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y9 t /Tt\ ; UNITED STATES ENVIRONMENTAL EROT LC CION AGENCY WASHINGTON. D C. 2CMG0 December 22, 1975 MEtiORAfiPUM oi rice or cr.ronccwrr.r TO: Regional Administrators Regional Enforcement Directors Regional Surveillance & Analysis Directors FROM: Assistant Administrator for Enforcement SUBJECT: Identification and Control of Environmental Sources of PCBs As the Administrator enunciated in his statement to the press today, attached as Exhibit A, the elimination of the introduction of PCBs into the environment is a high Agency priority. His statement outlines several measures EPA is undertaking to accomplish this. He has asked the Office of Enforcement to coordinate the efforts of the Regional Offices to accomplish the first of these measures: the elimination of PCBs from discharges from facilities using PCBs, particularly those facilities manufacturing transformers and capacitors, and the elimination of PCBs, related wastes and by products from dis charges from facilities manufacturing and formulating PCBs. The steps necessary to implement this task are set forth below and are summarized in the work schedule attached as Exhibit B. 1. By 12/31/75 each Regional Office should identify each manufacturer, formulator and user of PCBs within its jurisdiction, Including the manufacturers of PCBs, capacitors and transformers listed on Exhibit C. ` 2. By 1/9/76 submit to -the Office of Water Enforcement, to the attention of Blake Biles, a schedule to survey such facilities. All surveys of the facilities listed in Exhibit C should be completed by 2/28/76 and surveys of other facilities, as appropriate, should be completed as soon thereafter as is possible. The survey of the facilities listed in Exhibit C should follow the format outlined in Exhibit 0 to determine ail points at which PCBs enter the environment from the subject facilities and to identify appropriate corrective measures. The surveys will develop information on PCB losses to water, air and land. The resulting water data will be used by the Regional Offices to accomplish steps 4 and 5, discussed below. The air and land data will be forwarded by the Office of Hater Enforcement to other offices for the development of appropriate remedial measures. Since the land disposal data may ultimately be used by Regional solid waste personnel, in conjunction with slate and local solid waste authorities, Regional solid waste personnel HONS 029300 2 should accompany your survey teams. It will be impossible to survey all users of PCBs. As indicated above, all facilities listed on Exhibit C should be surveyed. Priority should be given to facilities concerning which little information is presently available. Surveys of other facilities should focus on larger users of PCBs and can be incorporated as priority items into routine compliance monitoring visits. A meeting will be held in Washington, D. C. on January 7, 1976, to discuss in detail the surveys and appropriate remedial controls. Your lead person on the surveys from the Surveillance and Analysis Division and your lead person on the permit effort from the Permit Branch should plan to attend this meeting. Further information on the meeting, will be forthcoming from Carl Schafer, Acting Director of the Permit Division. Please contact Tom Gallagher, Director of the NEIC, Immediately if you will require NEIC assistance to complete these surveys. 3. By 1/31/76 review the IIPDES permit status of all known dischargers of PCBs and commence enforcement actions where appropriate. Check OMRs and other data on discharges to identify noncompliance with existing PCB effluent limitations. Determine whether enforcement actions should be taken for any failure to Identify PCB discharges in permit applications. Immediately commence actions against any non-filers and expedite issuance of permits to any dischargers who have applications on file. Include a summary of all such activities in your February status report described in item 8 below. . 4. By 3/31/76 issue a public notice of the proposed issuance of a permit to-any facility listed on Exhibit C which has a direct discharge and which does not currently have a permit, and issue public notices of proposed modifications of permits previously Issued to facilities listed on Exhibit C. All such proposed permits and modifications should contain conditions requiring the elimination of PCBs from the discharges as expeditiously as possible. . .. 5. By 3/31/76 commence negotiations with all facilities listed on Exhibit C which discharge into municipal treatment systems to eliminate FCBs from their discharges, utilizing jawboning, public pressure, proposed zero PCB limitation in municipal permits, and possible section 504 actions. Since success in regard to these facilities may require municipal as well as Federal action, municipal facilities should be fully briefed and their active cooperation should be solicited. A municipal inspector should be invited to accompany surveys of these facilities. It should be noted that some states require permits for dischargers of industrial wastes into municipal treatment systems. Where this is the case, active state participation should also be sought to the end of n.odifying such state permits to require a final zero PCB limitation. HONS 029301 3 In regard to items 4 and 5, it should bo noted that the Administrator will be meeting in January with the presidents of companies utilizing PCBs in the manufacture of transformers and capacitors. At the meeting he will outline the measures we expect them to undertake to eliminate PCB contamination. This should lay the groundwork for your subsequent contacts with these facilities. A range of measures designed to accomplish the elimination of PCB contamination is discussed in Exhibit D. In regard to items 4 and 5 it should be further noted that seme of the facilities discharging PCBs are located in states with ilPDES authority. You should coordinate your activities with them to make sure that all actions called for are accomplished expeditiously. In this regard, attached as Exhibit E is a copy of a memorandum sent today to those states outlining the problem and the requested course of action. Please note that EPA may modify an outstanding EPA issued permit, unless the state wishes to use the occasion to issue a state NPDES permit with a zero final PCB discharge. Where a state wishes to issue its own IlPDES permit Incorporating a zero final PCB discharge, EPA should terminate its permit after the state permit is effective. ' 6. By 3/31/76 submit a schedule to accomplish the same actions, ps appropriate, for all PCB dischargers not listed on Exhibit C. 7. Some Power plants use capacitors and transformers which contain significant quantities of PCBs. You should assure that permits for all such power plants contain zero PCB limitations. For power plants with permits that presently contain no PCB limitations, the facility should be contacted by telephone to determine whether it has transformers or largo capacitors that contain FCBs. If it docs, its permit should be modified to contain a zero PCB limitation. As you know, the effluent guideline for the Steam Electric Power Gene rating Category contains a zero discharge PCB limitation. 0. The Administrator has expressed a strong desire to be kept completely informed of EPA's activities with regard to PCBs. My memorandum of August 29, 1975, attached as Exhibit F. was designed to initiate regional activities to control PcB discharges and provide appropriate feedback to the Administrator. In order to provide the Administrator with the information he needs, please provide, by the first Friday of each month, a detailed account of your activities during the previous month. The first report is due on January 9, 1976, and should describe fully all. of your activities to date in response to the August 29th memo together with the dates on which such actions were taken. Items to be covered in the January 9th report are: MONS 029302 4 (a) The complete list of PCB manufacturers, formulators, users compiled pursuant to item 1. above; (b) A brief statement of what specific actions (if any) have been taken with regard to each facility on the list in item 1. above; (c) Where no action has taken place with regard to a facility on the list in item 1. above, a reason for the non-action and a Schedule of what will be done; - (d) Additional activities performed or to be performed in response to the August 29th memo; and (e) A full description of all activities that IIPDES states have performed regarding PCBs. Blake Biles and Murray Strier are the appropriate Contact persons in the Office of Enforcement for these activities. In particular, all information and reports requested herein should be directed to Blake Biles (202-755-8731) and all questions relating to the technical aspects of PCBs and their control should be directed to Murray Strier (703-557-7420). Enclosures Stanley w. legro MONS 029303 Exhibit B pen wouk sciientiu: 12/31/75 Identify each manufacturer, rorr.ulator and us-.er of rCDs. (Item #1) Commence review of IIPDES permit status of all known dischargers of PCBs. 1/7/76 Attend mooting in Washington, D.c. to discuss plant surveys and appropriate remedial controls. (Item #2) 1/9/76 Submit monthly activity report to Blake Biles, Ell-338, Office of Water Enforcement. (Item 48) This report should cover the items described on page 4 of the attached cover memo. Submit (with monthly activity report) a schedule to survey all facilities listed in Exhibit C. (Item *2) 1/31/76 Complete review of NPDES permit status of all known dischargers of PCBs and commence appropriate enforcement actions. (Item #3) 2/6/76 Submit, monthly report of January activities. (Item HO) 2/28/76 Complete surveys of all facilities listed in Exhibit C. (Item 12). ' 3/5/76 Submit monthly report of February activities. (Item 48) 3/21/76 No later than this date, issue public notices of proposed issuance or modification of NPDES permits to require the elimination of PCBs from the discharges from facilities listed in Exhibit C as expeditiously as possible. (Item #4) No later than this date, commence negotiations and other activities to eliminate PCBs from the discharges into municipal treatment systems from facilities listed in Exhibit C. (Item #5) , Submit a schedule to accomplish plant surveys, permit `issuances and modifications, elimination of discharges of PCBs by industrial contributors into municipal treatment systems, and similar activities for all PCB dischargers not listed in Exhibit C. (Item KG) 4/2/76 Submit monthly report of March activities. (Item #8) 5/7/76 Submit monthly report of April activities. (Item 48) In addition to the items listed in the above work schedule, you should review the NPDES permit status of power plants ns soon as possible, and act promptly to make any modifications and take necessary enforcement action. (Item 117) Furthermore, you should review the NPDES permit status of all PCH dischargers wlmuo identity you learn after 1/31/7G, and you should take appropriate enforcement actions for any discharges in violation of the nriH'f* permit program. HONS 029304 Region I - PCD Users AEROVOX Industries, Inc. 740 Belleville Ave. Now Bedford, Mass. 02741 617-994-9661 contact - Norman Butterworth Manager of Environmental Control Cornell Dubilier Electric Corp. 1605 East Rodney French Blvd. New Bedford, Mass. 02741 contact - Fhilip Murray, General Manager Jard Company, Inc. Bennington, Vermont 05201 contact - Richard L. Rollins Sanders Associates, Inc. 95 Canal Street Nashua, New Hampshire 03060 contact - E.J. Boutin Sprague Electric Company Brown Street ' North Adams, Mass. contact-Fred A. Windovor Tobe Deutschmann laboratories Canton, Mass. 02021 contact-Tobo Deutschmann Universal Manufacturing Corp. Capacitor Division 902 Crescent Ave. Bridgeport, Conn. 06607 corporate offices? Univera) Manufacturing Corp. 29-51 East Sixth St. Paterson, N.J. 07509 contact - N. Ray Clark M0NS 029305 Region II - PCD Users Axel Electronics, Tnc. 134-20 Jamaica Avenue Jamaica, New York 11418 contact - Robert II. Elkos, Data Manager General Electric Corp. 570 Lexington Avc. New York, N.Y. 10017 .contact - Stu Richel 518-374-2211 Xnductotherm Corp. 10 Indul Ave. Rancocas, N.J. 08073 contact - Roy T. Ruble 609-267-9000 R.'F. Interonics, Inc. 100 Pine Aire Drive Bay Shore, Long Island N.Y. 11706 contact - Hervin H. First 516-231-6400 Niagra Transformer Corp. 1747 Dale Road P.O. Box 233 '' Buffalo, New York 1422S contact: Herman E. Gabel', Jr. 716-896-6500 Research Cottrell, Inc. Radel Ave. Finderne, N.J. 08805 Bridgewater Township corporate offices! P.O. Box 750 Bound Brook, N.J. 08805 contact - Frank L. Armour , Associate Counsol Universal Voltronics 27 Radio Circle Dr. Mt. Kisco. N.Y. 10549 contact! Lewis Cohen HONS 029306 Region IX - continued York Electronics Corp 104 South Fourth St. Brooklyn N.Y. 11217 contact H. Dubilier HONS 02930? Region I XT - Pen Users Buell Division of Envirotcch Corp. 200 North Seventh St. Lebanon, Po. 17042 corporate offices: 253 North Fourth St. Lebanon, Pa. 10742 contact: D.J. St. John Energy Systems Company Division of Aydin Corp. 960 River Road Croydon, Pa. 19020 corporate offices:Energy Systems Co. Division of Aydin Corp. 401 Commerce Dr. Fort Washington, Pa. 19034 contact: Nicholas J. Scafidi H.K. Porter Company, Inc. Transformer Manufacturing Plant Lynchburg, Va. 24505 corporate offices: H.K. Porter Company, Inc. Porter Building Pittsburgh, Pa. 15219 contact - F.M. Vignovitch 412-391-1800 R.E. Uptegraff Manufacturing Co. P.O. Box 182 Scottsdale, Pa. 15683 contact - R.E. Uptegraff, Jr. President Kestinghouse Electric Corp. Power Systems Transformer Division 469 Sharpsville Ave. Sharon, Pa. 16146 Region III - continued Westinghouso Electric Corp Small Power Transformer Division Box 920. Highway 56W South Boston, Va. 24592 corporate offices: Wcstinghousc Building Gateway Center Pittsburgh, Pa. 15222 contact - Roger Wills, Jr., Attorney Western Electric Baltimore Works 2500 Brooninq Highway Baltimore, Maryland 21224 corpofote offices: Western Electric 222 Broadway New York, New York . 10038 HONS 029309 Region IV - PCB Users enrolina Capacitors, Inc. Division of Daldour Electric Co. P.0. Box 125 Ridgoville, South Carolina 29472 contact - E.J. Nershey Helena Corp Helena Industrial Pork P.O. Box 251 Helena, Alabama 35080 contact - K.A. Thallnor General Manager & Vice President Sangamo Electric Co. Capacitor Division P.O. Box 129 Pickens, South Carolina 29671 contact - Jessie L. Butner Manager, Manuracturing Services McGraw Edison Power systems Division 1520 Emeral Road Greenwood, South Carolina 29646 corporate officer. McGraw Edison Power systems Division P.O. Box 440 Cannonsburg, Pa 15317 contact - P.P. Cnmpcnu Buildings s Grounds section Hevi-Duty Electric Division of Sola Basic Industries, P.O. Box 26B ' Goldsboro, North Carolina 27530 Inc. corporate offices: llovi-Duty Electric Marine Plaza Guito 1934 Milwaukee, Kis. 53202 contact: Harry Bikenbcrry, President HONS 029310 Kuhlman Electric Co. Division of Kuhlman Corp. 198 Porter St. Crystal Springs, Miss. 390S9 corporate offices: Kuhlman Corp. P.O. Box 288 Birmingham, Michigan 48012 contact: J.A. Smelko, Vice Presdient P.R. Mallory & Co., Inc. Mallory Capacitor Co-. Waynesboro, Tennessee corporate offices: P.R. Mallory & Co., Inc. 3029 E. Washington, St. Indianapolis, Ind. 46202 contact: S.P. Wolsky - Director, R&D Middle South Transformer Co. Highway 49W Belaoni, Miss. 39038 corporate offices: Standard Transformer Co. 212 Dana St., N.E. Warren Ohio 44481 contact - O.M. Olivier, Vice President of Operations Baldor Electric Co. Carolina Capacitors, Inc. P.O. Box 125 Ridgeville, South Carolina 29472 corporate offices: Baldor Electric Co. P.O. Box 28G0 St. J*ouis, Missouri 63122 contact: E.J. Worshoy 803-873-2481 HONS 029311 Region V - pcft Users Dings Company 4740 W. Electric Avc, Milwaukee, Wisconsin 53246 contact - Dennis M. Pural Electrical Utilities 2427 St. Vincent Avo. La Salle, ill. 61301 contact - Richard L. Hauser, President Westinghouso Electric Corp. . Distribution Apparatus Division Curry Pike Bloomington, Ind. 47401 Westinghouse Electrio Corp Outdoor Lighting Division 1216 West 58th Str. Cleveland, Ohio 44102 corporate offices: Westinghouse Building Gateway Center Pittsburgh, Pa. 15222 contact - Roger Wills, Jr., Attorney Cornell Dubilier Electric Corp. Distribution center 2070 Maple Ave. Dee Plaines, Illinois 6001B contact - Philip Murray General Manager McGcaw Edison Power Systems Division P.O. Box 300 11131 Adams Road Franksvillc, Wis. 53126 corporate offices McGraw Edison Power Systems Division P.O. Box 440 Cannonsburg, Pa 15317 contact - P.P. Campcau Buildings & Grounds Section M0NS 029312 Rett ion V - conti nuod Standard Transformer Co* 712 Dona St., M.E. Warren, Ohio 44481 Elgin Transformer Co. 560 Chester St. Elgin, 111. G0120 Western Electric Hawthorne Works Hawthorne Station Chicago, 111. 60623 corporate offices; Wostern Electric 222 Broadway New York.N.Y, 10038 contact: J.R. Lauritsen 212-571-2345 Van Tran Electric Corp, 1505 Van Tran Ave. Vandalia, III. 62471 contact - A.E. Bolin, Jr., President HONS 029313 Rogion VI - PCD Users Van Tran Electric Corp. 7711 Imperial Dr. Waco/ Texas 76710 corporate offices: Van Tran Electric Corp 1505 Van Tran Ave. Vandalia, ill. 62471 contact - A.E. Bolin, Jr., President McGraw Edison Power Systems Division P.O. Box 627 Nacogdoches, Texas75961 corporate offices ' McGrow Edison Power Systems Division P.O. Box 4-10 Connonsburg, Pa 1531? contact - F.P. Canpcnu Buildings Grounds Section HONS 29314 Region IX - PCD Users Capacitor Specialists, Inc. P.O. Box 2052 Dol Dios Highway Escondido, Calif. 92025 contact - C. Wayne White, Vice President, Engineering Electro Engineering Works 401 Prcda St. San Leandro, Calif 94577 contact - Richard Maycock Manufacturing Manager 415-569-3326 Electro Magnetic Filter Co. 4093 Transport St. Palo Alto, Calif. 94303 corporate offices: Cine-Chrome Laboratories, Inc. 407S Transport St. Palo Alto, Calif. 94303 contact - Harold E. Martin Vice President - Cine-Chrome 415-321-5678 Federal Pacific Electric Co. 1200 Piper Dr. Milpitas, Calif 95108 contact - Ralph H. Moore - Manager, Transformer Marketing Glenn-Gibson Corp 205 Teal Court Benicia, Calif 94510 ' contact - Robert G. Glenn 707-745-3100 H.K. Porter Company, Inc. Transformer Manufacturing Belmont Works 1777 Industrial Way Belmont, Calif. 94002 rorpniMl.r of f in-?;: Rtnmlnnl Ti .mnl'oimor Co. 2)2 Dana Si., H.K. Warren Ohio 44.1 Ml Plant . contact - o.M. Olivier, Vice President, of Operations M0NS 029315 Potion X - PCD Users pacific Standard Transformer Co. 0001 Table Rock Road Medford, Oregon 97501 corjK>r<ite office**?: Standard Transformer Co. 212 Dana St., u.K. Warren Ohio 44*581 contact - O.M. Olivier, Vice President of Operation:) McGrow `Edison Power Systems Division 7533 Ave. 304 Visalia, Calif. 93277 - cotj'ovatc officer. McGrow Edinon Power Systems Division P.0. Box 4*10 Cannonsburg, Pa 15317 contact - F.P. campoau Buildings f. Grounds Section HONS 029316 Exhibit 'O TRANSFORMER AND CAPACITOR PLANT DESCRIPTIONS Introduction The purpose of the Inspection program for'transformer and capacitor plants Is to determine how fillins fluid is lost and vihat can be done in each case to eliminate the losses so that the requirement of ''zero" discharge of toxic fluid or any of its components can be met. The filling fluid for transformers may be mineral oil or a mixture of polychlorinated biphenyls (PCSs). For capacitors, they will usually be a mixture of polychlorinated biphenyls (PCSs) or, in certain cases, other oily liquids such as castor oil. Polychlorinated biphenyls are sold Under various trade names, but most commonly as Aroclor. Aroclors are manufactured by Monsanto Chemical Co. The PCB liquids are commonly called "Askarol" in the electrical equipment Industry. A list of trade names under which PCEs are sold in provided herein. The way our Inspections will be oriented is to try to account for all the PCBs brought into the plant; this means to establish a weight balance of purchases, uses of products, and losses to air, water, and landfills. Typical transformer and capacitor plant operations are described herein, including the important filling operations and specific ways that PCBs would be expected to be lost from the process. Thereby, it would be possible to make the necessary recommendations for loss control. A check list, is provided to assure that all key points of the plant have been adequately covered and for conveniently recording the values necessary for performing the weight balance for each plant In a uniform manner. Inspection Details (A) General Before a plant site visit is made, it is Important to review the details of the section 308 letter response for that plant. Pertinent areas of the plant include the following: (1) receipt, transfer, and storage; (2) process - (a) electrode, Insulator, and container fabrication and preparation, (b) filling liquid purification, and (c) vacuum filling; HONS 02931? -2- (3) laboratory; (4) process waste treatment; and (5) land disposal. All parts of transformer and capacitor manufacture are performed under clean and sterile conditions, since performance is dependent on the absence of foreign matter, especially water. (B) Plant Operation The filling fluid is received by tank car, tank truck or 55-gallon drums. It is likely to be transferred into stainless storage containers under inert gas pressure. Transfer hoses, pipes and nozzles and, in fact, all transfer equipment and procedures must be scrupulously clean. The filling liquid may be stored under vacuum or inert gas pressure. The filling liquid is purified prior to inclusion in transformer or capacitor by treatment with filter-aid clay-11l:e material to effect removal of last traces of impurities. This is done while the liquid is heated. The spent clays may be reactivated by heating at elevated temperatures prior to reuse. Suitability of the liquid for capacitor or transformer filling is determined by electrical measurement. ' Prior to filling with liquid, capacitors and transformers are assembled in the dry state, Including electrodes and insulating material in appropriate inert containers. Last traces of moisture are removed by heating under vacuum. Filling with liquid is cone under heat and vacuum (direct) for the larger devices. Smaller capacitors may be filled under flooding conditions (submersion under liquid) under vacuum. Then, the device is sealed and tested for leaks. The sealed capacitor or transformer is finally tested electrically for its appropriate circuitry. Assembled capacitors and transformers failing to pass the sealing and electrical tests and which cannot be readily repaired are dismantled, with essential components salvaged and reused accordingly. When a liquid other than PCBs is used prior to PCBs for capacitor filling in the same manu facturing line, the line must be scrupulously cleansed of the other liquid. The plant would have a laboratory for performing tests of a quality control nature on filling liquids such as dielectric constant and loss tangent and miscellaneous mechanical and electrical tests on solid component materials. The larger plants of 1000 employees or greater are likely to be performing research on filling liquid modification, advance purification, component modification, and advanced design prototype testing. MONS 029318 -3- Hasto treatment practices for handling PCBs in water by direct dischargers consist of oil-water separation at various degrees of sophis tication from simple settling to dissolved air .flotation. Included v.'ould be filtration by filter-aid, incineration of the oil phase, and use of activated carbon to achieve the most refined separation of organic phase from the water effluent. Process wastes and possibly storm runoff wastes Will be treated here. Cooling water blowdown may be included as well. Land disposal sites for the plant's solid wastes are likely to contain such items as discarded transformers and capacitors and solid components, spent filter-aid (clays), spent sorbents, miscellaneous solids removed during the oil-water separation in the waste treatment operations, and various solid residue, including slags from incineration. All of these solids could contain PCBs. (C) Significant Points of PCB Losses In general, it may be said that the principal cause for losses of filling liquid during plant operations will occur during various liquid transfer operations. These will now be highlighted. Receiving and Storage: Transfer of filling liquid from the tank car or tank truck to the storage vessel i.s a likely area for leaks and spills. Joints, valves, pipes, and hoses are'potential loss points. At this point samples of liquid would be taken for loss tangent (dissipation factor) measurement to assure quality of the liquid. The condition of the areas around joints, valves, and pumps would be indicative of the amount of care exercised in liquid transfer. P,outine internal cleaning and disposal of rinsings, especially when other liquids have been used in advance, contribut to losses. This area is likely to contribute most significantly to storm runoff owing to its openness and the nature of the operation. The general housekeeping condition will determine the contribution of storm runoff to filling liquid loss. Purification of Filling Liquid: This is likely to be a source of fillirigTiquid and its vapor. TFeHoss would occur during filtration by means of day-like filter-aid under heat and vacuum. Filling liquid vapors are exhausted through vents or hoods. Spent filter-aid is reactivated by furnace (dynamic gas draft) or oven heating without draft. Expelled vapors are exhausted through hoods, vents or vapor condensers. Unreactivated filter-aid destined for discard is likely to contain sorbed filling liquid. Overall, the purification of filling liquid and regeneration of filter-aid processes will be conducive to those losses associated with handling and HONS 029319 transfer operations involving vacuum, heating filtration, and regeneration of clay-like material at elevated temperatures. Drip pans, pumps, valves, pipes, filtration equipment, and miscellaneous .'chemicals are involved. The purified filling liquid is sampled for electrical insulating quality prior to vacuum impregnation of capacitors or transformers. The preparation and assembly of dry capacitors and transformers with associated heating and vacuum to attain an optimal moisture-free state is obviously free of any loss of filling liquid. Capacitor liquid Filling: This operation is performed under scrupu lously clean conditions in order to minimize chances of any foreign matter entering the device. In this operation the filling is performed undar heat and vacuum from a filling liquid tank. Once again, various connecting hoses, valves, and adapters arc used. Direct vacuum filling is less likely to lead to liquid losses than flood filling. In the former operation, losses will occur around connecting points at the top. In the latter operation, the entire outside of the device container will be wet with filling liquid; therefore some losses will be expected during wash and cleaning procedures with organic solvent, i.e., triehlorethylcne. Further filling liquid may be lost during seal testing-for maintenance of vacuum, especially if a leak is detected amt-the seal or cover must be replaced. The techniques for vacuum seal testing and repair are likely to vary to different degrees of refinsness. In the entire vacuum filling operation losses may be associated with transfer and filling operations, i.e., the manner by which this is generally being handled. Drip pans, hoses, mechanical pumps, steam ejectors, liquid condensers, vents and exhausts, and gas scrubbers {wet or dry), viill be associated with lost filling liquid. Transformer Filling: Same losses as for direct filling of capacitors. Laboratory: In this area tests are performed on the filling liquid for quality control purposes. The most frequent test would be "loss tangent" or otherwise known as "dissipation factor," which is a measure of the Impurity of the liquid. Although the amount of liquid required for the test may not be more than an ounce or so, there will be seme losses, duo to cleaning of test equipment before each test. Disposal of test liquid may vary but it is likely to be returned for further purification. Other tests such as distillation, density (specific gravity), electical breakdown, etc., would result in further losses. If the plant is large enough to perform its own RAD, then larger-scale uses and losses of filling liquid would occur. 029320 HONS Name Aroclor Asbestol Askarel Asbestol Chlorcxtol Diaclor Dyfcanol Elemex Hyvol Inerteen Fenclor Clophen Kennechlor No-Flamol Phenodor Pyranol Pyrolene PK Saf-T-Kuhl Santothorm Soval LISTING OF NAMES ANO MANUFACTURERS OF PCBs IN CAPACITORS ANO TRANSFORMERS Manufacturer Monsanto * -- -- American Corporation Allis Chalmers Sangamo Electric Cornell Oubilier McGraw Edison Aerovox Westinghouse Electric Caffaro (Italy) Bayer (Germany) Kenneclor (Japan) Wagner Electric Prodelec (France) General Electric Prodelec (France) Caffaro (Italy) Kuhlman Electric Mitsubishi (Japan) -- Capacitor X -- X .... __ .... -- -- -- -- -- -- ----- Transformer X X X X .... .... X -- -X -X -- -X -X HONS 029321 Check Ust Capacitors Date of Znspoctlon Company Idcntlficall on ` Plant (name, address, telephone) Parent company or headquarters (name, address, telephone) Responsible Officials Plant (name, title) - Parent company or headquarters (name, title) Inspection Team Federal (name, title, division, organization) State (name, title, division, organization) Municipal (name, title, division, organization) Other (name, title, division, organization) Disposition of Wastes Receiving waters (for direct discharge) Municipal treatment system (Including receiving waters) Landfill (name, address) ' Incineration (name, address) Other (such as disposal) Filling Or impregnating fluids used Receipt, Transfer, and Storage How received (tank cars, trucks, drums) Where received (how far from use area) How unloaded into storage tanks Are tank cars cleaned after unloading? How? , What happens to flushings or contaminated cleaning solutions? Drip pans under hose or pipe connections to tank car or trucks? Transfer hose or pipes drained where? Unloading area paved and diked? Collection sump? \iow ore sumps emptied and to where? Unloading area roofed? How are samples taken? Where is excess sample disposed of? What disposition .is made of samples after testing? Storage tank area paved and diked? Collection sump?' (! Y" <u&i* ^ QiU, ^- 7 MONS 029322 -2- Receipt, Transfer, and Storage -- cont. Yea ' Arc raw filling fluids stored open to tlic atmosphere or under Inert gas or under specially dried atmosphere or vacuum? If vacuum, how is vacuum obtained? Where docs vacuum system exhaust to? Is exhaust equipped with vapor condenser? If so, where does condensate go? Where is vacuum pump cooling water obtained? Where does vacuum pump cooling water go? Is vacuum pump equipped with drip pans? How is contaminated vacuum pump oil disposed of? If stored under special atmosphere: What is it (nitrogen, dry air, etc.)? What pressure maintained on tank? Whore does tank vent to? Is vent equipped with vapor condensor? If so, where does condensate go? Are transfer pumps In the storage area provided with drip pans' In all cases where drip pans are used, what disposition Is made of accumulated drips? General Observations Workers handling of fluids Housekeeping Other Filling or Impregnating Fluid Purification Are pumps and filters equipped with drip plans or diked, with sumps? If filter aid blending tank surrounded by paved, diked area? How la spent filter aid taken off the filter? How la spent filter aid packaged for disposal? Is spent filter aid handled by employees? How? Whnt Is disposition of spent filter aid? If regenerated on site, where does regeneration provess exhaust to? Is exhaust equipped with vapor condensor? If so, where docs condensate go? HONS 029323 -3- Purification -- cont. Is purified fluid sampled? How ore samples taken? What is done with excess sample?. If fluid does not meet requirements, what happens? What disposition is made of samples after testing? How arc miscellaneous floor spills of fluid cleaned up? What happens to the sweepings? What happens to rage, wiping cloths, etc.? What happens to workers' clothing, gloves, etc.? General Observations Workers handling of PCBs Housekeeping Other Capacitor Impregnation-Submersion or Flood Filling Process Is impregnation tank cleaned before each filling? What is done with any filling fluid removed from the tank in cleaning it? . What la done with any rags used in the cleaning? What is done with workers' clothing worn in cleaning? Are PCB vapors given off In preheating the tank prior to loading with capacitors? Where is tank vented to during preheating? How is vacuum obtained? Where does vacuum system exhaust to? Is exhaust equipped with vapor condensor? If so, what happens to condensate? Is vacuum pump equipped with drip pans? What oil is used in vacuum pump and how much? What happens to contaminated oil: After copncitors have been flooded, where is impregnation tank drained to? Are drainings sampled? How? What happens to excess sample? What happens to nample after testing? What happens if drained fluid is defective: to the fluid? . to the capacitors? What happens if drained fluid is good? Are pumps equipped with drip pans? Yes .Ho MGNS 029324 I Arc tanks surrounded by paved, diked areas?' With pomps? What disposition is node of contents of sumps and drip pan? After impregnation tank is drained, arc capacitors allowed to drip in tank, or taken out? If the capacitors arc taken out for dripping, are drip pans provided? What is done with the contents of the drip pans? Is the area where newly filled capacitors allowed to drip adequately ventilated? Dow? Where does ventilation system exhaust tn? Is the exhaust equipped with vapor condenser and, if so, what happens to the condensate? How are capacitors transferred to the sealing area? Are drip pans provided? What disposition of contents? llow are spills or overflows of PCBs collected In the sealing area? After sealing, how are capacitors cleaned of residual fluid on the outside? .. If by solvent or vapor degreasing, how is solvent reclaimed? How is filling fluid residue from the solvent recycle system collected? How is it disposed of? If by washing with water or detergent solution, how are contaminated washings disposed of? Are capacitors rinsed after washing? If so, is rinse water reused? How is contaminated rinse water disposed of? What happens to solid waste contaminated with filling fluid? Especially, what happens to wiping rags and workers1 clothing? If solvent cleaned, how is filling fluid residue from the solvent system collected? How is it disposed of? General Observations Use of protective*clothing, gloves, etc. Workers1 handling of fluids Housekeeping Other Ncto in particular whether walls and ceilings ore coated with filling fluid in the vicinity of the impregnation tank and drip area. HONS 029325 I -5Yft Ijo Obsorvo workers who cowo in contact with filling Hold for cMoroacne or pignent dlGcolocotion. If oil-water separator is used to separate? filling fluid from water what is done with oil layer? With the water layer? . Laige Capacitor Jmpregnation/Tronsfonner filling -- Direct Filling process Is area around filling operation paved and diked? How arc spills cleaned up? What disposition is made o contaminated solid waste? How is vacuum pulled on the capacitor or transformer? If by vacuum pump; where pump exhaust to? Is exhaust equipped with vapor condenser? Where does condensate go? Where does pump cooking water go? How is contaminated vacuum pump oil disposed of? If by steam jet, how is steam condensed? What disposition is made of condensate? How is filling line drained? Laboratory Ho. of employees Quality control Types of test performed and amount of sample used (a) dielctric constant and loss tangent (b) electrical breakdown (c) distillation range (d) density (specific gravity) (c) others RtD Typos of equipment used, test performed and amount of samples used? Samples to be taken: Soil scrapings in tank car unloading area Vacuum pump cooling water Oil-wntcr separators (water layer) Spent detergent solutions Contaminated rinse water, etc. Plant effluent n) direct discharge* b) to municipality Ftcam jet condensate General How are defective capacitors or transformers disponed of? Is filling fluid recovered? Is rejected unit utora&c area paved mu! diked? MONS 029326 UNITTD STA'I liS (INVIRONMCNTAL PriOTF.CVlOH ACW.NCY WASHINGTON. DC 20450 an Exhibit E. o ficc of cr.TORCi mcwt MEMORANDUM TO i State NPDSS Directors FROM* Assistant Administrator for Enforcement (EN-329) SUBJECT: Identification and Control of Environmental Sources of PCBs AS you know, the discharge of PCBs into the environment represents a substantial national problem. Attached as Exhibit A is a copy of a press statement made today by the Administrator outlining the problem and EPA's response to it. Since the control of PC9 discharges into the Nation's waters represents the most positive action the Agency has authority to undertake at the present time, the issuance and modification of NPDES permits to require the expeditious elimination of PCB discharges naturally assumes primary importance in our PCB program. Insofar as dischargers of PCBs are located in your states, your active cooperation and participation will be necessary to assure the success of this program. Attached as Exhibit B is a memorandum that I am sending today to our Regional Offices outlining the steps we are requesting of them to implement. I am asking you, as partners in our national regulatory program, to cooperate fully'in those efforts and to take any necessary implementing actions with regard to dischargers of PCBs subject to your jurisdiction within the same time frame outlined in my memorandum to the Regional Offices. Insofar as your efforts could be strengthened by field assistance in conducting appropriate surveys, please contact EPA's Regional Offices for assistance. I am not asking you to report to me on your actions taken to implement this program, but do ask you to keep EPA's Regional Offices fully informed so that they can do so. Please feci free after contacting the Regional Offices to make specific inquiries of Murray Strier and Blako Biles of this office regarding any questions you have on these efforts. Murray Strier is the appropriate contact on technical matters regarding plant surveys and permit issuance and modification (703-557-7-J20). MONS 029327 -2- Bloko Biles is tho appropriate contact on the broad rango of epa's PCD efforts (202-755-3731). The attendance of your representatives at tho technical meeting on PCDs on January 7, mentioned in my memorandum to tha Hogional Offices, is also invited. Attachments Stanley wYK. Legro v HONS 029328 lixMbi t F UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20-HiO August 29, 1975 OFFICE OF ENFORCEMENT MEMORANDUM TO: All Regional Administrators FROM: Assistant Administrator for Enforcement SUBJECT: Enforcement Activities Concerning Discharges of PCB Compounds and Mixtures As a part of the Agency's efforts to limit discharges into the environment of Polychlorinated Bypheny.ls (PCBs) and comparable chemical substances, we must ensure that all known discharges of PCBs arc in compliance with all applicable provisions of the FWPCA, particularly those concerning NPDES permits. I am therefore requesting that you review the permits held by those companies in your Region which have been identified as possible usors of PCBs. Such companies include those to whom EPA recently addressed Section 308 letters, plus any others which have been identified by personnel in your Region. For permits which contain limitations or prohibitions upon the discharge of PCBs, you should in the near future determine whether the permittees are complying with such limitations or prohibitions. In any cases of noncompliance, appropriate enforcement actions should be taken immediately. Where no application is on file from a discharger of PCBs enforcement action should be undertaken immediately. Enforcement actions should also be taken against any dischargers of PCBs whoso permits contain no PCB limitations and who did not identify PCBs either directly or by a general term (e.g. chlorinated hydrocarbons) as present in their discharges in their Refuse Act or NPDES permit applications. In order to aid in the identification of such dischargers, your staff should review the responses to the recent 308 letters. Please inform Blake Riles of tho Legal Branch at (202)755-8731 of all such PCD users whoso permits contain no limitations or prohibitions for the discharge of PCRs. You should also contact Blake regarding proposed modifications of limitations contained in permits which were previously issued by the Agency. MONS 029329 If your Region is proposing to issue permits which will contain limitations upon PCBs, (other than through the application of effluent guidelines) or if permits with such limitations arc the subject of adjudicatory hearings, please contact Bob Schaffer of the permits Division at (703)$57-7470 for assistance in developing the precise offluont limits which should be included in such permits. . Thank you for your prompt attention to this important matter. Sincerely yours MONS 029330