Document peNKOwQyE3mDboOV4eLQXKNME

VCIW fbtl May 16. 1978 Qantltman: For lha part thraa yean, Vamr hat baan performing research on the anvironmantal problamt of PCBi for tha U. S. Environmantal Protaction Agancy. Wa hava analyzad many different samples of PCBi and hava looked closely at tha problem* associated with this chemical. Wa would like to pan dong to you tome information on wayi that tha now regulations on PCBt and the expected changes in there regulations will affect your transformer repair business. SPECIAL LABELS AND DISPOSAL REQUIRED FOR ASKARELS PCBs are tha major component of askarel transformer liquids. There askarels have also been sold under tha following trade names: ASKAREL PYRANOL INERTEEN ABESTOL CHLOREXTOL NOFLAMOL SAF-T-KUHL In spite of tha rather casual ways that askarels hava been handled in tha past, tha vapor from hot askarel can be poisonous. Vaporized askarel re cently poisoned some firefighters and utility workers in Toronto (sac attached article from Electrical Weak). Hitfi vapor levels can also result from baking out transformer cores or welding on transformer cases. Tha long-term health affects of PCB exposure are subtle, but even more serious. A recant study by tha National Institute of Occupational Safety and Health raviewed.tha available in- ... formation on the health effects of worker exposure to PCBt and concluded by recommending that tha OSHA standard decrease the allowable air concentration of PCBt to one tenth the present limit. The NIOSH report is well worth reading If you are handling askarel. The citation is as follosvt: Criteria for a recommended standard . Occupational Exposure to Polychlorinated Biphenyls (PCBt). Sep tember, 1977. U. S. Government Printing Office, Washington, D. C. 20402. ($4.00 per copy) EPA has recently issued a set of regulations which hava tha intent of preventing PCBs from^petting into the environment because of spills or Im proper disposal. Tha regulations apply to everyone who uses, services, repain, HONS 000128 ! 6621 ELECTRONIC DRIVE, SPRINGFIELD. VIRGINIA 22151 TELEPHONE: (7031 750 3000 _ J vcrur transports, disposes of, or is otherwise Involved with any PCBs, including askaral tsansfonnsrs. The regulations hay* the titla; Polychlorinated Biphenyls (PCBs) -- Disposal and Markina (Federal Ragistar, February 17, 1978). You can gat a fraa oopy by calling tha EPA Industry Assistance Office toll fraa (800) 424-9066. Tha basic labeling and disposal requirements for askarel transformers are as follows (check the regulations for exact details): Labels: Special labels must be applied to all askaral transformers by January 1, 1979. Labels must be applied to PCB containers and to PCB storage areas by July 1, 1978. Labels mutt be applied to trucks carrying askaral transformers of over 100 pounds (9 gallons) of PCBs as of October 1,1978. Disposal of liquid askaral and contaminated solvents: Special high temp erature incineration required after April 18, 1978. Note: The only incinerators known to be able to proparly handle liquid PCBs art: ' Rollins Environmental Services: Bridgeport, NJ. (609) 467-3100 Baton Rouge, LA (504) 778-1234 Houston, TX (713) 479-6001 ENSCO: El Dorado, AK (601) 863-7173 Disposal of oontaminatad rags, fullers earth, etc. with PCB concentrations abova 600 parts par million (one pound par ton): Special high temperature incineration (same as liquids) exoapt disposal in approved chemical waste landfills approved until January 1, 1980. Note: Check with your EPA Regional Office for information on tha availability of approved chemical waste landfills. Disposal of iontaminatad dirt and debris: High temperature incineration or chemical waste landfill par above. HONS 000129 0021 ELECTRONIC DRIVE, SPRINGFIELD, VIRGINIA 221S1 TELEPHONE: (703) 750-3000 verm. Disposal of atkarel transformers: Drain tnraformar and Audi with tolvant (kerosene, ate.) for 18 Noun. Drain tolvant and taal transformer. Liquids require high temperature incineration par above. Transforman must than be disposed of in chemical waste landfills. note: These regulations alto apply to other equipment which contains PCBt. This indudes oertain electromagnets, electric motors, hydraulic systems, com preason and eapaciton. MANY OIL FILLED TRANSFORMERS ARE CONTAMINATED WITH PCBt A substantial number of oil-filled trantforman are contaminated with PCBt. This contamination may have occured when the trantforman were manu factured or during field servicing. The concentration of the PCBt in the 10-C transformer oil Is leu than 500 parts per million, but is probably above 50 parts per million in one half of the oil-filled transformers. There it no easy way to check tramtformar oil for the presence of low levels of PCBt. Use of oontamImated transformer oil for oiling roads hat resulted in actions being taken against repair shops by the EPA, and dose attention from the EPA it expected in the future (see attached article from Chemical Week magazine). The EPA is expected to propose new regulations within the next few weeks that would require special high temperature incineration of any oil containing over 50 parts per million PCBt, and ban the further use of oil containing any PCBt u road oil. The precautions necessary to protect the health of your workers and die oost of disposing of wasta transformer oil and contaminated materials will both depend on the oonoentration of PCBt in the oil. PCBs are completely soluble in transformer oil. and there is no easy test bated on color, smell, pacific gravity, electrical characteristics or other physical property that can reveal the presence of small quantities of PCBs in oil. Quantitative analysis for PCBt it complicated because the commercial TCB' it actually a mixture of about thirty different, but similar, chemicals. Quantitative analysis for PCBt requires that these different chemicals be separated 6621 ELECTRONIC DRIVE, SPRINGFIELD. VIRGINIA 22151 TELEPHONE: (7031 750-3000 HONS 0 0 0 1 3 0 Vcrsar. from each other and from other non-PCB chemicals such as trichlorobenzene end naturally occuring chlorine and sulfur compounds that interfere with the analysis for PCBs. The concentration of the different types of PCS chemicals must be determined separately, and the results added to determine total mount of PCBs in the oil. Reliable analysis for PCBs requires the use of an electron capture gat chromatograph, experienced lab technicians, end considerable experience in analyzing for PCBs. Venar routinely performs analyses for PCBs, and we know how to get the information which you will need to make your plans for repairing oil-filled transformers. The attached price list is for the analysis of PCBs in 10-C transformer oil. The range of concentrations for quantitative results (10 1000 parts per million by weight) covers the cut-off points for the various regulations. The accuracy of * 10% is not the ultimate that we can achieve, but should be adequate for the information you need;.ft takes more work to get greeter-accuracy and the price goes up aooordingly. Analysis for PCBs in other materials such as silicone fluid, dirt, river sediments, fish, etc., can also be done in our lab; the price depends on the work involved and the accuracy required. We will be glad to quote prices based on your pacific problem). PCBs are ne longer being manufactured end askarel transformers are no longer being made. Jowever, the PCB problem is going to remain with us for the next 20 to 30 years jbecauaa of the large number of askarel end contaminated oilfilled transformers now in service that will require maintenance. EPA end OSHA actions to assure safe handling and disposal of PCBs ere just starting and will continue for at long as there era PCBs in service. PCBs will be your 'problem to the extant that you don't know whet is in the transformer that you an working on. Quantitative analysis for PCBs in the oil of transformers being repaired will be needed for e long time to oome, and field sampling surveys to determine the concentration of PCBs in existing transformers may be required in tome cases. Vertar is in the business of furnishing analytical chemical services, end we would be glad to have the opportunity to help you live with the problem of PCBs. MONS 000131 i