Document qaLnoVXr0gx0E7x0vJ8o3mNJq

lA-fiOQ.I (8- i 2) ron u lt o r e r e tri o y t ^ dmi ELECTRIC T E C H N IC A L INFORM ATION S ER IES T it* P it t author su bject cla ssific a tio n A,L.tBridgmar 1 1 2 Pyranol Bibliography NO. 56TP423 date 3-27-56 TlTLEThe Physiological Hazards of Pyranol Components Bibliography and Review ABSTRACT A list of 43 published references on the physiological hazards of Pyranol components is presented. A brief review of the information gathered from these references is reported. 9 G.E. CLASS III GOV CLASS CONCLUSION REPRODUCIBLE COPY FILED TECHNICAL DOCUMENTS Pittsfield Data Bureau NO. PAGES 6 G ENP 002366 r a r t f l a g M t tfcia r a c ta a e fa a t o f a t i l i * a a f l u c a r t a i Mm .tfta i k n i i r f a r m r B a a c a i t o f t t t a i la ta ( U M j r card fl*. f m u n a f M i t i f t i - a n i R p . t o a t a a . r t c a t o Par t r t t o O a a aa a r r t n . a t o . in f o r m a t io n prepared p o r Engineering and Manufacturing Information____________ n<2J2iDEife?n s S a g s^_A ,_X^._Brldgman_________________________________ _ __ c o u n t e r s ig n e d R> R- Ralston section Analytical Chemistry Sub. `Bull.DING ood BOON No ____________ ._____ LOCATION _________ P l t t S f l C l d 737114  VThe Physiological Hazards of Pyranol Components 56TF423 INTRODUCTION Some question has arisen on several occasions concerning the physiological hazards resulting from misuses of Pyranol. A search is now under way for information available on the toxicity of Pyranol components and decomposition products. This bibliography is presented as a survey of published literature on The Toxicity of Pyranol Components. A brief review of information gathered from these references is submitted. REVIEW The subject matter was of interest as far back as 1899 (20). Only one reference of the forty-three collected gives any information concerning the chlorinated benzenes (34); no authoritative sources are listed for this information. The remainder- deal primarily with chlorinated naphthalenes - which are not a current component of Pyranols, secondarily with the chlorinated diphenyls. Toxic quantities of the chlorinated aromatics can be ingested (1,6,29,41), although this is considered as a minor source of introduction. Inhalation (1,2,6,17,18,9,29,32,41) and absorption through .the skin (2^,17,18,29,32,41) are considered the major avenues of contamination. Introduction of these materials into the system have been known to cause acute yellow atrophy of the liver (1,6,9,17,18,29, 32,41). Exposure either to the fumes or to the bulk material has caused a characteristic dermatitis, frequently called chloracne (6,9,17,18,29,32). Fatal poisoning from exposure to chlorinated naphthalenes has been reported in seven cases (6,9,17), from exposure to chlorinated aromatics in several cases (17), and from exposure to chlorinated diphenyls (9,41). Frequent cases of dermatitic poisoning have been reported (17,37). One- author claims that the chlorinated diphenyls are more toxic than the chlorinated naphthalenes (1). Maximum allowable concentrations for exposure during an eight hour period are reported of 1 mgm per cubic meter for chlorinated diphenyls and chlorinated naphthalenes (2,9,34); of 0.5 ragra per cubic, meter for chlorinated diphenyls (6,7,41,43); of 10 mgm per cubic meter for chlorinated diphenyl (7); and of 50-75 parts per million in air for chlorinated benzenes (34) . As a safety measure, it is recommended that these materials be transferred, handled and poured in the cold (17,18), and under conditions of adequate forced draft ventilation (43). One paper deals primarily with the design, construction and ventilation of wire impregnating tanks using chlorinated hydrocarbonds (43). GENP 002367 737115 The Physiological Hazards of Pyranol Components 56TP423 Pre.-employment and periodic physical examinations for all employees working with chlorinated aromatics is recommended (17,18,32), as is also direct medical supervision (9,28,32). Knowledge of and prevention of hazardous conditions is considered the responsibility of, the foreman, under direct engineering control (17,18). It appears to be generally agreed upon (3,7,17,18,32,35,41) that the following hygienic measures should be taken by personnel working with these materials: (a) regular daily change of work clothes; (b) shower and scrub down of exposed parts of body at the end of the working period; (c) use of a protective skin cream on all exposed body parts; and (d) regular periodic cleansing of the work area, A cleansing cream of equal parts of butyl stearate and sulfonated castor oil built up with a corn meal abrasive is recommended by one author (18). Analysis of air samples by combustion over a platinum catalyst with determination of chlorine and chloride is described (9,29). Another method (29) suggests collection in amyl acetate, a lamp combustion and determination by argentometry or turbidimetry. Of the forty-three references collected, only twenty-seven were abstracted; the other sixteen were not readily available to the William Stanley Library. Three textbooks (29,34,39) gave no source material for their information. Experimental work with rats and rabbits has been reported (1,6,33,40). . ACKNOWLEDGEMENTS The author is indebted to Mr. S. Sass of the William Stanley Library for his aid in collecting the material. He is also indebted to Dr. F. G. McKerr for review of the paper. 10-31-55 Since the writing of this report,.a new monograph by W. F. von Oettingen, U.S. Department of Health "The Halogenated Hydrocarbons, Their Toxicity and Potential Dangers" Public Health Service Publication No. 414 (1955) has been received by the William Stanley Library. Chapter V, Halogenated Aromatic Hydrocarbons (pp 283-320) is of interest with respect to this paper, particularly the sections: 1-C: Polyhalogenated Benzene Derivatives (pp 297-299) 5- C : Polychlorinated Diphenyl Derivatives (pp 306-307) 6- B : Polyhalogenated Naphthalene Derivatives (pp 308-314) A bibliography is given with each section. 2 737116 O o oCO\v The Physiological Hazards of Pyranol ComDonents 56TF423 BIBLIOGRAPHY 1. Bennett, Drinker & Warren J. I n d . Hygiene & Toxicology, 20; 97-123, (1938) Morphological Changes in the Livers of Rats Resulting from Exposure to Certain Chlorinated Hydrocarbons. 2. Brown Chemist Analyst, 36; 33-34, (1947) On the Toxicity o7~the "Arochlors". 3. Cleary J. Biol. Chem., 127; 403 (1939) 4. Collier Lancet, 244; 72, (1943) 5. Cranch Industrial Medicine, 1 3 ; 110, (1944) 6. Drinker, Warren & Bennett ' J. Ind. Hygiene & Toxicology, 1 9 ; 283-311, (1937) The Problem of Possible Systemic Effects from Certain Chlorinated Hydrocarbons. 7. Drinker Ibid. 21; 155-159, (1939) Further Observations on the Possible Systemic Toxicity of Certain of the Chlorinated Hydrocarbons with Suggestions for Permissible Concentrations in the Air of Workrooms. 8. Ellis Synthetic Resins and their Plastics Chemical Catalogue Company, New York (1923) 9. Fairhall Industrial Toxicology p. 255ff Williams and Wilkins, New York (1947) 10. Flinn Proc. S o c . Exptl. Biol. Medicine, 35; 115 (1936) 11. Flinn Am. J. Hygiene, 7; 19, (1938) 12. Floret Chimie et Ind., 19; 1066-1067, (1928) Intoxications prFessionelles dues aux hydrocarbures des series aromatiques et aliphatique (hydrocarbures chlores); comment les viter. -3- GENP 002369 737117 The Physiological Hazards of Fyrarol Components 56TP423 13- Fulton Penn-State Dept. Labor Spec. Bulletin #43 (1936) 14. Genevois Ann Hyg. Publ. Ind. Sociale (1936) 139-149 Physiological properties of Chlorinated Solvents (CA 30:8399,1936) 15. Greenburg Ind. Hygiene JJ3; 11, (1939) 16. Greenburg, Mayers and Smith J. Ind. Hygiene Sc Toxicology 21; 29-38 (1939) Systemic Effects Resulting from Exposure to Certain Chlorinated Hydrocarbons 17. Greenburg N.7. State Deptc of Labor Ind. Bull. 22; 404-407 (1943) Safety Measures for Use of Chlorinate^Naphthalenes and Biphenyls in Industry r 18. Greenburg Ind. Medicine, 12; 520 (1943) Chlorinated NapKthalenes and Diphenyls 19. Harry Paint Manuf. 6; 288-290 (1936) Toxicity of Industrial Solvents 20. Herxheimer Mnchen med Wchnschr ^6; 278 (1899) 21. Hunter Industrial Toxicology, p. 67 Clarendon Press, N.Y. (1944) 22. International Labor Office. World Peace Foundation, Boston Brochures 34 Sc 285 (1925) Occupation and Health, Encyclopedia of Hygiene, Pathology and Social Welfare 23. Jones Arch. Dermatol. Syphilol. j$3; 1022-1034 (1936) Air Acneform Derraatergoses 24. Jones J. Ind. Hygiene and Toxicology 23; 290-312 (1941) The Etiology of Acne with Special Reference to Acne of Occupational Origin -4- OENP 002370 737118 The Physiological Hazards of Pyranol Components 56TP423 25. Mayors N.Y. State Dept, of Labor Ind. Bull. Jan. (1942) 26. Mayers & Silverburg N.Y. State Dept, of Labor Ind. Bull. JJ; Nos. 8 & 9 (1938) Skin Conditions Resulting Prom Exposure to Certain Chlorinated Hydrocarbons 27. Mayers & Silverburg J. Ind. Hygiene & Toxicology 20; 244 (1938) Dermatoses from Chlorinated Hydrocarbons 28. Meigs, Albom & Kartin J. Am. Med. Assoc. 154; 1417-1418 (1954) Chloracne from Unusual Exposure to Arochlor 29. Patty, F. A. Industrial Hygiene and Toxicology, Vol 2, p, 1064 Interscience, N.Y. (1949) r 30. Peck J. Am. Med. Assoc. 1 2 5 ; 190 (1944) - 31. Pensky & Grad Arch Dermatol & Syphllol. 4 8 ; 251 (1943) 32. Riley Industrial Bulletin 22; 80 (1943) Hazards in IndustriaT"\Jse of Chlorinated Naphthalene and Diphenyl 33. Rosanova G.E. Main Library Translation # M-2378 Toxicology of Certain Chlorinated Hydrocarbons of the Aromatic Series 34. Sax Handbook of Dangerous Materials p. 92 Reinhold, N.Y. (1951) 35. Schwartz Am. J. Public Health 26; 586 (1936) Dermatitis from Synthetic Resins 36. Schwartz U.S. Public Health Reports 57; 1747-1752 (1943) 37. Sc hwartz J. Am. Med. Assoc. 122 ; 158 (1943) An Outbreak of Halowax Acne (Cable RaBh) Among Electricians -5- GENP 002371 737119 y The Physiological Hazards of Pyranol Components 56TP423 38. Schwartz Sc Beck U.S_. Public Health Reports B9; 546 (1944) The Patch Test In Contact Dermatitis 39. Schwartz Occupational Diseases of the Skin p. 60 Lea Sc Peblger, N.Y. 2nd e d . (1947) 40. Sulzberger N.Y. State J. Medicine 34; 894 (1934) 41. Von Wedel Rubber Age (N.Y.) 53; 419-426 (1943) Toxic Effects Resulting from Exposure to Chlorinated Naphthalenes and Phenyls 42. White The Dermatergoses Hoeber, Inc. N.Y. 4th e d . (1925) r 43. Yaglov, Sands Sc Drinker * J. Ind. Hygiene Sc Toxicology 20; 401-418 (1938) Ventilation o f ,Wire Impregnating Tanks Using Chlorinated Hydrocarbons GENP 002372 -6- 737120 l i m i a m o <! V UjTATE IN SEQUENCE: 'x 1. HEADING INFORMATION 2. NAMES OF. ADDRESSEES 3. n a m e s o f c a r b o n e e s ' IMMEDIATE ACTION NEEDED REPQRT O N CALL CUSl3>AERname V cnrantate / S 'WESTINGHOUSE ELF.GTOTn 0ATERECEIVED BLOOMINGTON, IND. > OATEOf CAU 4/20/70 DATETYPED CUSTOMER MAILING LIST C H A N G E S '- SERVICE CENTER USE ONLY N A M E A N D TITLE "PUT _2N_ MAG CATEGORY COOES REPORT CAPTIONS: 1. OBJECTIVE 2. PERSONS CONTACTED 3. RESULTS 4. ACTION REQUIRED / R E G IO N EASTERN SERVICECENTER CINCINNATI SALESMAN R. GRAHAM r r D. A, Olson - S t . Lq u 1r _ W. B. Papageorge - St. Louis PERSONNEL CONTACTED;__ Don McClain - Manager, EnglnArcing George Mercer - Capacitor Design Engineer ______________________ Ken Tyson - Buyer ..-Purchasing-- Dept-.------ _____ Presented contract per Purchasing request fnr earne-.-- ------------ _____ Discussed rebate situation and ohtalned_cnnfi rmatlon -from P.O-.__ Benignus re same and have since confirmed via telephone to Ken Tyson. In meantime. Ken learned of de tails.from Kelly .__ _____________________ _____ Purchasing currently considering.purchase nf milk--trunk- fnr material to be hauled to Findett. Recommended that they contact Farmers Co-op in Indiana area for surplus trunfta.___ These, units-- shouLdcost approximately $1.00/gal. Kelly and Tyson unaware of April 21 meeting. Learned about it at the last minute. This type of situation^ ahould -he^a-vnl.ded-- and--it^waamy understanding at our January meeting that such customer presentations in St. Louis would be arranged through the_fleld^---- Had-we-set-- thla up, Purchasing would have seen that someone from Bloomington had attended this meeting.________________________________________________________________ _____ In future, salesman will-plan to arrangerall-suck-meeilngs-- at-----Westinghouse unless there has been a change in how we formerly agreed to _do_t_hls_A______________________________________________________________________ __________DuP.ont_no.w_aupplying -polypropyl ene_film_to-Westinghouse^-- Additional! using binding straps for power factor capacitors made of polypropylene ____ tape___________________________________________________________________________ Westinghouse statea_that _General-Elec trie-uses -,045-and-- ^060 polypropylene film in their capacitor designs. --- Don McClain states that he has one of the first Westinghouse A,,oclor .capacitors_il93^)-.in-his laboratory. -He is agreeable -to Monsanto- r ----reference in a Monsanto magazine article. This capacitor is a 2400 volt, S - 331 REV. 12/68'. P L A IN T IF F 'S 1|! U tS 5 I 1 1 900064 ' ALL KCrWM -- Wftvnii. .........--- ---- DICTATE: JA CUSTOMER NAME DATE O f C A U .. HEADING INFORMATION Z NAMES OF ADDRESSEES AND CARBONEES ORT: IMMEDIATE ACTION REQUIRED 2. PERSONS CONTACTED 3. OBJECTIVE 4. RESULTS 5. FURTHER ACTION REQUIRED ' WESTINGHOUSE ELECTRIC cirr a n d state _ 4/29/70 CHANGE REQUIRED CAU. UNITS BLO O M IN G T O N . IN D . CONTACT DATA AND MAILING LIST CHANGES -DISTR CT OFFIC E USE ONLY N A M E A N D TITLE P O T Ta k e ON OFF MP MAG. CATEGORY COOES -2- TO CC Electrical industry growth now stocftmft doubling every 8 years according to McClain. He states that for every KVA generation, have to add 1/2 KVar capacitants. Engineering would require following characteristics from any new imprgnant to replace Aroclor: ^ 1. High corona extension voltage almost equal to starting voltage 2. High dielectric constant to shift stress to film and off of fluid (Aroclor higher DK than polypropylene film; Aroclor DK, 5.0 and polypropylene DK, 2.4). 3 Requires UhdaxnxtiHxAx Underwriter laboratory listing as being fire-resistant Westinghouse Engineering states that silicones offer some attractive advantages, such as wide temperature range, good corona characteristics, and doesn't attack polypropylene film or Jack up the power factor; however, it does have a lower dielectric constant than Aroclor and the price is prohibitive. Of Interest is fact that Westinghouse polypropylene film designs use Aroclor as follows: 100 Kvar - 24 lbs. Aroclor; 150 Kvar - 3o lbs. Aroclor. When asked about a Dot higher dielectric constant imprgnant, McClain responded that if a film could be developed with losses of 1/2 watt or lower and a dielectric constant of 3 to 4 instead of 2, then a fluid with a dielectric constant of 10 to 12 may be of interest (such a fluid would throw more stress on film). In addition to require ments mentioned above, one additionally must consider how such a fluid would respond over a wide temperature range. Metallized film capacitors were discussed and Westinghouse Engineering feels that metallized film processes,as we know them today, are too expensive for manufacture of power factor capacitors. DISTRICT OFFICE SO S I (REV. 7/66} SALESMAN \ - CENTRAI OFHC COPY 1 159|DATE RECO. I DATE TYPED 900065 cx-wia rEt 1. HEADING INFORMATION 2. NAMES OF ADDRESSEES AND CARBONEES "ORT: IMMEDIATE ACTION REQUIRED 2. PERSONS CONTACTED 3. OBJECTIVE 4. RESULTS 5. FURTHER ACTION REQUIRED c u si m e . N A M i WESTINGHOUSE ELECTRIC _____________BLOOMINGTON, IND. CITY A N O STATI DATE OF CAU 4/29/70 CHANGE .EQUI.ES C A U UNITI CONTACT DATA AND MAILING LIST CHANGES - DISTRICT OFFICE USE ONLY n a m e A N D title ~ f u t 7 7T ON OFF mp MAC. CATEGORY COOES -3 - TO CC However, the losses of this type system are much less becais e removing paper and Aroclor (here Is where losses occur). However, unless economics of the metallized film process change, It Is out as far aa Westinghouse Is concerned. Metallized film currently priced at $4.00-20.00/lb. and machines for capacitor manufacture are expensive. If metallized film is much over twice the cost of -- the Aroclor-filra system and unless a the metallized film has some super qualities, then economics dictate polypropylene film in power factor units. Additiomlly, metallized film winding procedures are slow, low volume operations and it doesn't appear that significant tonnage can be developed which would lower cost or cause machine manufacturers to design more rapid handling and processing equipment. Presently, there is a large volume of scrap with metallized film. Attn. P. G. Benlgnus; Westinghouse has raised the question as ,fWhat do we tell our customers?1' re disposal of failed capacitors and Aroolor. We must come up with some VXy type of response for our customers. Have been asked this question* at almost every account. DISTRICT O FFICE M i l (REV. 2/66) SALESMAN 1 - CENTRAL OFFICE COPY DATE RECO. AI TYPED 11 900066 EXHIBIT NO./ AumeencTBk YES NO NO M OW tfM E NOMML M M N EB M IM IK YE8 NO NO KNOWLEDGE NinW WiHwfirriMna n>P--PITfnlMnim11VrIr1rr YES NO tT ira u ra OTHBtWtSE: YES NO NO KNOWLEDGE B0IBUL ELECTRIC WESTMGHOUSE MONSANTO # . "5 Beer p. a. B m o N u s D. A. OLSON A u g u st 14, 1970 Dr Lyon Kandelcor) Advisory Scientist Research & Development Center Vfestlnghouse Electric Corporation Pittsburgh, Pennsylvania 15235 Dear Dr Kandalcortu Attached are copies or (l) activate sludge bio degradation test method and (2) analytical pro cedures for the determination of polychlorinated biphenyls In water, sediment, biological specimens and gases I promised this information during our interesting meeting at your Research Center on July 23 I hope the delay has not inconvenienced you a n d , if Z can be of further service, please let me know. Sincerely, ms Attachments ccs 0. R. Graham Monsanto Company V. B. Papageorge Manager Environmental Control NEV 003391 703129 i ** i CrL;:a< N15a5tiEoansatl 4E4letchtSrfteraee!tManNuefawctYuorrakr,aNA.aYs.o1d0fit1i7en212-682-1500 MINUTES : COMMITTEE ON USE AND DISPOSAL OF ASKAREL; OF THE BOARD OF DIRECTORS; OF THE POWER EQUIP-* MENT DIVISION ; PLACE OF MEETING: O'HARE INN , CHICAGO, ILL. DATE AND TIMS: ! * MEMBERS PRESENT; t Da E. Allen J 7* Ku2ela Ea La Rftab W. C. Reinhardt J- C. Kissinger H. R* Rowe TUESDAY, FEBRUARY 23, 1971 10:30 A.M. - 3:45 P.M. Allis-Chalmers Manufacturing Co. Sangamo Electric Company General Electric Company Molon Electric Company Westinghouse Electric Corp. McGraw Edison Power Systems Div. MEMBERS ABSENT: NONE OTHERS PRESENT: P. G* Benignus Aa O. Mauser H, B. Papageorge A. L. Rickley A. M. Salazar Monsanto Company Electric Utilities Company Monsanto Company Doble Engineering Co. NEMA Staff PRESIDING OFFICER: W C. Reinhardt, Chairman I. APPROVAL OF PREVIOUS MINUTES ' The minutes of the August 20, 1970 meeting not being available, as yet, no previous minutes were submitted for approval. II. PURPOSE OF THIS MEETING The Committee noted that the purpose of this meeting is to review developments since the August 20, 1970 meeting and develop recommendations to ANSI on a suggested program of action, including priorities for various activities, list of organiza tions to be invited to participate, etc. The Secretary's letter of Frebuary 10, 1971 calling this meeting and outlining the agenda, also contained a chronoligical list of steps taken, so far,.-am|f a master list of organizations that might have interest in th|rs problem. A copy of the letter is attached as EXHIBIT "A". >> 200279 i) Messrs* P. G. Beniqnus and W. B. Papageorge of Monsanto and A. 0. Hauser, whose company manufactures capacitors and A. L. Rickley, who is associated with a well known electrical in sulation consulting firm, were invited to participate in the discussions. III. REVIEW OP DEVELOPMENTS SINCE THE AUGUST 20, 1970 M E E T I N G _______ Members of the Committee presented reports on develop ments, as outlined in the Chairman's working agenda, as follows: A. The PCB problem in brief, including the status of the Massachusetts House Bill No. 3635 - - - - W. B. Papageorge NOTE A copy of the Bill is at tached as EXHIBIT "B" B. Report on developments within IEC,'IEEE and ASTM, on the askarel problem - - - - - E. L. Raab NOTES Mr. Raab distributed copies of written reports, which are attached as follows: 1. Letter providing the Chair man of IEC WG/02 on askarels with information on US acti vity, (EXHIBIT "C"). 2. Report on October, 1970 meetings of IEC No. 10 on Liquid and Gaseous Dielectrics and Subcommittee 10B on In sulating Liquids Other than Hydrocarbon Oils. Messrs. .Raab and Benignus, who. are the US Delegates, attended these meetings, (EXHIBIT "D"). 3. ^ Lecture given by Me. P. Jay of the Prodelac Company, a foreign producer, at a university in Sweden, in 1970. This information was distri buted at the October IEC meet-- ings, by the Delegate from France, (EXHIBIT "E"). Comm, on Dis. of Askarel - Div. 8 - 5- February 23, 1971 mSMaoBMaai ijsgBsgaress wm '.- npc 00008521 200280 I' ) 4. Appropriate excerpt from minutes of the April 15, 1970 meeting of the Insulating Fluids Subcommittee of the IEEE Trans formers Committee, (EXHIBIT "F"). 5. Excerpt on further dis cussion from the minutes of the October 28, 1970 meeting of the parent IEEE Transformers Com mittee, (EXHIBIT "G"). fi. Appropriate excerpt from the minutes of the September 11, 1970 meeting of Subcommittee B, of A5TM Committee D27 on Insulating . Fluids, (EXHIBIT "H"). C. Which PCB1s remain in use in the electrical indus try? - - - - - P. G. Benignus. D. Status of disposal facilities - - - - W . B. Papageorge. Mr. Papageorge commented on the above* as follows: 1 Monsanto facilities for bulk fluids. 2. "Monsanto facilities for moderately Sized solid materials. 3. Rollins-Purle/lnc. facilities .for bulk fluids. 4. Kemtrol Pollution Services, Inc. facilities for bulk fluids. (Still under investigation by Monsanto). 5. Landfills The value, of landfills depends on the type of soil conditions, distance from waters, etc. Preli minary investigations with Officials of some states indicate a negative.reaction to state sanctions. States usually defer to locVal levels on t h e s e ' matters. IV. FORMATION OF THE ANSI COMMITTEE After some further discussion', the Committee approved the following; A. The holding of an ANSI conference, as soon after re ceiving ANSI formal approval as is possible. B. Mr. W. B. Papageorge should act.as discussion leader for the Conference and'should present the backgrounds} leading to Monsanto's and NEMA's sponsorship of the formation of an ANSI Committee. As was the case at Comm, oh Dis. of Askarel - Div. 8 - 6- February J.*- -1971 NPC00008522 200281 today's meeting, others involved in the discussion, so far, should be called upon to assist, as is considered to be appropriate* The following objectives, developed at today's meeting, should also be proposed: OBJECTIVES In addition to developing procedures and guides for safe use, maintenance and disposal of askarel and askarel soaked materials used in electrical equipment, it shall be the objectives of the ANSI Committee to: 1. Serve as a source for technical information and advice for Federal, State and local authorities and for the information of all others concerned. 2. Encourage the development of suitable disposal facilities and maintain a list of their capabilities and locations, for the information of all concerned. 3. Serve as the advisory group for US participation in CEE, IEC, COPANT, SEGRA and other international organizations. As appropriate during the presentation, or during the following, discussion, Mr. Papageorge should propose that the following Subcommittees should be considered to develop specific proposals for Committee action: 1. Procedures and guides for disposal of askarel and askarel soaked materials. 2. Procedures and guides for safe use, care and main tenance of askarel. 3. National and international communications.. At an appropriate time during the meeting, the Secre tary should recommend that a small Steering Committee, comprised of the Chairman of the Committee and the Chair men of the ESI, IEEE, ASTM andN E M A Delegations. The purpose of the Steering Committee is to appoint the above Subcommittees and, in general, assist the Chairman in the performance of his other responsibilities as Chairman of the ANSI Committee. `* C. The letters inviting interested organizations to .participate should briefly comment on the need for th A ANSI Committee and indicate that a Conference is being f called by a certain date, to review the matter in more I',' detail and formally establish the Committee and any needed Subcommittees. An attachment to the letter should cover the sponsors, the scope aDproved by ANSI and a list of Organizations being invited to oarticipate.; Comm- on Dis. of Askarel - Div. 8 -7- February 23, 1971 NPC00008523 200282 :-T\ ii1 V 4 D. In addition to any other Organizations represented on the ANSI Electrical and Electronics Technical Ad visory Board (EETAB) that may express interest in this activity, the following Organizations should be invited to attend the Conference: American Public Power Association American Society for Testing and Materials Association of American Railroads Association of Edison Illuminating Companies Automobile Manufacturers Association Inc. Certified Ballast-Manufacturers Association Doble Engineering Co. Edison Electric Institute Government Groups Atomic Energy commission Corps of Engineers Department of Health Education and Welfare - Food and Drug Administration Department of Interior Environmental Protection Agency General Services Administration * National Bureau of Standards Rural Electrification Administration Tennessee Valley Authority i International Association for Pollution Control Institute of Electrical and Electronic Engineers Kntrol Pullution Services Manufacturing Chemists Association Monsanto Company National Electrical-Manufacturers Association National Fire Protection Association Rollins-Purle Inc. Underwriters' Laboratories Inc. Water Pollution Control Federation V. TIME AND PLACE OF THE NEXT MEETING. Left to the call of the Chair. VI. ADJOURNMENT There being no further business before the Committee, the meeting was adjourned at 3:45 P.M. Luncheon was served during the meeting and there was, therefore, no recess for that purpose. AMS:dk ATTS: EXHIBITS "A" - "H" APPROVED BY COUNSEL: A.,M. Salazar, Executive Secretary Power Equipment Division Comm, on Dis. of Askarel - Div. 8 1 -8- February 23, 1971 ^OTC00008524 200283 EXHIBIT NO. AUTHEVTICATB): YES NO NO K M M tB S E OMUL N U M B * itm in YES NO NO KNOWLEDGE n o suotcson m m nm m tnt: YES NO STIPOUTB) OTHBtWISE: YES NO NO KNOWLEDGE GENERAL ELECTRIC WESTWBH0U8E MONSANTO # BLOOMINGTON WORKS TO: J. Brittain, Mgr. Engr. R. Thompson, Manager Materials K. Tison, Buyer Purchasing J, Howells, Cap- Engr. Dr. T.W. Dakin, R Sc D Lab. From Materials Department WIN . Date : November 4, 1970 subject: Meeting with Monsanto Chemical Co Messrs. Ken Tison, Jeff Howells, Keith Kelly, Don McClain,together with Dr. T.W. Dakin of R & D Labs attended a meet ing with Monsanto Chemical Co., in St. Louis, October 30. Monsanto personnel included Messrs. Baber, Benignus, Bergen, Davis, Gossage, Graham, Munch, Papageorge, and Bryant. 1. Status of work on polychlorinated biphenyls (PCB's), including capacitor grade aroclor 1242, as potential environmental contaminants, was reviewed. Monsanto is now involved in at least 2 lawsuits. More than 125 different laboratories have Joined in the in vestigation of the effects of P.C.B.'s pn the en vironment. P.C.B.'s appear to have effects similar to DDT, but in reduced magnitude and rate. 2. Monsanto response to the situation has been A. Controlled usage of aroclors (1) Where loss to environment appears certain, sale has been stopped. (Usage as hydraulic fluid, plasticizers, etc. has been stopped). (2) Where usage may be contained and controlled (as in capacitors and transformers), supply is continuing.3 (continued) (3) Publicity and plant visitations have been used to alert customers and users to problems and to initiate strict control procedures in manufacture and application. -2- (*0 Participation in the ANSI Committee will aid in setting guidelines and publicizing use, application, and disposal of PCB's. B. Provide for Disposal of Scrap Aroclors (1) Incinerator being installed at Sauget, Illinois for disposal of waste fluids, (Cost @ 3^/lb. + freight;.* (2) Other commercial disposal plants investigated: Rollins - Purle Truck Co., is installing first of what may become 100 kiln-type disposal plants. One is installed outside Philadelphia, with others under way at Baton Rouge, Chicago and Cleveland. (3) Studied land-fill disposal. It is their opinion that restrictions will develop that will finally eliminate this means of disposal. (*0 Studying other disposal methods for saturated solids combined with metals (containers, foil, wire, etc.) * Note: It was estimated that cost for "small" incinerator of type developed by John Zink Inc., Tul3a-, Okla., would cost approximately $250,000.00, Installed with gas scrubber, and having a 5,000,000 to 5 *000,000 lb./yr. capability. C. Provide suitable replacement fluid Monsanto indicated, by their heavy commitment, a strong conviction that the problem can be met and askarel production continued on the basis of introduction of a new askarel, "MCS - 1016". Gas chromatograms were introduced comparing the initial and final composition of conventional aroclor 12^2 , treated for 72 hours with sewage sludge* Degradation of mono-, dl-, and trichlorinated biphenyl was evident, but concentrations of higher molecular weight material remained relatively unchanged. The new MCS-1016 has all high modecular weight aroclors (above 12^2 ) removed, and rapid bio- degradability by sludge treatment is to be expected. It is hoped that use of such a non-persistent material would not be considered a serious threat to the en vironment . (continued) Typical comparative analyses were offered: 900542 7 CO 0289 C0riC7rTITRArr,iriT Aroclor 1242 Aroclor 1254 Aroclor 12'!3 Aroclor 1242 Di.chlorinated Biphenyl Mono-Chlorinated " Non-chlorinated " 0^ 18 f. (Balance) TO 'T 12 < .05 r- Kcc-10 1 6 t 0 .1j 4 9.0 (Balance 19 f' +) ( 01 .;'+) . Flash point for the MCS-1016 comperes with Aroclor 1242. ("Fire point" has not yet been defined.) Monsanto has supplied 55 gallon drums for trial by all of their major customers, and expect to recieve reports within 2 to 4 months. They an ticipate favorable results on life tests, and data indicate dielectric properties comparable to Aroclor 1242. Monsanto has ordered a distillation column suit able for mass production of MCS-1016 and expect to be able to make deliveries beginning in July 1971* from the Krummerick plant. Cost of MCS-1016 will be about 2</ to 3^/lb. higher than for Aroclor 1242. Availability of Aroclor 1252 will be continued. 5. In summary, Monsanto plans to do everything in their control to remain a supplier of askarel to the capacitor and transformer industry. Should events force total discontinuance of polychlorinated biphenyls or if competitors begin to offer more pallatable materials, they will have no alternatives to offer. (a) Monsanto has agreed to redefine the 90 day clause in the present contract. Mr. Gossage will write a letter to K. Kelly redefining this clause and assuring supply of 1242 until an adequate substitute is developed. (b) Monsanto has also suggested a meeting between their top management and J. Sterling of Westinghouse. Their intention would be to further assure "W" of Monsanto's intent to remain in the business. The need for this meeting will be explored following satisfactory rewording of the contract. (continued) 900543 (c) Monsanto stated that their costs have increased $.05/#- They plan to announce a price increase effective January 1971 (effective July, 1971 to DAD due to contract). The amount of this price increase has not been determined but it is es timated at about $.02/#. D. McClain Manager Capacitor Engr KK:emc 900544 7C 0291 EXHIBIT NO. AUTHENTICATE*: YES NO NO KM M tBM E N o w m lim o n i icw w re YES NO NO KNOWUDOE no t u * * * oMNw orncm f: YB NO STIEUUTB OTHBWmE: YB NO NO KNOWLEDGE GENERAL ELECTRIC HISTWOHOUSf MONSANTO t . \ : -j i Monsanto A. E. PELTOS- 'LO rt i - -- MONSAITTO INDUSTRIAL CHEM ICALS CO. 8 0 0 N. Lindfctrgh Boulevard St. Louis, M issouri 83108 Phon: 014) 884-1000 February 8, 1972 M r , A. E. Feltosalo, Group V.P. General Electric Company 570 Lexington Avenue Hew York, New York 10022 Dear Sir: We have recently been in communication with you concerning Monsanto's policy to restrict the sale and delivery of poly chlorinated biphenyl (FCBs) products Including those sold under tradenames such as Aroclor, Inerteen , Pyranol , and under the generic term askarel. As you are aware, effective January 15, 1972 Monsanto discon tinued sales and delivery of these products to manufacturers of transformers and capacitors, except those who have entered Into special agreements to Indemnify Monsanto with respect to these products. You have entered Into such an agreement. In the past Monsanto supplied these PCB-containing askarel products to transformer repair shops, and to companies need ing these products for top-up of existing transformers. These sales have now been discontinued. Future Inquiries from these companies owning or desiring to repair a transformer of your manufacture will be referred to you as the source for additional askarel fluids. In the event you desire to supply top-up product to your custom ers or to repair shops, Monsanto Intends to make these products available to your company or to your designee upon receipt of your order. In either case, the sales will be to you and we will Invoice you. If you choose to ship directly from your own stocks to your customers, we will be happy to make available to you all Information we have on proper packaging of these products. Please contact us concerning your Instructions for referral of these customers to you. If you have any questions, or If you GENP 000126 -Page 2 wish to meet with representatives of Monsanto concerning the program Monsanto Intends to follow, please telephone (314) 694-2513 or write directly to Mr, Paul Benignus, Monsanto Company, P. 0, Box 14617 St. Louis, Missouri 63178. We sincerely regret any Inconvenience that this decision may cause you, but it is taken in an effort to continue to make available these products for these Important applications with in the framework of our overall sales policy. Very truly yours, T. L. Gossage Marketing Director Specialty Products Group Ai cc: Mr. Valter A. Schlotterbeck, Corporate Counsel 570 Lexington Avenue Hew York, Hew York 10022 Mr. Edw. L. Raab Transformer Department 100 Woodlawn Avenue Pittsfield, Massachusetts 01201 Mr. James P. Kinney Redmond Circle Rome, Georgia 30161 GENP 000127 734902 EXHIBIT NO. AUTMCimCXre: YB NO NO O NM tSM E wm iML M a n a s ernirr: YE8 NO NO KNOW IO mo qm YB NO ST M JU fB OTHBWIIE YB NO NO KNOWLEDGE IO GENERAL ELECTRIC Hwftf9lT1BwinoinMvUUIfvf* MONSANTO # -J Monsanto rm ty * mi'* i w Iihi Industriai Chsaicals Co. a*TM Deoeaber 17, 1971 U ./ ( C T St Loula cc T O Direttore of Marketing Fisld Sales tirsotor Fleld Salsa Msjnagers Ulstriet Salsa S&rectors COMFlPBfnAL At thsir Board Bastine on Dacenber 9, 1971# Monsanto's Board of Ursotora approvai corporate Monsanto decisioni prsvioujly taJcon aa follava: 1. Terminata all salsa of FCB fluida for uss in haat transfer applioations by f o n a i notics to all eustoasra. 2. Zassdiatsly inplensrt a pian to terminate all salsa of polyohlorinated terphanyls by March 31# 1972 for piaatielzsrs. 3. Salsa of FCB fluida for tranafonasr or capacltor usa ili bs depandant upon tha racalpt of agrosaenta acoaptabla to Monsanto, holding Monsanto haraless fron lagai liability assoclatad ith tha usa of FCBs in treniformeri and capaoitors froai custoasra hoas financial raaponsibllity alesa auoh agreements neaningful in Monsanto'a opinion. Sinos Monsanto Industriai Chsalcals Coopany sella thess producta to Bany key oorporats Monsanto custoaers, a vant you to ba avara of thssa dsciaions and thair iapleaentation so that custonar visiti don't laad to surprisas. Vhat MICC producta ara' involvadt 1 Sosolalty Froducts Businass Oroup lesionai Products Qtoup laat Transfer Fluida: Theimlnol* FR-Lo Taaip Thenainol* FR-0 Ibernino 1* FE-1 900369 300 / r r oob 2 Capacitor Dielectric Fluid: Capacitor 21 Aroclor 1016 Aroclor 1242 Aroclor 1248 Aroclor 1254 Transformer Aekarel Fluid: Inertten 100-42 Inertan 70-30 Inerteen FFO 2. / Plasticizer Business Orouo Fyranol A13B3B Rubber a Process chemicals Division KCd "" Plasticizers Aroolor1221B Aroclor432 Arocloi5442 Aroclor-*%460 Aroclor*6000 Serlas Hontar 3 Santlclsar 301 Samtlclzer 311 Santlclsar 326 Santlclsar 327 Santlclsar 335 Santlclsar 336 Santlclsar 337 KXF 101 What effect will this have on our customers? While everyone wishes these decisions did not have to be taken, and while they will cause some inconvenience to customers, the picture le not ee gloomy as might be supposed. 1* These decisions should not come as a complete surprise to any ouatomer. Ve have been alerting customers by letter periodically since February 1970 ofthe problems associated with PCBe. 2. Ve phased out PCBe from oertain applications (plasticisers, hydraulic fluids and proeass fluids) from mid-1970 to early 1971 3 Ve discontinued eales of FGBs to new heat transfer fluid yateme several months ago* 4. Since August 1971 many existing FOB heat transfer fluid users have effected conversions to non-PCB fluids. (To date over 150 of such systems have converted. We have retained 900 of these conversions for Monsanto with our non-FCB heat transfer fluids Thenslnol 33 and 66.) 300 r\ r s t :c 900370 -3- What help are ws offering oar customereT 1* Haat Transfer Fluids Aa explained In our customer notification letter, ve have assembled an experienced engineering teaa to give help to customers aa they decide on conversions. We alao offer the aervlcea of a high temperature incinerator to diapoae of uaed PCB heat tranafer fluids, and will accept return of originally paokaged PCS fluids* 2. Dielectrics The decision an dielectric fluids will probably not affect aoat ef you since transformer and capacitor manufacturers are a reasonably amall and separate group. We emphasize that we are not discontinuing dielectric PCBs alnce their usage la inportant to the national interest. Monsanto la conditioning ouch aalea, however, on obtaining certain financial safeguards, while acting responsibly In the interest of the electrical industry, its consumers, and thus ths country. Vs are also actlvs in ANSI Cl07# a commlttse set up to devslop guidalines and policies for handling PCB in the electrical industry. 3. Plasticisers Monsanto la working to davslop a list of suggssted re placement products and suppliers to bs uaad as a guide in replacing our Aroclor* products in existing formula tions Questions from customers Customers are going to aek guestions about thsss decisions. Wo would suggost that your salsamen not try to answer these questions but to refer the customer to St. Loals: Host Transfer Fluids Telephone* (314) 694-2314 Nail* Cumming Patn Monsanto Company P. 0. Box 14617 St. Louie, Missouri 63176 Dielectrics T. L. Ooseage P. 0. Benignas C. Paten 300 2607 900371 - 4- Plasticisers V. 8. Clark (314) 694-2516 Direct inquiries fro cuatoaara to Monsanto dlatrlct offlooa should bo handled in the same way. If you wlah to paaa cm quaatIona or atataaenta fro cuatoaara, please foal froa to do ao through tha aaaa channels. Kay Monsanto cuatoaara y Attach#* you will find a list of koy oorporata Monsanto ouatooara who will ba given special notification of Monsanto's daclslone. Separate lists ara siwan for Boat Transfar Fluid* and chlorinated terphenyl plaatlolsera. Mo H a t la given for dielectric cuatoa ara since discontinuation of aalea will not result unless our tana ar# rejected. Cuatoaara not Included in these lists will receive tha fomal notification letters by all (eoplea attached). Kay cuatoaara will ba notified as follows: Beat transfer 1 By ail: Fonal latter plus cover letter indicating that conversions are already underway or (in the case of ultl-plant locations) have actually taken place at some locations. 2. By phone: Foraal latter will than ba ailed. 3. By Phone Plus personal visit (latter hand-carried); in this category we nay ask assistance fro Regional Flea Presidenta or Dlreotora of Sales/Marketing to introduce ua to tha "right" people. Tha personnel primarily involved fro Specialty Products Group in notifying key customers will b| H. ,8. Bergen Jr. - Business Group Director T. L. Gostage - Director of Marketing M. T. Johnson - Field Salas Manager C. Fata i - Product Manager Plasticisers 1. Bv allt Formal notification by lottor addressed to the Office of tho President to bo aallod on 13/31/71. 2. Br Bboni Ir r n i o u l H M i i r i u d h Ii h u during ' prtod froa 12/20/71 to 1^31/71. A l a *111 cov.r .11 laportwt aeoeunta. 300 2658 900372 -5- 3 Faraona! calli: By ragionai menagers and salesaen rroa 12/20/71 to 1^33/71 with follow-up vialta by St. Louis management peraorniti from 1/3/72 to 3/1A/72 at key aecouota aa appropriata. i Cuatomer Motlflcatlon 0. Sm Domaatlc Cutt o t ra / Heat Transfer Fluida: Decamber 15-20 1971 ;Flaetlolxer Aroclor: Deoember 20-31 1971 Canada notification 111 folio tho V. 3. pattern aa quickly tharoaftar aa practical. International lotion 111 be taken through World Area Marketing management In the first quarter of 2972. It la very Important that you do not make thla subject a deliberate topic of eonveraatlon In your dealing with your customers. Flaaaa do not preeopt the bualneaa groups In volved in notifying customers. We have alerted you ao that you are not caught unaware should delicate negotiations con cerning your products be going on. We vould aak in return that you treat thla information in confidence ao that we can Implement these corporate doolalona aa affectively aa possible for both Monsanto and our euatomara. Competition Bo particularly carehil in ho you handle thla information at tho follovlng accountsi Do Bo Corning All oll ooMpaaioa Do 1s Monsanto*s major compotltor in aynthetic hoat transfer fluid Thay have nover had firo-f alatant fluida llka Therminol FM fluid Hoevar, thay will bo out to obtaln f fl 11a of fluid vlth Davthani againat our Themlnol 66 If tha cueteuer oper- ataa at tamporaturoa belo 550*- or ao ha may eloot to go to lovor ooat fluid auch aa Therminol 55 In theso oaaeo our oempetltlon 111 bo petroleum-baaed fraotlona from Bumbla Mobil, fholl oto. 300 ^ i* O V' w 900373 -6- finally, nay we aalc that this neno be furnished only to those with a need to know. C. Paton Product Manager E&electrlo, Heat Transfer ft . Prooess fluids Specialty Products Business Oroup V. S. Clark Product Supervisor Plastlolzer Business Oroup toe. (K. T. fluid Utter) (Plasticiser Aroolor Utter) (Key H. ?. fluid Accounts) [Key Plasticiser Aroclor Acceunts) 300 2660 900374 EXHIBITH0.y5 6 jfcy AumamcxTHfc YES to no ctowud Notmu.N N M cmmt m NO NO KNOWIEMC KO SUSPICIONOfflSTMDmCITT: YEN NO lTWUTB) OTHERWISE: YD NO NO KNOWLEDGE BBtEIUL ELECTRIC WESTMHOUSE MONSANTO # * ' . L COMMENTS BY THE GENERAL ELECTRIC COMPANY ON "PROPOSED TOXIC POLLUTANT EFFLUENT STANDARDS FOR POLYCHLORINATED BIPHENYLS" _______ (41 FR 30468, July 23. 1976________ INTRODUCTION The General Electric Company is a major manufacturer of electrical capacitors and transformers whose dielectric fluids contain polychlorinated biphenyls (PCBs). Consequently,-we have followed diligently the develop ment of the regulatory structure for PCBs, and we submit the following comnents' regarding the proposed toxic pollutant effluent standards for PCBs published in the Federal Register on July 23, 1976 (41 FR 30468). We hope that our comments will assist the Environmental Protection Agency in promulgating effluent standards for polychlorinated biphenyls (PCBs) that are technically sound, clear and equitable in application, and in compliance with the terms of the Federal Water Pollution Control Act. Although these comments are directed specifically to the p r o p o s e d standards for PCBs, they are also relevant to two related issues: (1) th e establishment of effluent limitations on PCBs for dischargers not c o v e r e d by the proposed standards, and (2) the development of effluent l i m i t a t i o n s and guidelines for the 65 chemicals and chemical classes covered by the same consent agreement* that established a deadline for the proposal o f these PCB effluent standards. * Approved on June 9 by the U. S. District Court for the District of Columbia, NRDC v. Train, 8 ERC 2120. P LA IN T IFFS EXHIBIT IZ ] 776249 GENP 007846 -4- a) Definition of PCBs fSec, 129.4(f)! Does Not Differentiate Among Isomers and Homologs There is neither chemical nor biological justification for consider ing all PCB isomers and homologs to be equivalent in respect to the criteria for toxicity used by EPA in selecting pollutants for the list of toxic pollutants (38 FR 24342). An interdisciplinary group of life scientists on the staff of GE's Corporate Research and Development Center recently conducted an exhaustive analysis of the available toxicological and environmental literature on PCBs. This analysis disclosed substantial evidence of large differences in toxicity, bioaccumulation, and environmental persistence among different commercial grades of PCBs and among different test species. For example, large ranges of toxicity have been seen in animal studies that focussed on the nature of the effect produced by similar doses of different Aroclors, including studies conducted by the same group of workers In the same laboratory. Thus, the same group (Kimbrough, Burse et al) that reported that Aroclor 1254 or 1250 in rats could provoke a progression of hepatic changes, beginning with hypertrophy and pyperplasia, and going on to adenofibrosis, neoplastic nodules, and carcinomas (cited under "(4) Carcinogenesis" on p. 30472) also reported parallel studies indicating that none of these toxic manifestations occurred with Aroclor 1242 or 1015. Similarly, the initial liver response to Aroclors 1254 and 1260, i.e. marked induction of drug-metabolozing enzymes, was absent when Aroclor 1016 was used. The extensive Japanese investigations of the Yusho poisoning episode, particularly the more recent findings summarized by Dr. Kuratsune at the t4' 775250 G E N P 007847 -5- National Conference on PCBs in November 1975, have disclosed the origin of the huge ranges in toxicity exhibited by different grades and even different specimens of the same grade of PCB. The actual'toxic agents in the PCBs have been identified as the polychlorodibenzofurans (PCDFs). Kuratsune showed that it was the PCDFs, not the PCBs, that were chronically accumulated in humans and that it was the levels of PCDF, not those of PCB, that correlated with toxic manifestations in man. It is remarkable that the very first clinical report on PCB poisoning in humans, that of Jones and Alden in 1936, clearly recognized that the toxic action had to come from an impurity; however, the impurity was not actually identified as PCDF until -more than 35 years later. Clear-cut correlations of toxicity with PCDF level were reported for chickens by Vos et al in 1970-72. We reviewed all relevant data in the scientific literature describing chronic PCB toxicity studies on mammals. We then constructed Table I, in which columns 3, 5, 6, and 7 present our best quantitative estimates or calculations, from these published data, of PCDF concentrations in the PCBs used, of "maximum no-effect" concentrations of PCB in.food, of food intake rates, and of "maximum no-effect" dose rates. For comparison, we have included Kuratsune1s data on humans. Among the animal studies, we note in particular that the lowest "maximum no-effect" concentrations and "maximum no-effect" dose rates were associated with the highest estimated PCDF con centrations (>> 1 ppm PCDF in PCB). Furthermore, the "no-effect" numbers for hepatic effects in rats are significantly higher for Aroclor 1016 (w h ic h was estimated to have no PCDF) than for the higher chlorinated Aroclors ( w h i c h were estimated to have about 1 ppm PCDF in the PCB used.) G E N P 007848 7?62Si 0 ra oO (1) -"d 00 . 4^ Test VO abject TABLE I. (2) PCB/PCDF Tested CALCULATION OF MAXIMUM NO-EFFECT DOSE RATE FOR PCB/PCDF COMPOSITIONS (3) Ppm PCDF in PCB (Estimated) (4) Major Toxic Effect (53 Max. noeffect, ppm PCB in food (6) Intake rate, kg.food/kg. body w t .-day (7) Maximum No-effect dose rate, mg.PCB/kg. body wt.-day ir.an inkey tdult) sr.key Infant) Kaneclor-400 ,** (heat aged) Aroclor-1248 (shelf aged) Aroclor-1248 * 10,000a >> ln ^lb Dermal Dermal Dermal (0.5g.)c <2.5d >300. e ^3. o o.oo u*.* (n.000 day)* ''0.007 ' <0.1 >12. V V H* O Lr.k at i. Aroclor-1254 (metabolized) Aroclor-1254 Aroclcr-1260 Aroclor-1254 Aroclor-1242 Arclor-1260 Aroclor-1254 Aroclcr-1242 Aroclcr-1016 :K *1 : ,b ''Vo'1lnra <Vlb ob Hepatic ii Hepatic ii ii Hepatic) " " )f ii <0.6f <5. g h <100. >100. i *'101 m 5fiooj 0.05 0.03 n : 0.05 n <0.03 <0.25 ^0.3 <3. >3. *0.5 <5. vjree s , Kuratsune, 1976. b. Bowes et al., 1975. c. Kuratsune, 1972. d. Barsotti et al-, 1975. . Abrahanson and Allen, 1973. f. Platanow and Karsted 1973. g. Ringer et al., 1972. h. Keplinger : al., 1971; Calandra, 1975; as interpreted by FDA, 1973. i. Keplinger et al., 1971; Calandra, >75; Kimbrough et ai., 1972; as interpreted by FDA 1973. j. Burse et al., i974. k. Assumption of /i, 13 73. m; Ax and Hansen, 1975. n. Estimated from progressive increases in toxicity observed n going from early to late (Ref.d) tests, o. Estimated from use of liver, known to concentrate CD? relative to ?CB (Ref.a) as mink food. * This figure is the maximum no-effect dose in grains of PCB. * This is FDA's assumption of number of days over which dose is accumulated by humans. -7- Even more significant was the demonstration by the Japanese group that the particular PCDF's chronically and specifically accumulated by the human liver were the penta- and hexachlorinated homologs. Since the PCDF's were found to arise from the PCBs upon aging, particularly under conditions favoring thermal oxidation of the PCB's, it is evident that the source of the chronically toxic penta- and hexachloro PCDF's must be the corresponding penta- and hexachloro PCSs. In this connection, it is significant that Aroclor 1016, which i s essentially the only Aroclor used by the capcitor industry since 1971, wasspecifically designed to contain virtually none of these more e n v i r o n m e n t a l l y persistent and potentially toxic penta- and hexachloro homologs. The w i d e l y quoted Monsanto prospectus indicates a total content of these " h i g h e r homo!eg as 1.1%; however, the product quality control limit was set at 0.4%; and the actual material shipped to GE during the past two years has u s u a l l y contained less than 0.12. This contrasts with the 100-fold higher l e v e l of "higher homologs" found in Aroclor 1242 (typically, around '9%) o r the 1000-fold higher level in 1254 or 1260 (^TOX). Thus, there i s a c l e a r chemical basis for the strikingly lower toxicity levels actually o b s e r v e d in mammals whose diet contained Aroclor 1016. Toxicity in fish probably results from a general anesthetic e f f e c t of the PCBs themselves rather than PCDF activity in most cases; even s o , there are significant differences in chronic toxicity among the v a r i o u s product grades, which appear only partly relatable to differences in bioaccumulation. Reported values for bioaccumulation of Aroclor 1016 in various species and life stages of fish run from 2,500 to 55,000, ar.d are usually 10-20,000. Bioaccumulation of Aroclor 1254 is typically 2-5 776253 G E N P 007850 -8- fold larger. .In continuous flov/ chronic toxicity tests, reported LC 50 values for various species and life stages of fish cover the range 11-81 ppb for Aroclor 1016 (Hansen, Parrish and Forester, 1974) and about 1-5 ppb for Aroclor 1254 (Nebeker and Puglisi, 1974). There is one report of "significant mortality" in sheepshead minnow fry at 0.1 ppb of Aroclor 1254; the same authors also reported, however, that 100-fold higher levels were required to produce a comparable effect with Aroclor 1016. (Nebeker and Defoe, 1974). In summary, all available evidence indicates that Aroclor 1016 is 10- to 100-fold less hazardous than the higher PCBs to fish; 100- to 1000fold less hazardous upon direct exposure to animals, and probably 500- to 5000-fold less hazardous if exposed via the fish bioaccumulation - fish consumption route. Inasmuch as there is no analytical problem in distinguish ing among the different degrees of chlorination present in a given PCB sample it is scientifically.justified and practically feasible to establish separate ambient water criteria for PCBs with degrees of chlorination 4 Cl/biphenyl (which represent 65% of current U.S. production) and for PCBs with degrees of chlorination 5- 5 Cl/biphenyl (which are the homologs most persistent in the environment and potentially the most toxic). We believe that separate criteria for the higher and lower PCBs would be in the public interest for three reasons. o The development of Aroclor 1016 by Monsanto,and its subsequent use by capacitor manufacturers beginning in 1971, represented a major and technically successful effort by industry to reduce to a negligible level the most environmentally persistent components of the dielectric fluid used in capacitors. Failure of the proposed rules to give any 776254 G E N P 007851 -9 recognition to the differences between the toxicity and persistence of different commercial grades of PCBs would certainly discourage other manufacturers from attempting to remove objectionable impurities from other products in the future. o A regulation that attempts to discourage the use of one substance on the basis of a gross exaggeration of its toxicity increases the likeli hood that it will be replaced by a substitute that may in fact be environmentally less desirable than the original substance. o Although the proposed effluent standards apply only to manufacturers of PCBs, capacitors, and transformers, the ambient water criterion could be used as a basis for regulating other dischargers, such as paper mills, .whose effluents contain Aroclor 1242 because they recycle paper containing that material. A water quality criterion that recognized the more benign nature of Arcelor 1242 compared to higher chlorinated PCBs, which were not used in paper products, would protect aquatic life and still enable the public to enjoy the environmental benefits of recycled paper, b) Derivation of Proposed Ambient Water Criterion The criteria that are mast defensible, and that best serve the p u b l i c interest, are those that follow in the most logical and straightforward manne r from the demonstrated scientific facts of the situation. The establishmenc of such* criteria requires (1) a thorough, critical evaluation of the a v a i l a b l e toxicological data, in order to separate the solid, self-consistent f a c t s from the anomalies, extrapolations, and inferences, and (2) a clear statement of the safety factors used in proceeding from any "maximum no-effect d o s e " thereby established to the proposed criterion. If such safety factors have been generated ad hoc, then the rationale behind them should be indicated. 776255 GENP 007852 -10- The preamble to the proposed standards contains a series of categorical statements relating to the reported toxicity, carcinogenesis, and human health effects of PCBs, and to the persistence, mobility degradability, bioaccumulation and biomagnification of PCBs. These state ments summarize the highlights of "the extensive data base set forth in the criteria document" (which is referred to in Appendix A), and lead EPA to the conclusion that "a criterion level of 0.001 ug/1 would appear to avoid adverse effects to most aquatic organisms..." However, the only direct connection made by the Agency between the biological data and the proposed criterion is its statement that "This level is based primarily on the bioaccumulation properties of PCBS." But, in fact, the Agency does not develop any such quantitative derivation of the criterion from bioaccumulation data. Instead, it says:. "Based upon a bioaccumulation factor of 274,000* a concentration of 0.001 ug/1 would result in bioaccumulat*. to 0.274 ppm in flesh, which is below the dietary levels which have been showr injurious to aouatic birds and mammals who may feed upon them." (underlining added). The Agency goes on to say: "In addition, however, there is e v i d e n c e that in some waters some fish bioaccumulate at rates roughly ten times t h i s , and in waters where the chronic level generally exceeds 0.001 ug/1, such as Lake Michigan, there is evidence of sublethal toxic effects on fish." "cne of the foregoing provides any rational basis for choosing 0.001 ug/1 as- the ambient water criterion. * The upper end of the range the Agency says is found "after prolonged esposure-in the laboratory." 776256 .G E N P 007853 -n Even after proposing this ambient water criterion, the Agency proceeds to raise doubts about its adequacy in its statement that "the Agency recognizes the possibility that such water quality level may not provide absolute safety for ail organisms in all waters," and "there probably is no numerical concentration level above zero which one can at this time say with great confidence provides an `ample margin of safety' for all organisms under all circumstances." Furthermore, the Agency goes on to say that "even if every point source discharge were prohibited, PCB concentrations in the v/ater would remain for a long time not only above zero, but in some water bodies, above .001 pg/1. Moreover, since the capability does not exist presently to measure PCB concentrations below 0.001 vg/1 with any reasonable degree of reliability, no useful purpose would be served in establishing a criterion number below this." In essence, the Agency appears to have adopted the position t h a t no level of PCBs in the ambient waters provides' an "ample margin of s a f e t y , " and is setting an actual numerical value at what it believes is the l o w e s t level of analytical detectability. (On this point the Agency a p p e a r s to be inconsistent, because the analytical method specified for PCBs i n S e c t i o n 129.105 states that "the limit of detection is approximately 1 yg/1 f o r each Aroclor mixture.") There is no doubt that some PCB/PC0F systems are toxic, that th e y do bioaccumulate, and that safety factors are required whenever one i s attempting to regulate exposure to a toxic agent that is difficult to d e t e c t (e.g. PCDFi) via the level of a more readily detectable congener or p r e c u r s o r (e.g. PCB). However, regulation should be derived from sound data. W e ig h t 776257 G E N P 007854 -12- must be given in the regulatory process to the established, self-consistent % portions of the data base rather than to"values reported by individual observers. 2) Technological Basis for Proposed Effluent Standard. a) Control Technology Required He can understand the pragmatic approach of the Administrator in interpreting the language of Section 307(a) to authorize consideration of control technology in setting toxic pollutant effluent standards. However, because Section 307(a) contains no explicit language on control technology, the Administrator should look for guidance in this area to those sections of the Act that do require specific levels of control. For existing plants, such guidance is provided by Sections 301 and 304, which call for effluent limitations that shall require the application of BPCTA (1977) or BATEA (1983). The present proposal, as it applies to existing plants, is neither BPCTA or BATEA. Instead, it more closely resembles Section 306, which applies to national standards of performance for new sources. Section 306 requires "a standard ... which reflects the greatest degree, of effluent reduction ... achievable through application of the best available demonstrated control technology, processes, operating methods, or other alternatives, including where practicable, a standard permitting no discharge of pollutants." Note the striking parallelism between the language of Section 306(a) and the current proposal that "the Administrator is requiring that discharges be prohibited where possible and that other discharge comply with the very best results which available technology can achieve." including specific process changes and o p e r a tin methods, such as replacing steam jets with mechanical pumps and replacing detergent washing with solvent vapor degreasing (underlining added). 776258 G E N P 007855 -13- We understand the Intent of the law to set more stringent effluent limitations for new plants than for existing plants and to require exist ing plants to meet more stringent limitations by 1983 (BATEA) than by 1977 (BPCTCA). Vie also understand that under Section 304 the Administrator is directed to consider process changes in his assessment of BAT, which wouId be applicable to existing plants. But the timetables set forth in the Act certainly do not authorize the requirement that these proposed rules would impose, namely that existing plants must institute process changes within only one year of promulgation. In light of the foregoing, the Administrator should amend the proposed standards to make the items listed in the column "type of technology applied" (p. 30475) that relate to process . changes* applicable only to new sources. Existing sources should be subject only to requirements involving treatment technologies (e.g. carbon adsorption), not process changes. * E.g.- "Replace steam jets with mechanical pumps" and "Replace ( d e t e r g e n t washing water) with solvent vapor degreasing." ^7 S 259 GENP 007856 -14-, . b) Analytical Method Acceptable (Section 129.105) We have reviewed the method specified in 40 CFR Part 136 for PCBs (NPDES, Appendix A, FR 38, No. 75, Pt. 11) and have compared the procedure and the claims made for it with our own experience in analyzing industrial effluents for PCBs. We have two comments -concerning the use of the EPA method to establish compliance with an effluent standard. 1) The published method fails to specify the details of the procedure to be used in obtaining effluent samples for analysis. In our experience, the scatter among the results of single analyses on successive samples of a given waste stream is far wider than the scatter among successive analyses on aliquot portions of a single sample. Standardization of sampling pro cedures is essential if results obtained on samples taken at different times are to be meaningfully compared either to each other or to a prescribed effluent standard. 2) Our experience and that of other laboratories offers qualified support to the EPA claim that "the limit of detection is approximately 1 vg/1 (1 ppb) for each Aroclor mixture." When blanks are very low, and no interferences are present, and the calibrating standard is qualitatively the same as the sample, this limit is reasonable. The results of a recent ASTM round robin test indicate that the 95% confidence limits at the 1 -ppb level ranged from + 25% to + 75% of the reported value for a single analysis. In this test the samples used were pure Aroclors in distilled v/ater and one sample of river water. In the real-v/orid sequence of industrial sampling, sample preparation, sampling handling, and analysis, the reliable limit of 776260 G E N P 007857 -15-. detection may range from 1 to TO ppb, and the 95% confidence limit for a single determination at the 1 ppb level may be ; + 100%. We believe it is essential that EPA prepare a revised version of its proposed analytical method that will include the following items: 1) A description of acceptable-sampling procedures. 2) A description of acceptable methods for removing or correcting for interferences likely to be present in industrial waste water streams. (The present version refers primarily'to pesticide-type interferences, which are unlikely to be present in industrial samples). 3) A well-documented statistical analyses of the method as applied to industrial waste samples so that decisions on compliance with the effluent standards as promulgated will be based on a realistic understand ing of the confidence limits associated with results reported by dischargers. Submitted August-19, 1975 \r \ 776261 GENP 007858.