Document pBXkEmx0D86NRqREXdZBnwwkk

Electric Pow*r ReaMfch Inatltute 6 July 1983 Dr. Carl McMillin Monsanto Research Corp. 1515 Nicholas Road Dayton, OH 45418 Dear Carl: As per our telephone conversation, I am sending you a copy of EPRI's statement of work for analysis of dioxins and furans in PCB and PCB contaminated oil. I anticipate that Monsanto would address Tasks 1, 2, 3 and 8. However, if you feel that you can contribute to any of the other tasks, then you may wish to respond there too. Your response should include completion of EPRI Form 112 for each task and another form for all tasks taken together. In addition, you should indicate whether you think Monsanto can accomplish the work as stated using state-of-the-art technology. If you feel some tasks cannot be done, please indicate the rationale for your position. Do provide budget and timetables for those tasks that you feel are achievable. Since EPRI is very anxious to begin this work, I would appre ciate a rapid response. Feel free to call me if you have any questions (415) 855-2018. Sincerely, Jacques Guertin Project Manager Environmental Physics and Chemistry JGims Enclosures cc: Gil Addis PLAINTIFF'S EXHIBIT 1915- K NEV 036916 803303 STLCOPCB4025853 RP2028 Cl \ J I EPRI - RFP2028 PCDF PROPOSED WORK STATEMENT 1, STATEMENT Of WORK 1^ Background Con corns about offvctv of polychlorinated biphenyls (PCU) on liuman hat1th and the environment ltd to a ban on produotlon and to regulation of usa and diapoaal In tha Uni tad States* PCI, oftan blandad with tri-and totrachlorobanaanaa (T/TCB), vara uaad aa dialaotrio fluids in oapacitors* transformers and othar alaotrleal oquipmuut. Uuyulation of PCU continues to have a vory diract offset on ownara or oparators of this equipment* Work at tha Elaotrio Povar Research Inotituto (EPRI) is oimod at aiding alactrio utilitios in complying with thasa regulations. SPRZ also la investigating araaa which may affsot tha future paroaption of tha hatarda of PCI or altar tha raquiramenta for complianoe* - Many of tha affacta associated with PCI now appear to be attributable to either polychlorinated dibanaofurana (PCD?) and/or dibeniediesine ^ (PCOD) * PCDF can be formed from PCI* PCDF and PCDO can be feramd ffrom T/TCU* It is possible than that PCDF and PCDD vara introduced* J into electrical apparatus as traoa oontaminanta in PCI during mmi* factura or installation or that they may be formed during normal or . abnormal operation* However* there la little hard information on tho occurrence if any of PCDF and PCDD in alaotrleal equipment and no basis for assessing their affects* Tha purposes of tha program are to identify the level* of PCDF and pcdd in operating eleetrloal equipment and to attempt to relate these levels to tha conditions of earvioa of the equipment* To accomplish thasa purposes* appropriate analytloel techniques oust be demon* strated and relevant dialaotrio liquid samples must be aelaotad and analysed* The results should have maximum reliability and credi bility. Ifce overall program thus includes several participants the University of Umea with C. Rapps as consultant* ths battelle Memorial Institute with Kuhlman Corporation as sub-oontractor and thu Naw York State (NY8) Department of Health* Where desirable* equipment trials vilKbs'staged in order to provide particular PCU oxposuro sconarios which may not be readily available from equipment in servioe. The final report of BPRX program RP1263-11 will be used as a literature base* A. --Wo--rk----Tas--ks t- 1 * Task It Preparation of Samples The purpose of this task if,to provide samples of insula ting liquids spiked with C*3 labeled PCDF and PCDD con- NEV 036917 803304 STLCOPCB4025854 uvauau a. genera* Carbon-13 containing congeners in measurable qusntitias ara abaant in normally occurring materials and are clearly distinguishable from normal isotopic materials by mass speotromstry. Spiking samplef with labeled congeners providos a uniquo Internal standard for accurate analysis* Synthesis and spiking will be done by 7 .. One grdm silted aliquots-of .the spiked liquids will be supplied to- the round robin partibipants - Battalia Memorial Insti tute, Nts and the University of Umea (C, Rapps), Similar aliquots will be retained for use in this program by the splker. This procedure minimises the risk of loaa of these ooetly and potentially hasardoua materials* A representative of Blttelle will participate In the spiking procedure end the associated record keeping* The work in thia task la divided into three partai a* Standard Materiala . . * \ Six congeners of FCDF, prepared from C13 precureert, J; will be provided to spike approximately ninety (90) tL-*1 dieleotric fluid aamplee of one gram aise at appremi-^r mately the 100 ppb level of eaoh congener* The 'f .. congeners will bei ' ` l.s.1 1.S.2 1 s*3 l.a.4) 1.a.3' 1a *6^ 3,3,7,8-FC0F 1,3,3,7,S-PCDP 3,3,4,7,9-FCOF 1.3.3.4.7.9- FCOF 1.3.3.7.9.9- FCOF 1,3,3,6,7,8-FCOF Does the use of any of these pose any separation problems with present state-of-the-art techniques? . kb.Baseline Samples Samples of five liquids will be spiked with measured amounts (100 ppb) of each of the six PC0F and one PCDD congeners listed above (1a*1-1*a*7)* The five liquids will bet . 1*b*1 ^ 1*b*3 Aroolor 1016 Aroolor 1343 1 1*a*4, 1.a.5, and 1.a6 are prepared as a mixture in the ratio of 1i1.3i0*5, 803305 NEV 036916 STLCOPCB4025855 RP2028 1<b<3 1.b*4 i.b.5 3, > Aroclor 1260 Tri/tetrachlorobensene mixture (T/TCB) Aged mineral oil containing 500 . ppn PCB and 500 ppm T/TCB The first four eamplee will approximate ae closely ee possible unused liquids formerly employed in the manu facture of eleotrioal apparatus* The oil used in wumplo 1.b5 will be obtained from an aged transformer and will be spiked with Aroolor 1254 and T/TCB approx imating the condition of unused eskerel* o. In-Service Samples Samples of up to twenty liquids supplied by Battalia from electrical apparatus in service (sad Task 3 for o discussion of the sample selection and adqulsitien process) will be spiked in the seats way as samttat^ . l .b* 1-1 b5* Spiking lavel will be dsteralne^sljtev ' completion of Tasks 34 and 3b* lbs spiking la beat f ' done for all samples in one* or at most* twe batches* This will maximise reproduoibility and aaii4r ; ability and minimise demeqds on an outside expert* .,rw.v,>- (Aliquots of only ten samples will be provided/te ' University of Urnea*) ... . . .'mfv'..- 2. Task 2_i selection of Samples from In-8arvioa Equipment ' a* Selection of Cenerlo Candidates The range of applications of equlpnsnt filled with askarel or mineral oil containing PCB will be surveyed by ?__ _ and their typioal and extreme conditions of service will be delineated* Prom this, approximately twenty (20) generic equipment candidates for sampling and analysis of liquid will be identified* Xmphasis in the identification process will be on equipment operating under extresm conditions* However* a broad enough range of samples should be planned to determine conditions under whloh no PCOP/jwlll be found* A chart of pertinent history to be obtained on each sample will be devoloped together with a listing of desirable added optional information to be reported as available* The sample selection prooess and the format ef the history chart will be confirmed by the CPUS project manager* A milestone report on this work will be written* b Acgulaltioii' of Samples Battelle with the help of the BPRI project manager* if needed* will arrange to aoquire liquid samples repre sentative of the candidate types identified above in 803306 nV 036919 STLCOPCB4025856 RP2028 order to supply ths samples to ?_-CRD for spiking Task 1c. 3. Task 3 Gas Chromatographv/Hass Spectroscopy Analysis (GC/HS) v' Ths purpose of this task is to analyse dielectric fluids containing J*cu for PCDP and PCDD congeners, specifically those listed in Task 1. 7__ Battalia, and NY8 (and, under uubcontruot, tlio University of Unua (C. Rappu)|, will use the hist'separation and CC/M8 techniques at their disposal and will implement any improvements in methodology appearing during this work. The work in this tusk is divided into four sectionsi a. QC/M8 Cross Check . 7 the University of Urnsa, Battalia, and NYf will 'analyse the five samples provided under Task 1b ` (,i*.5> for PCDP and >CDD. At a sdminua, the eamplea - will be analysed for the Six 2,3,7,8,x-PCOF oongensrs . listed in Task la and for 2,3,7,B-PCOO. The initial t goal for the lower limit of detsotion will be 1 ppb. Actual detection limits for oaeh of tho slgnifleant V compounds will be estimated. Control samploe will bo? evaluated as neoeseary. (Zf neoeeaary, replicate ", anelyees will be performed on selected samples ee requested by BPAZ - at an additional ooet of 12000 per sample.) Other compounds, particularly PCOP end PCDD oongensrs will be determined when feasible. Any aignifleant unknown or indeterminate peaks found in the gas chromatogram or mats apeotrogram will be noted. v " ' . b. Assessment of Methodology 7___ (and, via subcontract, C. Rapps), Battalia, and NY8 will participate in the preparation of a mile*ton# report summarising the results of ths analytical croaa-oliock, the sourcos of any initial differences, the resolution of these diffenoes and any remaining unrosolvod problems with suggsstions for future reso lution. The report will be prepared in order to provido a common working basis for the later round robin (Task 3o) and to provide reoommendatlons to BPRI to either continue the program as plannsd initially or to divert funds for additional verification of analy tical methodology. Contaminated aged transformer oil will rocoiVe particular attention hors because its chemical complexity may not alias analysis of con geners at ths ppb or even tans of ppb level. Such e finding could affeot ths sample selection process (Task 2). This report is not intended for publication 803307 NEV 036920 STLCOPCB4025857 RP2028 5, and would not bo distributed beyond EPRI end its reviewers end the participants in this task* o. Round Robin Analysis ? Bettel le, end Mrs will enelyse e minimum of ' twenty (20) aamplea (University of Umaa 10 samples) from Task 1c for the six 2,3,7,0,X-PCDP congeners listed in Task la and for 2,3,7,8,-PCDD and, by standard methods, for PCBs* Other compounds will be determined when agreed upon between each contractor and.EPRX* Any additional oosts for additional analysis will be agreed on before hand* Detection limits sought will be specified based on results in Tasks 3a and 3b* 4* Task 4i Equipment Trials The purpose of this task is to investigate the conditions under which PCOOs and PCOPs might be formed in utility operations* Battelle will have primary responsibility for supervising this task. Their subcontractor (Xuhlman) will run at least ten trials using 10 kVa single-phase trams- * formers operating under a variety of conditions* Contam- ' inated mineral oil or askarels 'ferom the test equipment will* be sampled and analysed by the OC/KS technique validated litf v Task 3 to evaluate faotors whloh can lead to PCDP and PCDD formation.' experimental variables will include suoh faotors as aroing, corona, high temperature aging, and variations in askarel and contaminated oil composition* ?___ will provide consultation on this task* 5* Task 5i Pyrolysis of Aroclors 1016, 1243, 1354, and T/TCB Three Aroclors will be pyrolysed by WV8 using literaturebased procedures to explore their relative tendencies to fora PCOPs and related materials* It has been suggested that 1016 and 1242 may form much lower amounts of biologioally active isomers than the Aroclors which have already been studied* This hypothesis will bo touted using analytical procedures developed in ` Task 3* ?_ will provide coneultation^n this task* . 6* Taek 6i Combustion of Aroclore 1016, 1242, 1254, and T/TCB 'V ttirte Aroclors will be burned in CLtR's (NY8) model inoinerator to explore their relative propensity to form toxic PCDPe* These experiments may shed light on the hasard posed in the combustion of Aroclore 1016 and 1242* 7__will provide^consultation on this taek* 803308 NEV 036921* * STLCOPCB4025858 RP2038 0 7. Talk 7 Development and Validation of a Rapid MS/MS Band Softening Tachniqua NS will develop a chemically baaed screening tachniqua to _ provide a rapid, economical complacent to traditional rigorous analytical prooedures. The availability of the aamplea and extract! dlaeuaaad in Taaka 3.a, 3*o, 5 and 6 provide an unuaual opportunity to validate a M8/HB-based screening procedure rapidly and economically* Zt may be daairable to involve an independent coneultant agreeable to both NYS.and EPRZ for technical guidance* U* Taak th Heporta a Preparation of Monthly Reports Informal monthly letter reporta eumaarlilng technical progreae will be prepardd during the oouree of thle project. b. Prepiration of HilMtone Mports `V* .- . y; * Kile a tone reporta will be prepared on ooapletien of i. ' bl. bii. bill.. Taak2a 7 Taak2b (Battalia) Taak3b (All) c. Preparation of Pinal Re porta Pinal report# Including all work reported in previoualy mentioned mileatone reporta will be prepared in publlahable form by each of the con tractors. d. * PCOP and PCOO in Electrical Equipment" - Each oontraotor will participate in preparation of a report aummariting the PCOP and PCOO content found in the equipment sampled. The report would Include any conclusions poaelble about the sources of any PCOP and PCOO found, Zt would also include any extrapolations possible About the FCDP and PCOO content of electrical equipment in general. This report as well as the milestone report on -s* Task 3 may be beat coordinated by an indepen dent consultant who is not a participant in the analysis of samples. Each contractor will contribute 803309 N6V 036922 STLCOPCB4025859 RP2038 7. his sxpsrtiss in ths chsaioal analysis of dislsetrie fluids, in ths chsaistry of PCB, PCOP and PCOO and in ths bshsvlor of slsotrioal tquipmsnt* f * i m-* * 803310 NEV Q36923 STLCOPCB4025860