capacitor designs can meet the need fo r economical* capacitor in s ta lla tio n s in the 1970's, and the v e r s a t ilit y o f the d ie le c tric system w ill support any mcve to underground d is trib u tio n . Any th re at o f environ mental contamination posed by the new Arocior 1016 C3ft be controlled by careful observance o f the procedures for use and disposal of PCS's now oeing prepared by ANSI C-107. > REFERENCES 1. "Direct-Buried Capacitor Tests Show Promise", A. 3. Sorski, TV .TSir.iS5''on and D is trib u tio n , pp. 30-33 (November 1971), i Subject 41 - Page 4 NPC00007299 769938 POWER CAPACITORS - A MANUFACTURING OUTLOOK R. 0. McClain Westinghouse E le c tric Corporation Bloomington, Indiana Presented to the P.C.E.A. Engineering and San Francisco, C a lifo rn ia March 18. 1976 NPC00007300 769939 POWER CAPACITORS - A MANUFACTURING OUTLOOK R. D. McClain Westinghouse E le c tric Corporation Over the past 50 years, the American capacitor industry has more than matched the technological progress of almost any other i comparable endeavor. In constant d o lla rs , the o ve ra ll cost trend, do!1ars-per-kva, has been downward. Wide ranges in ratin g s have been made a vailab le and containers have diminished in size and weight. Along the way, flam m ability was brought under control, along with a host of m aterials contamination problems. Energy losses were drasticallyreduced. I f anything, the recent ra te o f technical change has accelerated i rath e r than diminished. "Progress" has posed serious problems at times when technology introduced the c a p a b ility to produce, w ith e xistin g f a c ilit ie s , at a rate s u b s ta n tia lly greacar than the growth of demand. During the pase 5 years, pressures have been compounded by -owing concern over cne possible adverse effects of persistence of the d ie le c tric f lu id , polychlorinated biphenyl, in the environment. Manufacturers have -espo-; by use of a more biodegradable f lu id and by working, strenuously, toward control o f PCB's in manufacturing plant water e ffluents to extremely low i le ve ls . In the midst o f th is , there appears an increasing concern ever what is considered to be an excessive fa ilu re rate for caov-ito-; nanufactus a during the past several years. We address th is la s t c:r^-n today. The "industry problem" - i f indeed there is one (as opposed to several concurrent, individual problems) -- is not yet c le a rly defined, nor localized as to to ta l magnitude, kind o f application, design, user(s), NPC00007301 769940 -2- ra tln g (s ), vintage, o r m anufacturers). An e ffo rt in th is direction Is being launched by the IEEE Capacitor Subcommittee; Some potential factors in the expressed concerns are ~ 1) A change In f lu id , from Aroclor 1242 to Arcelor 1016, In 1971. 2) A change in the polypropylene resin fo r capacitor grade film in 1973. 3) Phase out o f manufacture of insulating pressboard by the major source in 1974. 4) Changes In ownership and possible changes In operation by the companies supplying capacitor paper to the industry. i 5) Appearance of new capacitor deslgis w ith somewhat i higher voltage between winding electrodes. 6) Pressure by the E.P.A. and othe^ agencies to achieve s trin g e r.:ly low le ve ls of PCB e fflu e n t, re s u ltin g in major i change", in manufacturing processes and procedyrgs. With a ll due respect, and in view of what is known to data, almost none of these appear to be the cause fo r what is reported ' be happening; a) The switch to Aroclor 1016 was well investigated and sub stantiated before production. At most, the change, from a d ie le c tric standpoint, was minor, involving elim ination of i the small fra c tio n o f higher chlor-ruted (less b lc d s s ^ * 1*' concurd$ frem i r ; : ! c r 1242. ,,ar;s nuriters ;rs are in successful operation with Aroclor 1016. b) E sse n tia lly the same can be said o f the improvement in the base resin fo r the film : removal o f trace contaminants enhanced performance. NPC00007302 769941 -3- c) A lte rn a tiv e sources fo r pressboard, o r use of a lte rn a tiv e m ate rials, posed no Id e n tifia b le problem. d) Capacitor grade paper continues to meet the strin g ent req uire ments developed over the years, and suppliers have acted responsibly In completely checking out results of minor modifications of process. i e) Desiyi changes are always most suspect--and, fo r th a t reason, are always most c a re fu lly checked out. Proof of the adequacy of such investigations lie s 1n broad, large scale, success ful f ie ld operation, p a rtic u la rly fo r designs o f highest stress and highest voltage, fo il- to - f o il. , f ) Response o f the several manufacturers to E^P.A. pressures to reduce PCB plant e fflu e n t cannot be measured, as th is i is considered pro p rietary Information. I t is suggested th at any change which produced capacitors w ith in h e re n tly d iffe re n t individual h is to rie s could overshadow misplaced tru s t in tests based on sampling procedures cr based cn advance "type'' tests. Two actions ty t'r: 1 reports of hi*., f a ilu r . 1) IEEE survey of experience [mentioned above} i 2) Review of industry standard (IEEE - ANSI)' C c x :r:t5 in th :: two t n s s v= a) To be e ffe c tive in id e n tifyin g "a" pr. lam, or "th e 11 probler,, d e ta ils o f f ie ld performance and application surrounding an occasion o f high fa ilu re rate trust be supplied to the manufacturer as soon as possible: type of application, NPC00007303 769942 -4- pratection, and attendant tra n sie n t phenomena are valuable data. Complete nameplate data from each fa ile d u n it makes i t possible to match performance data to design, manufacturing records, and even to source m aterials records. When data are ava ilab le to the manufacturer from more than one user--and the experiences are comparable, or e n tire ly i d iffe re n t, the time frame can be id e n tifie d and the l i s t of variables to be researched narrowed to only one or two, fo r most cases. b) Standards now contain the essential requirements fo r v e rific a tio n and application. However, a consensus has not been reached in several important areas. Perhaps the d if f ic u lt y 1n achieving consensus can be given by three illu s tra tio n s : 1) Accelerated l i f e testing by application of high temperature and high voltage, w ithin discrete lim its , has produced several procedures and sccompanying analyses w ith t h e ir various devotees. Consider the consternation -..hen such tests predict very long l i f e (type t e s t) , but production units f ii* i t 1; erasures 2nd voltages w ithin a few an inciden: occurred, abroad, ana the snsui.-ij resulted in a simple, delicate adjustment in chemistry.) 2) Great strid es in detecting internal p a rtia l dischar;-:: r:-c r< i '. i-ut *11 size! ca:a: he. : r**.n reported with fa ilu re s shewing a ll tne earmarks : f p a rtia l discharge damage, when none could be detected beforehand. Manufacturing controls--ra th e r than dirA te s t--was the only assurance of q u a lity . 3) Case rupture p ro b a b ility te s t methods are not standardized. NPC00007304 769943 -5- Preparation o f test samples in e vita b ly leads to differences from fie ld conditions. Another Important aspect of fie ld performance in th is area lie s with d iffe re n t application practices in the industry: Using even the most ' d a rln r (optim istic) curves i t is d if f ic u lt -- I f possible ~ to properly coordinate group fuses for large d is trib u tio n banks having isolated n e u tra ls . Where does a ll th is leave the perplexed user who has both a continuing need to apply leading vars to his system and who has a recent h is to ry of bad capacitor performance? 1) Gather data on fa ilu re s , in d e ta il, and feed the information back to the manufacturer. There is strong reason to believe the fa ilu re s w ill be found to be specific to a single s itu a tio n not part of an "industry problem". .Fast fa.dback shortens the time to make a f ix . 2) Dc not f a ll prey to easy generalizations. Exams!ss: a) 1500 v o lts , fo i!- to - fo il is said to be'better than 2400 volts fo il- to - fo il. Check th is . the extensive h is to ry o f successful operation for _ b) High d.c. overpotential te s t (6.25Vrate(1) on capacitor gives b e tte r performance than (4.3Vpate(jj te s t. While the r.igfcer test gives greater d ie le c tric strength margin and may be is sV a b '.e i f rsscrlfcing . r s , etc , ir- involved, actual fie ld fa ilu re s w ill not be reduced i f the basic problem is factory processing, or a d e fic ie n t chemistry. E ith e r te s t level has lim ite d effectiveness in fe rre tin g out defects of very small area 1n only one' of the two sheets of film between f o ils . NPC00007305 769944 -6- ` The overall objectives appear to be to get re lia b le perfornance w hile continuing to be able to supply vars at low cost. These objectives can be served when the user knows his requirements and specifies to them, when f ie ld performance data is fed back, when tests re la te both to manufacturing procedure and to operational requirements, and when judgements are based on a bread base of information. NPC00007306 769945 PLANT FACT SHEET OH PCli'S HIAT Anr f ;QN KNOWLfW.C HI OUR PLANT Our plant uses PCB liq u id in the manufncI*'.'* II is called Inerteen because i t does not burn. Capacitors are an e le c tric a l device th at l. if. rn argy, The PCB liq u id is in a seated or closed o>- A ll residue,vastes (even the sawdust on tlu: . n idr; th a t have PCB on o r 1n them are shipped out of Indiana to two v .y ureas th a t are equipped to handle PCB disposal. The sewage leaving th is plant contains less than ` r. per m illio n o f PCB. Over 90% of PCB's used fo r capacitors are biodegradeaM There if. no disgrace or problem w ith H actions. However since PCB are and th e ir e ffe c t on the environment are the subject of p o litic a l discussions and technical debate among specialized s c ie n tis ts , i t is a d i f f i c u lt subject to understand completely. Mr. B rita in and Mr. McClain are in a position to get complete and accurate facts. A ll requests fo r Information should be channeled to Mr. B rita in 's o ffic e . This w i l l avoid rumor and c o n flic tin g reports. We have no knowledge of any health or environmental problems caused by the use o f PCB's in H capacitors. NPC00007307 <o C3O NC.O & P i-ci y ^ / l a > y < ^ J CIGR2 //ofl> * $ ' ^ d - 6 ^ < *J-**~L*J /^'/L--^ t<r*?> International Confrence on Large Kigh Voltage Electric Systems 112, boulevard Haussmann - 75006 Paris -- *---------- - 1976 Session - August---- ------------------ N O V E L SINGLE A N D M I X E D LIQUIDS FOR HIGH VOLTAGE DIELECTRICS by K.W. P L E S S N E R a n c E.H. R E Y N O L D S (Paper presented in the name of Study Committee No. 15, Insulating Materials) (U.K. SUMMARY t This paper reviews the recent changes in some material supply conditions and the constraints arising from ecological ccnsid? `Vo--- to their effects upon the existing range o: liquids . Voltage equipment. Over many decades, liquids :cr the im.pr -st. .n . . -A dielectrics of transformers, capacj'-ors and c-LUs ;>v/ ;allj*.Vf-- i::v: - lines of development leading to the establishment of International Codes-a: Practice and Specifications. Chlorinated biphenyls have been very success fully developed for transformers and capacitors, while natural mineral oils NPC00007308 769947 and certain synthetic hydrocarbons have been evolved to very high standards of performance and reliability for all types of electrical equipment. Two recent changes have altered some of the accepted criteria on which choice of liquids can be based. Firstly, the discovery that polychloro- biphenyls were causing cumulative and persistent contamination of the environ ment, giving rise to fears of*a toxic hazard. Secondly, the dislocation in the world supply of familiar crude petroleum oils, led to unavailability of certain types traditionally produced by rigorously controlled processes for standard ised insulating hydrocarbons. Increased research has been stimulated into the . evaluation or evolution of alternatives for both polychlorobiphenyls, and natural insulating oils, especially of naphthenic character. The search for technologically and ecologically acceptable alternatives to PCB's has posed the greater problems, more so for power capacitors requiring liquids o: permittivities in the range o: 3- .0, har. for transformers, where hydrocarbons could be re-adopted. Thus the stimuli provided by the foregoing constraints have promoted re-assessment of ail class* . carbons, natural and synthetic esters and mixture* *->: ' stabilisers and diluents, the provision of non-toxic, z ..`orir.z:- hydrocarbons and c reappraisal of the practicability a.-*.'- . . * wider applications c: p 'ys*.I;>:cr-es ord ::::or c?.:tens :or 12t y c :: Hir:Vo 1:r.;- equipment. Liquids, Dielectric, Novel forms for Cables, Capacitors, 1Transformers. Switchgear. NPCOOOO7309 769948 -3 REPORT I. G E N E R A L I N T R O D U C T O R Y S U R V E Y In evolving more efficient, economic and compact High Voltage equipment, great importance has to be placed upon ensuring long, fault-free service, usually between 20-40 years. The establishment of existing designs has not only been based upon lengthy research and development in the laboratory, but also upon extensive field trials and operations with continuous feed-back of data. A change in even a minor material or component cannot be assumed to be satisfactory without full and rigorous assessment. Changes, therefore.`in a major component, such as the impregnating fluid, carry onerous liabilities, much more so than in most other heavy industries. Despite the title of this paper, which m a y be slightly inappropriate, novelty in insulating liquids r.:v have vanished by the time bulk commercial utilisation is realised. Neverthe less, the drive for novelty must persist, though it is notable that over the last few years two unusual constraints have emerged to stimuSit - They have arisen from two entirely disconnected sources, bu; their repercussions is timely, if not crucial to the m-atr.:-:: .r. men: o: exisr.r.g or future standards of design, operation r-rhau: .:y. Firs:, the widespread reliance upon the use o: polycnlorcuiphonyls ("Askarels" or PCB's) in transformers and capacitors as non-inflammable saturants for paper-based insulation, first introduced in the middle 1930's, and more recently in the 1960's for mixed paper/plastic film dielectrics for NPC00007310 769949 -4- H. V. unit capacitors, has been questioned on ecological and environmental grounds. This situation was first revealed in 1966 by Jensen, who published analytical results showing that chlorinated biphenyls could be detected in fish and birds and in certain natural waters. Other studies have produced similar evidence, and recently in the official Journal of the European Community^ it % was stated that, recognising the risks to the environment of continued dis persal of PCB's in the lithosphere special legislation constraining their use might have to be introduced. Since polychlorobiphenyls are molecules of high chemical stability (one reason why they make excellent dielectric liquids), having a mild similarity in this respect with certain insecticides (notably DDT) i: has beer. tacitly concluded that they were equally objectionable towards the environ ment. Greater control c;*the manufacture, use, handling and disposal of waste P C B 's has very largely eliminated 'risks derived from their use i:i H.V. Electrical Equipment, and if the provisions incorporated in the C1GKE "Code of Practice''^ are observed, future hazards would be negligible. Nevertheless, the publication of such information amid muen ill- informed speculation has forced a closer examination of the possibility of utilising alternative liquids, which can give equivalent performance in ail respects, but '.vh.ch car.no: become a persistent =:-u:*ce c; pollution dis persed in the environment, nor attract condemnation as having specific toxic effects detrimental to man. - * Secondly, the recent interruption in the free availability of some natural mineral oils, resulting in certain cases in the complete removal NPC00007311 769950 from the market of specific types of crude oil, has stimulated research into and evaluation of hydrocarbons, both natural and synthetic, having an internal balance of molecular species very different from that which has been custom ary, and on which continuity of manufacture and standardisation of performance of H. V. plant has been based. International Publications such as "IEC No. 422" are typical collections of the accumulated technical experience and knowledge which is essentially based upon deriving complex products for long service duty and also upon the continuing availability of a specific class of raw material of well defined composition, refined and incorporated into the final artefact by an established, repetitive series of production processes. Alternative products, of competitive price and similar technical reliability, meeting the same specifications and tests, despite radically different Chemical composi tion, m a y be difficult and expensive to establish, while failing to preserve technical continuity. The changes reviewed in this paper mostly affect the availability' and choice of liquids for impregnating, cables, capacitors and transformers. However, since a given liquid depending upon its range of properties might be used in one or more of these classes of H. V. apparatus, it to be tv. appropriate to consider ew possibilities or alternatives under the generic chemical classifications, and to summarise each class with an indication of '.vhere any changes m a y most successfully be made, in rerarc to their employment in any particular type of high voltage apparatus. It is, of course, well understood that, having indicated the possible applications for a now single liquid or mixture, extensive compatibility trials would have to be made, encompassing all the other constructional and insulating materials. NPC00007312 769951 -6 - II. GENERAL TECHNICAL REQUIREMENTS All dielectric liquids for high voltage equipment should display certain characteristics to an advanced degree, in addition to high electric strength, high electrical resistivity and very low 50 Hz loss tangent. These other physical and chemical'properties, common to all applications, m a y be summarised as follows Low cost and easy availability High purity (or easily purified) Stability to oxidation and hydrolysis ..High Flash point Low pour point Resistance to discharges Hydrogen (Gas) absorbing under discharges Non-inflammable L ow toxicity and easy disposal. Not many liquids currently in use meet all the requirements to the full. It is evident that all hydrocarbons, v.*h::r fulfill:ni tests, comply with the remainder, except for non-inflammability. In regard to this property the Askareis for Rciychlorobipher.yls) prohaciy come rivse'* to the ideal d:elect.-; .*dquid. Like si: J hycrocr;--- i:-.=, have high flash points and auto-ignition temperatures, and readily meet the other (especially electrical) requirements, save for their tendency to form hydrochloric acid under electrical discharges, despite constitutional aromatic unsaturation and gas absorption capability. In fact, it could briefly bo NPC00007313 769952 / observed that if the flammability of the hydrocarbons could be decreased with out detriment to their electrical properties, while maintaining stability towards oxidation and hydrolysis, eminently suitable uses in transformers and cables would ensue. On the other hand, for power capacitors, if the marked bio logical persistence of the poiychlorobiphenyls could be reduced, without t impairing chemical stability and non-inflammability, while preserving all the other properties especially electrical, much benefit would follow. The foregoing considerations broadly determine the pattern of research into and evolution of new dielectric liquids in respect of primary characteristics. It is just as important to preserve or improve the safety of electrical operations and reduce any fire hazard, as it is to evolve liquids of equal reliability of performance coupled with reduced disposal and'quasi-toxic problems. The greatest research and development activity has so far been con cen:rated upon the provision of non -halogenated, non-toxic lieu:7.-;to replace Askarels, especially for power capacitors. Thus there have r;an numerous novel liquids proposed in the higher permittivity : which have already seen limited `-- r.m?r ::al service (cf. Section VI. HI. K Y D H C C BON*3 Although tiiere has been ar. increasing tendency to replace natural hydrocarbon insulating oils by synthetic products, a considerable proportion (varying from one country to another) of the natural product is still very widely used. The principal change in the natural crude oils available has NPC000073H 769953 -8- been the reducrion in supply of those of essentially naphthenic character, with associated arom aticity and asphaltenes, to the m ore plentiful paraffinic categories often of high wax content, low u n satu rates and high sulphur containing compounds. The derivation of insulating oils for tra n s fo rm e r ,and cable applica- % tions from sweet naphthenic based crudes (such as Peruvian or Ecuadorian), having sufficient natural oxidation stability combined with low pour points (for low tem perature outdoor applications) and good gas (Hydrogen) absorption ch aracteristics under internal discharges, was a suprem e example of the refining art. Their replacem ent at economically and technically acceptable levels by paraffinic oils or synthetics has presented different problem s concerned wilh securing com parable oxidation re s ista n c e 1(especially in the presence ef copper) with positive gas absorption m.d low pour points. But for the cos: factor the synthetics, such as alkyl ber.ner.es or p ci;'b itsr.es, suitably compounded as required, may have a m ore prom ising future. Examination of recent reported data is instructive. (1) N atural M ineral Oils The range of hydrocarbon liquids available for a. capacitors, tra n sfo rm e rs and sw itchgear has been exte::. reviewed in the past.' * ar.c there is e t> . r.c enter.* : j direct attention to the comparison of individual pro p erties vu h selected synthetics as given in Table I. The v irtu al rem oval of traditional naphthenic crudes from the world m arket, has forced refin ers to m eet existing specifications from paraffinic NPC0000732J 769954 -9- ' crudes, which pose three specific difficulties (a) Cheap rem oval of was to achieve low pour points. (b) Introduction of sufficient unsaturated molecules to provide "gas absorption". (c) Preservation of adequate oxidation stability, without recourse to the use of added anti oxidants . The success with which suitable grades of refined oils have been provided, esp ecially for H. V. tra n sfo rm e rs, v a rie s from one country to another. Some u se rs seem .content to rely upon, m ineral oil derivatives to existing specifications; e th ers apparently perturbed by the hiatus in continuity o: source and composition, see the perpetuation of this ur.certain*.} :n the future and would seek to replace all petrpieum -based m ineral oils by synthetics, in ord er to re-estab lish complete technical control over th-f :r:gm , m operation of the newer m aterials. {Li) Synthetics Codecv. concerts w~ ^ ft cable impregnar.t with sev eral advantages claimed over the available petroleum o ils. This was followed by the use of nonvibonzeno^ 01 low er vi_scosity, giving improved oil flow over longer lengths of cable. Some attention is now being WC00007316 \ 769955 given to these hydrocarbons because of th e ir excellent hydrogen absorption p ro p erties up to 120C, and higher solubility of water, for use in large tran sfo rm ers, though it has been reported uiat these two alkyl benzenes, while meeting the oxidation stability te st in the usual cable oil specifications, do not do so when subjected to the m ore onerous test required for transform er oil. Perhaps this offers a chance to develop antioxidants for alkyl benzenes, since successful operational improvem ents have been reported by the use of DBPC e; alia (ditertiary butyl para- cresol) with many hydrocarbon dielectric liquids. N ear relativ es of the alkyl benzenes, develop*:*: specially for capacitors and transform ers are diaryl alkane ( able IJ ana alky; naphthalene. - ne fo rm er has a com paratively low p erm ittiv ity for this application (k 2. ij, but its e le c tric a l p ro p erties a re otherw ise excellent, :t displays good gas absorption and oxidation resistan ce and a toxicity no g re a te r than the general level t i s . . m in eral insulating o ils. N aturally it is ir.ila m : r . v `.h flash pom: e: 1 ( com pared v/i:h /alu es .. '! . 3 cS cable oil, 135C for a standar i r.apht :sn:c tr.tr.s oil (BSS. 143 1972) and 154C for trichlorodiphenyl for capacitors. This liquid is rep o rted as being used in s .ooitqnl&r'eiai capacitors in Japan in place of PCB, for the .,* - im pregnation of mixed pap er/p o ly m er film d ielectrics. NPC000073I7 \ 769956 Polybutenes are now widely used and are derived from the polymerisation of olefines from natural gases or cracked petroleum fractions, consisting essentially of iso butenes (A), with sm all quantities of norm al butenes (B and C) and some iso -p araffin s, % A . CH,,w C = CH, CH, B. CH, - CH- - CH = CH , 3* < Z C. CH3 - CH = CH - CH3 They are available as w ater white liquids having a very wide range of viscosities, with m olecular weights ranging from 325 to 2500. They have excellent e le c tric a l p ro p e rtie s, low perm ittiv ities (2,1) ar.d due to th e-resid u al o lefin :: u n satu ra- * tion, are normally fctnd to be gas absorbing in the usual test apparatus over the te m p e ratu re range cf 40 to 130C. They have two m inor disadvantages; first they a re as in:Tr* a s other hydrocarbons, secondly; owing to th eir rath-:flash points -heir use is re s tric te d to those grads.s \ m olecular weights which yield v isco sities w e r ~0 '~v :-S. The la tte r lim its th e ir usefulness to pipe-typo cables, and 'a s additives for m in eral-b ased oil-filled cable oil. Applica tions to capacitors a rc not a ttra ctiv e due to low perm ittivity, and used alone they do not seecn to hare excited the in terest NPC000073I8 \ 769957 .of transformer manufacturers. However, it is conceivable that they could be used with alkyl benzenes fv.i.) to produce lower viscosity mixtures of acceptable flash point and oxidation stability, where their excellent electrical pro perties could be valuable. TABLE 1 P rcpcr.y H yd ro e a rb o n '- v^ H ollow * C o re C ab le O il C a p a c ito r O il T ra n s fo rm e r O il D odccyihcnzenc JN N o nylb cnzer.e {''jlyb - tcttc 0 /3 A D ia ry l A lka n e O il B lend, w ith A lk y l Benzene S pecific C r:asw cly a.ass 0. BbC o .e :a 0.573 0 .5 6 ? 0.9011 0.879 - -- -i' - - Pour F o itt P la sh PoCin t !Vuebs1| c S ,i t2y0 C |j P ttirvmit vii 25C - 1 L ose j P .c sis::vi:y t Tangent! 25C | 25C | fe rn { Com m o.-.is -45 105 - 6 .0 2 .2 ; | 0.0001 (1j-2 .-5. x .101*4' jIj:uX_aa sp harhc es mo rcb. .0r.:^1. , 3 2 .0 2 .2 2 0.00001 I !j > 10*w P a ra ffin ic O il G as e vo lvin g . j \ * i:. j 4 0 1 3 5 2 9 .0 2 . 2 3 ; 0 .0 0 0 0 1 * 8 .5 x l o 15 jx a p liih c r . '.c O il ! -GO :3 0 ii 8 .1 n r* . c,, . a c o . 3 [ 4 .3^ x ..-o 1 5 i 'H a rd * ty p e. . 5C : <-S8 127 2.21 "7,0001 i * ! ! ! 10T 3.7 (920*o1C ) i 0.0003 ; ;5 .4 x lO :2: i 1 6 .5 ' 2.52 .0 .0 0 0 3 J .v x iO * 5 P vo iiria '.a ry. (30C t (3QCJ ; iao'^ci ! a*c u r. ;ii i i -32.5 136 1 1 .2 2a 22 0 ,0 0 0 2 U . T x iO 1* P rs p n c ii.- y fs rm t.a . <30C ) (80C ) j (30&CJ j (t-CC) s e e H e i. 31.' j NOTE- A ll th e H y c ro c a rb o n in th ia T a b le a re i.iilar-.m a**** ( 3 ) M i x e d P - 1 " o l s `:r'. a n d ? v n : i Though this xir-d of m ixture has been !-:r.i-v.: : many y e a rs, the longest usage has been in the form of sem i-solid impregnants for non-draining paper cables, .--where synthetic waxes (F isch er Tropsch) have been used with m icro -cry stallin e waxes dissolved in high viscosity NPC000073I9 \ 769958 - 13 - m ineral oils to produce compounds with drop points in the range of 85-105C, O ther attem pts to produce mixed liquids have been less evident and p ersisten t, but paraffinic type m ineral oils with synthetic olefines (octadecene) have been used in polymer film capacitors and polybutenes with % m ineral oil for low viscosity (6 c5 at 20C) fo r o il-filled cable o ils .^ Recently, a blend of m ineral insulating oil with alkyl benzene has been developed as a universal im pregnant for paper high voltage dielectrics, and is recommended as suitable for capacitors, transform ers, cables, switchgear and reactor-p. '-Though the permittivity _t 2. 22 is rather .. .y. y . ^ L w for the capacitor application, the high specific re sistiv ity and low loss tangent make it suitable fo r all the other appiica- * tions. The flash point of 136C is of the usual value for hydro carbon insulating liquids, but lower than for polychlorobiphenyls, hence it may be said to c a rry a ce .... if used in High Voltage T ran sfo rm ers. The assessm en t of the sericusr.-ts ` :.iv in High Voltage eq-ipm ent, especially :n enclosed h.:: .nl;=;s or cable ducts, has led to the w idespread use of PCB's in distribution transform ers. A recent development shows ^possibilities of improving the fire resistance and inflamm ability o; cables especially, by replacing the conventional NPC00007320 \ 769959 *1 low viscosity m ineral oil with eith er a polychlorobipher.vl (di o r tri-ch lo ro ) {c)or other suitably haiogenated hydro carbon mixtures using trichlorobenzene. An alternative approach to the reduction of inflammability of hydrocarbon oils (whether natural or % synthetic) was suggested by the work of Nettleton, by add ing sm all quantities by volume (up to 20%) of dielectrically acceptable haiogenated liquids. This could be of g re a ter in terest to m anufacturers of capacitors, tran sfo rm ers and sw itchgear than to cables. The la tte r have to be jointed in the field with free liquid constantly flowing in the welding zone and decomposition of haiogenated liquids or additives would pose a serio u s health hazard, as would the use of PC B 's or their m ixture with TCB described above. There also rem ains the latent objections of toxicity and environ- mental pollution hazards already levelled at the polychioro biphenyls as a whole, especially in field installation activities. IV. P0LYCi-:L0RO 3IP:-Ii.\'VL5 , These chlorinated aro m atic hydrocarbon licuids have reached a ::;g!i level of reliability and economy as im prgnants for paper and p ap er/p o ly m er film insulation for transform ers and unit capacitors. Since they consist of m ixtures of about 70-80 different iso m ers, the bulk properties are NPC00007321 \ 769960 - 15 - n ecessarily average values, as are the nominal chlorine contents. F o r tra n s fo rm ers, larg ely to secure low pour points, m ixtures of the PCB with trich lo ro benzeiie are preferred, while for m ost capacitors, the trichlorodiphenyl is widely used. In addition to the excellent e lec trica l p ro p erties and higher p e rm it tivities displayed by this class of fluids compared with hydrocarbons, their use has enabled a new level of safety in operation to be achieved, especially high chem ical stability, re sista n c e to oxidation and hydrolysis and p articu larly non-inflam m ability. The latter is a safety feature which is frequently taken for granted, since absence of serious fires in high voltage equipment sited in buildings becomes io be regarded as an inevitability ra th e r'than a valuable "sir.e qua nor.1' to be p reserv ed . Table li gives a sum m ary of the p ro p erties oi P C B 's against which to judge the altern ativ es. TAHLS 2 Prope Fluids T ransform er Trichloro- A6Hare 1 binhcnyl* Pour Point C -22 t:iax. -14 max. Density 55C 1.557 20*'C 1. 337/47 V iscosity cS 29 2j C 7-9 SVC iFlr.sn P a ir: C None :a li. at. *z 4 m*r., iTru'rir.;.! j ts o i '.tty i. L o w uin^eiit C102U; Perm ittivity (I00c: R e au tiv rty UOOc C! Out) . 0. 4 _ _ . 0. 02 max. 35 x l 12 4. 8 /5 .0 12 l . O x IO1" Auto-ifiriticn TC ' Casr.eitor Pcouchioro* A sk o rcl *" diphenyls :.:c 3 :ac 13 T- . 4.3 3d'J C s;7 135 204 AST;* 3 . . . ' 0.3323 S.9 25C 4.15/35 1. 5 x IG*2 1.0 x 13 1 M imtnun values. C40 NOTTS: * T his u the w ell knfffcr. v a rie ty with $2? c h lo rin e .. T his cor.tr.ir. 4 2 chl ori ne with reduced pen:.ichloro derivative 1 i i ( NPC00007322 769961 - 16 - .The chlorinated hydrocarbons as a whole tend to be very stable chem ically, even at elevated tem p eratu res, and this has led to their use in many applications outside the High Voltage field, often in consum er goods such as p la sticise rs for plastics, printing inks, certain varnishes, and especially in heat tra n sfe r fluids. The la tte r application is c lo se s: to the i e le c tric a l use, since it p a rtic u la rly takes advantage of th eir better therm al conductivity |whieh-4s. approxim ately double-that-of hydrocarbon oils).f The PC 3'5 naturally possess some m inor disadvantages, mainly that they are decomposed to,give hydrochloric acid under electrical d is charges, and are no: only p ersisten t but biostable under norm al environ m ental conditions. The la tte r only poses a problem to the d'ectrical and persistent are the molecules. The lower chlorine contents (dichlorcdiphenyl) are less stable and le ss p e rsiste n t, therefore m ore reactive .and likely to be ra th e r m ore objectionable, besides showing lower fire resistan ce. During the la st few y e ars, m anufacturers of PC B 's have not only conducted a great deal o: re s e a rc h into the discovery of adequate altern ativ es (See Section V), but have also attem pted to produce bio-degradable chlorir.a<ed derivatives, which w;li display the same e lectrical perform ance, resistan ce to oxidation and hydrolysis while p reserving the sam e degree of noninflamrnability. Much p ro g ress has been made, but before a total com m ercial solution-can be claim ed, there will have to be universal agreem ent on wna1 UPC00007323 769962 1*6 duty, the universally used PC E's. As a class, the available com m ercial este rs, developed as relatively cheap p la s tic is e rs , may contain too high a proportion o: other chem ical species and im purities to ren d er `.heir bulk purification for dielectric purposes either simple o r economically competitive and these d is advantages would only disappear if there were to be any constraints placed upon the use of existing liquids. As a class, e ste rs are not p a rtic u la rly well suited to d ielectric duties, for although they cover the range of perm ittiv ities req u ires (3. 0 - 10. 0) they tend to be o; ra th e r high v isco sity and a re susceptible 'to hydrolysis and oxidation. Even when carefully purified by extensive earth treatm ent {attapulgus clay o r activated alumina) it is ra re to find values above 1 . 0 x 1 0 -13 in th e u s e fu l o: r ^ r i... ttiv itie s abo*. ; 3 .0 . T a b le 3 p r e s e c ts s o m e ty p ic a l -. i i i a J i ` ; Jt : .% - _. L. . : n f _ r t h s r ' '.zc .. . . . j ,, -- -- : ; ?ropc-r:> C a tta r CM pvcii.s j fttu r C ravny P o x t j oc ; i 'o;:.! ; C f io .1.;.-.;: rom ; C V iscosity P 'r r'.it * v h .? 1 cS . tfvuy i T sn g if ; :o ac . ZZ^C 0. 96 - 1 5 j 235 1 31B | 1030 4.05 ! 0.002 N otes l , CiOSCtl c u p . 1 J !5c ! Ov-it H i'.t/l p tuiial;;io 1 .0 4 -3 5 | 111 1 340 1 ig .-j ! C. 30 o .o o rj ij 25 C jD i*n lla p ty l p i.ttu '.v i! i D i- id o O s :y i p<`.'*i.n.v.e 0. ?3 c.o :i; ,1 . i i h * *< ( * -" i S o n y ! {.rti- . . . i f J ji-i n : - 3 H.thyl J ili-A lpi.invi pliiM iate " C i 'i t o lccyt pn-S i.iat it. Oin o . u.: O .'jl - t o ; 524 ; ` -4G : :> i 1 * _ = ; 32.5 i ` 53.0 5. 2 0 .0 0 2 ! 1 - 5<>c ! 5. 3 j 0 .0 0 0 5 ! 1 C la s s e c\.p i 25C , l i. 3 0 . 020-J 1 --j . -4 5 '.n. . 1 f 211 j 1 1 4. Gli ' 0.01135 , ! i< 2 5 C - n c f . : : u J4J - !1 -- ^ j1 4. 3 j o. o c i * U ld * uo !1 fi* G * 5 .3 3 o. o ic j i, -.n>'y U- r . j 11 ~ _ 5 lU r . 30C-| j1 listi. r af j nlconoln. J 7j i 230 J " 5: 1. - i . 6usd 4. 5G J 0 ------ .0 0 3 |1 ! l'i::)s!;y Mi. ; i 1 i i 1 1 NPC00007324 1 j \ 769963 - 19 Of the uncompounded esters listed (and many more have been evaluated), only di-isononyl phthalate has so far been recommended for a. c. (1 capacitors.' A m o n g the remainder, promising results have been achieved on i paper and mixed paper/polymer film capacitors with di-n butyl phthalate, and i indeed it is the derivatives of phthalic acid which till now have attracted most attention. The dielectric loss tangents of most esters, even if below 0. 001 at 25C, tend to rise s:eepiv with increasing temperature and to be susceptible to chemical deterioration upon.prolonged duty at elevated temperatures. Also they are all inflammable, and when ignited m a y burn fiercely. Nevertheless, most phthalate esters /13 possess the attraction of providing a negligible environment!', hazard. si; re they are iritiallv cf lew or zero toxicity and swiftly decomposed by c o m m o n chemical or biological age:*.:. Ever, though trr.cea the widely used phthalate es'ers (r.i *n:*: derived from compounded P V C) have be-in found in concentrations up to 3. 2 m g fg in fresh water fish^ (compared with reported figures of 1. 3 mg/ g for P C B 's), the T L 50 value (tolerance limit concentration for 50% survival) for many species of fish, is well above 0.7 mg/litre of water, which is at least 40 times better than that for DDT. Little is known of the toxicity of the esters of other organic acids such as benzoic or triacetic, but their electrical properties arc a;::*s.t*ivr. Phosphc.:? isters birr-lay 5c m useful properties, but they vary very widely in potential toxicity. For example, 2-ethy.hexyl diphenyl phosphate can be used as a plasticiser in packaging materials which come in.-contac: with foodstuffs; but t-ritolyl or trixylyl phosphates are neuro.- N P C 0000732S r sJ 769964 toxic despite having relatively low L D 50 figures.^ These figures may be compared with those reported for polybutenes, which are reported as '`practically non-toxic" (LD 50 value greater than 15.4 mg/gl, white "soft" dodecyl benzene is thought of as non-toxic. | The general indication is that very few, if any, esters by >.emselves % provide a useful a. c. dielectric liquids, and the few referred to above as bavin some potential, should be compounded with stabilisers, such as the epoxy derivatives of Bisphenol A. Furthermore, greater promise is shown by c o m pounding with other easily obtainable and purifiabie liquids, using the ester as a solvent, as described in the next section. The c p c - irriri: a spiccisi as:=r (such as di-r. butyl phthsl.'.te with other dielectric liquids or organic ccrr.pc ncs has been explores quite extensively, as an alternative to the use of a single purified chemical species. In pursuing such a concept, other combinations of organic liquids besides esters, have been scrutinised and most of the reported results emphasise the need to incorporate a specific stabiliser, following the well-established practice of protecting trichlorobiphenvl with an epoxy'compound idigtycidyl e:tiers and derivatives c: ethylene oxide- which rapidly absorbs any hydro chloric acid liberated by internal discharges under a. c. operation. Different stabilisers, usually quincucs, ha--,e been used for d.c. applications. I*, cannot, be'ShSSurnfid. that the rates of reaction established for the various eooxies with the breakdown produc's ci F C B 's, will apply to their interaction with other *^00000.7326 769965 - 21 - organic compounds, and indeed it has been found ihat even with a substantial excess of epoxide groups to react with each phtnalie acid molecule, the reaction rates could be several hundred times slower than with the hydrochloric acid released by electrical discharges in standard trichlorodipner.yl. Perhaps the best example of an epoxy stabilised phthalate ester is provided by the liquid % known under its proprietary trade name ''Ecor.ol"/^ which consists essentially of di-2 ethyl hexyl phthalate stabilised with a diglycidy! ether of Bisphcnol A (DGEBA), one of a large number of diglycidyl ethers proposed as stabilisers for capacitor applications. (17) . A selection of mixed ester a1nd other organic liquids suggested as possible capacitor imprgnants are given'ir Table 4. Mas: 0: these have he?r. cons:i?red ir use with paper winsings, but sor.-.e tests have beer, carried out on mixe paper/plastic arc even all plastic film vindlr.gs, where an important audit! :;a! requirement is the interact: :-n between the liouid Dhasc and the oelvrr.er film. This r.na>v become critical where the absorption of two liquids by, for example, polypropylene is different. In such a case, the liquid possessing the higher absorbance will be sequestered preferentially in the polymer, and the carefully selected initial concentration distributions will not remain constant, especially under* thermal cycling. ^ 0 0 0 7327 / V 769966 iti.-trVv'.'p- TAHLE4 -- P r o p e r t i e s L iquid D n B P /O C E BA i | P o u r I F la sh B o.tir.g | D ensity | P oint | P oint . Porn: i oc j j oc 1 l. 03 i -4 5 > ICS j 340 | ! P errr.t:- ^.oss V is c o s ity i t:v ::y rr ur. e n t cS I 1 2. 5 /3 .0 J 6 .5 i' 0 .0 1 3 25c! 1CCC N oies E <peri m en tal 1 ( | O i-2 ethyl hexyl I'R -.haU 'e * U C E 2A D r.B P/D D B S O / D O P/Polybulene 5 0 /5 0 0 .5 3 0 .95 0 .9 1 5 218 j 290 6. 9 4 .6 0 .0 9 3 ! P ra p ru - i-ir y ..-.cr J i 5mm 80C { T5C ' l C u C j 'E c s.ta l". ite.V .'lS ) > 43 > ITS j t 1 4 /1 5 j 4 .2 5 '< 0 .0 1 IT xrr:--er.:al :o ac ; 25C 103C - .t . | j 3.13 j ! 9.04 P rz p r.rrz ry i 90C iu r. ::T t ' J i E s te r, S ulpiiar.?; ~ p a s .b e 0 . SsS ' 3" i * Jlrdrocarbcm Shipbor.c/ E poxide 1 .5 3 no j j 4. 30 ; 6 .2 ` 0.022 m cs UT5 i 1 0 0 C i* 255C :so c 113) i 1. 96 iooflc 1 ! S. 1 ; iooc; 0.1 0 100*C . MCS ::ei. '.5 3 3 ;:oi : i j : D c.9P 'X itr.n icr.rcr.e 8 9 /2 0 .* 1 iDn H P .'P o ly p ro p y len e G irb c m te 5C/50 - - - -i 1- 1 1 1 .8 11 1- r X2T"1^'ui Hit. * j * -i . 1 i1 r-G ! * E xacr.rr.er.:*! filri. H3) j I t i s o n l y n P t n * * '* able t a p r e s s r . t a i e w t y p i c a l e x a m p l e s 3t m i x e d -ICUltlS, o a r . i-a .V, ,ich 0>'jVh'C" "r . T2"2S.\~ SU `.0 or: cir .ta to :"? ra ; a . . 59";cu- e-in:v.'''c.-" consideri-.tier.. Evolution of mixtures has fallowed :wa genera'.approve t (1) Admixture of the ester with a suitable hydrocarbon, in relative proportions determined by the values of permit tivity and physical properties to be secured. (2) Dissolution in the ester of another organic compound or polymer of suitably hish permittivity ar.d dielectric acceotabilitv. Exantoles o: the firs: accroach giver, in Taoie 4 ir*vor.*e triie ise of dodocy-ibenzene o** n polybutene with respectively cioctyi phthaiate or dl-n butyl phthalate. The former approach, still hi the experimental stage, indicates a NPC00007328 \ 769967 general result which might characterise mixtures oi an ester with a range cf alkyl benzenes. The latter dev--'opmer.r, me subject of numerous pending patent applications, yields mixtures at the low end o: the permittivity range, which might prove less advantageous, especially for paper; film windings, unless the total combination permits very high working stresses. I Many investigators have experimented with liquids o: high permittivity such as the nitro-aromatics and particularly nitro-benzene (K s 36), facing the extreme difficulty o; achieving and maintaining high purity fcv using molecular sieves and. latterly, electrodialysis which has given useful results in the laboratory. The same workers also examined solutions of propylene carbonate [K = SS) in dibutyl phthalate though the resulting permit tivities o: the solettcr.s m*y still be rather high for ::r.merciai purposes. A b-1 'c-? :r.ustte s:ru::: otweor. the come 1txity ar/' ;c" a:puri*.:an or., and ;.v:- limited advantage cf h1m er aermiitivitv. Perhaps the more re.varbtrt* engineering route is to choose modest values o: liquid permittivlt- "-.'I - 7.01. and rely upon good a. c. strength with chemical and thermal stability, to permit realisation of reliable high stressed dielectrics of good thermal conductivity. Other recently reported mixtures-1^ include an aromatic ester blended with tolyi suiphone and stabilised with an epoxy, such as 0.1 to 3.0 per cent by weight c: 7-4 epoxy cyclchexyl-rr.emyl 3-4 epoxy cycle.io:-:5:--? car -: tato Diaryl sutphones, -.it;, various up ;t:er.:s huv-j gcrtcrzteu cor..*.itrruh'o . interest as dielectric components, though they tend to possess a rather incompatible select:on o: other properties. However, by prolonged refining ithas beenTdemons:ratc*d that a blend of a substituted diarvl sulohone and NPC00007329 769968 - 24 - hydrocarbons such as alkyl benzenes, naphthalenes and b ip h e n y ls/'"' can produce a nan-halogenated capacitor impregnar.t for paper, paper;polym er i film and all film constructions including also designs incorporating m etallise a i electrodes. A further useful claim for such a m ixture, is a. lower pour point than PC B 's. Unlike the latte:;, however, they are inflammable. VII. SILICONES This group com prises a related series of polydimethyl siloxanes or ' polymethyl phenyl silcxane, in the form c: clear liquids having a v id e ranee c: m olecular /eights ~r.c visc js: ties varying from 3. *35 cS *o 12 >00 c5 e to " tem perature (see Table C.. They are well hr.ov.r. for. tr.s extrem e v e r w i I their ccmr.i-.1 and in d u strial application, based upon e x c e l r m u stability anu resistan ce to oxidation coupled v.-ith r.on-ir.:Tammability and * general chem ical inertness. F o r d ielectric applications they display low lo ss tangents and good electrical stren g th , with an operational tem p eratu re range from -E0C to -250C. With p erm ittiv ities in the region of 2. 2 to 2.3 they could be used for cable and tra n sfo rm e r applications, though fo r cap acito rs the m ore recently developed flu or osill cone has a m ore attractive d ie le ctric const i.tt. NPC00007330 769969 T A I T - E . ^ ~ ^ ^ P r a p c r :ie * D .r r .* `. h ) l i l i c o ' . e S o o . i `.r C rav.:v Sc 0. 353 Pour P c -.r .t o L- .7 1 n * r. P e.n t c \ isccu .iy 2SC P e r n ii l i %:: v :s- L '** 2-1-U 232 :o 1 a < o .o :c ; S 1 et 1 r .-iil O ir* .c`. h y l < i l : c o n e 0 .9 7 * P n n > l ir.*:nyl iU eon * 0 .9 9 Pr.tCy l m e .'.I CtUCOA 1.102 F lu o r o - ivlicon * 1 .1 2 C h ia r o - p r e n y l m*-.>.yl p d ljrliloxxa * -3 0 316 1000 - * * 230 30! * >260 so SO 3 3C5 * 2 .7 6 * 0 .0 0 0 1 - . c;:to - in to - 1 2.9 0 - - d :-.3 . S .2 3 C o r .m t r : .; '..Y a*.a-.at*. 3. 3. x .1A0 - J Above 400C the polysiloxanes will begin ro depolymerisc, and under internal discharges the methyl derivatives display considerable gassing, which is much reduced or reversed in the methyl phenyl derivatives. Internal arcing, as ir. sv/itcngear, would cause complete de^rada4""'-'- <- -_ r? tj~ evolution o: ccrrcs. molecules cannot occur. .-or very high voi:.-,ge-. m. polys.1''.vane lie lids r.a-.-e even pr2:::isir.g res-Its in experiment?.*, taclri thougii with cellules: their non-w ettin~ orpoe -*.3 7? " orodT?ms ci s*-* control a: the licuid/fibre interfaces, complicating the design c: joints and sealing ends. Silicones, and mixtures of them with hydrocarbons have been proposed for the impregnation of solid, extruded crosslinked polyethylene cables/-^ it being claimed that higher impulse breakdown stresses ar.d improved levels of internal coror.a inception stress levels car be Detained by filling the residual voius .n the solid po'.ynu he irsu'.av.on. More vigorous exploitation of polysiloxanes bus beer, inhibited only bv cost. They are produced by intrinsically high energy consumption sviuneses, and compared with other liquids, this will hardly diminish in the futu * NPC00007331 ..... - ! ----- --- * 769970 T h e i r use could be justified in v e ry high voltage equipment where the cos: o: the liquid component is a s m a l l fraction o: the total in stalled cost. Apar t fro m certain embarrassing physical features arising from their strong hydropnoblc c h a r a c te r , they offer little threat to the environment and are no: known to disp la y unacceptable biological toxicity. F r o m this aspec t, introduction o: halogen a t o m s into the molecule would be di sad van tag eo us. A wide stu dy of substituted polysiloxanes has been reported'"'^ in which the substituent "R in the general formula:- (c h 3)3 s i o (r . c h 3 s :o )x s i (c h 3)3 n.is taken many varied form s including: - n n-C ,n .-, CF and o- j O.* Uc`-- as- *o a: 19.3, ne vo1 m e iz o : ; " 'virie.? from 1. 5 x 10* to T. 2 x 10*' . 3Lucy of these liquids p r o / : ; : valuable in formation or. the re l a ti o n s h ip between c h e m i c a l s t r u c t u r e and e le c t r i c a l p r o p e r tie s , but not a d i r e c t contribution towards the pro vision of new liquids for High Voltage d i e l e c t r i c s . It s e e m s that e l e c t r i c a l appli cat io ns (except f o r cables) must r e m a i n in the r e a l m of s p e c i a l i s e d app lications for soace or electronics. Yu.. Z"T t*p IvL'O.'.'c The introduction of Fluorine into the hydrocarbon structure introduces many useful changes in properties, due mainly to a great increase in stability (especially resistance to oxidation and inflammability), while retaining or even A * NPC00007332 \ *' 769971 ^7 improving the electrical properties. They have been introduced as electrical coolants and insulanis, heat exchange and hydraulic fluids wherever the duty ;s sufficiently onerous to preclude oth er c la s s e s of liquid, and justifies th e i r high cost. The l a t te r r e f l e c t s the high e n e rg y ab so rp tio n and cost uf all fluorine c h e m i c a l sy n th e s e s , and is unlikely to be much changed in the future. % The f lu o r o c ar bo n s of m o st i n t e r e s t as po ten tia l d i e l e c t r i c liquids a r e derived from benzene or naphthalene analogues such as:- perfluoromethy! cyclohexane, perfluorodimetnyl cyclohexane and perfluorodecalin. Despite a ttrac tive e le c tr ic a l p r o p e r t ie s ar.d inertness, excessive volatility is 3 proble m , and attention has m o r e r e c e n tl y bec-n focussed upon fluorinated e t h e r s , alcohols ar.dvnines, which are even m ore costly than the simple fluorocarbons. A few \J. .: = -.'.--- >'w a r e s u m m a r i s e s .ao.e r. T A '. 5 P r o p e r : . e* F tu o r o ; a r_ on H exailuoroentc-.e Perilucrodeei.in 5pec;Tic [ Gravity 1 25c" Pour Poift 11 C i * 1 i 1.55 | Soiling jV lisos::/ . Peine 1 oc 23C 1 so ! M2 ! 0.36 2. 65 Perrr.u - i L :ii tlvltv *[ T inrent 2C 25C i -2.07 1. 95 j< 0 . COCI \ ! i P e r f u o r o : : r. j t >. a r u r t :i 1. 8? P e rilu o ro c ir.c x y l e:i*e- 1.31 Perfluorocyclo-ocarol 1 > " -50 i *90 oo < i 7B 103 1 2.95 i 2.:: j 0.81 : . s ! < 0 . CCC3 1. 95 < 0 , 0005 1.83 <0.0005 j Korea i 1 i 1 11 1 1 ! j Und er the p r e s e n t search in g re - e x a m : . . ation cf the t o xi ci ty or p-: r si s te nc e of pollution ca u sed by d i s p e r s a l of sy nth et ic ch e m ic a ls of all kinds, coupled with recen t s t a t e m e n t s of the likely-cumulative detrim en ta l effect upon NPC00007333 769972 -T * * the a t m o s p h e r i c ozone l a y e r of w id es p rea d use of a e ro s o l s p ra y s containing mixed fiuoro-chloro nyd.-ocarbon gases, it is barely conceivable that fluorinate synthetic compounds would be delibera tely considered as re p la c e m e n ts for existing dielectric liquids, except for highly specialised purposes. However, their extrem ely low pour points in conjunction with their remaining properties, % might fit them for H.V. duties in arctic conditions, as well as in cuter space. IX . C O N C L U S IO N 'S In a rev ie w of this n a tu r e it is i m po ss ibl e to do m o r e than d i re c t attention to those as p ec t s which typify both advantages ar.d disadva ntages :n the se le c tio n and use of novel d i e l e c t r i c liquids. Efforts arc being directed towards finding more stable liquids for .ti'*c . . t r i m s : t o e s t a b --isr. ess inilp.mm-.tsi*? n y c rc c s ro or .s , *o .m e r v .e gas absorption under internal discharge*., and to optimise thermal cord .ctivity. Alter tatives to F C S 's for s m a lle r tra n s fo rm e rs , especi.'.l for distribution, are being sought as a safeguard against ahy unjustified limitation in use on ecological grounds. So f ar all possible candidates on tec hni ca l/ economic grounds c a r r y the serious objection of inflammability and explosion risks. F o r ca nle s t h e r e a p p e a r s to be a wide cnoice of a l t e r n a t i v e s , though the gradual evolutic- of new, solid, taped ins*-lotions (plastic ' r o p e r larn.na-.es pose p r o b le m s c: inc om patib ili ty between liquid and polymer. There is a w i d e r field of choice for c a p a c i t o r imp re gn ant s in the requisite permittivity range, since non-rr.flammcbility poses le3s of a hazard NPC00007334 769973 - 29 - in se al e d H. Y . t a n k de signs. I: m u s t be said, however, that the v a rio us t r i chloro dip hen yls av ailable now, ar.d the p r o m i s e of acceptable b i o ce r ea da b le types in the n ear future, provides an adequate base from which to develop units of l a r g e r kVAR. without s a c r i f i c e of safety e i t h e r in o p e r a r o n o r ir. dispo sa l. The r e q u i r e m e n t s fo%r s w itc h g e a r, r e a c t o r s and m i s c e ll a n e o u s duties ap p ear to r a i s e r a t t e r less onerous p r o b le m s, ar.d perhaps the usual p r o c e s s e s of selec tion and field t r i a l on the f u ll - s c a le will yield any n e c e s s a r y new or modified liquids. Finally, there does seem to be incre asing opportunity to consider a w i d e r range of m i x t u r e s of different m o l e c u l a r s p e ci e s , r a t h e r than r e l y ur*n single c l a s s e s c r homologues as in the p a s t, ir. o r d e r to o p t im is e the --ileal r?cu :r.rr er.ts. M. RE FERZXC E3 C) J o u rn a l of the Eu r o p e an Co m m u n ity (No. C . 4 9 / 1 , *. 3 . 7 5 . ) . ( 2) "The P r o p e r t i e s of A s k a r e l s and Recom mendations for th eir u se in E l e c t r i c a l Eq u i p m e n t ", (E le c tra , Xo. 33, M a rc h 1974, p . 11). (31 "Mai nten an ce and Sup ervision Guide for Insulat.ing Oils in S e r v i c e " , (IEC Publication 422). " H ' d r o c a r c o r . 1: vlst.nt Oils . '".Padi-m P i e l ^ c t r i c Mat*rial*, i Heywood and Cam *cany*, 1050 . Symposium on Insulating Oils, Institute of P e t r o l e u m , March 1953. NPC00007335 * \ A 769974 Anderson, J . K . , Banks, V . A . A . and O'Sullivan, D .. 'An Impro ve d Imprgnant for Oil-filled Cables and Accessories", (IEE Conference L a n c a s t e r , Pub lic ati on G7, J u ly 1970). Pelagatti, U., "A New Synthetic Imprgnant for High Tension Hollow Core Ca b le s" , (IEEE^ Conference on E l e c t r i c a l Insulation, White Sulphur Springs, November 1953). Gazzana-Priaroggla, P ., Piscioneri, J. and Uargoli, 3., "The Lor Island Sound Submarine Cable Interconnection", {IEEE T ra n s.P o w e r Applications and S ys tem s, Vol. TAS 90, No. 4, J u l y / A u g u s t 1971). "Synthetic Insulating Fluids in Pla ce of Polychlorinated Biphenyls", {Nippon Oil Co. Ltd. Te c hn ic a l Bulletin). C!e, ? . : . ?r.d Simm ons, M . A . , "Application c: A s k a r o'. I r r . j r ' g n a t Dial r e t r i e s for N on-inflamm able Oil-filled Csoles", (IEE C or.ierei.c* Cambridge, 1915,. Netiietcn, .M.A.., " Bu rn in g o: Po ol s o: Insula. :ng Oils", (Fuel, Vol. 54, A d: il 197 5). Kolbye, A . C . , (Bureau of Food and Drugs Administration, U .S .A ., September 1071). Sax, ' D an ge ro us P r o p e r t i e s o: I n d u s t r i a l M a t e r i a l s " , (Reinhold, 1353). Rut!:~v.ski. A .J . and F o r s te r , I . C . , (IEE Confer =r.:r ::t D i r l e a v t c Materials, M easurem ents and Applications, July 1075;. Segar and Tucker, "Hithalate Eaters undergo Ready Biodegradation (Plastics Eng in eering, August ISJ'3). NPC00007336 769975 (16) Goldy, H. and Solberg, W . O . , (Insulation Ci r cu i ts , J a n u a r y 1975). (17) Eustace, J . W . , "Stabilised E s t e r Impregnated C a p a c it o rs " , (USP 3, 574, 173). (18) Tobazeon, R. and G a r t n e r , E . , " B e h a v io u r of s om e New P o l a r Impregr.ants for Capacitors", (IEE Conference, Cambridge, July 1975). (19) Munch, R . H . , "Liquid Im p r e g n a t e d C a p a c i t o r s " , (USP 3, 311, 077). (20) Munch, R . H . , " C a p a c i t o r with non-Kalogertaie J Impregr.ar.i", (USP 3, 796, 934). (21) Bruins, P . F . , (Silicone Technology, Wiley, 1970). (22) Vincent, T . , Fe a ro n, F . W . G . and Orbeck, T . , " S t r u c t u r e P r o p e r t y Relatior.s.v.os in Silicons Fluid D i e l e c t r i c s ( S y m p o s i u m of Dielectric a r c Ins- lacinr M a te r ia ls , O c t o b e r 1ST2). ^00007337 769976