Document rOK7qEad5K0wGg0nw2JLkZGG

Monsanto --- ------------- ------------------------ Mons a nt o Co mp a n y 6 0 0 N. Li ndbsr gh Boul evar d St . Loui s. Mi s s our i 63166 Phona: (314) 6 9 4 - 1 0 0 0 CMtMKALS DMSJOH F e b r u a r y 18, 1970 D e a r Sir: Recently several n e w s p a p e r and m a g a z i n e articles have been published, indicating that Polychlorinated Biphenyls ( P C B s ) have been discovered at s o m e points in s o m e marine, aquatic and wildlife environments. T h e quantities detected are said to be in the parts per million and parts per billion categories. It is claimed that the P C B s found strongly r e semble chlorinated biphenyls containing 5 4 % and 6 0 % chlorine by weight. Products w h i c h are sold by M o n s a n t o under the trade n a m e s of Arocloi 1254 and 1260 do contain chlorinated "biphenyls. In addition to A r o d o i 1254 and 1260, M o n s a n t o sells certain functional fluids containing A r o d o i ^ 5 1254. T h ese include Pydraul 625, PydrauJ A C , Pydraul A C - Winter Grade, P y d r a u l 540, Therminoi F R - 3 and certain dielectric formulations. Several other companies around the world also produce products containing chlorinated biphenyls. A s your supplier of Aroclox 1254 and 1260 and formulated products containing 1254, w e w ish to alert you to the potential p r o b l e m of environ mental contamination as referred to in the n e w s p a p e r and m a g a z i n e arti cles. W e would like to point out the following additional facts: 1. Products such as PydrauE* 90,135, 230, 312, A-200, F-9, 150, and 60, Turbinol 153 and Thermi n o l F R - 1 and F R - 2 are not formulated with Aroclor 1254 or 1260. 2. P C B s with a chlorine content of less than 5 4 % have not been found in the environment and appear to present no potential p r o b l e m to the environment. 781901 NEL 000059 -2 We have developed and are now testing, new formulations to replace the Aroclor1254 and 1260 components in our Pydrauf^ products. The new products appear to be equal in performance and to have sim ilar physical properties. We feel that all possible care should be taken in the application, processing and effluent disposal of these products to prevent them becoming environ mental contaminants. Of interest to you may be an article in Chemical Week, October 29, 1969, regarding water pollution standards set by each state in the Union. It is attached. This article reflects that good manufacturing practice in the future may require that no product used by any company should find their way into waterways. We realize that you have marketed or may now market transformers and other electrical equipment containing dielectric fluids which include Aroclor 1254 and 1260. Although these fluids are sealed into such equip ment it is recognized that occasionally the fluid may be lost through leaks resulting from equipment misuse or equipment repair necessitating replace ment of the fluid. Since the dielectric fluid contained in .this, equipment is only an incidental part of the over-all unit manufactured by you, we are not notifying the purchasers of such equipment of the potential environmental contamination problem described in this letter. We do recommend however, that you notify such equipment users of this problem. Sincerely yours, p lb Attachment Donald A. Olson Director of Sales Functional Fluids Group - NEL 000060 781902 af - ENGINEERING G E N E R A L ^ ELECTRIC 1 RIVER ROAD, SCHENECTADY, N. Y. 12305 ; ./> dial. c r.i ! SUBJECT Rlectrr.cul Insulation Cil htirny in c u y o r t of I!-.tionni Industrial ollutioii Cci.trci Council O - C 'T--I , i n*?.'-1, Thank you for your rerdy agreement to help us out on the iTruC insulating oil study. The enclosed cop;* of mr letter to Jia Young, with his notation on the corner, gives general orientation. The exhibit I attached has been ucdr.tsd. i For,starters, we'd appreciate your help by documenting and filling out the information as to quantities of 10-0 used by the elect: leal industry as a whole. The year I960 would be a good base year. The enclosed Exhibit 2 , fro.ii purchasing consulting, nay be helpful, it shows who in G3 bought what fro::i whom (but I don't see ar.y rhilsdel*hiaovritchgear listing), Aatioir.g from Ga us-ge. w i V 1 estimates of rarket percentage, is of course cue approach to totals, but le.v/es out the products we don't .:..rl:o (such as cable, :.s you ..ewtior-ed in an earlier ccnversatioiv,. ..'nut would you th.i. 1 of conbacting several of the -.a;;or v.nicrs of 1C-- C (`obil, Gulf, Texaco, Calso) a/.d asking each for its c-sti ate of total usage of 10-C ? p;e ought to distinguish between new umufacture and field .nake-u`'r' to help us in assessing what happens ultimately to all the oil. * Another question we need your help on is total electrical industry use of askarel insulating liquids, I note that hor.snnto has refused to give t: air production figures to Representative Ryan (s.e the Congressional Record clipping 1 sent you yesterday); would you fare any 'better? Exhibit 3 of this lettir we see i t . Tour su 7, . L . ` . . . . i -"Li J-). outline of the whole project, as ecus on all osuects. 2est Regards, Z/.l. I'elson lS NEL 000061 781903 K W B I T 1 -- ALE, OIL a USE CA`i L-GO,,:Z_. !i. !| r - f,o / fe/v. ?-fV 1' /A. 7 ^ ?$Yf ///Yy CemfluuYs \j//-f1yC:;JiC'!'jfCtfiir.7 /. ? A 0*!C'h.'S) /. H' Ce**pfyijj LiSC | / r off f> % 7'4<|7 1, .. / s7 m/=?/.' yb/p jy 1 * !... t?,0 V =x/ /?<*'&/rso/r&ti.ffy,on 1 ; ;i. 3 fii dies*Vs ra; (3) (V ^.3 in.3 - 8Si /37.3 i 2, 3 Atier K/ia'es : x 7 // s/oh ilircrar f X .T Je/ Yjf'r"nr/ XL I/css:/$ k'AX&rGj . .... w:y .* . 3oM /^W&3 igi 37.6 . ft) tqif-A 10105M.8i1ii. r 0 32.7-5 7I.9 MJS8 3W.2___ ,zkte-M f 71^0 1~3i0 m\0 fv.'ofer '(?/ Ccynytrs'ion / (ifher > 0 873.,vf1g jl-j|cjS& .i ^i-3 o 3gjf^g . 3. 1 -3*z>#23 It. /is. ri*/r^/'/c/if.>;?/s (Sift? J 3 4/VW eisfWiW Ci/jVi;/ --^-3. S' kc'fl'ZG*/ ''.'hfic* ?) , 0 -: a !l 0! 0 qv.. 4S.2 /4L, IUI 32s;-'iSi.'J c`)U*.f[Y$ w /.o \0,01 0 8313.737,8" 17/3 iI A 0 To''~c--.'l I/Cfv'f; /.*c J 4 /C3.I J M 3^.3 m O rfm i 100 NEL 000062 (l;a(2),stc. bee r.exfc ;f.ge. rtefirer.ee numbers i/: coin ns apply to x. .gures below (e;:cept i.*i the cr.se of totals *.;hcse derlVitio/i is obvious). *iJsoetli;f.ue,eli':iesredste.rr:cer, bed -r.-i by t'r.s UcfeVi'tr.eat of distill .t:. fuel oil; Czo.*-.s*.c,elirre.ce pr.sri::,:acib':l?e.lndeleomfelnotw" .de J.S.N. 10-2-7C* 781904 COMPANY ONE RIVER ROAD. SCHENECTADY, NEW YORK 12305 . . . TELEPHONE AREA CODE 518-- 374-2211 December 22, 1970 ENGINEERING. SERVICES W Subject: Electrical Insulating Liquids CC JF Young, bet: 'for! Mr. S.A. Jordan, Executive Assistant to Vice President, Government Affairs V/estinghouse Electric Corporation 1301 K Street, Ktf Washington, D.C. 20006 Dear Mr. Jordan, Enclosed are seven copies of the study, THE USE AND DISPOSAL OF ELECTAICaL IKoUL'.TIKG LIQUIDS, for the use of the Electric and nuclear Sub-Council of the National Industrial Pollution Control Council. The present copy differs from that we discussed in New York on December 17 only with respect to the first recommendation on page five, which has been expanded to make clear what is meant by "incineration under carefully controlled conditions". Very truly yours c.3. I'elson Consultant - Product Safety NEL 000065 781905 ENG!::::r.i;:s GEHURAL / ELETniC 1 RIVER ROAD, SCHENECTADY, N. Y. 12305 SUBJECT \ ..si .-ctrio D 1Ai (J O .3 i r -i * COPIES: 73 7 **/-'tY^**1" ' T***-ijcr"* * Tr-.* i*' .f ^ 1ic 1 i`r' , 0 IJ 1_ _ _1**._- [4j- _ fhanl: you for the us:,re -ata rd specific-tiene 7 :;: have ser.fc .:= or. ycvr department1z rejoin-rr.eriis for diolcctric li.viris, J^-caus a I?s9 and 1970 *ore affected by the strike, I uouid axprsci'-ie having t e figures for 19o--. In addition, >.o"ld you sko*.; opyX'ito each: t ::c of fluid your esti..-ate of i:}3ri:ct r..rc s :t;g:t for the t.';. 0 ? caa'.citor vs ng such fluid, ar.d tas cal cu1:10 tot -1 u :ry: by ti;e _c -citor incj:?ti';*. Firnliy (i ' euro you hoye;. plc-ae indicate the disposal retied 3 used for v:\otv *f esc*- t e cf fluid, in your .r.rv."-ct.rir" opernii-jr.s. a ...e.vo its.:. .-.o-nanio records sko-.- shipment to you of ?, 939,i X 1 pounds of lyr.-r.ol i:: 'he so beta aro tc be "sobered i; to a eiudy **c are dolar ir. support of ..r. f e r - ' ur. tici .-.tio:. in the inbienal Industrial Follutior. foi.trcl Council, v-koro the interest is in ii.dv.s-ry to. els rrikor t'.ar. the norforneo of r.y one .a::.iifacturar. iliEik you for your continued help. :/er* truly rcurs <-.. i.exson NEL 000063 781906 ENGINEERING GEHEBAL0 ELECTRIC 1 RIVER R0A3, SCHENECTf.BY, H. Y. 12303 SUBJECT OL!0*.*-"* \C- O- i ft 1. co COPIES: leoc-jiber 1. 1470 r l***+ . . c 1*!s~hr rfi. 'ft:.X Re d a c t e d cils it' .jt. Yourv* is -.b thr; i-.l:'vJl '.."AO- iCV.UC;-- . or. the oils ;ti:ho'ise rifiv-ert .11 provide vr-to- '.*? _.r. Xtf^soi^ xr.ioi--ja -= ::or-s--o;; ae i ; v;or- i t .ith .*cs s r s . .-.r:bo -s xu s.:.d th e L'-oble w li'jfits C a : i .i t t e e . vrhich i s o f c.si:xro i - c c ;;oa.T-inxt d ::<st a r i a1 . ..iL'ur; oi ..r/ier, x JojJ. so to provide the basis for fu rth e r ii.f e ru p tio n on t NEL 000064 781907 ENGINEERING G E N E R A L ELECTRIC 1 RIVER ROAD, SCHENECTADY, N. Y. 12305 SUBJECT DIA L ' c o r.i r.; ; i^lq-226l| COPIES: D.H. Marquis Monthly Report cf Consultant - rroduct ..afty l> --9" j 1970 Mr. J.F. kcAllistsr KS:/ YudK REDACTED Insulating- .Oils Study A report entitled, "The Use and Disposal of HIectric.il Insulating Liquids" was prepared (with the assistance cf K. .iim, . ?.aab, arid others) and discussed in liar lor.: on Cecember 17 */ith .ir. Young and with Mr. 3,A. Jordan, Executive Arsistant t.o 71 eo --resident, Government Affairs, V/ccti:.r!\ousc Electric Corporation. v;ho is providing staff support to* M r . "urnham for the latter's participation in iiIPCC. It was agreed that legal clearance will be obtained, after* which seven copies vri.ll be furnished to hr. Jordan for the use of the Hiectrie and Nuclear Sub-Council, Mr. P'emeriy' granted legal clearance on December 21. .Ww' nS Mr. Ielson attended a meeting of the task force on disposal methods to be used with rC3 and rCB-co.itaminatod solids (December 22) to obtain background for reply* to the i ^ i i n y received from Northern States rower Company arid the Doble Clients Committee. Iv has been learned that Fi'blic Service Company cf Oklahoma ai.i Ohio Idison Company (members cf the Dcble Clients Committee} are .iniing the same inquiry of other manu facturers. Cur objective is to get some sort of reply out before the ne.'-t Bvble sioeting, slated for March, 1971. NEL 000066 781908 redacted /.. -Kelson 9000013M 781909 y,. /Ve(o-> { CORPORATE CC:;S'JLli;i SERVICES G E [ ! E F iM @ E L E C T R IC t RIVER ROAD, SCHENECTADY, H. Y. 1230S * j. D I S\ L ] ; ! , / ' C 6 IV; id h- 2 S 5 - i ' l : i Acply to I'o.'tliKA. t-utes 1 o*-:v.r Ccrpany O COPIES: <'i *.cAHis ttr cl: Ar/:arson :.a-ab 22, 1-/71 i-.r. ii.C . Csthoff Aa:i-'.yor - Materials and rechnology Laboratory r'o:;or Distribution Division PITfdFI^D Dear Bob, Since our1 :*acting on Tuesday I have riven scr:.e .ora thought to the possible interpratations of our proposed letter to northern States Fewer Cc.-.pr.r.y (and Doble Clients) and now propose the changes indicated cn the" enclosed rked-up copy and its inserts. After yon have integrated ur*y additional inputs from Steve and na, it is rscotLV.esded that it be submitted for review to i-ir. .illia-. r. Kennedy Associate General Counsel lew `fork Office. In addition, the letter should'be reviewed for conusrcial acceptability by someone in Electronic Jaru.onents Division (presumably Don Cross) inascuc h as the capacitor amrlets involved are only partially covered by the proposed signer of the letter(J.J. Fredrickson, manager - iov.'er Distribution dales Lb eration). Very truly yours, K iCelson, Staff Consultant Product Ehviroriuontal Cc .paaibility NEL 000068 781911 P ro p o s e d 0;':a n^ es t o K e p i;/ t o N o r t h e r n f h a t e s i o o r Co.:\r.;.ny (1) (..ecc:.d reranruyh} ( t l A l a # ! 1--**? 00* * . - X ^UCl * v:ili -o lechnic*:,! .'.dr I s or;,.- board of A*'51, an I-.r. activit* .!. A. r i s of c io the tta , lilect:*ic l1 Kw Yor: and C ity , !-.i3.ue. nctirco;r*.r.ui5c Coor dir:*,.to r . (2) (Third paragraph) Under some laboratory cor- litious, it is true that rCB-contai:;ir.g material in capacitors has been found to possess a decree of biodegradability. Cur technical people are folio:ring these" studies carefully, but vun til r.ore is learned about the completeness of the process ar.c the ir-ture of the depredation products, a cautious approach to the disposition of these materials appears to us to be in order. It is preb hie that few, if airy, of the landfill operations accessible to your industry are s uiyped to control and monitor materials of this rr-ture; accordingly, it is our present uosition that capacitors retired from "electric uti. lit - service shouldi be handlea ir. the same manner as transformer `.latcri *i s , :.d that scrap of this type should be contained until such time a s Audi and the industry have reached a viable solution to in is solid v:\ste riisyos'.l problem. NEL 000069 J1; l-22-]71 ii . 781912 G E R E S A L Q ELECTRIC POWER TRANSM ISSION fiD DISTRIDUTIOri SALES DIVISION 345 Park Avenue New Y ork, New York 10022 T e l. Area Code 212, Mr. R. H. Peterson, General Superintendent Protection and Electric Maintenance Northern States Power Company ISIS North Chestnut Avenue MinneapAolis, Minnesota SS403 Dear Mr. Peterson: Your letter of November 5, 1970 to Mr, Fagrelius has been referred to me for reply. The long delay in replying to your letter has been due to the fact that a great deal of General Electric Company effort has beqp devoted to the study of the problems associated with the use of polychlorbiphenyls, (PCB*s). Many of the answers are now available and we are in a position to respond to most of your questions. An American National Standards Institute Committee is being formed to address itself to the disposal of PCB's and PCB-containing materials on an industry basis. A_ x+ a Kir n 1rT H p-- i-- - A- JBi-c^Lottii of i ANSI of NbTT^fuj.X Ci ij. C [ j a **4**' is true that under some laboratory condii materiai^in^capacitors has been found to po egradability, it is our presfcni^gcoraraendation that these be handled in the same manner as transformer Our t( people are following the bio- degradation studies carefully, to date, current information is lacking concerning the eool jical implica the degradation products. te recommend that-s'cfap of this type be contained such time as ANSI and the indus-try'fiave reached a viable'solution to this prgb-i^mT disposal It has been shown that a properly designed incinerator can, indeed, dispose of solid PCB-containing materials in a satisfactory fashion. This observa tion has been confirmed by Monsanto Chemical Company, Rollins-Purle (r. company devoted to the ultimate disposition of wastes) and by work dene within General Electric Company. Such equipments are sophisticated in that careful temperature control, proper residence time, and the close control of many other process parameters are necessary for successful operation. General Electric Company analyses have shown that small scale units are not economically attractive. It is our recommendation that you seek a large disposal center such as is being proposed by several companies for the dis posal of solid PCB affected wastes of this typo. While no one is yet in a position to handle solid wastes, several organizations have stated that they will be in a position to accept solid materials in 1971 on a basis similar to that already established for liquids. NEL 000070 781913 GENERAL ELECTRIC Mr. R. H, Peterson January 21, 1971 Pago 2 POWER TRANSMISSION AND DISTRIBUTION SALES DIVISION General Electric Company personnel sbvloualy are establishing a broad base of knowledge in regard to the maintenance and disposal of PCB-containing equipment. Our people participate in.industry groups which establish standard, guides, and procedures for the use of PCB's. Of course, vie will be pleased to help you by making available any specialized knowledge you may require in this regard. If you have any further questions on the matter of PCB's, please don't hesitate to let us know. I hope we have been of help to you t Very truly yours, ^ J. J. Fredrickson, Manager Power Distribution Sales Operation /ra t NEL 000071 781914 CORPORATE CONSULTING SERVICES GEHERAL^ELECTBIC 1 RIVER ROAD, SCHENECTADY, H. Y. 12305 : ,.p D I A L C O -H SUBJECT Ls235=22l____ North err. States/Doble Clients In ;uiry February 1, 1971 4t/ COPIES: J? McAllister KY RC Osthoff Pfld Mr. J.J . Fredrickson, Manager Power Distribution Sales Operation 315 Park Avenue New York, K.Y. 10022 Dear Mr. Fredrickson, As agreed in our telephone corive' sation, I am enclosing a copy of the original inquiry from northern States Power Company. Also enclosed is a copy of Mr. Fagreiius' letter of May 13 j 1970, to Northern States t based on a for;aat recommended by the Ames Task Force on PCS. Bulletin EPS 4-1, likewise enclosed, is needed for a full understanding. The sequence of events is as follows: Mr. Fagreiius wrote to Northern States, as requested. Northern St'.tes replied, ir. their own interest and ir. behlf theDoble Clients Committee. Mr. Hsrshey requested the advice of Counsel, Hike Dobbins, who referred the correspondence to Jim Young (who had originally empaneled the Ames Task Force). Young, through McAllister, asked me to handle it, an-.1 I secured the aid of Dr. Osthoff, who is centralizing such ratters for Mr. Meloun. The reply you have been requested to send is the joint work of Dr.Osthoff, Ed Baab, Dr. Steve Anderson, and the undersigned. You will note that this reply (as well as Mr. Fagreiius1 letter) follows policy as enunciated in Bulletin EPS 4.1. Although the above paragraph sounds like a bureaucratic run-around, it is not rea.\ly as bad as all that. While these papers -were being shuffled, more was being learned about the n'.ture of the problem, the cooperation of ANSI in bringing the problem before, the industry was assured, and various work was going forward to find out how to incinerate the material, as a result, we can now give the customer a more meaningful reply. Meanwhile, through telephone with Mr. Fagreiius, the curtomer has been a vised that his letter had not been forgotten, and that he would receive a reply before the March meeting of the Doble Clients. If you have any further questions, don't hesitate to call. ___.Very truly yours, \ s. (J.J4 Kelson, Staff Consultant W o d u o t Environmental Compaqibiiiry NEL 000072 CORPORATI: CCHSUUWG SERVICES G E iIE H A L ELECTRIC I RIVER ROAD, SCHENECTADY, II. Y. 12305 r,;; ; '* SUBJECT Jar.iia.ry 27, 1971 r AL ... ~ ... i.j , 1_J Power Co...pany ckson, 1-25-71 COPIES: % JS Anderson EL Dobbins Kennedy CJ Meloun rc Osthoff JF McAllister u - Kr. J.J. Fredrickson, Manager Power Distribution Sales Operation Fever Transmission and Distribution Sales Division 345 Park Avenue New York, Kew York 10022 Dear Mr. Fredrickson, 3efore processing the proposed reply to Northern States Power Company, please modify the third paragraph by the insertion of the clause between dashes in the following sentence, to make it read: Our technical people are following these studies carefully, but until more is learned about the completeness of the process and the nature of the degredation products, a conservative approach to the disposition of these .materials appears to us to be in order; and the use of landfill operations -- which generally are not susceptible to accurate monitor ing and control -- should be avoided. With this change, the lette will reflect mare faithfully the state of the art ar.d of our understanding of correct practice. If you wish to discuss this or ar.y other aspect of the PCS question as it affects our customers, please do not hesitate to call. Very truly yours, James S. Nelson, Staff Consultant Froriuct Environmental Compatibility NEL 000073 781916 CORPORATE CONSULTING SERVICES G EN ER A L ELEGTHIC 1 KIVER ROAD, SCHENECTADY, N. V. 123D5 ; SUBJECT Activities Report January, 1971 dial C O I 13 redacted COPIES: L / February 1, 1971 Mr. J.F. McAllister HEV; YCilK I. EMVIRC'MiPMTAM FROTFCTIOK FCB - Solid aste In cooperation with Messrs. Osthoff, Raab, and Anderson, a reply has been forssulated to the inquiry by Northern States ro.-rer Company and the Doble Clients Committee. It is planned that the reply will be signed by Mr. J.J. Fredrickson, Manager- ? ov;er Distribution Sales Operation, after approval by Mr. Kennedy. The letter reports progress on the for ration of an ANSI committee addressed'to this rroolerr. and on preparations by waste processors to receive this type of -- terial for controlled destruction. Meanwhile, in view of lack of precision controls on landfills, utilities are asked to contain scrap eolids containing FCB a '.ting the activation of controlled disposition processes. t] NEL 000074 781917 REDACTED J.S. Kelson fi- NEL 000075 781918 ' '( a ACTIVITIES REPORT FEEBOAHY, 1971 OH Marquis Schenectady, March 3* 1971 Mr* J. 7 . McAllister Staff Manager Product Quality NEW YORK OFFICE redacted I* ENVIRONMENTAL ITOTECTION Doble Clients /Northern States A Company reply to the inquiry of Northern States Paver Co. in behalf of the Sole Clients concerning several aspects of FCB control has been sade in the f a m of a letter ffaa Mr. J.J. Fredrickson, Manager - Power Distribution Soles Operation. ANSI Committee on PCS The Electrical and Electronics Technical Advisory Board, in an action initiated by GE through BEKA, has sent out a letter ballot seeking approval of a caanittee on Disposal of Asksrel. HEKA vlll be the Secretariat. It is planned that Mr. Ed Raab will represent Com pany Interests on this committee. NTPCC The Electric and Nuclear Sub-Council of NIFCC Is Interested in publishing our study of the use and disposal of electrical insulating liquids under the imprint of the U.S. Department of CciMJercc. Mr. Nelson v l U accompany Mr. Young on a visit to Mr. Sam Jordan (Westlnghouse), Washington, to make plans. Ms&ntfhlle, both tha Ccmaoznrealth of Massachusetts and Arthur D. Little have been written for permission to use data in their report on waste oil disposal. NEL 000076 781919 Hr J. F. McAllister redacted Bags 2 March 3, 1971 REDACTED 1 1 781920 NEL 000077 J Mr. J. F* McAllister Page 3 March 3# 1971 r e d a ctED < j) \) JSN/rr J. S. Nelson, Staff Consultant ftroduct Environmental Compatibility 781921 NEL 000078 CORPORATE ENGINEERING .GENERAL ELECTRIC 1 RIVER ROAD, SCHENECTADY, N. Y. 12305 SUBJECT > '. 7 D A L I ;''tv. c -oV r.i 1j! 5-2261 COPIES: J.r. i'lcHiXiser Status Report -- Environmental Topics April 7, 1971 Mr. J.F. Young KE.. YORK Dear Jim, The following notes are offered for the status report you are preparing: REDACTED p 2. NIFCC r.eoort The following are highlights of the letters of oocment regarding the draft report, "The Use and Disposal of Electrical Insulating Liquids": Monsanto -- In substantial agreement.. .expand section on toxicology Westir.ghouse -- In general agreement; puts the problem in proper perspective; Suggest fuller treatment of solids problem, move petroleum ; data to an appendix... present for approval for publication at next sub-council meeting Texas Instruments -- Thorough ana well done...add detail to paragraph on incineration Standard Oil of tl=w Jersey -- Agree with main points...regards material on automotive waste as extraneous; remove and substitute reference to Arl report on used oil disposal.. All of the suggestions, except those of Standard Oil, are being accomodated in a redraft. Transfer of the automotive material to an appendix may somevaht mollify Standara Oil, but to foi.low their suggestion in its entirety v;ould be to remove the perspective on the problem which received favorable notice from other critics. * / J/S. Kelson 781922 NEL 000079 *1 asocial SabJet: EXXCZBIC&L mSOUTVK LZQOISS April 16, 1971 Hi. Thoeus fl Jickiw Technic! Director ... Hatloaal Industrial Fellation Central Canari1 0 S. Separtnent of Co m i c VublaitM 0 C. 20210 Dear Hr. Jackson: Enclosed la redrafting of the report, The Ose and Pispossi of Electrics1 fflyttlsripg Liquids, based upon the letter^of c M n t hick ya trenanittad to Hr. Janes T e a s vtth year letter of March 4, 1971, and upon ether consider ations. To facilitate the deliberations of the Xlectrlc and Hacinar Sut1Caune11, addition al coplea vili be brought to the April 21st nesting by Br. J F. HrAllister, ho vili bn attending in behalf of Hr. Tseng Very, truly your, lions a. anisen, consertane Product Enrlronneatal Compatibility Product Quality Staff _ JSRitr Em . ecs Hr. S. A. Jordan beesclit Assistant to Vice President vestlagbouan Electric Corporation 1801 n Street, SB Washington, D, C. 20006 v/enc. Hr. J. F. McAllister Manager-Product Quality Staff Geasral Electric Cenpsey 570 Loxlogtoa Avenue New York, I. 7 10022 v/eec Hr. J. 7 Yeang Tice President and Staff Executlva-iechaleal Baeoercae Gnearal Electric Coepsny 570 Lexington Asnean Nav York, M. Y. 10022 v/eee 781923 NEL 000080 THE USE AMD DISPOSAL OF ELECTRICAL INSULATING LIQUIDS Prepared by Technical Resources Division General Electric Company April 16, 1971 P NEL 000081 781924 1 the use and disposal of electrical insulating liquids Abstract Electrical insulating liquids (EIL), their application and disposal are studied against a background of similar information relating to petroleum' products in total. Naphthenic mineral oils are found to comprise over 80 percent by .volume of the total usage of EIL. Polybutenes are second, at almost 10 percent. Thus, 90 percent of EIL are petroleum-based. Being relatively non-toxic and biodegradable, they represent no environmental threat when subjected to conventional secondary waste treatment. The third largest-volume EIL group is the askarels, or polychlorobiphenyls. This group has some toxic properties and contains members which have recently become suspect ecologically. Accord ingly,' 'the report contains recommendations regarding the control and disposition of askarels. f NEL 000082 781925 2 INTRODUCTION this study of the use and disposal of electrical insulating liquids has been undertaken in support of the objectives of the Electric and Nuclear Sub-Council of the National Industrial Pollution Control Council- Its purpose is to examine electrical insulating liquids (EIL) for their possible toxicological or ecological impact and, as appropriate, to provide information which may lead to advice concerning government programs which would facilitate private sector efforts directed at environmental improvement, or voluntary actions by industry. Specific areas of interest include pollution which may occur from the plants where EIL are used in manufacture of electrical apparatus, and that which may occur during use or disposal. A variety-of'insulating liquids is used in electrical apparatus -such as transformers, circuit breakers, capacitors, and high-voltage cable in order to optimize, for each application, a range of design parameters typified by dielectric strength, losses, dissipation factor, arc and flame*suppression, heat transfer coefficient, and product life expectancy. Requirements and conditions to be met will, in a given instance,, quickly narrow the practical options available to the designer down to a very few or even to a single fluid. For this reason it should be borne in mind that, even though a particular electrical insulating liquid may be characterized as containing the potential of contributing to the pollution of the environment, the socially-desirable and economically correct action may lie in the adoption of precautions a n d control measures rather than in the'substitution .of - -j a material which would not perform the required function as well. 'r^ Representatives of many organizations, both in industry and in government, have contributed information and suggestions; their cooperation and helpfulness are acknowledged with thanks. 781926 3 1.0 Classification of Electrical Insulating Liquids While there are a great many types of electrical insulating liquids used for special purposes, such as scientific apparatus, there are only a few used in such quantity as to be of economic importance to the electrical industry and relevant to the subject of national pollution control. The specifications and general characteristics of the principar electrical insulating liquids (hereinafter referred to as EIL) are shown in Table No. 1 . ` 2.0.; .Quantities and Usage of EIL Six of the nine specifications listed in Table No. 1 are petroleum oils. Table No. 2 provides a breakdown of the principal uses of naphthenic~ mineral oils as insulating liquids. The information on transformer and cable usage is derived from the market estimates of several oil producers (10)*. Switchgear (circuit breaker) and capacitor data are estimated from knowledge of one manufacturer's usage and assumed market position (10}. The second column of data in Table No. 2, field use, may be taken as a measure of ..the. generation of waste oil during the use of the apparatus. The gallonage'shown represents direct shipment of oil to users of electrical apparatus, as distinguished from manufacturers. Make-up oil is seen to be about 17% of the total usage of naphthenic EIL. The waste percentage varies with the class of apparatus, being zero in the case of capacitors and highest in the case of cable. Table No. 3 is similarly derived and presents an analysis of the total quantity of EIL according to the apparatus in which it is used. The grand total of EIL used in the year 1968 is estimated to be 62 million gallons (or 1.5 million 42-gal. barrels). The subtotal consisting of the first two entries, naphthenic oil and polybutene liquid, is 57.26 million gallons (1.4 million barrels); thus, 91% of the total annual usage of EIL is petroleum based. The remainder is mostly askarels (polychlorinated biphenyls, abbreviated PCB). The chlorinated benzenes shown are not used alone, but as diluents for the askarels, in some applications, The category, Other, includes relatively small quantities of such materials as dibutyl sebacate and silicone oil, used in specialized apparatus of low production quantities. 3.0 Toxicology 3.1 Mineral Oils Naphthenic oils and polybutenes are essentially non-toxic. The only reported danger is from inhalation of vapor or mists, in which the maximum allowable concentration is 5 parts per million. Numbers in parenthesis are references to the Bibliography at the end of the renort. NEL 000084 4 .3.2 Toxicity and Safe Handling of Askarels (13) Inhalation At ordinary temperatures' the askarels have not presented industrial toxicological problems. The hazard of potential toxic exposure varies with their volatility: the lower-chlorinated, more-volatile ones present more of a potentialproblem from the standpoint of both inhalation and skin contact. When askarels are used at elevated temperatures, engineering controls must be applied, either by the use of closed systems or by effective local-exhaust ventilation together with general workroom exhaust. Vapor at room temperature should not be breathed in a confined space, and no vapor of any askarel evolved at elevated temperatures should-be' *. allowed to be dispersed into the general workroom. Inhalation tests on animals indicate that the maximum safe concentration of vapor is in the range of from 0.5 to 1.0 milligram of the lower-chlorinated askarels per cubic meter of air. The threshold limit values (maximum allowable concentration for an 8-hour working day) set by the American Conference of Government Hygienists are 1.0 milligram of the lower-chlorinated askarels per cubic meter of air and 0*5 milligram of the more-highly-chlorinated . compounds per cubic meter of air. -- Skin-Contact ;; 1 l ' W` 1 1 Schwartz patch tests on 200 volunteers showed that 547. chlorinated, askarel was neither a primary skin irritant or a sensitizer. Prolonged or repeated skin contact with askarels must be avoided by the use of gloves and protective garments, because of the possible occurrence of a condition called chloracne. Although reports of this condition caused by askarels are rare, it can be produced by excessive skin contact. If any askarel is spilled on the skin, the skin should be washed in the usual manner with a soap solution. A burn caused by contact with a hot askarel should be treated like any ordinary burn. Material adhering to the burned area need not be removed immediately, unless treatment of the burn demands it, in which case either soap and water or repeated washings with a vegetable oil are recommended. NEL 000085 4.0 Ecology 4.1 Mineral Oils Mr. Claude E. ZoBell has written, "Mineral oils are susceptible to microbial oxidation, and certain fractions undergo autoxidation. This seems to be Nature*s way of remedying oil pollution in soil as well as in sea water. In controlled laboratory experiments, we find that oil-oxidizing bacteria convert an average of 30-40 percent of the carbon content of hydrocarbons into bacterial cell substance or protoplasm." (14) 781928 5 Mineral oils and polybutenes are not known to have a long-time effect upon the ecology. In the short term, the effect of large scale spills has received considerable notice in the public press. Small amounts, in isolation, have no detrimental effects. The materials are biodegradable and exist naturally in the environment. Thus, consideration of possible adverse ecological effects arising from the use of mineral oil in electrical apparatus becomes primarily a matter of scale, rather than properties of the oil. 4.2 Askarels The askarels, particularly those with more than 50% chlorination, have recently been identified as a possible ecological threat to marine _ and bird life. The attention of the industry was called to this subject in a number of published articles and specifically in a widely-distributed letter from the Monsanto Company (sole U. S. producer) under the date of February 18, 1970. (11) Certain askarels introduced into eco-systems are believed to act in a manner somewhat analagous .to the persistent pesticides, being concentrated in successive links of the food chain. For the short term, effects of askarels may be kept from the environ ment by limiting applications to closed systems (of which transformers and capacitors are examples) and by the exercise of suitable precautions in the disposition of waste, as recommended in section 6.0. For the longer term, the producer is working to develop modified chlorinated biphenyls which will be biodegradable. This means that even if minute quantities are released to the environment by accidental spills the consequences will be minimal, and it will be possible to remove the modified materials from waste water streams in conventional secondary treatment facilities. (12) 5.0 Mineral Insulating Oil in Perspective In section 4.1 above, mineral oil is characterized as harmless to the environment if the amount released is not excessively concentrated in time or space. The data in the Appendix were assembled to place this matter in perspective. We find, for example, that the total use of mineral oil in electrical apparatus is about 0.03% of all oils (Table A-l); that total field make-up is approximately 0.005% of all oils. Perhaps a more realistic comparison is the one drawn in the Appendix, i.e., that total usage as insulating oil is equal to a small fraction - 10% - of the amount of used lubricating oil now being applied directly to land and stream. These comparisons do not lessen the need for prudent disposal of mineral insulating oil in accordance with accepted industry practice, but they do suggest a low action priority in the context of a national assessment of pollution problems in the electrical industry. P NEL 000086 781929 6 It is concluded that any recommendation at this time for:industry action on mineral oils would serve only to dilute the force of recommendations to be made in an area where greater leverage _e::ists_:_ the containment of askarels. _ __ . : :i 6.0 Recommendations In view of the suspected ecological hazard presented by state-of-the-art formulations' of polychlorinated biphenyls, it is recommended that the,electric cal industry employ the following guidelines in the manufacture and servicing of electrical apparatus: ` * ! _ i v - 1. Provision is to be made for qualified destru^tionoijPCB whste'1'_ materials, such that there will be no release of""materials" to the atmosphere or to ground or surface water significant from the stand point of toxicity or adverse ecological impact. Initially, the only process which appears to meet these requirements is incineration under carefully controlled conditions. With proper adjustment pf temperature, residence time in the incinerator, and other parameter's, products of combustion will be limited to HC1; C02,, and-H20 (in the form of steam). The hydrochloric acid may be absorbed in a scrubber- and the resultant solution neutralized with lime .tp, form-calcjLum. chloride solution, CaCH^. In the process;decrabe^,*thejpnly i to the environment will be a plume of steam, carbon dioxide-,"and brine, [ the discharge of which must be held to regulatory:limits: 2. All liquid waste is to be held in impervious-containers pending disposal. 3. Solid wastes contaminated by FCB's are to be*held in impervious containers ^'ending disposal or purging. Purging may be accomplished by cleaning with proper fluids. The resulting contaminated liquids,, may be incinerated as above. As the result of programs undertaken since the industry was first alerted to indications of ecological harm from PCB's, the industry has progressed a long way toward the implementation of these recommendations. At least two enterprises are accepting liquid wastes for incineration; facilities are being prepared for the processing of contaminated solids; evaluations of improved formulations are in progress; and a committee of the American national Standards Institute has been authorized to conf.ider what standards may be appropriate. NEL 000087 781930 TABLE NO. 1 CLASSIFICATION OF ELECTRICAL INSULATING LIQUIDS _______ Application_____ ______ Specification_____ Combustible' Transformers, Oil Circuit Breakers ASTM D1040-69 FED W-I-530a (Note 1.3) Capacitors, Cable ASTM D2297-68 Capacitors, Cable ASTM D2296-68 . Cable, Low Pressure ASTM D1818-63 Cable, High Pressure ASTM D1819-66 Noncombus tible Capacitors ASTM D2233-68 (Note 2) . Transformers, Capacitors ASTM D2283-70a (Note 1.1, 1.2, 2.0) FED W - 1 - 1219 (Note 1.1, 1.2, 2.0) _____ Type of Material Naphthenic mineral oil Naphthenic mineral oil: Polybutene oil* Naphthenic mineral oil" Naphthenic mineral oil Polychlorinated biphenyl Polychlorinated biphenyl mixtures with diluents Notes : 1.0 Certain grades contain small quantities of additives which serve as antioxidants and/or scavengers for hydrogen chloride. Commonly used materials and typical concentrations are: 1.1 dicyclo-diepoxy carboxylate 0.147. 1.2 phenoxypropene oxide 0.22% 1.3 2,6 ditertiary butyl p-cresol 0.15% 2.0 Certain grades contain trichlorobenzene and/or tetrachlorobenzene as diluents. SS0000 781931 TABLE NO. 2 USE OF NAPHTHENIC OIL AS AN INSULATING LIQUID U.S., 1968 Millions of Gallons Apparatus Transformers Switchgear Cable Capacitors Total' Original Equipment Use Field Use (Make-up) Total ; -Percent of Total 39.13 2.07 7.57 .40 46.70 ; ;T 2.47 ; k 92.0 r. 4.9 ^ 1.05 .02 42.27 .52 1.57 f 0 : *02 3.1 ----- 8t 49---- -- 50.-76* ! q 100 NEL 000089 *1.21 million 42-gal. barrels 781932 TABLE KO. 3 QUANTITIES AND USES OF PRINCIPAL INSULATING LIQUIDS IN THE U.S.. X968 Millions of Gallons Liquid Trans formers SwitchCapacitors gear Cable Other Liquid, Total % of Total Naphthenic Mineral Oil 46.70 2.47 .02 1 .57 .30 51.06 82.4 Polybutene Liquid 6 .20 6.20 10.0 Askarels (PCB) Chlorinated Benzenes 1.35 .79 2.46 .01 3.81 6.1 % .80 1.3 Castor Oil .10 .10 .2 Other .01 .02 .03 Total 48.84 2.47 2.60 7 .77 .32 62.00* 100.0 Use, Percent of Total 78.8 4.0 4.2 12.5 .5 100.0 *1.48 million 42-gal. barrels 2 tn r1 781933 060000 appendix TOTAL FLOW OF PETROLEUM PRODUCTS Because a high percentage of the total-.wiume^.of7electrical insulating liquids is petroleum based, the use and disposition of EIL can best be understood against a background of the quantities of petroleum products used throughout the economy, and how they are disposed of. Table No. A-l displays the quantities and uses of petroleum products in the U. S. for 1968 (the most recent year for which relatively complete data could be searched out). This Table is useful in providing a perspective for the viewing of the consumption of electrical'insulating oils. 'Item 3.12, Electrical ' Insulating Oil, is the total of naphthenic and-polybutene EIL,.and corresponds to only 0.04% of "all oils". _ Disposal of Oils Similar to Electrical Insulating Oils Lubricating oil (Item 3.7 of Table A-l),was chosen for a comparative,study because of its similarity to elctrical insulating grades of petroleum oil. Although no national study has been made,; data are available (3)* from which a reasonable-estimate can be formed of what happens to lubricants throughout their life history, on a nation-wide scale. Lubricants may be classified conveniently- in two groups: automotive and industrial. Table No. A-2 is an estimate of the usage, waste generation, and disposition of automotive lubricants throughout the country, and Table No. A-3 presents similar data for industrial lubricating oils. A large portion of the waste generated is collected by scavenging firms, and the fate of this portion is indicated in Table No. A-4, Table No.. A-5 summarizes the results of the investigation of lubricating oil waste practices. It -will be noted that a little over half o f `all lubricating oil ends as waste, and of this half, more than half is dumped on the ground in one way or another -- as locally disposed waste, as road oil, in town dumps, etc. The concern of the petroleum industry for this situation, and the- vigorous steps being taken to evaluate its effect and to devise ameliorative procedures, where indicated, is the subject of another study. See Final Report of the Task Force on Used Oil Disposal. American Petroleum Institute (9). For the purpose of the present study, it may be pertinent to note that the total usage cf petroleum-derived insulating oils (1.4 million barrels) is equal to one-tenth of that portion of waste lubricating oil being dumped on the ground or sewered, according to available estimates of current practices. NEL 000091 * Numerals in parenthesis are references to the Bibliography. 781934 TABLE NO. A-l QUANTITIES AND USES OF PETROLEUM PRODUCTS IN THE_JJ.S., 1968 Use Category Millions* .of--42-gallon 3arrels 1.0 Heatins and Enerev Conversion 1.1 Electric Utilities 1.2 Heating 1.3 Industrial 1.4 Oil Companies 1.5 Off H'w'y Diesel 1.6 Military (excl. Jet) 1.7 Fuel for all other Total 2.0 Transportation 2.1 Railroads 2.2 Highv?ay Diesels 2.3 Motor Vehicles 2.4 Piston Aircraft 2.5 Jet Aircraft 2.6 Ships bunk'd in US Total Kero- Distil- Resid- sene late ual Gaso- Jet line Fuel Other Total 7. 76.2 ?6.7 102.9 3.0 . 512.0 45.8 9.4 49.5 12.6 12.6 644.9 185.0 173.0 135.7 39.3 35.0 8.3 576.3 *- .. . - 188.0 761.2 181.5 48.7 49.5 47.6 47.6 1324 J. 27.0 - 84.1 4.3 127.3 1925.4 30.6 349.4 18.2 87.6 0 229.6 91.9 1956.0' 349.4 88.4 127.3 1925.4 30.6 349.4 105.8 2626.9 fi53.6 3.0 Material Conversion and Other 3.1 Liquified Gases 3.2 Still Gas 3.3 Asphalt 3.4 Petrochem. Feedstocks 3.5 Coke 3.6 Ethane, Ethylene 3.7 Lubricants 3.8 Special Naphthas 3,9 Not Elsewhere listed 3.10 Road Oil 3.11 Wax 3.12 Electrical Ins. Oil Total 000 330.6 330.6 149.8 149.8 141.2 141.2 92.9 92.9 *76.3 76.3 55.2 55.2 48.5 48.5 27.0 27.0 16.4 16.4 ' 7.1 4.4 L.4 7.1 4.4 1.4 0 0 950.8 950.8 19.4 4.0 Grand Total 102.9 874.5 668.2' 1956.0 349.4 950.8 4901.8 100.0 The basic reference for the fuel oils is (A.2) (see BIBLIOGRAPHY); for gasoline and jet fuel (a blend of gasoline, kerosene, and distillate), (6); "Other", (6), (4.4) and (10). Some figures from other sources have been adjusted to yield totals in "final summary", reference (4.4). 781935 % ffl ' r1 o oo * O- vo to TABLE NO. A-2 LUBRICATING OIL -- AUTOMOTIVE ESTIMATE OF USAGE. WASTE GENERATION. AND DISPOSITION IN THE USA (Following the pattern observed in the Commonwealth of Massachusetts) 1968 User Service Stations Performing Oil Changes (1) User (2) Calc. Distri U.S. bution, Usage at (3) (4) (5) 7. Waste, % of End Million (4) ing as Gallons Col (6) (7) (8) Was te Was te Dumped col uncol on lected, lected, Ground % 7. in (1), Nas te Million lected Mil. Gal. Mil. Gal. Mil. Ga 1 Gallons 54.9 658 63 415 87.7 364 51 45 (9) Sewered, Mil. Gal. 6 , Other Svc. Sta. 1.6 19 0 0 0 0 0 0 0 Car Dealers, Garages 16.1 194 90 175 '88.0 154 21 20 1 Fleet Operators 18.8 226 63 142 60.0 86 56 52 4 Do-it-yourself Oil Changers 5.4 65 63 40 0 0 ?/ 40 37 3 Agriculture & Marine Users 3.2 38 50 19 0 0 19 18 1 , Total 100.0 1200 -- 791 -- 604 187 172 15 The total U.S. usage, 1200 million gallons (28.6 million barrels) is derived from a 1967 survey by the Bureau of the Census -- see Sources of Information, reference (7), The total was adjusted to 1968 usage by means of information in reference (4.4). Percentage distributions and disposal patterns are drawn from a survey made by the Arthur D. Little Company in the Commonwealth of Massachusetts, reference (3). Applying the Massachusetts pattern to the USA as a whole involves errors of unknown magnitude: a staff estimate by the FWQA yields a figure of 350 for the first entry in column (4) above (reference 2), an estimate 15.7% below that derived here. The American Petroleum Institute (reference 9) terms the ADL study "indicative of present disposal practices". NEL 000093 781936 LUBRICATING OIL -- INDUSTRIAL ESTIMATE OF USAGE. WASTE GENERATION. AND DISPOSITION IN THE USA (Following the pattern observed In the Commonwealth of Massachusetts) 1968 (Millions of Gallons) Use Category Lubricating Oil (1) Distribution 7. (2) Calc. US Usage (3) 7. Waste (4) Voi. of Waste (5) 7. Collect. (6) Voi. Coll. (7) Voi. Un collect'd (8) 7. Burned (9) Vol. Burned (10) 7. Sewered (11) Volume Sewered 51.0 426 35 149 Hydraulic Fluid 27 .A 229 20 46 Straight Cutting Oil 10.5 88 30 26 * Soluble Cutting Oil 11.1 93 30 28 100 28 Total 100.0 836* 249 76 189 60 1.2 3 28 781937 Data in columns (1), (3), (5), etc. are from the A.D. Little report, Bibliography Reference (3). * Bureau of Mines total lubricants, less automotive use from Table No. A-2. ^600001 3 N t r* m o u* TABLE NO. A"4 FATE OF COLLECTED WASTE OIL Estimate of U.S. Disposal Practices Based on Massachusetts Pattern Final Disposition Reprocessed to Fuel Oil or Re-refined Used as Road Oil 1968 Millions of Gallons Automotive Percent Volume (1) Industrial Percent Volume CD Total Volume Collected Waste Lube Oil 69.1 417 -- -- 417 21.7 131 52.6 100 231 Used on Farms 4.6 28 -- -- 28 Disposed of Locally (Town Dumps or Local Roads) 47.4 89 89 Unknown 4.6 28 -- -- 28 Total Collected 100 604(2) 100 189 O ) 793 (1) Study of Waste Oil Disposal Practices in Massachusetts, Ref. (3). (2) Table No. A-2. (3) Table No. A-3. NEL 000095 781938 TABLE KO. A-5 FATE OF WASTE LUBRICATING OIL U,S.. 1968 Summary of Estimates in Collected and Uncollected Categories Ultimate Fate Dumped or Applied on Ground Volume, Millions of Gallons Volume, Millions of 42-gal. Barrels Distribution, Percent of Total Lubricating Oil Used 549 13.1 27 poured into Sewers 43 1.0 2 Reprocessed, Re-refined, and/or Burned 420 10.0 21 Unknown Total Ending as Waste 28 1040 0.7 24.8 1 51 Total Used, as Memo Item 2036 48.5 100 J L 000096 781939 bibliography 1. 2. 3. 4.0 4.1 4.2 4.3 4.4 4.5 4.6 4.7 5. 6. 7. .8. 9* 10. 11. 12. 13. 14* Environmental Quality, The First Annual Report of the Council on Environmental Quality. U. S. Gov't. Printing Office, August, 1970. Clean Water for the 1970's. A Status Report. June, 1970, U. S. Dept, of the Interior, Federal Water Quality Administration, U. S. Gov't. Printing Office, Study of Waste Oil Disposal Practices in Massachusetts. Report to Commonwealth of Massachusetts, Division of Water Pollution Control, January, 1969, C-70698, by Arthur D. Little, Inc. Mineral Industry Surveys. U. S. Department of the Interior, Bureau of Mines, Washington, D. C. 20240. Idem. Petroleum Statement, Monthly, March 18, 1969 (Preliminary) Idem. Fuel Oil Shipments, Annual, Sept. 17, 1969 Idem. Liquified Petroleum Gas Shipments, Annual, Oct. 13, 1969 Idem. Petroleum Statement, Annual, Dec. 16, 1969 (1968 Final Summary) Idem. Petroleum Statement, Monthly, March 24, 1970 Idem. Asphalt Shipments, Annual, June 11, 1970 Idem. Liquified Petroleum Gas Sales, Annual, September 30, 1970 Statistical Abstract of the United States. 1969, Table 758. U. S. Department of Commerce, 1969 Business Statistics, pp 167, 168, 169 Sales of Lubricating and Industrial Oils and Greases, 1967. Nov. 21, 1968 Series MA-29C(67)-1, U. S. Department of Commerce, Bureau of the Census, Industry Division, Washington, D. C. 20233. Cleaning our Environment: The Chemical Basis for Action (book) American Chemical Society, Washington, D. C. 1969 Final Report of the Task Force on Used Oil Disposal. American Petroleum Institute, 1271 Avenue of the Americas, New York, N. Y. 10020 General Electric Company, unpublished studies. Letter to Electrical Industry from Monsanto Chemical Company, February 18, 1970. Congressional Record - House H10214, October 14, 1970. Monsanto Company, St. Louis, Missouri. The Occurrence. Effects, and Fate of Oil Polluting the Sea. Int. J. Wat. Poll. Pergamon Press 1963, Vol. 7, pp 173-198. Printed in Great Britain. NEL 000097 781940 8*233-2261 August 6, 1971 r.J. Young - HEW YORK J. F. McAllister - HEW YORK B. L. Bash - PITTSFIELD v/att Mr. Robert B. see Vice President 6 General Manager Power Transmission Division General Electric C f | w y 6 Bast Baltimore Pile Media, Pa. 19063 Dear Nr. Absss Enclosed is a copy of a MXPCC Subcouocll report on the use and disposal of electrical Insulating liquids. You will note that the recomoendatlona (page 14) follow those of your task force on PCS. Very truly yours U J* S. Halsou, Consultant JSRler Att. NEL 000098 781941 TECHNICAL RESOURCES G E N E R A L ELECTRIC 1 RIVER ROAD. SCHENECTADY, N. Y. 12305 SUBJECT D IA L Co n 8*235-2261 MONTHLY ACTIVITIES REPORT J , S . N e l s o n _______________________ COPIES; FS Hothe September 1, 1971 Mr. J. F. McAllister NEW YORK Redacted f NEL 000099 3 Congressman Ryan's bill H.R.. 8576 has been the subject of a recommendation by the Capacitor Department that NEMA assume a position of opposition. Now Congressman Ryan, citing recent chicken and egg contamination, has introduced a stronger bill, 11.R. 10085, v/ithout the exemption provisions of the earlier bill, concerning which a similar representation has been made to NEMA (letter attached). 781942 G E H E R A L 0 ELECTRIC Mr. J. F. McAllister 2 redacted September 1, 1S71 A NEL 000100 Att. 781943 1, "*# V' v 1, ' " E C : L , F . 4 Uj ^ i . J . r>. E J . F. U rpko, Sy August 20, 1071 o Mr. Barnard 11. l?alk national Electrical Manufacturers Association 155 Knot AVdy-iitreet Mow Voi:!;, re*:/ York 10017 / Osar Mr. Falk: Von should have received our coeraoaUs on 11.1-;. 575 in n y letter to you dated August 15, 1571. Yhe latest proposed legislation, H.R. 100G5, # calling for total banning of 153*3 has just cccic to viy attention. Our position hero in the In-dustrial end Ferrar Cnpactor i'roducts Department of Ccaercl Flee trie continue e to bs to oppose eny lcgioletion which bane the use of cnpscitar-graUe A scarel in scnlcd capaciter. Cur primary basis for fchi3 opposition has becn set forth in tsy lctter to you of August 15, 1971. 7o amplify our position further, there io no Icnovm impregnane for capacitors which can be directly interchanged with capacitor-grade Asherels. Any such substitution generally would require a much larger capacitor with an unproven reliability end long tor safety experience. Since the largest t-iraber of Askarcl-impregnated capacitors arc used as components in other systems, this would fur idler force a redesign to a raueh larger system. For examples existing bnlleets could no longer accept the larger capacitor, and the larger ballast would in turn necessitate a redesign of lighting fixtures. The economic penalty would be compiotoly out of proportion to the seriousness of the problem it seeks to solve. Sincerely yours, * i A. Posefsky Man ngcr-Dngincoring /c NEL 000101 781944 MONTHLY ACTIVITIES REPORT J. S. Nelson_____________ October 29, 1971 Mr. J. F. MeA1II*ter NEW YORK F. S. Rothe ( REDACTED NEL 000102 781945 Mr. J. F. McAllister 2 October 29 1971 6. PCB A meeting vas held with interested parties from Pittsfield, Hudson falls, and RKCO to plan a data collection progran leading to an up-to-date status report on measures taken to avoid FCB contamination. Included will be a statement on the reasons for using PCB in electrical equipment (of possible usefulness to NEKA). J^~ S. Belaon JSN:sv NEL 000103 781946 TECHNICAL RESOURCES GENERAL ELECTRIC 1 RIVER ROAD. SCHENECTADY. N. Y. 12345 SUBJECT DIAL COMM 8*235-2261 T A S K FORCE' ON CONTINUATION OF PCB USE December 17, 1971 Messrs. O. H. LeBlanc, Jr. j ^A. Pozefskyi> E. L. Raab E. L. Simons -- /> // COPIES: AE Peltosalo WA Schlotterbeck CJ Meloun TA Vanderslice LP Hart, Jr. EL Dobbins DJ Voss M. Drucker JF McAllister JS Anderson AM Bueche JF Young RJ Boudreau tri:i K l*vtr ~?-lt L, Task Force Objective On December 15, 1971 a meeting occurred between corporate representatives of Monsanto and General Electric Company to.discuss conditions under which Monsanto will continue to supply polychlorinated biphenyls (PCB) as a dielectric and coolant in sealed-electrical"apparatus; Reference is made to the memorandum of that meeting issued by J;,F. McAllister '(12/15/71).* This is a statement of the work now contemplatedf.as'-neessary-to execute Task #1 and Task #2-as.identified in that ?}. memorandum, viz.: ' tii ' .. Task #1 - General. Electric Risk/Benefit Analysis Task #2 - Statement of Public Need, for submission to the Office of Science and Technology (O.S.T.) For each task, it is expected that responsive information will need to be generated for each of the product classifications involved (i.e.*, transformers, power capaci tors, and small industrial capacitors), after which the product-oriented findings mush he^melded into, the two final reports constituting the output of the task force. Structure of Task Force and Deployment of Resources Our proposal for the structure and membership of the Task Force is diagrammed as Exhibit I (attached). It contains two "product" teams (capacitors and transformers) and assigns responsibility for consultation, liaison, and final report writing. The proposed product team structure involves Che premise-that each team chairman will be able to call upon whatever Group specialists are required for task accomplishment. It is evident that support will be .needed from persons involved in such activities as strategic business planning and marketing, as well as engineering. . As noted above, each product team (headed, respectively, by Pozefsky and Raab) will provide material both for Task 1 and Task 2. A preliminary description of the content of the reports to be generated is given in Che accompanying Exhibit 2 and Exhibit 3. Each team will be assisted by Dr. LeBlanc in achieving the degree of documentation and the basis for credibility appropriate to corporate-level review (in the case of Task 1 information) and review by the prominent scientific personnel of O.S.T. (n 7 the case of Task 2 information). Mr. Nelson will serve a liaison function as a member * Copy attached for those not on original distribution. NEL 000104 781047 3?. GENERAL ELECTRIC Messrs* 0. H. LeBlanc, Jr. A..Pozefsky. E * -I**, M lC in - o i i E. ilw^simons^ -2 ... V-* ' --- ;:r - '' December 17, 1971 ' V ' : "**! ........ ' .. ................ . . of each product team and assist Dr. Simons with the organization of the final reports. The Time Element The first orderrof business must bd th accomplishment of ;Task 2 . ' Because a "government position news''release.." is anticipated fffcbm~0.*S;T. (or possibly from the Interagency Task Force on PCB^using inputs-from* O.'SiT.) within 30 days, it is apparent that for.our contribution to be properly assimilated, it must be submitted to O.S.T. in about two weeks from the date of the Monsanto meeting; i.e., January"1, 1972. This leaves precious little time, with the seasonal holidays intervening. Accordingly,..Task 2 must receive priority, with Task 1 appropriately following a few weeks later. Initial Task-FofoiferMeeting ^ `;>ttrLj. t -- >:>i rVt. ., ' -.. .* -- *; ' The first meeting is .called -by-Chairman McAllister f-orf-Manday,.December 20, at 9:30 a.m. in Schenectady, Building 36, Room 505; . Work .statements, assignments, and schedules are to be firmed up. Jlo/6. Nelson, Consultant Product Environmental Compatibility JSN:ev Att. NEL 000105 781948 TASK FORCE DM CONTINUED USE OF PCB EXHIBIT I NEL 000106 *To serve in liaison capacity as a member of each team. 781949 EXHIBIT II TASK #1 - GENERAL ELECTRIC RISK/BENEFIT ANALYSIS Products Involved: Transformers Power Capacitors Small Industrial Capacitors la Review what has been done: a. In-plant controls and disposal provisions b. Clean-up of accumulated wastes c. Instructions, reviews, audits of users d. Change in formulation of PCB (biodegradability) 2 Review future necessary actions a* Investment in plant, new operating processes, disposal technology b. Actions with users - information conditions of sale provisions for returns * 3. Differential Between Risk of Continuing vs Stopping -- i.e., existing vs* incremental exposure 4. Risks vs. Benefits; Benefits in sales, profits, market share Risk in terms of liability suits and their nature, number and magnitude -- in light of alternatives. , 5. Evaluation of Business Results of alternative dielectric/coolant design solutions NEL 000107 781950 EXHIBIT III TASK #2 - STATEMENT OF NEED (Public Eisk/Benefit Analysis for submission to O.5.T.) Transformers Power Capacitors Small Industrial Capacitors 1. Description of the applications. 2* Description of properties of PCB's which make them essential to the applications, e.g.: system stability systsn reliability non-flammability code requirements size system cost 3. Nature of hazard involved - related to product/application/degree of chlorination: environ mental consequences of continued use - biodegradability and paths to reach the environment - closed, concentrated, controllable applications vs. distributed r applications 4. Impact on users and the public of the use of alternative dielectric/coolant ' design solutions. 781951 - N E L 000108 1 2/15/71 M eeting with M onsanto R e p re se n ta tiv e s re P C B 's ATTENDANCE MONSANTO GENERAL ELECTRIC E. J. P utzell V . P . 8t C o rp . C o u n se l Howard B urgen M gr. -Specialty P roducts' W inthrop C orey M gr. -F unctional P roducts John M ason A rthur E. P eltosalo W aiter A. Schlotterbeck C h arles J. M eloun Thom as A. V anderslice Lucas P . H art, J r. E. L. Dobbins Donald J. V oss M argerie D rucker John F. M cA llister M r. P u tz e ll began by indicating th at the num ber and m agnitude of su its being bro u g h t ag ain st M onsanto as the n atio n 's sole su p p lier of P C B 's h as n e c e ssita te d re a p p ra is a l of the ex ten t to w hich they should serv e the m a rk e t involved, and u nder w hat conditions. He m entioned th at they a re now involved in a su it in T ennessee seeking $62 m illio n dam ages, of w hich about $50 m illio n as punitive d am ag es. M r. M ason b riefly su m m arized the background. He pointed out that PCB takeup by fish and b ird s w as f ir s t rep o rted by Sw edish sc ie n tists in 1966, and th at la te r w ork by D r. R.obert R isebrough, of the U n iv ersity of C alifornia, identified PCB as a cause of egg sh ell thinning. He cited som e recen t episodes w here, b ecau se of accid en tal spillage, o r contact betw een PCB containing m a te ria ls and anim al feed, high PCB concentrations w ere observed in dow n-chain locations o r o rg an ism s. He stated that in view of the com bination of public concern and unknowns involved, M onsanto discontinued supplying P C B 's to "o pen-ended" ap p licatio n s in m id -7 0 , and has now decided to d isco n tin u e sales fo r use as a th erm al fluid even in "clo sed " app licatio n s. He pointed out th at th is la te st d ecisio n w ill affect a t le a st six GE locations (M orrison, H endersonville, F t. W ayne, M adisonville, E dm ore, and M t. V ernon). M r. P u tz e ll stated th a t w hile M onsanto p la n s to continue supplying PC B fo r c lo se d -sy ste m e le c tric a l ap p licatio n s only, in view of the ris k s involved they w ill do so only if th e ir c u sto m e rs a g re e to indem nify, and have fin a n c ial re s o u rc e s ad eq u ate to e ffectiv ely ind em n ify , M onsanto ag ain st su its a risin g fro m leakage of PCB into the en v iro n m en t. He then offered a statem en t of conditions, o r "u n d ertak in g s" (copy attached) w hich p u rc h a s e rs m u s t sign in o r d e r fo r M onsanto to c o m m it to d e liv e ry . NEL 000109 781952 -2- M r. M ason stated that M onsanto re c e n tly d isclo sed sale s volum e in f o r m a tio n f o r th e l a s t 11 y e a r s to a n O ffice o f S c ie n c e an d TechnologyT ask F o rc e . He pointed out th a t th ese w ere quite clo se to the e stim a te s re p o rte d in the NEPCC book let "T h e Use and D isp o sal of E le c tric a l Insulating L iquids. " He stated th a t w h ereas a to ta l of 42, 000 tons w as p ro d u ced in 1970, only 21, 000 to n s w ill be shipped in 1971, and sm a lle r am ounts still in future y ears. He stated that inasm uch as future p ro duction w ill involve o p eratin g a t a low fra c tio n of p la n t capacity, it w ill b e n e c e s s a r y to i n c r e a s e u n i t 'p r i c e s f r o m 15 to 20 c e n t s / l b . He a d d e d that "p ro fit m otive is no longer a facto r in this b u sin ess. " A s to the OST T ask F o rc e , h e stated th at its C h airm an w as anxious to se c u re , a t the e a rlie s t opportunity, statem en ts fro m e le c tric a l m a n u fa c tu re rs as to why continued PCB u sage is n e c e ssa ry . E v id en tly ,th is m a tte r is now receiv in g th e ir e a rn e s t co n sid eratio n , and w hile a form al re p o rt cannot be expected for 2-3 m onths, M r. P u tzell was of the opinion th at th ere m ig h t be a "g o v ern m en t p o sitio n new s re le a se " w ithin 30 d a y s. A fter the M onsanto re p re se n ta tiv e s left, it w as ag reed that G en eral E l e c tr ic sh o u ld re e x a m in e th e m a tte r , an d s p e c ific a lly (1) p r e p a r e a ris k /b e n e fit a n a ly sis, fo r p ro d u c ts of the two G ro u p s involved, of co n tin u in g to s e r v e a s s u p p lie r; (2) p r e p a r e a s ta te m e n t fo r th e O ffice of Science and Technology a s to the ro le of PC B in satisfy in g im p o rta n t public n eed s; and (3)p re p a re a re sp o n se to M o n san to 's p ro p o sed new "conditions of sa le s." M r. Schlotterbeck accepted responsibility for integrating as a p p ro p ria te 'a n d effectin g ite m (3); M r. M c A llis te r, s im ila rly , fo r ite m s (1) an d (2). ft J FM cA lii s te r 12/15/71 D istribution: A ttending GE R ep resen tativ es J . S. N e ls o n E . L. F.aab A. Pozefsky NEL 000110 781953 Draft Subject; Benefits of FCB Use December 29, 1971 Dr. Edward J, Burger, Jr. Executive Office of the President Office of Science and Technology Room 4224, New Executive Office Building Washington, D. C. 20506 Dear Dr. Burgers Accompanying this letter is a statement describing the benefits to the public arising from the use of polychlorinated biphenyls in the electrical industry. It is submitted in response to your invitation to prepare material for the consideration of the Office of Science and Technology in supporting the work of the Interagency Task Force on FCB. Whereas there is a growing body of literature on the putative ecological impact, wide dispersal, and toxicology of this class of materials, nowhere do we find adequate treatment of the unique properties which have occasioned its use in electrical apparatus, nor of the advantages in safety, performance, and economy which have ensued. Our paper is offered to help remedy this lack and thereby assist in arriving at a balanced comparison of public risk with public benefit. There is ample indication that the environment-carries a significant burden of some forms of FCB. This burden derives, we are convinced, in some measure from the untutored waste disposal practices of the recent past, but principally from the nonelectrical uses (e.g., as plasticizers in paints and plastic materials and as hydraulic and heaftransfer fluids in industrial machinery). It is our belief that the pattern of restricted use, process control, and waste disposal engineering now being put in place by voluntary industry initiatives in the U.S. and England will, if adopted also in other FCB-producing countries, prevent significant increase in this burden. The key feature of this program is to limit application to sealed electrical NEL000111 781954 Dr. EJ Burger, Jr. - 2- December 29, 1971 apparatus. Our calculations indicate that the portion of electrical FCB possibly reaching the environment from field disposal and repair activities is being rapidly reduced and may be already below 1% of total electrical industry usage in the United States. In the near future, this class of waste should be the only category remaining, as effluent from manufacturing plants approaches zero and the nonelectrical applications are cut off at the source. The residual field waste from electrical apparatus is Itself subject to further improvement, and ways to accomplish this are now under study by the 0-107 Committee of ANSI. If these efforts succeed in preventing an absolute Increase in such discharges as the power industry continues to grow, the contribution to the nation's total _ environmental burden would be so low as to require more than a thousand years to double the burden. To the extent that this assessment is confirmed by further study and future developments, it would appear_that we need have less concern for the technical problem itself than for the possibility of legislation or regulatory rulings which fail to take into*account the exceptional position of the electrical industry or the public benefits which would fall victim to any undifferentiated prohibition of FCB use. Please let us know if you or your colleagues desire more information on any of the points covered in the statement, or clarification of any obscurities, and we shall do our best to supply the deficiency. Thank you for the opportunity to introduce formal consideration of PCB benefits into the deliberations on this important public question. Very truly yours, JFM/ J. F. McAllister Manager-Product Quality Corporate Executive Staff General Electric Company NEL 000112 781955 U ffm im S S . u,*. iffZ TECHNICAL RESOURCES g e n e r a l ELECTRIC 1 RIVER ROAD. SCHENECTADY. N. Y. 12345 SUBJECT > D I AL COMM 8*235-2261 Participation in "Industry Working Group on FCBM fNIFCC) c COPIES: J. F. Young,.- ,NEW YORK J. F. McAllister - NEW YORK A. Pozefsky - HUDSON FALLS January 10, 1972 To: GE Task Force on Continuation of PCB Use, Messrs, O, H.'LeBlanc, Jr, R. J, Boudreau .--T. E. L. Raab E, L. Simons <> ^ 'V* In late December, Mr. Russell Train, Chairman, Council on Environmental Qualityj" asked the National Industrial Pollution Control Council for a statement sub stantiating the necessity for use of polychlorinated biphenyls in closed system electrical applications. NIPCC assigned this task to the Electrical and Nuclear Sub-Council (of which Mr, Bon Burnham is chairman, and Mr. Fred Borch is vicechairman), on December 20. The Sub-Council, in turn, formed an ad hoc Industry Working Group on PCB to deal with this matter.' The Working Group consisted of.: F Samuel A. Jordan, E. R. Boquist, and L. Ifemdelcorn of Westinghouse; Charles W. Metter of McGraw-Edison; B. B. Burton of The Bendix Corporation; and James S. Nelson of General Electric. Meeting with the working group on January 4, 1S72, in-the Commerce Building, Washington, D. C. were the following: W, Patrick Morris, Commerce Department (attorney); Walter A, Hamilton, Executive Director, NIPCC; Thomas W. Jackson, Technical Director, NIPCC; and Robert W. Cairns, Deputy Assistant Secretary for Science & Technology, Department of Commerce (representing Commerce on the Inter-departmental Task Force on PCB) (part time). Mr. Hamilton explained to the group the request from Mr. Train for a Sub-council statement. He indicated that the request was motivated by a need to support the work of the Inter-Departmental Task Force on PCB, The Inter-Departmental Task Force, in Hamilton's view, has probably decided what it wants to say, but realized late in the day that it was weak on documentation of its proposed position, and was therefore "scurrying to fill in the record". Dr. Jackson defined the objective of the Industry Working Group "to produce *a draft, today, acceptable to NIPCC". 781957 NEL 000113 G E N E R A L ! ELECTRIC GE Task Force on Continuation of PCB Use -2- January 10, 1972 Dr. Cairns spoke briefly to the Group about the work of the Inter-Departmental Task Force, leaving the impression that the Task Force has not yet determined whether or not it will be issuing a formal report on PCB (or accomplish its coordination function in less formal ways) He gave the impression of "having done his homework?'in achieving familiarity with PCB applications. He said that what was needed from N1PCC was a statement concerning the unique qualities of PCB serving safety and other system requirements, and the lack of a suitable substitute. ` Mr. Jordan (who is Mr. Burnham's technical representative on the Sub-Council) took charge of .the meeting at .Hamilton's invitation. He distributed copies of a V7estinghouse working paper on PCB and copies of the GE letter to Dr. Burger with our report attached. (I was pleased to note that Dr. Cairns picked up copies of both of these papers and put them in his PCB folder before leaving the meeting')'. The Westinghouse paper (which Dr. Simons has mailed to you) is the work of Ed Boquist and Lyon Mandelcorn of Westinghouse. Mr. Jordan suggested that the group evolve from these two- inputs a NIPCC document: which would draw freely from both. He suggested that this melding be accomplished by Boquist, Mandelcorn and Nelson, while the rest.of the group would "go out and read the Wall Street Journal" so as to permit more efficient wprk by a smaller group. This was done, with the result evident in ther attachments' to this Metier. The Working Group reconvened about six o'clock to approve-.the draft, which was then mailed out the following day. You will recognize much of Dr. Simons' (and your own) prose in the attachment. In essence, it is an executive summary of the Simons report, with illustrative material and a paragraph or two from the Westinghouse paper. Thus, we now have several paths by which the electrical industry needs and view point may reach the Inter-Departmental Task Force: The GE statement through Dr, Burger of OST and through Dr. Cairns; the Westinghouse working paper through Dr. Cairns; the NIPCC-paper through Commerce and CEQ. It is not clear at this writing whether we will be permitted a further occasion for communication of this material; but, in any case, Mr, McAllister has suggested it would be appropriate to stand back and look at what we did under forced draft and see if we can improve on it. Dr. Simons has written to you for your suggestions in this regard. Parenthetically, let me remark that corrections for the errors contained in our typescript (a couple of decimal points and the name of McGraw-Edison) have been given to Dr. Burger by telephone. He said he was very pleased to have our report, but "had not finished reading it", (This, on January 5 -- so multiple paths to the task force may be a very good insurance^) It is proposed that we wait a week or so for some indication of the formal position to be taken by the various government agencies involved before proceeding with what we have identified as Task One, the GE Risk-Bere fit Analysis. Thank you all.for your good work. Everyone in the Industry Group in Washington was full of praise for the GE report. S. Nelson, Consultant foduct Environmental Compatibility SN:cv Attachments NEL 000114 781958 U.S. DEPARTM ENT OF CO M M ERCE National Industrial Pollution Control Council Washington, D.C. 20230 ;>.*i'-" 5 January 1972 MEMORANDUM TO: Industrial Worx Group on PCB SUBJECT: R eport e n t i t l e d "The Need f o r Continued Use o f P o ly c h lo rin a te d B iphenyls as E l e c t r i c a l I n s u l a t i n g ........ liquids " I would lik e to ta k e th is o p p o rtu n ity to thank you f o r a v e ry e x c e lle n t job in p u ttin g to g e th e r ` he su b jec t re p o rt. A copy i s enclosed fo r your use. The re p o rt has a lre ad y en forw arded, as advance c o p ie s , to th e a p p ro p ria te p eo p le in.CEL and Commerce. Your cooperation on th is im portant m atter i s d e ep ly .a p p re c iated . S in c e re ly , / C Walter A. Hamilton Executive Director L i Copies of re p o rt to : Samuel A. Jordan W estinghouse E lect r ii'. C^rp. 1801 K S tre e t Northwest W ashington, D.C. 2(*C*>i James S. Nelson G eneral E l e c tr ic Co. S chenectady, N. Y. 123 E. R. Boquist W estinghouse E le c tric Corj . R esearch & Development Ct.T.s<-r P itts b u rg h , Pennsylvania i 235 C harles W. M etter McGraw-Edison Company 333 West R iver Road E lgin, 111. 60120 B. B. Burton The Bendix Corp. Executive O ffices - Bendix Center S o u th fie ld , M ichigan 1*8076 L. Mandelo o m Westinghouse E le c tric Corp. Research & Development Center P ittsb u rg h , Pennsylvania 15235 ?p/- NEL 0115 *XV 781959 % y U .5 . D E P ARTRf E PJT OF COMM ERO E l'Jationnl In d u strial Pollution Control Council W eahinyLon. D .C . 2 0 2 3 0 Jan u ary $ , 1972 >' <* t. '' , i - - ; Dear Chairman C ro ss: . '' ` ":t; i.: In response to th e C o u n cil's re q u e st of December 20, 1971, th e E le c tric and N uclear Sub-Council is p leased to tra n sm it herew ith a statem en t'su b stan tiatin g th e n ecessity fo r use o f FCB's i n c lo se d system e l e c t r i c a l a p p lic a tio n s . S in c e re ly , D. C. Burnham Chairman E le c tric and N uclear Sub-Council E n c lo su re NEL 000116 781960 !! -.'ii* I.U-T-l ~* THE NEED FOR CONTINUED USE OF POLYCHLORINATED BIPHENYLS AS' ELECTRICAL INSULATING LIQUIDS vi}t^ u* c?a z?* , i*: January $ s 1972 by E le c tr ic a l and N uclear Sub-Council N ational In d u s tria l Pollution- C ontrol Council U .S. D epartm ent o f Commerce Washington^ D.C. 20230 , * NEL 000117 781961 THE N EED FO R CONTINUED USE OF POLYCHLORINATED BIPH EN Y LS AS E L E C T R IC A L IN SU L A T IN G LIQ U ID S____________________________________ In tro d u c tio n In view of the q u e stio n s w hich have been ra is e d about the en v iro n m e n ta l im pact of P C B 's , it seem s ap p ro p ria te to exam ine the re a so n s why these m a te ria ls a re em ployed by the e le c tric a l industry, and the public benefits associated w ith such use. W hat a re P o ly ch lo rin ated B iphenyls (P C B 's)? Prily3ilorm ated biphenyls" a re d e riv a tiv e s of the h y d ro carb o n , biphenyl, w hich h a s'th e chem ical fo rm u la H^q c o n sistin g of m ix tu re s of v a rio u s ly I* c h lo r in a te d i s o m e r s a s s e e n in T a b le 1. T h e y a r e u s u a ll y id e n tif ie d by th e w eight p e rc e n t of c h lo rin e in the to ta l m ix tu re s , e. g. A ro c lo r^ 1254 co n ta in s 54% c h lo rin e .'' 'A r o e lo r s a r e c h a r a c te riz e d by s ta b ility - h ig h fla s h points and'OVnh ig h e r co m b u stio n te m p e ra tu re s e ss e n tia l to safe o p eratio n . NEL 000118 How a re 'P C B 's used by e le c tric a l in d u stry ? The p rin cip le use of PCB fluid in the e le c tric a l in d u stry is in tr a n s fo rm e rs and c a p a c ito rs (both la rg e and sm all) as an in su la to r and coolant. Transformers are devices for converting electrical pov/er iron one voltage and current level to another* and the conducting parts of these devices must be separated from each other by a suitable insulating medium. Capacitors are devices for storing electrical energy through the physical separation of charged metal surfaces by an insulating medium. * Konsanao gietered Trademark (Konsanto is the cole U.S. producer of P C B 's.) 781962 Table 1 Components - riven ns $ - * . C h lo rin e ;ji phenyl ."ono-chlorobiphenyl i-chlorobi phenyl 7 r i - chiorob i phenyl T etm -ci lorobi phenyl ?snta-ch3orob^phenyl ii'jxa-chlorobiphcnyi liir.il Monsanto A roclor s 1232 MCSlO'-hV 1 2 M2 KiCS lO lo , 124i3 t 1254 1260 2 1 32 ib .B 56.3 2 6 .9 % >^55 1J|2V .c6 32 h i ha' 43 .<& .02 .02 : 22.2 . ..72 93 : ih .h 1 5 .6 19 .u 3 .3 5>-5 6 U.5 -- 2t 2.5- 1 5 -0 ", ^ 5 5 .6 .7 * '' . l 6*ic r , 54 1 6o , i *z 60 V1/.' l * l *z t- 70 ^Includes higher than pcnta-chlorinated isomers 781963 6110001 3 N i B ecau se of the n o n fla m m a b ility ..(Table 2) of A ro c lo rs , th e ir vapors, and th eir arc-fo rm ed gaseous products, tra n sfo rm e rs filled with P C B 's a re fre e of fire and explosion h a z a rd s and m ay be u sed in lo c a tio n s w here fa ilu re s of o il-in su la te d tr a n s f o r m e r s would p re s e n t a p o ten tial d an g er to life and p ro p e rty . In addition to im p ro v in g the safety a sp ect of cap acito rs the u se of A ro clo rs also gives them the advantages of re lia b ility , long life , and sm a ll s iz e . T abl 2 U n d erw riter L ab o rato ry F lam m ab ility R ating F luid F lam m ab ility R ating E ther G asoline ' * . 100 90-100 Ethyl A lcohol ' 60-70 K erosene (100 F .F .) 3 0 T40 M ineral O il 10-20 A r o c lo r 1242 an d .MCS '1016 .2-3 f The need fo r P C B 's in T ra n s fo rm e rs P C B 's a r e u s fed in t r a n s f o r m e r s w h e r e v e r f i r e p r o te c tio n is p a r t i c u l a r l y im p o r ta n t - - fo r a b o u t 5% of a ll t r a n s f o r m e r s , -3- NEL 000120 781964 M ost of these tra n sfo rm e rs a re located inside public, co m m e rcial, o r in d u stria l buildings; on the ro o f tops of such buildings or in close p ro x im ity to such b u ild in g s, and re q u ire no sp ec ia l en clo su res o th er than what a re n e c e s sa ry to p rev en t accid en tal h azard o u s m ech an ical o r e le c tric a l co n tact of p e rso n s with the equipm ent. T he am ount of A ro c lo r u se d in v a rio u s ty p es of tra n s fo rm e rs r a n g e s f r o m 4 0 `to 500 g a ls', V{5T6' to 6 ,4 5 0 l b s . ) w ith a n a v e r a g e o f about 235 g a ls, (3^032 lb s .) . D uring 1968, the la s t com plete "n o rm al" y e a r fo r the e le c tric a l in d u stry , the to ta l am ount of P C B 's u sed in tra n s fo rm e rs was ap p ro x im ately 1.3 m illio n gallons (8 ,4 thousand to n s). The only p re se n t a lte rn a tiv e s to A ro c lo r-in su la te d tra n s fo rm e rs are m ineral oil-insulated tran sfo rm ers or dry-type tran sfo rm ers (either th o se open to the a tm o sp h e re o r th o se th a t a re g a s-fille d and se a le d ). A. M ineral o il-in su lated tra n sfo rm e rs 1. `If o n e d i s r e g a r d s s a f e ty c o n s i d e r a t i o n s , t h e r e a r e no te ch n ica l re a so n s why m in e ra l o il-in su la te d tr a n s fo rm e rs could not be d ire c tly su b stitu ted for FC B in su la te d tr a n s f o r m e r s . T he s iz e of the u n it would be unchanged; the w eight and co st would be le s s . 2. But one cannot d is re g a rd safety c o n sid e ra tio n s, w hich a re often em bodied in leg al co d es. O bviating the safety h a za rd s involves serio u s econom ic and sp ace c o n s tra in ts , th at would o ccu r c ith e r by -b- NEL 000121 7819fi* L the use of p ro te c tiv e v au lts, o r use of in su lated b uses 1 ?, * - (with the tra n s fo rm e r lo c ated o u td o o rs). E ith e r so lu tion, if the sp ace is av ailab le, could co st $5,000 -- $50, 000 p e r tra n s fo rm e r. B. D ry-type tran sfo rm ers In m o st lo c a tio n s, d ry -ty p e tra n s fo rm e rs (e ith e r th o se open to th e a tm o sp h e re o r th o se th a t a re g a s -fille d and sealed) could not be d ire c tly su b stitu ted fo r F C B -- insulated tra n sfo rm e rs. T here are sev e ra l re stric tio n s to such a d ire c t su b stitu tio n : 1. The re lia b ility , of d ry -ty p e tra n s fo rm e rs is le ss than that of com parably rated liquid-insulated tra n sfo rm e rs. f An E E I su rv ey of fa ilu re s in netw ork tra n s fo rm e r banks sh o w ed a 7% p e r y e a r f a ilu r e r a t e fo r d r y - ty p e u n its com pared to 0.2% for. liq u id -in su la te d u n its. 2. F u rth erm o re, liquid-insulated tran sfo rm ers have a much g re a te r overload capability. M any liq u id -in su lated units can su sta in a 100% o v erlo ad fo r 8 h o u rs and a -200% overload fo r 2 h o u rs. T hese tra n s fo rm e rs a re able to m aintain continuity of e le c tric a l serv ice during periods of tem p o rary m alfunction of related equipm ent. 3. Som e d ry -ty p e tr a n s f o r m e r s a r e la r g e r by 10 to 30% th a n c o m p a ra b ly , r a t e d *liq u id - in s u la te d u n i t s , an d m o s t are m ore expensive. -5- NEL 000122 781966 4 . Dry-type transformers are noisier by 5 -1 0 dB than arfe liquid-insulated transformers, 5'. O pen d r y - ty p e t r a n s f o r m e r s , w h ich a r e c h e a p e r th a n sealed d r y - ty p e t r a n s f o r m e r s , c a n n o t b e u s e d in c e r t a i n * c o rro siv e o r hazard o u s a tm o sp h e re s, e .g . on fu rn aces op on e le c tro sta tic p re c ip ita to rs n e a r hot sta c k s. C learly th ere is.no substitute for P C B -filled tra n sfo rm e rs w here fire protection is req u ired. The n eed fo r P C B 's in c ap acito rs FCB*s a re u se d in m o re than 90% of th e e le c tric u tility ( larg e, pow er) type and sm a lle r in d u stria l type c ap a c ito rs m ade today. They a re needed fo r safety , re lia b ility and long life , and to achieve siz e s com patible with equipm ent and in sta lla tio n re q u ire m e n ts. The p rin cip al types of F C B -im p reg n ated cap acito rs and th e ir applications a re high voltage pow er c ap acito rs u sed p rim a rily for ' p o w er fa c to r c o rre c tio n in the d istrib u tio n of e le c tric p ow er; low voltage pow er cap acito rs in stalled in in d u stria l plants at the load (ty p ically la rg e m o to rs); b a lla s t c a p a c ito rs to im p ro v e the efficien cy of lighting sy stem s; and sm all in d u strial cap acito rs fo r pow er facto r im prove m en t in such equipm ent as a ir conditioning u n its, pum ps, fan s, etc. A lm o st 80 m illio n su ch c a p a c ito rs a r e m a n u fa c tu re d a n n u ally , m o s t of them for first-tim e , u se. NEL 000123 -6 781967 C ap acito rs used in-lighting and a ir conditioning applications c o n tain 0. 005 to 0. 09 g a ls , of P C B p e r u n it. T he la r g e s t po w er cap acito rs contain about 6.7 g als, of a sk a re l. The m ost popular size co n tain s about 3.1 g allo n s. T he N ational E le c tric a l Code re q u ire s th at any in sta llatio n of c ap a c ito rs in w hich any sin g le un it contains m o re than 3 gallons of com bustible liquid sh all be in a vault lik e th at re q u ire d fo r tra n sfo rm e rs. D uring 1968, the la s t com plete "n o rm al" y e a r fo r th e e le c tric a l in d u s try ,:th e to ta l am ount of P C B 's u sed in capacitors was approxim ately 14.4 thousand tons. P o ssib le a lte rn ativ es to F C B -im p reg n ated c ap a c ito rs a re cap aci to rs im p reg n ated with m in e ra l oil, o r c e rta in o th er liq u id s. ........ _ a NEL 000124 A. M in eral Oil `1. Size The single m o st im p o rtan t p ro p e rty of a liquid to be u s e d 'in a c ap acito r is its d ie le c tric co n stan t (the ratio of its ab ility to sto re e le c tro sta tic energy re la tiv e to a ir). The d ielectric constant of the c a p a c ito r-g rad e PCB (A roclor 1242) is 5.85 w hile th a t of m in e ra l oil is 2 .2 5 . (See T a b le 3) R e v e rtin g to an o il- p a p e r d ie le c tric sy ste m would in c re a s e the a v e ra g e c a p a c ito r volum e (size) by a p p ro x im a te ly 600%, the w eight by 500% 781968 \ Table 3 F lu id Aroclor: 1242 A ro c lo r MGS 10 l6 A rc e lo r MCS 10^3 A lternate In su latin g Fluids Scir.c S ig n i f i c a n t P r o p e r tie s o f C e r ta in C an d id ate I n s u la tin g F lu id s to Replace A roclor 1242 \ . D i e l e c t r i c C o n sta n t , Cleveland Open Cue Flanraability e ',,- a t 25 C Flush P o in t - - Fire Point 5 .8 5 .-19^ ' 333 \ 5.85 191 319 5 .7 l6o . * 2Uh D ensity 1.38 1.36 1.28 C o st. i lb' 18 l3 ` .1 8 M in eral O il '2 .2 5 l'^ 150 3 781969 sz iooo la N > and the co st by approxim ately 400%. At the p resen t levels of dem and for capacitor KVAR, th e re would be a sh o rta g e of e le c tric a l g ra d e paper and a shortage of capacitor factory fac ilitie s fu rth e r tending to in c re a se the co st to the u tility , and u ltim ately to the c o n su m e r. 2. R eliability and life F C B 's a re th e rm a lly and oxidatively m o re stab le than m in e ra l o ils, and d isc h a rg e s, w hich can occur in c ap a c ito rs, a re le ss likely to g en erate gases from ask arels than from m in eral o ils. The chem ical sta b ility of F C B 's in the p re s e n c e of c a p a c ito r tissu e and p lastic film s and the favorable s tre s s d istrib u tio n s betw een solid and liquid have m ade it p o ssib le to d esign lo w -co st c ap a c ito rs with a life e x p ec ta n cy of m o re th an 10 y e a r s life in lig h tin g ap p licatio n s and m o re than 20 y e a rs in e le c tric u tility a p p lic atio n s. In each ap p licatio n the first,-y e a r fa ilu re ra te s a re le ss than 0.2% . T his lev el of life and re lia b ility had not been achieved p rio r to the intro d u ctio n of F C B 's, A: -9- NEL 000126 781970 3, Safety T he re la tiv e n o n -flam m ab ility of P C B 's sig n ifican tly reduces the fire h azard th at m ight otherw ise accom pany those failu res that re su lt in ru p tu re of the case, B . O ther Liquids 1. C asto r O il. The d ie le c tric co n stan t of c a s to r oil is 4 .5 and this m aterial is useful as an im pregnant in D .C . e n e rg y s to ra g e c a p a c ito r s . H o w e v e r, A. C . .... c ap a c ito rs filled with th is liquid have re la tiv e ly sh o rt lives and are not very stable under A. C. discharges and in the p re se n c e of w ater d e riv a b le fro m the cellulosic paper. 2. D ibutyl s e b a c a te . T his e s te r is e sp e c ially u sefu l in high frequency p a ra lle l plate cap acito rs b ecau se of its low , fla t lo ss c h a ra c te ris tic s o v er a b ro ad frequency ra n g e . In this type of co n stru ctio n the liquid is the sole d ie le c tric m a te ria l. W hen u sed in conjunction .w ith p a p e r, this e ste r is also unstable. 3. Silicone F lu id s. T hese m a te ria ls have a d ie le ctric #c o n s ta n t o f 2 ,7 an d w ould g e n e r a l l y b e s u b je c t to th e sam e disadvantages as m in eral oil. -1 0 - 781971 NEL 000127 In the in te re st of achieving a h ig h er deg ree of environm ental c o m p a tib ility th e c a p a c ito r in d u s try h a s sw itched d u rin g 1971 fro m A ro c lo r 1242 to A ro c lo r MCS 1016, fro m which the h ig h e r-c h lo rin a te d p ersisten t fractions have been substantially rem oved. E nvironm ental Protection The advantages to the public in te rm s of safe, re lia b le , and efficient e le c tric a l equipm ent m ade p o ssib le by the u se of P C B 's have been docum ented. It is also c lea r that th ere a re no p resen t o r p ro s pective su b stitu tes for th ese m a te ria ls and the functions they p erfo rm a re e s s e n tia l. Thus the continuing n eed fo r P C B 's in clo sed e le c tric a l sy stem applications is co n clu siv e. The e le c tric a l in d u stry w ell u n d e r stan d s, how ever, th at continued u se of th ese m a te ria ls re q u ire s unusual p ro tectiv e m e a su re s. T hese m easu res w ere the subject of recom m enda tio n s m ad e by a p re v io u s N IPC C S ub-C ouncil re p o rt (T he U se and D is p o s a l o f E l e c t r i c a l In s u la tin g L iq u id s ., Ju n e 1971) an d a r e ju d g e d to b e w ell on th e ir way tow ard im plem entation: w itness the introduction of the new cap acito r d ie le c tric , the provision of facilities fo r the in c in e ra tion of liquid and solid w a ste s, and the in stru ctio n s to o p erating p e rs o n nel and u s e rs reg ard in g the need for c a re in w aste d isp o sal, an activ ity now being fu rth e r fo rm a liz e d and stre n g th e n e d by A N SI's c o m m itte e C l 07. The annual re sid u a l leakage to the environm ent from the continued u se in tra n s fo rm e rs and c a p a c ito rs h as been e stim ate d betw een one p a rt in a th o u s a n d an d one in te n th o u s a n d of th e e x is tin g e n v iro n m e n ta l PC13 burden. -1 1 - 781972 NEL 000128 ELECTRIC AND NUCLEAR SUB-COUNCIL NATIONAL INDUSTRIAL POLLUTION CONTROL COUNCIL Cftatrmzn: D. C. Burnham Chairman Westinghouse Electric Corporation Vice Chair/nan; Frcd J. Borch Chairman and C hief Executive O fficer General Electric Company A. P. Fontaine President & Chairman The Bendi* Corporation Raymond H. Ciesecke President St Chief Exec. O fficer McGraw-Edison Company Members C. Lester Hogan President ft C hief Executive O fficer Fairchild Camera & Instrument Corporation Robert W. Sarnoff Chairman of the Board & President RCA Corporation NEL 000129 781973 TECHNICAL RESOURCES GENERAL ELECTRIC 1 RIVER ROAD. SCHENECTADY. N. Y. 12345 SUBJECT -D. A-'Lj C O mi / COPIES: Dr. E. L. Simons - Bldg. 36 January 26, 1972 Bv Telecopier Mr. J. F. McAllister NEW YORK The following is suggested as a second paragraph under the heading, "Risks in the summary statement on PCB: After the implementation of the new controls, some residue will still find its way into the environment. The primary source will be the discarding of failed, small capacitors, typically one or two at a given time, in widely-dispersed locations. The total of such residual contamination is esti mated to be, on an annual basis, less than one one-thousandth of the existing environmental burden of PCB. Furthermore, in the fall of 1971, the industry standardized on a new PCB formulation for capacitors, containing almost none of the higher-chlorinated fractions which have been of environmental concern. Gradually, the annual contribution will be converted to the new fluid, minimizing its ecological significance. f. JSN:ev NEL0013 781974 TECHNICAL RESOURCES GENERAL H I ELECTRIC 1 RIVER ROAD. SCHENECTADY. N. Y. 12345 SUBJECT - fY\ ' I Summary Statement on PCB January 31, 1972 COPIES: JF McAllister R J Boudreau OH LeBlanc EL Raab EL Simons A. Pozefsky Mr. Arthur E. Peltosalo Vice President and Group Executive Power Delivery Group . 570 Lexington Avenue NEW YORK, N. Y. Dear Art: The accompanying summary, "The Role of Polychlorinated Biphenyls in Electrical Equipment" has been designed as a companion piece to the report sent earlier to the Office of Science and Technology, and will be integrated with a revised version of that report as an executive sirmnary. We also contemplate making use of the summary as a hand-out for customers who are disturbed about the reports on PCB they have been seeing in the press. We have attempted to be responsive to your suggestion to Jack McAllister that we highlight the benefits in lay language, while also giving enough background and discussion of risk to maintain credibility with the scientific community. Please let us know if you have any additional suggestions for improving communication in this area. Very truly yours, nas S. Nelson, Consultant r^cjuct Environmental Compatibility JSN:ev Att. /* NEL 000131 781975 THE ROLE o f p o l y c h l o r i n a t e d b i p h e n y l s IN ELECTRICAL EQUIPMENT SUMMARY Polychlorinated biphenyls (PCB's) have been used in many applications for over forty years, but only recently was evidence discovered that these materials are widely dispersed in the environment. Systematic investigations of the toxic and biological effects of PCB's have been undertaken within the past few years to establish the effects of specific formulations upon specific species. Simultaneously, significant steps have been taken by U. S. industry to further limit PCB releases to the environment, PCB's have been used in three broad types of applications for the past 40 years, as follows: (a) "open ended" applications....for example, in paints, specialty inks, paper coatings, plastics, etc., (b) "nominally closed" appli-" cations.... for example, as the working fluid in hydraulic or heat transfer . systems; and (c) "closed system" applications..,.specifically, as the insulating fluid in certain types of transformers and capacitors. The Monsanto Company is the sole U.` S. producer of PCB's. It has discontinued supplying the material for all applications of type (a) and (b). Certain spokes men have recommended discontinuance of type (c) applications as well, but appear to have done so without consideration of the alternatives and risk/benefits involved. The purpose of this report is to provide information for such consi deration. Benefits 1. Askarel*-insulated transformers do not burn or explode under conditions of electrical arcing that can cause fires or incendiary explosions in oil-insulated transformers. Therefore, they are used in or near public, commercial or industrial buildings where oil-insulated transformers would present a potential* danger to life and property. 2. Askarel-filled power and industrial capacitors are significantly smaller, more reliable, more durable, and safer than oil-filled capacitors. As a result, askarels have supplanted mineral oils in more than 907. of the power and industrial capacitors made today. Over the past few decades most of the equipment that incorporates such capacitors has been configured to take particular advantage of the size, safety and reliability benefits of askarel capacitors (e.g., many types are today less than 147. of the size of equivalent oil capacitors and have a life expectance of 10 to more' than 20 years). The vital role that askarel-insulated transformers and capacitors have played in the safe, reliable, and efficient delivery of electric power is reflected in various standards, codes, and regulations that now effectively require or encourage continued use. MEL 000132 *FCB's used in transformers and capacitors are designated by the international term "askarel." 781976 2 Risks In the United States, medical records show that over a nearly 40-year period the only adverse health effects experienced by U. S. workers exposed to PCB's, either during the manufacture of these liquids or of electrical equipment containing these liquids, have been limited to occasional cases of non-chronic chloracne or other temporary skin lesions or irritations Askarel-filled transformers and capacitors are delivered to customers as sealed units from which there is ho escape of askarel under normal operation. While certain types of equipment failures can rupture the case and permit loss of some askarel to the environment, such failures are limited to approximately 0.02Z of the units in service per year. In addition, PCB's can get into the environment during the manufacture, delivery, improper use, maintenance, repair and disposal of transformers and capacitors. Specific control measures have already been instituted by individual manufacturers and will be supplemented and strengthened by national standards and procedures which are now being developed by a Committee^ of the American National Standards Institute. These forthcoming standards will be designed to prevent the inadvertent loss of PCB's to the environment at all stages from equipment manufacture through ultimate disposal. After implementation of the control measures contemplated, it is estimated that the annual release of PCB's to the environment will be less than one onethousandth of the present burden, mainly from failed, small capacitors. Further more, since in 1971 the industry standardized on a capacitor formulation containing less than 0.k% pentachlorinated biphenyls and higher, the fractions of main concern, the ecological significance will be further reduced. ? Alternatives NEL 000133 1. Askarel transformers already installed cannot be replaced by oil trans formers of equivalent rating without major construction changes in buildings and associated equipment required to compensate for the safety features of the askarel units. For certain applications and locations, dry-type transformers can replace askarel transformers, but not without reduction in system reliability. 2. The principal alternative to askarels for capacitors is mineral oil, but such replacement would return capacitor technology to its pre-1932 level and would necessitate redesign and replacement of such widely used equipment as fluorescent light fixtures and racks for power and induction heating capacitors, which could not now accommodate the increased size of oil capacitors while maintaining their present ratings. 3. The cost of askarel liquids is about $2.00 per gallon, compared to about $0.30 per gallon for mineral oil. Thus, long before there were any environmental concerns about PCB's, there was a strong economic incentive to find other less expensive insulating liquids with the desirable characteristics of askarels. Since the 1930's, at least 10 major chemical or electrical companies have invested large amounts of time and money in this earch, all with no success. While potential sub stitutes that arc more costly than PCB's have also received some consideration (e.g., fluorinated liquids) little is known about either their electrical performance or possible ill effects upon the environment. There are today no fluids that can be used as one-for-one replacements for PCB's. 781977 1/31/72 8*235*2261 January 31, 1972 0 Mr. David M. Mar lay Manager-Laboratory General Zlectrle Coapany 1501 Roanoke Boulevard SALEM, VIRGINIA 24153 Dear Mr. Morley: With reference to your telephone Inquiry about cuetonsr coMunicatlone In re polychlorinated biphenyle, ve e n d o a e d (1) a copy of an open letter to induatrlal cuetonera, (2) ditto for utility cuatoaera, (3) Monaanto*a February 18, 1970 letter and (4) a recently written aiaaaary atatenent on the beneflta of PCB uae. Very truly youra, Jaaea S. Nelaon, Conaultant Product Envlronaantal Compatibility JSN:ev Att. /* NEL 000134 781978 TECHNICAL RESOURCES 1 RIVER ROAD. SCHENECTADY. H. Y. 12345 SUBJECT COMM 8*235-2261 MONTHLY ACTIVITIES REPORT James S. Nelson__________ February 1, 1972 Mr. J, F. McAllister NEW YORK COPIES: FS Rothe REDACTED NEL 000135 3. Task Force The GE Task Force on Continuation of PCB Use has evolved a concise sunsnary of the case for PCB's as a companion piece to the report for OST (reported upon in last month's activity letter) and sent a copy to Mr. Peltosalo for his comments. This summary vill be integrated with the main report for resubmission to OST. Meanwhile, use is already being made of the document to aid in answering customer inquiries (e.g., Hudson Falls and Roanoke). 781979 GENERAL C i ELECTRIC Mr* J* F. McAllister 2 Fe b ru a ry 1 , 1972 The revised OST report will contain a new section evaluating the magnitude of the environmental burden and the incremental contribution to be expected from continuing electrical applications of PCB (draft attached) redacted ISlEL 000136 James S. Nelson JSNiev Attachments 781980 9a D R A FT FOR A D D IT IO N TO OST REPORT OH PCB's Environmental Burden The significance of the environmental burden of PCB in terms of biological effects vhich different formulations may have upon different living species is the subject of a growing body of investigative work which will not be reported upon here; but consideration of the origin and possible amounts of PCB in the environment, and specifically the contribution to be expected from continued employment of these materials in the electrical industry is within NEL 000137 the scope of this paper. From recently published data, it is possible to estimate that, since the beginning in the early 1930's, U.S. domestic usage of PCB*s has amounted to 4.3 x 105 tons. Of this amount, 63% was for the electrical industry and virtually all for "closed'1 applications; and 37% for "open" applications, such as paints,, plasticizers, specialty inks, etc., or for "nominally closed" p- applications, such as heat-transfer systems and hydraulic systems. If it be assumed that 10% of the former class and 80% of the latter have somehow leaked into the environment, the estimate of total burden for the United States becomes 1.5 x 105 tons. The rate of introduction of these materials into the environment has now been slowed to a small fraction of the former rate. Responding to studies indicating widespread dispersal of PCB, the Monsanto Company has ceased supplying the markets for open applications and for nominally-closed applications. The only remaining sanctioned applications are the closed ones, specifically trans formers and capacitors. Controlled incinerators have been designed and other provisions have been made for the purpose of handling waste from the production and % servicing of these items. Manufacturers have-sealed off former drains and increased recycling activities and waste-control vigilance. (See "Recommendations" of the Electrical and Nuclear Sub-Council of the National Industrial Pollution 781981 9b Control Council, contained in their report of June, 1971, entitled "The Use and Disposal of Electrical Insulating Liquids".) As was noted previously ("Background"), an industry committee, with public and governmental repre sentatives, has been formed under the auspices of the American National Standards Institute and is active in supplementing and further strengthening the application of such techniques with the end in view of preventing the inadvertent loss of PCB's to the environment at all stages from equipment manufacture through use and ultimate disposal. To quantize the effect of these measures taken voluntarily by U.S. Industry, the following conclusions or premises may be listed: 1. Factory waste will be properly handled and kept from the environment. 2. The loss of fluid from the servicing and rebuilding of transformers in the field (being under the control of a relatively few large responsible firms -- the manufacturers and electric utilities) f will be reduced virtually to zero. 3. The loss to the environment of FCB from capacitors failing in the field is a more difficult problem to correct, due to the diversity of applications. Proper disposal of utility capacitors does not present much of a problem, but the small industrial capacitors Involved in millions of fluorescent ballast and air-conditioning units will probably never be accounted for fully. The assumption is made that this class of loss will be cut in half in each of the next several decades, as waste disposal practices improve. NEL 000138 4. The total usage of electrical energy and consequent employment of PCB transformers and capacitors will increase at a rate of approxi mately 7% per year, i.e., doubling every ten years. Under these assumptions, growth in use will be offset by improved control practices, and the remaining annual contribution to the environmental burden 781982 9c will come almost entirely from the disposal of failed capacitors. The replacement capacitor market may be taken as a measure of annual failures, and the amount of FC5 now going into replacement capacitors is estimated as 345 tons per year. Capacitors are so constructed that approxi mately 80% of the impregnant is absorbed by the solid portions of the dielectric system, with only the balance, 20%, available to leak out of a ruptured or eroded capacitor case. If all of this residue should reach the environment, the annual contribution would be 70 tons. Thus, the maximum increase in the existing environmental burden to be expected from the continuation of the electrical applications of PCB is ----ZP------ B 0.00047, 1.5 x 105 i.e., less than one one-thousandth of the amount presumed to be already in the environment. Beginning in the fall of 1971, capacitors are made with a new FCB formulation which is almost free of the higher-chlorinated fractions which have been discovered in the environment (section on "Askarel"). As the percentage of these nev-generation capacitors among the failed population increases, the ecological significance of the industrial usage of FCB will be correspondingly reduced. J. S. N. 1/30/72 781983 MtiL, uuuuy TECHNICAL RESOURCES GENERAL ELECTRIC 1 RIVER ROAD. SCHENECTADY, N. Y. 12345 SUBJECT D I AL C OM M 8*235-2261 ~1 Meeting of Task Force on Continuation of PCB Use. February 23 COPIES: February 8, 1972 Messrs. J. F. McAllister R. J. Boudreau ^ O. H. LeBlanc^ A. Fozefsky -- ^ E. L. RaabJ^*' E. L. Simons-^/' i As agreed, the next meeting of the PCB Task Force will, be held on February 23, 1972 in Schenectady, Building 36, Room 507, at 10:00 a.m. The main purpose of this meeting is to address ourselves to what we called Task #1 in my letter of December 17, viz., General Electric Risk-Benefit analysis. There are a number of related problems, and the following agenda is suggested: Status of ANSI Consnittee C107 and prediction of the recommendations which will be forthcoming - Pozefsky and Raab. Customer Communications: review of information letters to customers, information in instruction books, caution labels, advice to OEM's (inside and outside the Company) relative to capacitors and trans formers containing PCB - Pozefsky and Raab. Status of provision, in the industry, for the destruction of solid waste - Raab. a Discussion of need for updating of Bulletin 4.1 (9-21-70). A copy is attached for your review - Nelson. Findings of Woods Hole Oceanographic Institute with respect to PCB in the environment - LeBlanc. Problems with Company installations - Simons. Latest estimate of the position to be taken by OST and other Federal agencies - McAllister. Further definition of Task #1 - McAllister. NEL 000140 J SN:ev Att. S. Nelson, ConsultantProduct Environmental Compatibility 781984 ENGINEERING GENERAL ELECTRIC 570 LEXINGTON AVE, NEW YORK. N. Y. 10022 SUBJECT COPIES: G r o u p E x e c u t i v e s J . F . Young J. S. A n d e r s o n J. S. N e l s o n E . L . Raab S eptem ber 21, 1970 To: D ivision G eneral M anagers Deputy D ivision G eneral M anagers G entlem en: The C orporate Policy C om m ittee has req u ested that I distribute inform ation on the use and furnishing of PC B m a te ria l, pending planned issuance of a P olicy on Environm ental P ro tectio n p er n orm al procedure. A ttached is a B ulletin fo r this p u rp o se. Copies of th is B ulletin a re being m ailed to a ll holders of the P ro d u ct Safety M anual. M ay 1 re q u e st th a t you bring this m a tte r to the atten tio n of a ll rep o rtin g com ponents and locations fo r w hich the subject has application. V ery tru ly yours, JFM cA :rts A ttachm ent \ John F . M cA llister, M anager P roduct Safety and R eliability NEL 000141 781985 BULLETIN EPS 4. 1 INFORM ATION ON TH E USE AND FURNISHING OF M ATERIAL CONTAINING POLYCHLORBIPHENYLS T h ere is som e evidence that P olychlorbiphenyls (P C B 's) have u n d esirab le ecologic consequences. P C B 's, also known as a sk a re ls and by such tra d e -m a rk nam es as A roclor and P yranol, a re com ponents in certain electrical, hydraulic and h e a t-tra n sfe r fluids, and in p la sticiz e rs for plastics and paints. A T ask F orce w hich included m an ag ers of the th ree la rg e st u ser D ivisions h as re c o m m en d e d th a t (1) w h e n ev e r p ra c tic a b le , a lte rn a te m a te ria ls be u sed o r fu rn ish e d ; and (2) co n tin u ed u se be con tin g en t on im p le m e n ta tio n of a co n tro l p ro g ram w hich includes the following elem ents: A. P ro v isio n is to be m ade fo r qualified d estru ctio n of PC B w aste m a te ria ls. Initially, the only qualified p ro cess is in cin eratio n under carefu lly controlled conditions. (This serv ice is available from the M onsanto Company, 800 N. L indbergh B lv d ., St. L ouis, M isso u ri. In due c o u rse . Com pany fa c ilitie s m ay also be developed and q u a lifie d .) B. A ll liquid w aste is to be held in im p erv io u s co n tain ers pending tra n sfe r for ultim ate disposal. C. Solids contam inated by P C B 's a re to be held in im pervious containers pending disposal or purging. P urging m ay be accom plished by cleaning contam inated solids w ith p roper liquids. The resulting contam inated liquids a re to be tre a te d as in A and B above. D. A ll sto rag e and loading a re a s fo r P C B 's a re to be designed and c o n stru cte d to p rev en t sp ills and leakage. E. F o r w aste generated as a resu lt of off-site custom er service, a rra n g e m e n t is to be m ade to re tu rn it to Com pany fa c ilitie s fo r p ro p e r d isp o sal, o r d ire c tly to M onsanto fo r disposition as indicated in A. F. A p p ro p riate in stru ctio n s a re to be com m unicated to em ployees. G. A ro u tin e is to be estab lish ed to a s s u re a p p ro p riate in itial and follow -on advice to c u sto m e rs, including identification of need and instructions on use and disposition. 781986 NEL 000142 -2 - Guidance and C ounseling C ounsel and guidance is available fro m the following w ith resp ect to th e su b je c ts in d icated : M atters concerning PCB in products John F . M cA llister M anager P ro d u ct Safety and R eliability, C orporate Staff 570 Lexington Avenue New Y ork, New York 10022 M atters concerning PCB in plant operations D r. J . Steven A nderson, M anager E nvironm ental P ro tectio n O peration, C orporate Staff Schenectady, New Y ork R elationships w ith M onsanto E. L. Raab, M anager C h e m ic a l Sc P r o c e s s e s S e c tio n , P o w e r D is tr ib u tio n D ivision, P ittsfield , M assach u setts, for m a tte rs w hich in any way b ear on relatio n sh ip s w ith M onsanto. S ep tem b er 21, 1970 781987 NEL 000143 GENERAL ELECTRIC COMPANY. 1 RIVER ROAD. SCHENECTADY. NEW YORK 12305 Phone (518) 374-2211 TECHNICAL RESOURCES SUBJECT: Revision of Draft Paper on Benefits of PCB Use February 16, 1972 Dr. Edward J. Burger, Jr. Executive Office of the President Office of Science and Technology Room 4224, New Executive Office Building Washington, D. C. 20506 bcc: OH LeBlanc A. Poaefsky EL Simons RJ Boudreau EL Raab AE Peltosalo CJ Meloun AE Schubert JF Young Dear Dr. Burger: / Please substitute the enclosed papery "The Role of Polychlorinated Biphenyls in Electrical Equipment" for the draft sent to you by Mr, McAllister on December 30, 1971, (There are' ten copies furnished for your convenience if you should elect to make further distribution within the Interdepartmental Task Force on PCB.) We have added an executive summary and a discussion of the plausible dimensions of the environmental burden and the effect of continued use of PCB in sealed electrical equipment. Except for these additions and the correction of some errors previously called to your attention by telephone, the document is essentially the same as the December draft, We are pleased to renew our offer to attempt clarification or substantiation of any points upon which you or your colleagues desire more information and again thank you for the opportunity to help provide the basis for an informed assessment of a public issue. Very truly yours JSrcv Enclosures c c : J, F . McAllister James S. Kelson, ConsultantProduct Environmental Compatibility Corporate Executive Staff MEL 000144 781988 TECHNICAL RESOURCES GENERAL ELECTRIC 1 RIVER ROAD, SCHENECTADY, N. Y. 12305 SUBJECT DIAL COMM 8*235-2261 J7 COPIES: /*. ' "// ^ iiL-'iirfAtt*-*-'' ;w>Ri Ai Cm-tii.il- SYRACUSE J. F. McAllister - NEW YORK A. Pozefsky - HUDSON FALLS E. L. Raab - PITTSFIELD E. L. Simons - SCHDY. - Bldg. 36-1*. March 10, 1972 Mr. E,, R. Ruterman Program Manager Safeguard PAR Development f~ Electronics Systems Division Court Street - Bldg. 5-C3 Syracuse, New York 13201 ,1 ' ' * Dear Mr. Ruterman: Thank you for the opportunity to review your proposed package of communications to Bell Laboratories and Western Electric relative to PCB's in components of the FARSS. It is our feeling that portions of .the.package contain material more appropriate for use within the Company, where-manufacturing oper ations are conducted, than for use with a customer who has only minimal exposure and risks. On the other hand, we agree that the customer and ultimate user should be put on notice as to existing concern for the- ecological consequences of dispersal of PCB's into the environment, and that -- because of wide press publicity on the subject -- he needs some additional information in order to view the problem in perspective. The enclosed draft is an attempt to perform these communication functions without "overkill". The complete proposed package would be the revised draft letter, your "Attachment 3" and the enclosed excerpt from the N1PCC pamphlet. We would omit (or possibly revise).your Attachment 1. Bulletin 4.1 (your Attachment 2) is for internal use and not entirely up-to-date. Questions of this type should be much easier to field once Committee C107 of ANSI has completed its work. By copy of this letter, I am requesting the spokesmen for our Transformer and Capacitor interests to let us know at once of any reservations about this proposal. If you use the proposed draft, or something similar, be sure to obtain approval of legal counsel. If it doesn't seem to meet your needs, we would be pleased to confer with you further. In addition, we have enclosed a copy of a paper written for the Office of Science and Technology in support of their activities as participants in the Interdepartmental Task Force on PCB's. We do not suggest you include this booklet in the initial mailing to the customer, but if he requests additional briefing, the document is in the public domain and there would be no objection to passing it along ("The Role of Polychlorinated Biphenyls in Electrical Equipment", General Electric Co., Feb. 4, 1972.). 781989 NEL 000145 JSN:ev At- r TiSOvS S* Nelson, ConsultantProduct Environmental Compatibility G ?3 i La ^ US s 9 DRAFT f r> ! rt b i t S \j GENERAL ELECTRIC COMPANY, 1 RIVER ROAD. SCHENECTADY, NEW YORK 12305 Phone (518) 374-2211 PARS5 Askarel PCB Materials TECHNICAL RESOURCES March 10, 1972 Bell Telephone Laboratories Western Electric Company Gentlemen: This letter will inform you of some recent findings and General Electric's recommendations with respect to the use of polychlorinated biphenyl (PCB) insulating fluids (designated also by the international term "askarel" and by fi various trade names -- notably Monsanto Company's "Aroclor", General Electric's 'Tyranol" and Westinghouse1s "Inerteen")* It is suggested that you may wish to bring this information to the attention of your customer. As you are well aware, the public concern with pollution is rapidly escalating. As time goes on, it can be expected to reach out to affect more and 's] 00 CcOo o more materials that are even suspect of being potential pollutants and contaminants of the environment. Recently there have been indications that polychlorinated biphenyls have been found at some points in marine, aquatic, and wildlife environ NEL 000146 ments. While quantities are relatively small, it is a matter of growing concern as to their effect on some species of wildlife. There have also been instances reported in the press of the contamination of discrete lots of milk and fowl intended for human food. Monsanto Chemical Company is the sole supplier to the industry of various grades of PCB's for use as liquid dielectric in electrical apparatus. Monsanto has been reviewing procedures to be sure that these materials do not find their way into the environment, and has established a policy of QG E N E R A L ELECTRIC DRAFT 2- discontinuance of sales of PCB's for use in paints, plasticisers, specialty inks, adhesives, paper coatings, hydraulic and heat-transfer fluids and all other opensystem applications. It is believed that no reported instances of PCB contamination are traceable to leakage from electrical apparatus. Monsanto is continuing to supply responsible manufacturers of transformers and capacitors. While the broad subject of the interaction between PCB's and the environment continues to be studied (e.g., by the Office of Science and Technology and by the Interdepartmental Task Force on PCB's) we see no reason to anticipate governmental action which would require discontinuance of the use of these materials in transformers and capacitors, where there are today no fluids that can be used as suitable replacements. In the PARSS, the greatest volume of askarel is contained in the beam current power supplies (BCPS) manufactured by Saratoga Industries. The BCFS contains Westinghouse transformers insulated with Inerteen PPO (7336-9), believed to be a PCB diluted with polychlorinated benzene. Approximately 300 gallons of askarel are contained in the BCPS, and smaller amounts are contained in the many high-voltage capacitors used in filters and other applications throughout the system. The transformers and capacitors are sealed, and not repairable on site. Thus, with normal system function, there is no exposure of personnel or the equipment site. As to accidental exposure from leaking or ruptured apparatus, see the enclosed statement on Toxicity and Safe Handling, quoted from a National Industrial Pollution Control Council report. In the United States, medical records show that over a nearly 40-year period the only adverse health effects experienced by U. S. workers exposed to PCB's, either during the manufacture of these liquids or of electrical equipment containing these liquids, have been limited to occasional cases of non chronic chloracne or other temporary skin lesions or irritations. 781991 GENERAL ELECTRIC DRAFT 3 As to possible environmental impact, in addition to measures already adopted by industry (e.g., restriction of application to closed systems) the American National Standards Institute has established ANSI Committee C107 on the Use and Disposal of Askarel Used in Electrical Equipment. This group, (which includes two representatives of the Department of the Army among its broad member ship) will recommend national standards and procedures to prevent the loss of PCB's to the environment at all stages from equipment manufacture through ultimate disposal. Guidance is expected on such subjects as the ultimate disposal of discarded apparatus or components, and the content of warning labels, should such be considered necessary. If wide deployment of the PARSS system is to take place before the recommendations of the ANSI committee are in general implementation, or if for any other reason it is desirable to issue interim instructions on this subject, the following content is offered for consideration: 1. Inform site personnel of proper FCB handling, storage and disposal procedures. Any significant volume of liquid waste should be shipped to Monsanto in a sealed container. Contaminated solids, such as defective capacitors, contaminated clean-up materials (Fuller's earth or rags) should be collected in sealed containers for eventual disposal in a controlled incinerator or by such other means as may be recommended by the ANSI Committee. Contact the manufacturer for instructions on obtaining the repair or disposition of any failed or leaking transformer. 2. Include suitable reference -in the FARSS Instruction Manual and MDS frames. 781992 NEL 000148 G E M E R A I C E L E C T R I C draft 4 3. Place caution labels on transformers and large capacitors (or sub-assemblies containing PCB transformers or large capacitors). NOTICE: This apparatus contains PCB's. In order to avoid possible damage to the environment, dispose of only in accordance with Instruction 7.2.4.1. Enc. Very truly yours, NEL 000149 781993 TOXICITY AND SAFE HANDLING OF AS KARELS (13) Inhalation At ordinary temperatures the askarels have not presented indus trial toxicological problems. The hazard oi potential toxic exposure varies with their volatility: the lower-chlorinated, more-volatile ones present more of a potential problem from the standpoint of both in halation and skin contact. When askarels are used at elevated tem peratures, engineering controls must be applied, either by the use of closed systems or by effective local-exhaust ventilation together with general workroom exhaust. Vapor at room temperature should not be breathed in a confined space, and no vapor of any askarel evolved at elevated temperatures should be allowed to be dispersed into the general workroom. Inhalation tests on animals indicate that the maximum safe con centration of vapor is in the range of from 0.5 to 1.0 milligram of the lower-chlorinated askarels per cubic meter of air. The threshold limit values (maximum allowable concentration for an 8-hour work ing day) set by the American Conference of Government Hygienists are 1.0 milligram of the lower chlorinated askarels per cubic meter of air and 0.5 milligram of the more highly chlorinated compounds per cubic meter of air. Skin Contact Schwartz patch tests on 200 volunteers showed that 54 percent chlorinated askarel was neither a primary skin irritant or a sensitizer. Prolonged or repeated skin contact with askarels must be avoided by the use or gloves and protective garments, because of the pos sible occurrence of a condition called chloracne. Although reports of this condition caused by askarels are rare, it can be produced by excessive skin contact. If any askarel is spilled on the skin, the skin should be washed in the usual manner with a soap solution. A burn caused by contact with a hot askarel should be treated like any ordinary burn. Material adhering to the burned area need not be removed immediately, unless treatment of the burn demands it, in which case either soap and water or repeated washings with a vegetable oil are recommended. -- The Use and Disposal of Electrical Insulating Liquids, Sub-Council Report, June 1?71 National Industrial Pollution Control Council 781994 MEL 000150 TECHNICAL RESOURCES G E N E R A L ^ ELECTRIC 1 RIVER ROAD. SCHENECTADY. N. Y. 12345 SUBJECT DIAL COMM 8*235-2261 PCB Transformer Labeling COPIES: JF McAllister - NEW YORK A. Pozefsky - HUDSON FALLS EL Raab - PITTSFIELD EL Simons - SCHENECTADY March 17, 1972 Mr. E. R. Ruterman Program Manager Safeguard PAR Development Electronics Systems Division Court Street - Bldg. 5-C3 Syracuse, New York 13201 Dear Mr. Ruterman: Supplementing my letter of March 10, we now have available to us the precise wording of caution labels currently being evaluated by the subcommittee on transformers of the ANSI C107: CAUTION: The insulating fluid in this transformer contains polychlorinated biphenyls, which some studies have shown may be an environmental contaminant. Extreme care should be taken to prevent any entry into the environment. In case of malfunction or leaks, consult the instruction manual or the manufacturer. Very truly yours, JSN:ev is S. Nelson, Consultantfduct Environmental Compatibility NEL00151 781995 TECHNICAL RESOURCES GENERAL; ELECTRIC i RIVER ROAD, SCHENECTADY. N. Y. 12305 SUBJECT D IA L comm 8*235 -2261 COPIES: JF McAllister - NEW YORK EL Raab - PITTSFIELD EL Simons - SCHDY. March 24, 1972 Dr, Abbott Pozefsky Manager-Engineering Industrial & Power Capacitor Prods. Dept. John Street Hudson Falls, N. Y. 12839 Dear Al: Thank you for your memorandum on "Procedures for Disposal of Failed or Obsolete Capacitors Containing PCB's." My initial reaction is that, in incorporating this in a revised Bulletin 4.1, we will wish to transpose the order to continue incineration as the preferred method of disposal. Also, as discussed, we shall need to be clearer as to what ve mean by a "non-corroding container" (e.g., an ordinary polypropylene container for household refuse, with a snap-on lid, to be buried upright-- this method to be used only where supervision of the actual burial is under control of the party initiating the disposition). With regard to caution labels, it would seem logical to begin using these on the sizes for which they are to be recommended, as soon as your ANSI subcommittee is satisfied with the wording to be recommended -without awaiting final issuance of the Standard. Apparently, the Transformer subcommittee is already at this point in their deliberations, and Ed Raab has made the recommendation that we start using labels on GE transformers forthwith (see his letter to transformer marketing managers, copy enclosed). Very truly yours, JEN rev Enclosures James S. Nelson, ConsultantProduct Environmental Compatibility NEL OO0l52 781996 A -li-4 GENERAL ^ ELECTRIC dial comm. 8*236-4385 date. March 20, 1972 0pT* ADORESS. SUBJECT* D ie le c tric System s la b o ra to ry , I3L0 P itts f ie ld , Mass. LABELS FOR FYRAJQL TRAKSJORJ.EES J, S. V rl ^ i MAR 2 2 1972 COPIES* R. C. G sthoff . L . Dobbins J . 0 . Sweeny V J . S. Kelson E. L. Simons M essrs. L. L. Dangler R. V/. Frsfca W. B. G a ith e r Gentlemen: " * t* t* $ 7J*c/ . H a t*rr*e/' * / W > r 7/nfc. f ' f M I t i s s tro n g ly recommended th a t a p p ro p ria te la b e ls be a ffix e d cn each Pyranol tran sfo rm er. W estinghouse has been doing th i s f o r about a y e a r. ANSI (American N a tio n a l S ta n d a rd s I n s t i t u t e ) Committee C-107 on th e "Use and D isp o sa l o f A sirarel Used In E l e c t r i c a l Equipment" v n .il u n d o u b ted ly recommend t o th e in d u s tr y t h a t a p p ro p ria te l a b e l s be u s e d . A d d itio n a lly , some a re a s are i n t e r p r e t i n g a s e c tio n o f OSHA (O c cu p a tio n a l S a fe ty and H ealth Act) as re q u irin g warning la b e ls on any m a te ria l, equipm ent, e tc . where such m a te r ia l c r f o r equipm ent c o n ta in in g a m a te r ia l t h a t may be con sidered to be a possible h ealth hazard.- The c u r r e n t th in k in g of ANSI C-107 on la b e l s f o r a s k a r e l - f i l l e d e le c t r i c a l equipment i s as fello w s: A) N-w Annar a t us A ll new tra n s fo rm e rs t h a t c o n ta in PCB's s h a l l have a l a b e l o f adequate d u r a b i l i t y p erm anently and p ro m in e n tly a tta c h e d t o th e ta n k by th e manu fa c tu re r giving th e follow ing warning in s tru c tio n s . Label in s tru c tio n s should include th e follow ing: CAUTION The in s u l a t i n g f l u i d i n t h i s tra n s fo rm e r c o n ta in s p o ly c h lo rin a te d b ip h e n y ls , which come s iu d ie c have shown may be an en v iro n m en tal con ta m in a n t. Extreme care should be tak en to p rev en t ary e n try in to th e environment. In case cf m alfunction o r leaks consult the in s tru c tio n manual o r th e m a n u fa ctu rer.. -'Ml' **-/ NEL 000153 781997 *\J2 L , L . D engler H* V/. Praam V/. B. G a ith e r 2 liarch 20, 1972 3 ) " S `!'-'VT*Ci* AT)"i?lTnt'!? The tra n s fo rm e r m a n u fa c tu re r should male s u ita b le l a b e l s avai2 a b le w ith a s im ila r f a m in g as i n (A) above f o r u s e r s o f e x is t in g tr a n i io izers, Very tru ly y o u rs, E. L. Eaab, lianager D ie le c tric Systems Laboratory B u ild in g 11-315 ml NEL000154 781998 d- r- a- f - t jr r/- - j: PROCEDURES FOR DISPOSAL OF FAILED OR OBSOLETE CAPACITORS CONTAINING PCB's The Pyranol inpregnant used in GE capacitors is part of the PCB family of materials. Because of the present national concern about PCB's generally, it is recommended that great care be exercised in the handling and disposal of scrap capacitors. The following guidelines should be followed: 1. Disposal of failed or obsolete capacitors or systems containing capacitors (e.g. ballasts, air conditioners), where the capacitor case is intact and the impregnant remains sealed in, can be done in clean dry landfill areas which are isolated from rivers or streams. 2. Scrap capacitors which have opened should be placed -in a non-corroding container and sealed before disposal in a clean dry landfill area. 3. Spills of Pyranol coming from capacitors should be immediately soaked up with absorbing earth or sawdust, which should then be placed in a .non-corroding container and sealed for disposal in a clean dry landfill iti i " 1 area. Incineration services have become available recently as an alternate t method of disposal. Monsanto Chemical Company offers a disposal service u. for scrap liquid PCB's. Chem-Trol Pollution Services, Inc. offers incineration services for both liquids, solids slurries, and scrap hard ware (e.g. capacitors, ballasts). Further information can be obtained by contacting the following: Mr. T. J. Reese Mrs. Carol Jordan 'i Chem-Trol Pollution Services, Inc. Monsanto Company 4818 Lake Avenue 800 N. Lindbergh Blvd. Blasdell, N. Y. 14219 St. Louis, Mo. 63166 Phone 716-826-3850 Phone 314-694-3352 N E L 000155 . / j :^0 l' yc; 3/20/72 AT 781999 TECHNICAL RESOURCES GENERAL ELECTRIC 1 RIVER ROAO. SCHENECTADY, N. Y. 12345 SUSJECT -1 DIAL COMM 8*235-2261 MONTHLY ACTIVITIES REPORT James S. Nelson__________ March 30, 1972 Mr. J. F. McAllister NEW YORK COPIES: FS R o t h e 2. PCB Electronic Systems Division has been counseled on the handling of the subject of FCB in the informational support system of a large phasedarray radar. The ANSI committee is making progress in such matters as disposal methods and labeling requirements. When Monsanto withdrew PCB from open applications, Laminated Products switched to a chlorinated terphenyl (Aroclor 5432) as the plasticizer in their flame-resistant printed circuit boards. That material, in turn, is now being withdrawn from the market as part of Monsanto's environmental retrenchment. The Department received our concurrence in efforts to negotiate the required turn-around time, and has been urged to check out the environmental compatibility of the thirdgeneration plasticizer, which will probably be either a phosphate ester or a brominated epoxy. NEL 000156 782000 G E N E R A L O ELECTRIC Mr. J. F. McAllister 2 M arch 3 0 , 1972 B * 0105 James S. Nelson JSN:ev P NEL 000157 782001 TECHNICAL RESOURCES GENERAL ELECTRIC 1 RIVER ROAD. SCHENECTADY. N. Y. 12345 SUBJECT D AL COMM 8*235-2261 ] Capacitor Disposal Recommendations COPIES: JF McAllister - NEW YORK OH LeBlanc - CR&D-SCHDY EL Raab - PITTSFIELD EL Simons - Bldg. 36-SCEDY March 31, 1972 Dr. Abbott Pozefsky Manager-Engineering Industrial & Power Capacitor Products Dept. John Street Hudson Falls, N. Y. - Dear Al: My letter of March 24, 1972, expressed certain reservations about the proposed procedures for disposal of failed capacitors which you have offered for an updated version of Bulletin EPS-4.1. On further reflection, and after hearing Jack McAllister's views, I'm returning to the attack with additional arguments. We are now inclined to question both the need for and the practicality of the "container method" of disposal. We are influenced in our thinking by the presumably insurmountable difficulty of reaching and controlling the actions of all those who have small industrial capacitors to throw away; by the small per-unit content of dielectric fluid; and by the relatively low degree of chlorination of capacitor-grade Aroclor. Since there has recently been some confusion on this latter point, it is appropriate here to quote from Dr. Papageorge's statement to the C107 Meeting of September 14: "Professor Charles...has isolated at least three microbes that seem to thrive on polychlorinated biphenyls...What this tells us is that there are microbes out there that will eventually destroy these materials..." "The studies (in St. Louis) so far show that there are isomers within each of these mixtures that do degrade. The lower the chlorine level, the faster they disappear, the higher the chlorine level the more resistant they are, which only confirms what many of us had expected." Further considerations are the difficulty of verifying long-term containment by the proposed method of containerization and -- what is most significant -- the availability of at least one service (Chem-Trol) for the controlled incineration of contaminated solids. For various practical reasons, it appears appropriate to make a distinction in our recommendations between power capacitors and small industrial capacitors. NEL 000158 782002 G E N E R A L ^ ELECTRIC Dr. Abbott Pozefsky -2- March 31, 1972 In view of these considerations, we should like to propose the following revised disposal recommendation for the consideration of our working group : PROCEDURES FOR DISPOSAL OF FAILED OR OBSOLETE CAPACITORS CONTAINING PCB'S The Pyranol imprgnant used in GE capacitors is part of the polychlorinated biphenyl family of materials ( P C B ) C o n s i d e r i n g the national concern over the problem of potential environmental contamination, it is essential to adopt procedures to prevent unnecessary entry of these materials into the environment. The following guidelines should be followed: A. Power Capacitors - (Large electric utility and industrial types containing typically 3 pounds of dielectric fluid, and in large sizes as much as 77 pounds.) Scrapped power capacitors should be shipped to a firm offering a controlledincineration disposal service. If the case has been opened or has ruptured, any spill should be soaked up with absorbing earth or sawdust. The absorbing material should be collected, and both it and the failed capacitor placed in a sealed container for shipment to the disposal service. Further information may be obtained from: Mr. T. J. Reese Chem-Trol Pollution Services, Inc. 4818 Lake Avenue Blasdell, N. Y. 14219 Phone 716/826-5850 B. Small Industrial Capacitors - (This class of capacitor is used in fluorescent ballasts, air-conditioners, motor operation, and electronic filtering, for example. Typical dielectric fluid content varies from 0.05 lb. to 1 lb. per unit.) Scrapped small industrial capacitors, and scrapped equipment containing small industrial capacitors may be disposed of in ''sanitary landfills" -- i.e., managed landfill operations where suitable precautions are taken to isolate the area from rivers and streams. There quantities are large (as, for example, in the case of liquidation of an obsolete OEM inventory), the capacitors should be handled as in Part A. Very truly yours, JSN:ev Jarnos S. Nelson, Consultantroduct Environmental Compatibility n e l 0159 782003 TECHNICAL RESOURCES GENERAL ELECTRIC 1 RIVER ROAD. SCHENECTADY. N. Y. 12345 SUBJECT D A L; C OM M` 8*235-2261 PCB and the Food Industry COPIES: M. J. Kolhoff - NEW YORK J. F. McAllister - NEW YORK W. M. Rodgers - ROME, GA. April 7, 1972 Messrs. S. R. Anderson Food Service Equip. Bus. Dept. K. Cox - Md. Transformer Products Dept,.*- W. F. Powell - Ballast Bus. Dept. S j y ^ A. Pozefsky - Industrial & Power Capacitor Dept. E. L. Raab - Dielectric Systems Lab.-Power Delivery You have seen the Notice of Proposed Rule Making concerning PCB's which the Food and Drug Administration issued recently (Federal Register, Vol. 37, No. 54, Saturday, March 18, 1972, p. 5705-5707). Interested persons have 60 days from March 18 in which to file written comments. Attention is called to Part 128, Par.128.4 (b) (iii). At least one representative of the food industry is interpreting this to require the elimination, from food processing plants, of all PCB transformers and PCB-capacitor motors. Presumably, fluorescent ballasts could also be affected, depending upon the interpretation given to this paragraph. f Inasmuch as we know of no instance in which the contamination of food or food packaging materials has been attributed to capacitors or transformers, we regard this remedy as unsuitable. If you agree, it would be appropriate, for example, through your trade association, to suggest wording which would specifically exclude these components from the proposed equipment ban, substituting whatever precautions as to location or protection you may deem advisable. Hie same considerations apply to the corresponding sections on food packaging materials and animal feed. Very truly yours, J S N :ev S. Nelson, ConsultantProduct Environmental Compatibility NEL 000160 782004 T TECHNICAL RESOURCES GENERAL ELECTRIC I RIVER ROAD. SCHENECTADY. N. Y. 12345 SUBJECT Reply to Dr. Quinby D A L COMM 8*235-2261 COPIES: JF McAllister - NEW YORK April 10, 1972 Dr. E. L. Simons Manager-Environmental Information Center BUILDING 36-120 Dear Ed: As discussed, this letter will contain notes on two subjects for a suggested reply to Dr. Quinby's March 30 letter. You speak of the danger of "hysteria based on excessive fear". We, of course share your concern for such a development, and for this reason recommend that -- even in correspondence between friendly parties -- we must all exercise care to avoid overstatement of the problems associated with FCB. For instance, we find in your letter of the 30th of March a reference to "the cases and epidemics of industrial poisoning with dielectrics, heat-transfer agents, and insulators". The fact of the matter is (so.far as we have been able to ascertain) there has not been one single instance of industrial poisoning attributable to the use of FCB's as dielectric fluid or insulator, either in capacitors or transformers. Furthermore, the several cases of food contamination we have learned about all had their origin in leaks of fluid from heat-transfer or hydraulic systems, or in "open" applications such as plasticizers in paints or coatings. Even within our own factories, where PCB's were handled for.many years before recent research findings made us aware of some of Tts undesirable properties, there were no cases of "industrial poisoning1.1 As was pointed out in the paper prepared for OST and previously mailed to you, "in the United States, medical records show chat over a nearly 40year period the only adverse health effects experienced by US workers exposed to FCB's, either during the manufacture of these liquids or of electrical equip ment containing these liquids, have been limited to occasional cases of non-chronic chloracne or other temporary skin lesions or irritations." In such cases, symptoms disappeared when the worker was transferred to other occupation. The products of the electrical industry have a clean record. We are endeavoring to keep it clean through the adoption of more stringent control and disposal methods, while preserving the public values of fire safety and efficient design. We welcome your support for this aim. P NEL 000161 782005 GENERAL ELECTRIC Dr. E. L. Simons 2 A p r il 1 0 , 1972 Your letter inquires about the chemicals formulated with PCB's in dielectric systems. A good reference to this subject (and a report which belongs, in any comprehensive library on PCB) is "The Use and Disposal -nneVElectrical Insulating Liquids", Sub-Council Report, June, 1971, National Industrial Pollution Control Council. This publi cation is obtainable from the U.S. Department of Coiranerce, National Industrial Pollution Control Council, Washington, D.C. 20230 under stock number 5254-0028, for the price of 25$. We have attached for your convenience a copy of Table No. 1 from that report. I hope that the above will prove helpful in formulating your reply to Dr Quinn. Very truly yours, J S N :ev Att. James S. Nelson NEL 000162 782006 TECHNICAL RESOURCES GENERAL ELECTRIC 1 RIVER ROAD, SCHENECTADY. N. Y. 12345 SUBJECT D I AL C O MM ' 8*235-2261 UPDATING OF SHAREOWNER-MEETING ENVIRONMENTAL GUIDEBOOK C O P IES: J. F. McAllister - NEW YORK o '/ April 14, 1972 Dr. E. L. Simons Manager-Environmental Inform. Center BUILDING 36 Dear Ed: In general, the material provided last year in preparation for the Annual Shareowners' Meeting is adequately descriptive of the current situations. The following notes highlight more recent developments: REDACTED NEL 000163 782007 GENERAL ELECTRIC Dr. E. L. Simons Special Environmental Issues: 2 April 14, 1972 REDACTED ? NEL 000164 PCB's The old PCB write-up contains some inaccuracies, some proprietary information, and significant omissions. The following re-write is offered for your consideration: SPECIAL ENVIRONMENTAL ISSUES POLYCHLORINATED BIPHENYLS BACKGROUND Mixtures of various polychlorinated biphenyls (referred to as PCB's or under the 782008 GENERAL ELECTRIC Dr. E. L. Simons 3 April 14, 1972 international term askarel or by trade names, such as Pyranol) are used by the electrical industry as dielectric and insulating liquids in capacitors and trans formers, in which applications their use dates back some forty years. They are used in transformers because they are "fire-proof" and in capacitors also for the long-life, efficient designs they make possible. In recent years, a host of non-electrical industry applications for these fluids have been developed: plasticizers in paints and coatings, carbonless duplicating paper, hyraulic and heat-transfer systems, among others* - PROBLEM Evidence is accumulating that when PCB's get into the environment they behave much like DDT in their persistence and ubiquity through the ecological chain of fish and bird wildlife, and in their harmful effects on these species. There have been several instances of finding identifiable amounts of PCB's in food, generally traceable to specific industrial accidents involving contamination from spills of heat-transfer fluid in food processing plants or from open-ended applications, such as paints in silos. None of these Incidents has been attributed to any electrical application. CURRENT GE PRACTICE The GE products that contain PCB's are filled at the factory and are delivered as sealed units to the customers. There should be no loss of liquid during normal service life, which is measured in decades both for transformers and capacitors. Concern for contributing to the ecological problem is thus confined principally to the disposition of process losses and the ultimate disposal of used products. REMEDIAL MEASURES Through private industry initiatives, all of the more vulnerable applications of these materials are rapidly being phased out. In 1971, Monsanto, the sole US producer, withdrew the materials from sale for the open-ended applications (plasticizers, paints, etc.) and in 1972 withdrew from the "nominally-closed" systems business (hydraulic and heat-transfer fluids). The Food and Drug Adminis tration is in the process of confirming this industry initiative through a proposed rule making, March 18, which will make it illegal to use these chemicals in food processing. To make sure that PCB's are handled responsibly in connection with the remaining "closed" applications in transformers and capacitors, the American National Standards Institute is drafting standards governing the safe use and disposal of these materials. The ANSI committee, formed at the Instigation of GE, is presently at the stage of circulating advanced drafts for industry comment. 782009 NEL 000165 GENERAL ELECTRIC Dr* E. L. Simons 4 April 14, 1972 Because research indicates that PCB's with a high chlorine content are more persistent in the environment, a new capacitor dielectric from which the highlychlorinated fractions are largely eliminated was introduced by Monsanto last year and quickly evaluated and introduced into production by GE and others* Provision has been made in the industry for the incineration under controlled conditions of scrap PCB liquids and for the safe disposal of contaminated solids, there now being several facilities which afford such services* redacted 991000 T H N - JSN :ev (Not read by Mr. Nelson) Very truly yours, Product Environmental Compatibility 782010 sy/1 7 Subject: Compliance With Proposed FDA Regulations On PCB April 28 1972 Hr. A. L. MeLane Purchasing Department NABISCO Inc. 425 Park Avenue New York N. Y. 10022 Dear Mr. MeLane: Your letter of April 21 1972, addressed to the Office of the President has been referred to us for reply. You will be hearing from us after we have had time to give the matter appropriate consideration. Very truly yours, J. S. Nelson JSN:g bcc: J. F. McAllister E. Raeb A. Pozefsky W. Powell Please let me have your thoughts on matters to be considered in reply (without contacting the customer). J. S. Nelson 782011 NEL 000167 TECHNICAL RESOURCES 1 RIVER ROAD. SCHENECTADY. N. Y. 12345 SUBJECT D .I A L COMM 8*235-2261 1 MONTHLY ACTIVITIES REPORT James S. Nelson__________ May 2, 1972 Mr J. F. McAllister NEW YORK C O P IES: FS Rothe Re d a c t e d 782012 NEL 000168 GENERAL ELECTRIC Mr. J. F. McAllister 2 M ay 2 , 1 9 7 2 REDACTED 3. The F.D.A. and PCB The F.D.A.'s proposed rule making on PCB's in food plants is causing a number of customer inquiries. It seems clear that the intent behind these regulations is to get rid of PCB's in process uses associated with handling food or food packaging materials -- the heat transfer and hydraulic applications, principally; however, the language is broad enough to cause -- concern about the legitimacy of using PCB-containing capacitors and trans formers in such plants. We plan to urge clarification of the language to except sealed electrical apparatus, working through the Certified Ballast Manufacturers' Association and also filing a letter of comment by GE as a manufacturer (statement to be prepared by this office). NEL 000169 REDACTED 6. Departmental Consultations Brief consultations during the month included: Specialty Hiidics -- environmental reporting Battery Products Section -- toxic materials PECO -- relations with Dr. Quinby, who is doing contract work for Oak Ridge on toxicology, specifically PCB's. Industrial Heating -- Incineration Standards activity Nuclear Energy Products Division - Annual environmental report: consequential damages. \ 782013 V TECHNICAL RESOURCES G EN ERAL! ! ELECTRIC 1 RIVER ROAD, SCHENECTADY. N. Y. 12345 SUBJECT D r L C OM M 8*235-2261 C O P IES: JF McAllister - NEW YORK May 2, 1972 Mr. W. F. Powell Manager-Engineering Ballast Business Department 1430 E. Fairchild Street DANVILLE, ILL. 61832 Dear Mr. Powell: Per our telephone conversation today, the enclosed papers may be helpful to you in formulating the position of the Certified Ballast Manufacturers1 Association with regard to PCB. Very truly yours, James S, Nelson, ConsultantProduct Environmental Compatibility JSN:ev Enclosures - The Use and Disposal of Electrical Insulating Liquids and The Role of Polychlorinated Biphenvls in Electrical Equipment NEL 000170 782014 a. TECHNICAL RESOURCES GENERAL ^ ELECTRIC I RIVER ROAD, SCHeT eCTADY, N. Y. 12305 SUBJECT PCB D I AL COMM 8*235-2261 Z l C O P IES: J. F. McAllister J. S. Anderson E. L. Simons AIR MAIL May 15, 1972 Mr. Walter T. Kinsey Consultant - Manufacturing Services Compagnia Generale di Elettricit S.p.A. Via Paleoc2pa 7, Milano, Italy Dear Mr. Kinsey: This letter is intended to supply background information on PCB to help understand GE's position with respect to Monsanto's request for various special undertakings and the various restrictions proposed by governmental agencies. PCB (GE's Pvranol) has been the subject of several Company studies since 1969, when we first began to receive word of the possible potential for ecological harm. Dr. Anderson has no doubt explained to you the various measures that have been taken to reduce PCB waste from our domestic operations to acceptably small values. The following enclosed documents should provide a basis for evaluating your position with respect to product applications and for fielding any inquiries you may receive from your customers: 1. Bulletin EPS 4.1, Information on the Use and Furnishing of Material Containing Polvchlorobiphenvls. with transmittal letter, sent originally to all Group Executives, Division General Managers, Deputy Division General Managers, and all Product Safety Representatives and Holders of the Product Safety Manual. Dated September 21, 1970, this bulletin continues to be a sound guide to General Electric components in the handling of PCB's. 2. The Role of Polychlorinated Biphenyls in Electrical Equipment. February 4, 1972. This report was designed primarily to influence the U.S. Government's InterDepartmental Task Force on PCB's to reach a balanced appraisal of risks vs. benefits in considering what governmental action is appropriate. The Summary is suitable for separate use as a short orientation piece for answering inquiries from customers or outside parties. 3 . Open Letter to Industrial Cup tenets; Letter to Electric Utility Cast ers. These form letters were widely used in 1970 to inform customers of the co ern over PCB*. _ Distribution was handled through Mr, Clyde Bascue, Advertising 782015 NEL 000171 GENERAL ELECTRIC Hr. Walter T. Kinsey 2 May 15, 1972 and Sales Promotion, Building 23-279, Schenectady, the individual letters being signed by the sales personnel with cognizance of the particular account. -- Please let us know if you have any unanswered questions pertaining to the use of PCB's in products. Questions regarding the control of plant effluent should, of course, be addressed to Dr. Steve Anderson. Very truly yours, JSN:ev Enclosures uames S. Nelson, ConsultantProduct Environmental Compatibility p u NEL 000172 782016 G EN EnA .IL ELECTRIC GENERAL ELECTRIC COMPANY. 1 RIVER ROAD. SCHENECTADY. NEW YORK 12305 Phone (51C) 374-2211 Sub ine Li POLYCHLORINATED BIPHEYLS - NOTICE OF PROPOSED RULE MAKING FEDERAL REGISTER, Voi. 37, No. 56, March IS, 1972, pp, 5705-5707. TECHNICAL RESOURCES May 15, 1972 Hearing Clerk Department of Health, Education, and Welfare Room G-G8 5G00 Fishers Lane Rockville, Maryland 20S52 Gentlemen: We support the expressed intent of the proposed rule making on poly chlorinated biphenyls -- "that the sources and levels of PCB's in animal feeds, feed components, and food for human use (can and should) be significantly reduced or eliminated so as to minimize the overall long-term human exposure to PCB's." We are also in general agreement with the proposals made, recognizing that to a considerable extent they confirm and codify steps already taken as a result of private initiatives. These private initiatives include, among other steps: e an evaluation of PCB pollution problems, described in The Use and Disposal of Electrical Insulating Liouids. published by the National Industrial Pollution Control Council, June, 1971; o the withdrawal from the market - by the sole U.S. producer - of PCB's for "open" applications such as formulations in lubricants, and ingredients in paints, plastics, inks, etc.; the withdrawal from the market - by the sole U.S. producer - of PCB's from semi-closed applications such as heat-transfer liquids and hydraulic liquids, and their replacement, free of charge, in foodproducing plants, by non-PCB formulations; and the activation, by the American National Standards Institute, of Committee C107, to draw up guidelines to protect the environment from any adverse consequences of the remaining uses; i.e., sealed electrical equipment, v i z . , capacitors and transformers. * NEL 000173 Our purpose in making these comments is to aid the Cocrnissioner in achieving such clarity and precision in the rules that the intent may be carried out without jeopardizing the public and industrial benefits accruing from the use of PCB's in two classes of scaled electrical apparatus: transformers and capacitors. These 782017 GENERAL 0 ELECTRIC 2 1 benefits -- chiefly fire safety and design efficiency of electrical apparatus -- are detailed in our memorandum, "The Role of Polychlorinated Biphenyls in Electrical Equipment", February A, 1972, which document is submitted in support of this letter of comment. With specific relation to the food-processing industry, there are a number of roles fulfilled by PCB-containing electrical apparatus which cannot be adequately performed by substitutes... For example, where transformers are required, as in stepping down distribution voltage to utilization voltage or supplying furnaces or large motors, only PCB transformers can meet required performance criteria while at the same time offering the degree of fire protection essential to installation in occupied premises. The capacitor applications likely to be found in a plant of the type at issue include the compressor systems of air- conditioning units, the ballasts of fluorescent lighting, phase-splitting and power-factor correction for electrical motors, filtering of electronic power *" supplies, and others (see accompanying report). Both types of equipment possess several characteristics relevant to the subject of protection against PCB contamination: 1. Both capacitors and transformers are constructed in sealed metal cases, 2. Failure rates arc low -- of the order of 0.1% to 0.27. per year. 3. Failures severe enough to affect containment integrity are still rarer. About 0.01% of failed capacitors rupture, that is, about one in 3 million installed units. Such events in transformers are too rare for a statistical estimate to be made with any confidence. A. In the rare event that a failure affecting case integrity occurred, the immediate loss of electrical function would be a signal to operating personnel to take appropriate precautions or remedial measures to avoid any effect upon the material in process. Because of these characteristics, none of the PCB contamination events of which v;e have kmw l e d g e has been ascribed to the use of capacitors or transformers. Because of the widespread use of fluorescent lighting in factories of all types, an additional conment about that application seems appropriate. The capacitors used in ballasting fluorescent lamps are, as noted above, in sealed metal cases. These cases, in turn, are imbedded in a sealing compound surrounded by a second metal case, housing the complete ballast assembly. The ballast is installed in a lighting fixture (luminaire) which may or nay not be itself enclosed. The amount of free, unabsorbed dielectric liquid in a ballast capacitor is very small - about ten grams per unit. Furthermore, in some ballasts (notably those supplied by General Electric) internally protected capacitors are used. These capacitors contain a thermal or pressure-sensitive device to remove the capacitor from the circuit in the event of electrical failure, thus isolating it before internal pressure can build up to the point of case rupture, making the possibility of a leak still more remote. NEL 000174 782018 GEN ERAL^' ELECTRIC 3 For the above reasons, as veil as information contained in the accompa nying report, .we feel that electrical components in factories engaged in the processing of animal or human food or food packaging materials merit special consideration in rule making. Failure to accord the appropriate recognition would result in chaotic rebuilding and re-equipping programs accompanied by inordinate expense. Transformers, for instance, could be replaced by mineral oil types, which would require location outside and/or in vaults to meet fire underwriter and electrical code provisions. Replacement capacitors, should they be obtainable, would be larger -than PCS types and in many cases vjould not fit into existing equipment -- requiring, for example, the ripping out and complete replacement of factory lighting systems, ninety percent of all industrial and power capacitors made today contain PCB. Their inadvertent banning, as a consequence of broadly stated or loosely interpreted prohibitions against the use of PCB's, would require engineering inspection and possible design and rework attention to virtually all electronic and electrical systems _ in a modern factory; all without demonstrable improvement in sanitation. Our concern focuses on the language of two prohibitions, each appearing, with appropriate variations, in the Part 3 section on animal feed, and Part 3 section on food-packaging materials, and the Part 12D section on human foods. He quote only the first pair of references to illustrate our comments, which should be understood to apply to the others as well: Part 3, Section 3, Par. (b)(2) - New equipment or machinery for handling or processing feed in or around an animal feed producing establishment shall not contain PCB's. (Our reference "A") Part 3, Section 3, Par. (b)(3) (iii) - Eliminate from the animal feed producing establishment any other PCB-containing materials, whenever there is a reasonable expectation that such materials could cause animal feed to become contaminated with PCB's whether as a result of normal use or as a result of accident, breakage, or other mishap. (Our Reference "B") With regard to Reference "A", we recommend making a distinction between equipment or machinery which is in physical contact with the feed (or packaging material, or food) on the one hand; and, on the other hand, associated power supplies, control equipment, or auxiliary equipment which is not in contact with the material it is desired to protect. For example, PCB would be banned in cookers, pasteurizers, conveyers, storage vessels, electrostatic separator electrodes and the like; but PCB as dielectric fluid in scaled capacitors or transformers would be allowed in electronic controls, power supplies, machinery drives, air conditioners, lamp ballasts, electrical substations, and the like installed in the same factory where the feed (or packaging or food) is processed. Therefore, in consonance with what we believe to be the Commissioner's intent in the original formulation, we suggest the following wording: Part 3, Section 3, Par. (b)(2) - New equipment or machinery for c m I n directly in handling or processing feed in or around an animal feedproducing establishment shall not contain PCB's. 782019 NEL 000175 5G E N E R A L ELECTRIC A Following the same logic, in Part 3, Section 3, Par. (b)(1), we suggest: New equipment or machinery for TrenurReturing employed directly in physical operations upon or handline of food-packaging materials shall not contain or use PCB's. Again, in Part 128, Section 128.A, Par. (b)(1): New equipment, utensils, and machinery for employed directly in handling or processing food in or around a food plant shall not contain PCB's. With regard to Reference "B", similar considerations apply. The difficulty lies in defining the concept of "reasonable expectation11. From an administrative viewpoint, the easiest way for administrative personnel to decide such issues is to ban PCB in nil forms (without regard to the fire hazard or expense so introduced); and indeed, shortly after the publication of the proposed rule making, it came to our attention that some people in the food industry feared that this paragraph would be interpreted to ban all capacitor-equipped motors, for example, from food-related factories. Whereas we are confident that such is not the intent of the proposed rule making, we have no wording to recommend that would insure uniform interpretation of "reasonable expectation". We propose instead the insertion of language specifically authorizing the use of PCB trans formers and capacitors, excluding them from the category of banned materials. This could be accomplished in the following manner. After the proposed Reference "B" paragraphs (i.e., Part 3, Section 3, Par. (b)(iii), animal feed; Part 3, Section 3, Tar. (b)(2)(ii), food packaging materials; and Part 128, Section 128,A, Par. (b)(2)(iii), human foods.) insert the words: This provision does not require the elimination of certain sealed electrical apparatus: specifically exempted are transformers and capacitors containing PCB, when applied within the manufacturer^ ratings and installed separately from that equipment which is in physical contact with the material being processed. Respectfully submitted, James S. Nelson, ConsultantProduct Environmental Compatibility JSNsev kcc: Anderson - Mgr.-Environmental Protection Oper. -SCHDY. EN Deck - Mgr.-Safety & Security - NEW YORK EL Dobbins - Division Counsel-Transf. & Distr. Equip. - PITTSFIELD JF McAllister - Manager-Product Quality Staff - NEW YORK AE Peltosalo - Vice Pres.-Power Del. Group - NEW YORK WF Powell - Manager-Engrg. - Ballast Bus. Dept.-DANVILLE A. Pozefsky - Manager-Engrg.-Indus.Power Capacit. - HUDSON FALLS EL Raab - Manager- Dielectric Sys. Lab. - PITTSFIELD JF Repko - Division Counsel -Electronic Comps. - SYRACUSE WA Schlotterbeck - Vice Pres.^Corporate Legal Oper. - NEW YORK EL Simons - Environmental Protection Oper.-RECO - SCHDY. tt? vainer - vice President-Technical Resources - NEW YORK 782020 NEL 000176 TECHNICAL RESOURCES G E N E R A L # ELECTRIC RIVER ROAD, SCHENECTADY, N. Y. 12305 SUBJECT dial COM M 8*235-2261 INTERDEPARTMENTAL TAS" FORCE REPORT .i. i / COPIES: RJ Boudreau - HUDSON FALLS OH LeClanc - K-1-3CHDY. A. Pozefsky - HUDSON FALLS EL Raab - PITTSFIELD EL Simons - RSCO-SCHDY. May 17, 1972 Mr. J. F. McAllister NEW YORK Dear Jack: This morning I received a copy of the Interdepartmental Task Force report, entitled Fo]ycMorinated Einhenvls and the Environment. CGM^72-10419, May, 1972, distributed by the National Technical Information Service, U.S. Department of Commerce, Springfield, Va., 22151 (Price $6.00). From a quick reading of the report proper (20 pp) and a scanning of the entire bock of 181 pages, it is abundantly clear that the work of our task force has paid off. Appendix C is taken verbatim (with appropriate credit) from the NIPCC paper written by the "Industrial Work Group on PCI!" which met in Washington on January A, 1972. That paper, in turn, was created by committee "massage" of our own task force paper, "The Role of Polychlorinated Biphenyls in Electrical Equipment", plus some contributions by Uestinghouse. Appendix C, in turn, is quoted or paraphrased repeatedly in the main text of the report. As Ed Simons has noted, the position taken with regard to continued use of FCB in capacitors and transformers is consistent with our recommendations. Very truly yours, JSN:ev -James S. Nelson, ConsultantProduct Environmental Compatibility P.S. There are also two references to the original NIPCC pamphlet, "The Use and Disposal of Electrical Insulating Liquids" and one reference to "Private communication. E. L. Raab, General Electric Co." JSN NEL 000177 782021 Av ::e ;v Y-nV, N Y. 10022 lv'j: iAC:SCO f? 12', 751-5033 General Electric Co. 1 River Road Sehnectady, N.Y. 12305 Office of the President Dear Sir: . The Food Sc Drug Administration has recently published in the Federal Register Volume 37, No. 5^, dated March lo, 1972, a proposed rule which in effect states that new equipment or machinery for the handling, processing or packaging of food for human or animal consumption shall not contain Polychlorinated 3i-Phenyls (PCS). As a supplier of equipment to Nabisco,Inc. you are requested to investigate all components of your equipment or machinery to insure us in writing that your equipment complies with existing FDA regulations concerning FCE. In the event. PCB is found to exist, your recommendation for replacement of contaminated units and replacement cost and availability would be appreciated. Thanh you for your cooperation and assistance in this important matter. Your prompt written acknowledgement of this letter would-be appreciated. AU4:ab PURCHASING DEPARTMENT j?.f Jk; .iMsiio l /t*7t-i't1. j LJ !..,./ ' '. J ;<*.(/ I 782022 rcJ-f' '-'-'"O ' . ff-2 S '> fi NEL 000178 /S. GENERAL ELECTRIC GENERAL ELECTRIC COMPANY. 1 RIVER ROAD, SCHENECTADY, NEW YORK 12305 Phone (518) 374-2211 TECHNICAL RESOURCES f1 May 22 , 1972 Mr. A. L. McLane Purchasing Department NABISCO, INC. 425 Park Avenue New York, N. Y. 10022 Dear Mr. McLane: Replying further to your inquiry of April 28 relative to PCB, to the best of our knowledge the General Electric equipment in your factory containing P C B 's is limited to certain classes of transformers and capacitors. To meet the fire requirements of electrical codes and underwriters, the dielectric fluid of transformers installed in or near occupied premises contains PCB. There is no substitute. One possible alternative would be to replace the transformer with a mineral-oil type, in which case the transformer would be required to be placed in a fire-proof vault or installed outdoors. PCB-containing capacitors are widely used in the motor circuits of airconditioners and as accessories to other small "split phase" motors; as powerfactor correcting equipment in substations; as a component of the ballast in fluorescent lighting installations; and as filters or electrical wave-shape modifiers in electronic control panels, rectifiers, inverters, and the like. An example of such an application is the vibration control unit of your weigher made by the Pneumatic Scale Company, which has been the subject of discussiou between your people and our offices in New York and Hudson Falls. It has been estimated that 907. of industrial and electrical-power capacitors contain PCB. While functional replacements theoretically could be manufactured, they would be too large to fit in existing equipment in many applications, and would somewhat increase fire hazards. Fortunately, both transformers and capacitors are sealed, so that in normal service there is no evolution of PCB. Failures severe enough to cause leakage are extremely rare and generally cannot occur without disruption of electrical function, which event would signal the need for clean-up and repair. The special status of transformers and capacitors is recognized in a government report released just this week, Polychlorinated Biphenyls and the Environment -- Interdepartmental Task Force on PCB's. May 1972, One of the findings of this report (sponsored by the Departments of Agriculture, Commerce, 782023 NEL 000179 GENERAL ELECTRIC Mr. A. L. McLane -2 May 22, 1972 Health, Education and Welfare, and Interior; and Environmental Protection Agency; plus other participating agencies) is, in part: "6. The use of PCB's should not be banned entirely. Their continued use for transformers and capacitors in the near future is considered necessary because of the significantly increased risk of fire and explosion and the disruption of electrical service which would result from a ban on PCB use. Also, continued use of PCB's in transformers and capacitors presents a minimal risk of environmental contamination." From our reading of the proposed FDA rule making, it does not appear to be the intent to outlaw either capacitors or transformers when applied in accordance with the manufacturer's ratings and installed separately from that equipment which is in direct contact with the food, feed, or food-packaging material being processed We have written to the Hearing Clerk of the Department of Health, Education, and Welfare with the suggestion that the exemption of capacitors and transformers so applied be made explicit in the final version of the proposed rules. A copy of our letter is enclosed. Please let us know if you require additional information. Very truly yours, JSN:ev Enclosures bcc: S. C. Van Voorhis - NEW YORK J. F. McAllister - NEW YORK E. L. Raab - PITTSFIELD A. Fozefsky - HUDSON FALLS W. F. Powell - DANVILLE E. L. Dobbins - PITTSFIELD James S. Nelson, ConsultantProduct. Environmental Compatibility NEL 000180 782024 PROPOSED rule making Proposed Rule Making 10003 DEPARTMENT OF LABOR Wage and Hour Division I 29 CFR Parts 520, 570 ] WORK EXPERIENCE AND CAREER Signed at Washington, D.C., this 9th day of May 1972, H orace E. M enasco. Deputy Assistant Secretary for Employment Standards and Administrator of the Wage and Hour Division. thorized under titles XXV and XVI, and the program of Medical Assistance au thorized under title XIX, of the Social Security Act to: 1. Extend Federal matching to cases where States measure disability solely against the individual's capacity to en gage in paid employment or self-employ EXPLORATION PROGRAMS [FR Doc.72--7513 F iled 5-17-72:8:49 am i ment, without considering also the in- Proposed Extension of Programs in States Where Such Programs Have Been Approved DEPARTMENT OF HEALTH, victual's capacity to keep house and care for others; 2. Permit the use. on the State review team, of persons of other disciplines, in Notice Is hereby given that the Wpge and Hour Division is considering fthe limited extension of the work experience and career exploration programs, how scheduled to terminate August 31. 1$)72, for another year in those States now having such programs In operation. Evaluation of the 1971-72 school year programs will not be completed uhtil December 1972, or later: and where such programs have been set up and funded, it is desirable that such programs' be continued. Before the end of the 197273 school year our evaluation will be complete and the Department will then be in a position to determine whether and the extent to which modification of cer EDUCATION, AND WELFARE Food and Drug Administration 121 CFR Parts 3 ,1 2 1 ,1 2 2 ,1 2 8 1 POLYCHLORINATED BIPHENYLS Extension of Time for Filing Comments The proposed regulations regarding polychlorinated biphenyls (FCB's) in animal feed, food, and food-packaging materials (21 CFR Parts 3,121,122,128), published in the F ederal Register of March 18, 1972 (37 F it. 5705), provided for the filing of comments thereon within stead of or in addition to a social worker; 3. Allow for the use of other appro priate documents in lieu of a current medical report: 4. Provide that States with definitions of disability not narrower than the def inition under title n of the Social Security Act may accept, as evidence of disability, a certification of current eligibility for disability benefits under title H; 5. Provide that States may contract to have disability determined by the State vocational rehabilitation agency, or by another agency that makes disability de terminations under title n of the Act. tain provisions of the child labor stand 60 days alter date of publication. Prior to the adoption of the proposed ards applicable to the employment of The Commissioner of Food and Drugs regulations, consideration will be given minors in such programs would be ap has received requests for an extension of to any comments, suggestions, or objec propriate. It Is also proposed to extend such time and, good reason therefor ap tions thereto which are submitted in the authority to issue subminimum wage certificates In connection with such pro pearing. the time for filing comments on the subject proposal is extended to writing to the Administrator. Social and Rehabilitation Service. Department of grams if the programs are extended. July 16.1972. Interested persons are invited to sub m it written comments, suggestions, or arguments regarding the proposed revi sion to the undersigned within 30 days after publication of this notice In the This action is taken pursuant to pro visions of the Federal Food, Drug, and Cosmetic Act (secs. 402(a), 406, 409, 701, 52 Stat. 1046 as amended, 1049, 1055-56 as amended by 70 Stat. 919 and 72 Stat. F ederal R egister. 948, 72 Stat. 1785-88 as amended: 21 It Is accordingly proposed to amend UJ5.C. 342(a), 346, 348, 371) and under Title 29 of the Code of Federal Regula authority delegated to the Commissioner tions as follows: (21 CFR 2.120). 1. Paragraph (b) of 520.12 is pro Dated: May 11,1972. posed to be revised to read as follows: \ S am D . F i .ne, 520.12 W ork experience and career Associate Commissioner' Health. Education, and Welfare, 330 Independence Avenue SW-, Washington. DC 20201, within a period of 30 days from date of publication of this notice in the F ederal R egister. Comments re ceived will be available for public inspec tion in Room 5121 of the Department's offices a t 301 C Street SW- Washington, DC, on Monday through Friday of each week from 8:30 am . to 5:00 pm . (202-- 563-7361). The provisions of these sections are to be Issued under section 1102, 49 Stat. 647, 42 UJS.C. 1302. exploration programs. ------ -- JoFCompliance. Dated: April 25,1972. (b) This section shall terminate and have no force and effect after August 31, 1973, 2. Paragraph (e) of 5 570.35a Is pro posed to be revised to read as follows: 570.35a W ork experience and career exploration program*. > (e) This section shall terminate and have no force and effect after August 31, 1972, except that States operating ap proved work experience and career ex ploration programs may continue to operate programs In their States until August 31,1973. |F R Doc.72-7509 F iled 5-17-72;B.'49 am ) Social and Rehabilitation Service [ 45 CFR Parts 233, 248 1 PUBLIC ASSISTANCE PROGRAMS Determination of Disability Notice Is hereby given that the regu lations set forth in tentative form below are proposed by the Administrator. Social and Rehabilitation Service, with the approval of the Secretary of Health. Education, and Welfare. The proposed regulations would amend current policies pertaining to the program of Aid to the Permanently and Totally Disabled au J ohn D. T wxnahe. Administrator, Social and Rehabilitation Service. Approved: May 10,1972. Elliot L.Richardson, Secretary. 1. Section 233.00 of Part 233 of Chap ter n of Title 45 of the Code of Federal Regulations is revised to read as set forth below: 233.80 Disability. . (a) State plan requirements and op tions. (l) A State plan under title XIV or XVI of the Social Security Act must: (I) Contain a definition of perma nently and totally disabled, showing that: fDEXAl REGISTER, VO L 37, NO. 97-- THURSDAY, MAY 18, 1972 7P9n9R NEL 000181 TECHNICAL RESOURCES G E N E R A L ELECTRIC 1 RIVER ROAD. SCHENECTADY. N. Y. 12345 SUBJECT D IAL COMM 8*235-2261 MONTHLY ACTIVITIES REPORT James S. Nelson__________ COPIES: FS Rothe May 31, 1972 Mr, J. F. McAllister NEW YORK IV-PRODUCT ENVIRONMENTAL COMPATIBILITY 1. PCB and the FDA A letter from the Company to the Hearing Clerk, HEW, suggests that in the final regulations concerning PCB and the food industry there should be an explicit exemption of capacitors and transformers from the rule banning most PCB applications in the food industry. A compatible letter has also been filed by the Certified Ballast Manufacturers' Association as arranged by Walt Powell in consultation with Technical Resources. It may be some time before we learn the result of our efforts, as FDA has extended the time period for the filing of conments on the proposed rule-making. Mean while, a copy of our letter of comment has been furnished to the Nabisco Company, which had written to "The Office of the President" of GE for information concerning PCB in products which might have been furnished to Nabisco. It is understood that the Industrial and Power Capacitor Products Department has received a number of inquiries from customers, which are being answered in similar vein, 2. California Grand Jury Inquiry into PCB The Department of Justice has subpoenaed certain Company information with respect to FCB's. It now appears that the scope of this Investigation comprises four southern California counties, with a focus on Service Shop and I.SE. activities. The most likely conjecture as to the origin of this inquiry is that EPA investigators discovered PCB in LA sewage. (See accompany ing letter from James Bruce to R, S, Birch et al.) Technical Resources and RECO have been furnishing Mr. Bruce with supporting information, 3. Interdepartmental Task Force The long-awaited government report on PCB's has been published and advises that continued use in transformers and capacitors is justified. GE's various inputs to this study are much in evidence, as noted in Nelson's note of 5/17 to McAllister. We feel it is significant that EPA allowed this report to issue after learning of Japan's strong strictures on PCB. 782026 NEL 000182 GENERAL ELECTRIC Mr, J. F McAllister 2 May 31, 1972 4. Compagnia Generale di Elettricit S.p.A. CGdE (Kinsey) has been advised regarding the signing of an agreement proposed by Monsanto, covering aspects of FC5 usage by the Italian company, and has been sent a package of relevant background material. 5. Stationary Combustion Installations. New York State Technical Resources consulted with RECO and Gas Turbine Products Division in the preparation of testimony which has been delivered to the New York State Department of Environmental Conservation on proposed regulations concerning emissions from stationary combustion sources. 6. Paint Solvents Since New York State's proposed Fart 205, controlling the use of volatile organic solvents (including photochemically reactive solvents) will apply only to the NYC metropolitan area, Insulating Materials Department declined to prepare testimony for the hearings held this month. 7. Annual Report - 20.13 Product environmental compatibility review notes have been forwarded for each Group in preparation for Sessions E. 8. Departmental Consultations Minor consultations during the month included: Major Appliances, in re Japanese ban on PCB; Industry Control, on Dowtherm A and E; Medical Ventures on noise; ICE on PCB background; NEMA (Salazar) on pending toxic substances act; and various Departments on details on the annual Product Environmental Compatiblity reports. Very truly yours, James S. Nelson JSN:ev Att. 782027 X cn ooor 00 u> THIS PAGE INTENTIONALLY LEFT BLANK * 782028 2 m oo o TECHNICAL RESOURCES GENERAL ELECTRIC 1 RIVER ROAD. SCHENECTADY. N. Y. 12345 SUBJECT D I AL COMM 8*235-2261 Your Information Latter - MT-168 COPIES: E. L. Dobbins - PITTSFIELD J. F. McAllister - NEW YORK E. L. Raab - PITTSFIELD J. F. Repko - SYRACUSE A. Pozefsky - HUDSON FALLS J. A, Sainz - HUDSON FALLS E. L. Simons - Bldg. 36-SCHDY June 2, 1972 Mr. R. W. Frahm Manager-Marketing Medium Transformer Department Rome, Georgia Dear Mr. Frahm: We have had occasion to review your GE - Confidential Information Letter, MT-168, entitled "Pyranol Update'1. We feel that this is an excellent job, and should put your field sales people in a good position to handle most customer inquiries. We think the "Update" should be updated, however, by quoting directly from the Interdepartmental Task Force, rather than from a news release about the same, and by adding a paragraph on the FDA proposed regulations. In addition, the proposed "Caution" notice, while an improvement on earlier versions, should probably have the word "any" deleted for the same reasons that "extreme" was taken out (per my letter to Ed Raab of March 28, copy attached). Several people have expressed the need for a shorter statement of the current FCB situation, which could be used as a customer hand-out or incorporated into letters on the subject, both for transformer and capacitor customers. We are attaching a draft of such a statement, and request a specific comment from each recipient showing either concurrence or suggestions for change. Very truly yours, JSN:ev Enclosures James S. Nelson, ConsultantProduct Environmental Compatibility NEL 000185 782029 ADVICE TO GENERAL ELECTRIC CUSTOMERS CONCERNING FCB (PYRANOL) 1. GOVERNMENT REPORT SANCTIONS CONTINUED USE OF PCB IN TRANSFORMERS AND CAPACITORS General Electric customers may continue to purchase and apply General Electric Pyranol (R) transformers and capacitors, secure in the knowledge that all relevant US government agencies are parties to a report sanctioning the continued use of polychlorinated biphenyls (PCB) in such apparatus. The following paragraph is quoted from one of the findings in which the government's Task Force concurred: "6, The use of PCB's should not be banned entirely. Their continued use for transformers and capacitors in the near future is considered necessary because of the significantly increased risk of fire and explosion and the disruption of electrical service which would result from a ban on PCB use. Also, continued use of PCB's in transformers and capacitors presents a minimal risk of environmental contamination. The Monsanto Company, the sole domestic producer, has reported voluntarily eliminating its distribution of PCB's to all except manufacturers of electrical transformers and capacitors." -- PCB's and the Environment, by the Interdepartmental Task on PCB's, sponsored by the Departments of Agriculture; Commerce; Health, Education, and He1fare; and Interior. Also sponsored by the Environmental Protection Agency, plus other participating agencies. Published May, 1972, distributed by NTIS, Springfield, Virginia 22151, under access number COM-72-10419. 2. APPLICATIONS IN THE FOOD INDUSTRY The FDA has issued a proposed rule making concerning the application of PCB's in human foods, animal feeds, and food-packaging material (Federal Register, 37-54-5705, March 18, 1972). From our reading of the proposed rule, it does not appear to be the intent to outlaw either capacitors or transformers when applied in accordance with the manufacturer's ratings and installed separately from that equipment which is in direct contact with the food, feed, or food-packaging material being processed. We have written to the Hearing Clerk of the Department of Health, Education, and Welfare with the suggestion that the exemption of capacitors and transformers so applied be made explicit in the final version of the proposed rules. 3. ANTICIPATED LEGISLATION It will be noted that progress in controlling possible adverse environments effects from PCB's has come about largely as the result of private industry initiative in limiting applications to situations which are controllable, i.e., the use of PCB's in sealed transformers and capacitors. As noted in the Task Force report cited above, 782030 NET. 000186 2 "The government has no power to restrict imports of PCB's by foreign manufacturers and if it disagreed with Monsanto's judgment on allowable uses it could not impose more stringent limitations on Monsanto or on any other potential manufacturer. "This regulatory gap would be filled by the Administration's proposed Toxic Substances Control Act.,,*" We see no reason to anticipate that the passage of the Toxic Substances Control Act will affect the continued availability of GE Pyranol transformers and capacitors. While more restrictive legislation was at one time proposed (by Congressman Ryan of New York), it was prepared before the findings of the Task.Force were available, and has never come out of committee. 4. APPARATUS FOR EXPORT Those intending to export PCB-containing apparatus to certain foreign countries are advised to check for possible import restrictions. Japan and Sweden, for example, are known to have enacted restrictive legislation and/or license requirements. 5. DISPOSAL The Electrical industry, having recognized that continuation of the public benefits resulting from the use of PCB's rests in part upon industry cooperation and success in keeping this material out of the country's water system, has formed Committee C107 of the American National Standards Institute to erect guidelines for the proper handling of PCB's in manufacture and upon ultimate disposal. General Electric intends to promote full compliance with these guidelines, thus helping to implement an additional recommendation contained in the Interdepartmental Task Force Report, namely, "an educational campaign aimed at users to assure proper disposal". The ANSI guidelines are expected to provide for high-temperature incinerat of surplus FCB liquids (e.g., fluid discarded from a transformer) and disposal in properly-managed land-fill operations of solid material which has been saturated with PCB's (e.g., discarded capacitors). Three pertinent statements from the Task Force report may be noted in connection with these proposed procedures: (1) "Incineration at 2000 F or above for two seconds will destroy PCB's...." (2) "PCB containing material buried in soil is not expected to migrate but should remain in place." (3) "PCB's are being designated as hazardous substances under section 12 (of the Federal Water Pollution Control Act), and the authority contained in the section could be used if an accidental spill of PCB's into water should occur." (The referenced authority concerns notification and clean-up responsibilities, etc.) Pending promulgation of the ANSI guidelines, those with a disposal problem are requested to contact the appropriate General Electric field sales office. NFT. nnniR7 782031 TECHNICAL RESOURCES GENERAL ELECTRIC 1 RIVER ROAO. SCHENECTADY. N. Y. 12345 SUBJECT PCB Caution Notices DjAL C O M 17! 8-235-2261 COPIES: EL Dobbins - PITTSFIELD JF McAllister - NEW YORK A. Pozefsky - HUDSON FALLS March 28, 1972 Mr. E. L. Raab Manager-Insulation Systems Section Materials and Technology Laboratory Building 11-223 100 Woodlawn Avenue Pittsfield, Mass. 01201 Dear Ed: Confirming our telephone conversation, we would like to propose a change in the wording of the ANSI C107 PCB Caution Notice for transformers from that currently before the task `'force. While agreeing with Lhe inform ation conveyed by the proposed notice, and the general intent of the phraseology, we feel that the use in the second sentence of the phrase "extreme care" might serve to attribute too much importance to an isolated instance of accidental spillage. "Extreme care", being undefined, could lead to environmentally unsound attitudes toward the application of PCB transformers. We suggest deletion of "extreme.... any", with the resulting notice to read: The insulating fluid in this transformer contains polychlorinated biphenyls, which some studies have shown may be an environmental contaminant. Care should be taken to prevent entry into the environment. In case of malfunction or leaks, consult the instruction manual or the manufacturer. We recommend that the same change be made with respect to the labels now being considered as a result of your March 20, 1972 letter to G.E. transformer marketing managers. Very truly yours, ft NEL 000188 James S. Nelson, ConsultantProduct Environmental Compatibility JSN:ev 782032 TECHNICAL RESOURCES 1 RIVER ROAD. SCHENECTADY. N. Y. 12345 SUBJECT Swedish PCB Ordinance DIAL C O MM 8*235-2261 COPIES: JF McAllister RB Smith June 5, 1972 Mr. E. L. Raab " ' Manager-Dielectric Systems Laboratory Insulation Systems Lab. Operation 100 Woodlawn Avenue Pittsfield, Mass. 01201 Dr. A. Pozefsky Manager-Engineering Industrial & Power Capacitor Prods. Dept. John Street Hudson Falls, N. Y. 12839 Dear Ed and Al;` The enclosed material has been obtained by Dick Smith for us from the Swedish Embassy. Please communicate it to the proper interests within your respective businesses. Dick is trying to get similar definitive information from the Japanese. As I read the law, transformers do not require permits, and neither do capacitors above 2 kvar; however, all require labeling as to PCB content. In addition, smaller capacitors require permits. There seems to be some ambiguity as to v;hether..equipment containing small capacitors requires a permit, as the rference is to "separate condenser" (Paragraph A, Subparagraph 4). Very truly yours JSN:ev Att. James S. Nelson, ConsultantProduct Environmental Compatibility NEL 000189 782033 'i.L't15T.d CP AGiU-CUjj'i'Ui,' N a t i o n a l Sv: g d i s h a v j . r o n nic i i t Protection Board POLYCILOiili1ATBB BIPiiYLO Kotico on the PCB of June 1971 and its Implementing Ordinree coming into .force on 1st June, 1972_____ Backgroun A The polychlorinated biphenyls (PCBs) are known as ver persistent chlorinated hydrocarbons. As such they hav the quality of being spread in water and air and of being transported under biological enrichment in natu z'al food chains. Swedish investigations, have demonstrated high concor. trations of PCS in certain fish species in the souths part of the Baltic.. Also fresh-water fish, sea birds and birds of prey have shown high contents of PCB. Ti biological effects are not very well known as yet. Howevers the chemical similarity of FCB to BBT makes it possible that PCBs have an unfavourable effect on the reproduction of birds and fishes, further, it ha. been observed that PCB and BBT appear together in hi; eonccntralicn/; ?i\ the sumo specimens, whereby the effect of one seems to increase the effect of the . oilier. NEL 000190 782034 The main danger of unintended distribution of RGBs ijj the environment arises from the destruction of p.voducts containing VOB, such as paint, sealing compound: hydraulic oil, etc. *. With--regard to the environmental hazards connected with the use of PCBs, the Environment Protection lioarc suggested, in February 1971, that measures should be iytaken to prohibit in principle import, manufacture and sale of PCBs and products containing such compounds. After having reviewed the proposal made by the Board, -- the Ministry of Agriculture put forward a bill on the 'subject to the Swedish Riksdag (Parliament). In the bill it was,stated the need for preventing and con^ trolling the distribution of the-most noxious forms o jPCB, with special reference to environmental pro tection interests, Subsequently, after approval by the Riksdag, the PCB Act came into force (SPS 1971:339) on June 23d, 1971. In this Act the King in Council is empowered to prohibit or control the import, manufac ture, marketing, or handling of polychlorinated biphe nyls (PCB) and any merchandise dangerous to environ ment due to its contents of PC3. Under the provisions of the PCB Act -the King in Council has issued an inplementary ordinance (SPS 1972:34) specifying in what way the Act is to be applied. The ordinance will cone into force on June 1st, 1972. 782035 NEL 000191 Uttofricin 1 trargQ a "ion PCB Act. lft.6.3.971 (SKS 1971:355) 1 It it is of special importance from an environment aspect the King in C o u n c i l - hereafter referred to as the King - or the authority commissioned, thereto by the King, may prohibit or dictate terms on the import, manufacture, marketing, or handling of polychlorinated biphenyl3 (PCB) and any merchandise dangerous to environment due to its content of BCE. 2 The King, or the authority that the King commis sions, may prescribe that anyone who imports, manu factures, or trades in PCB or in any merchandise contar--ing PCB shall report his activity. 3 The authority commissioned by the King shall supervise the observance of this lav; and the directives issued on the basis of it. The supervising authority has the right to obtain, on demand, the information and documents necessary to the supervision. The supervising authority shall be granted admission to the premises or the area where PCB or any merchandise containing PCB is manufactured or handled and it may carry out investigations and take samples. No compensa tion shall be paid for the samples drawn. -4 Anyone* who wilfully or through negligence offends against any prohibition or directive issued on the basis of 1 shall be fined or sentenced to imprison ment for a maximum of six months. Concerning the penalty in certain cases for anyone v/ho unlawfully imports PCB or any merchandise referred to 1 ^ t O v.. U: C C Y U i y v i ' *VC . ciiiptu to do so there arc pro- vision:: in the act (iy60: 4J.b) on the penalties on smuggling. 7Qono/> NEL 000192 5 A line will be imposed on anyone who wilfully or through negligence 1. fails to report the matter according to directives issued on the basis of 2 or neglects his duty by 3 , the second paragraph, 2. gives misleading information in cases intended in 2 or 3 j the second prrcgrojh if penalty is not imposed on the deed in the Criminal Code. 6 Nobody who has concerned himself with supervis ing activities by this act may disclose any information given to him regarding business secrets or business conditions. Anyone who wilfully or through negligence offends against this prohibition shall be fined or sentenced to imprisonment for a maximum of one year. A public prosecution may only be started if the plaintiff reports the crime for legal action or if legal action is called for* from a public point of view. 7 If anyone has failed to report the matter according to directives issued on the basis of 2 J or if he has neglected his duty according to 3 , the second para graph, or has refused to grant admission according to 3 , the third paragraph, the supervising authority may impose a fine on him.1 6 Merchandise that has been the subject of crime by this lav; or the equivalent value and the returns of such a crime shall be declared forfeited if it is not obviously unreasonable to do so. 782037 Unoffic nsl.'t Implementing; Ordinance on PCB, l#c2.197?- (SFS 172:34) On the basis of 1 - 3 of the PCB Act (197b:33?) the Swedish Government has thought fit to decree the fol lowing. 1 In this ordinance, PCB merchandise it understood to be merchandise, the environmentally deleterious qualities of which arc conditioned by the fact that Per forms part of the merchandise. 2 PCB must not be imported, manufactured, marketed, used, or handled in any other way without a permit. 3 A transformer, or a condenser with higher effect than two kilovoltampere (rcactively) or being part of an oil burner may be marketed, transferred, or used without a permit if it contains PCB. 4 PCB merchandise of the following kinds may not be marketed, transferred, or used professionally without a permit; 1. paint, jointing or sealing compounds, 2. hydraulic oil 3. heat transfer medium 4* separate condenser 'with an effect of two kilovolt ampere or less $ The question of permit according to 2-4 are decided upon by the National Environment Protection Board. 6 The National Environment Protection Board may decree that 4 5 ohr II be correspondingly applicable to ruy Ouhc*v 'ind of PCii mere;:'"dine than is referred to in 3 or 4 , if the merchandise has a high PCB content o r i s V.'i d i':3 v NEL 000194 7 Packaging material fui* PCB or PCI3 merchandise referred to in 3 j 4' or 6 5 shall be clearly marked with information as to its content of PCB. This also applies to sucl) PCB merchandise itself, if it is not padeed in any way. The national Environment Protection Board may grant exceptions to the marking duty according to the first paragraph of this section. g PCB, PCB merchandise, and any packaging material for PCB or PCB merchandise shall be handled in such a way that dissemination of PCB in the nature is prevented as far as possible. The National Environment Protection Board will issue directives as to the seizure, destruction, or conversion of PCB or PCB merchandise and any packaging material for PCB or such merchandise. 9 The National Environment Protection Board may prescribe that anyone who imports, manufactures, markets transfers or uses professionally PCB or PCB merchandise shall report this to the Board. 10 The central supervision of the observance of the PCB Act (1971:365) and this ordinance is exercised by the National Environment Protection Board. In questions concerning electrical power equipment the Board shall consult the National Electrical Inspectorate. When necessary, the Board shall consult the National Poisons and Pesticides Board. The County Administration exercises continuous super vision v/ithin the county; as regards the importation of PCB in co-operation v;ith local customs authorities. !}' NEL 000195 782039 1 1 s Detailed directives as to the application of this ordinance will be issued by the National Environment Proto ction Board. 12 Appeal against the decision node by the National Environment Protection Board according to this ordinance shall be submitted to the King in Council. 1 This ordinance shall come into force on June 1, 1972. 2. Anyone who, at the date of tis coming into force, prosecutes activities for which a permit is called for by this ordinance may, unless the National Environment Protection Board decides otherwise, continue his activities notwithstanding the regulations given in this ordinance till the end of June 1972 or, if the has before then applied for a permit according to the ordinance, until his application has been given .final consideration. 3* The National Environment Protection Board may prescribe the deviations form this ordinance considered necessary in view of the transitional difficulties of industry and commerce. 782040 NEL 000196 TECHNICAL RESOURCES G E N E R A L O ELECTRIC 1 RIVER ROAD. SCHENECTADY. N. Y. 12345 SUBJECT ----- - 1 D I AL COMM 8*235-2261 ^ MONTHLY ACTIVITIES REPORT James S. Nelson__________ June 29, 1972 COPIES: FS Rothe Mr. J. F. McAllister NEW YORK IV-FRODUCT ENVIRONMENTAL COMPATIBILITY 1. PCB Both Transformers and Capacitors are planning to institute the use of caution notices about the disposal of PCB. The wording of these notices has been the subject of consultation with the appropriate parties, and a meeting is scheduled for July 6 to review the completed drafts of ANSI statements on PCB. In addition, a draft of an informational "update" or position statement on PCB use has been circulated for comments within the Company. A copy of the Swedish regulations on PCB has been obtained and disseminated. Similar efforts on the Japanese regulations have not yet produced a satisfactory result. The Japanese embassy provided us with a tract in Japanese, purporting to be a copy of their government's regulations. Upon translation, it turned out to be merely a discussion of the subject from a periodical. REDACTED NEL 000197 782041 G E N E R A L O ELECTRIC Mr. J. F. McAllister June 29, 1972 Very truly yours, t * *c3aj ?P; N E L 000198 782042 TECHNICAL RESOURCES G E N E R A L ELECTRIC 1 RIVER ROAD. SCHENECTADY. N. Y. 12345 SUBJECT ' - * -- T** D I AL COMM 8*235-2261 COPIES: \ June 30, 1972, // Mr. J.-F.:McAllister NEW YORK Dear Jack: Per our telephone conversation, here is another copy of my proposed PCB status statement, together with comments received to date. In addition to the letters from Hoseltom. and Fozefsky, ; I have received concurrence from Ed Simons, who suggested changing- "relevant^govemment agencies" to "cognizant". .... t 1ii Very truly yours, JSNrev Enclosures James S. Nelson b y / V" :. ' / . NEL 000199 782043 TECHNICAL RESOURCES wGENERAL ELECTRIC 1 RIVER ROAD. SCHENECTADY. N. Y. 12345 SUBJECT b iaI c o r.i M 8*235-2261 Your Information Letter - MT-168 A COPIES: E. L. Dobbins - PITTSFIELD J. F. McAllister - NEW YORK E. L. Raab - PITTSFIELD J, F. Repko - SYRACUSE A. Pozefsky - HUDSON FALLS J. A. Sainz - HUDSON FALLS E. L. Simons - Bldg, 36-SCHDY. June 2, 1972 Mr, R. W. Frahm Manager-Marketing Medium Transformer Department Rome, Georgia Dear Mr. Frahm: We have had occasion to review your GE - Confidential Information Letter, MT-168, entitled "Pyranol Update". We feel that this is an excellent job, and should put your field sales people in a good position to handle most customer inquiries. We think the "Update" should be updated, however, by quoting directly from the Interdepartmental Task Force, rather than from a news release about the same, and by adding a paragraph on the FDA proposed regulations. In addition, the.proposed "Caution" notice, while an improvement on earlier versions, should probably have the word "any" deleted for the same reasons that "extreme" was taken out (per my letter to Ed Raab of March 28, copy attached). Several people have expressed the need for a shorter statement of the current PCB situation, which could be used as a customer hand-out or incorporated into letters on the subject, both for transformer and capacitor customers. We are attaching a draft of such a statement, and request a specific comment from each recipient showing either concurrence or suggestions for change. Very truly yours, JSN:ev Enclosures Tames S. Nelson, ConsultantProduct Environmental Compatibility . NEL 000200 782044 a d v i c e t o g e n e r a l e l e c t r i c c u s t o m e r s c o n c e r n i n g p c b (p y r a n o l ) 1, GOVERNMENT REPORT SANCTIONS CONTINUED USE OF PC3 IN TRANSFORMERS AND CAPACITORS General Electric customers may continue to purchase and apply General Electric Pyranol (R) transformers and capacitors, secure in the knowledge that all Zo^rtltariX -folovoat US government agencies are parties to a report sanctioning the- continued use of polychlorinated biphenyls -(PCB) in such apparatus* The following paragraph is quoted from one of the findings in which the government's Task Force concurred: "6. The use of FCB's should not be banned entirely. Their continued use for transformers and capacitors in the near future is considered necessary because of the significantly increased risk of fire and explosion and the disruption of electrical service which would result from a ban on PCB _ use. Also, continued use of FCB's in transformers and capacitors presents a minimal risk of environmental contamination. The Monsanto Company, the sole domestic producer, has reported voluntarily eliminating its distribution of FCB's to all except manufacturers of electrical transformers and capacitors." -- FCB's and the Environment, by the-Interdepartmental Task ForC on 1'CB`s, sponsored by the Departments of Agriculture; Commerce; Health, Education, and Welfare; and Interior. Also sponsored by the Environmental Protection Agency, plus! * other participating agencies. Published May, 1972, distributed by NTIS, Springfield, Virginia 22151, under access number COM-72-10419. f 2. APPLICATIONS IN THE FOOD INDUSTRY The FDA has issued a proposed rule making concerning the application of PCB's in human foods, animal feeds, and food-packaging material (Federal Register 37-54-5705, March 18, 1972). From our reading of the proposed rule, it does not appear to be the intent to outlaw either capacitors or transformers when applied in accordance with the manufacturer's ratings and installed separately from that equipment which is in direct contact with the food, feed, or food-packaging material being processed. We have written to the Hearing Clerk of the Department of Health, Education, and Welfare with the suggestion that the exemption of capacitors and transformers so applied be made explicit in the final version of the proposed rules. * 3. ANTICIPATED LEGISLATION It will be noted that, progress in controlling possible adverse envirorrnen effects from PCB's has come about largely as the result of private industry initiati in limiting applications to situations which are controllable, i.e., the use of PCB1 in sealed transformers and capacitors. As noted in the Task Force report cited abov 782045 NEL 000201 2 "The government has no power to restrict imports of PCB's by foreign manufacturers and if it disagreed with Monsanto's judgment on allowable uses it could not impose more stringent limitations on Monsanto or on any other potential manufacturer. "This regulatory gap would be filled by the Administration*s proposed Toxic Substances Control Act.*.." We see no reason to anticipate that the passage of the Toxic Substances Control Act will affect the continued availability of GE Pyranol transformers and capacitors. While more restrictive legislation was at one time proposed (by Congressman Ryan of New York), it was prepared before the findings of the Task.Force were available, and has never come out of comnittee. 4, APPARATUS FOR EXPORT Those intending to.export PCB-containing apparatus to certain foreign countries are advised to check for possible import restrictions. Japan and Sweden, for example, are known to have enacted restrictive legislation and/or license requirements. 5. DISPOSAL The Electrical industry, having recognized that continuation of the public benefits resulting from the use of PCB's rests in part upon industry cooperation and success in keeping this material out of the country's water system, has formed Coranittee C107 of the American National Standards Institute to erect guidelines for the proper handling of PCB's in manufacture and upon ultimate disposal General Electric intends to promote full compliance with these guidelines, thus helping to implement an additional recommendation contained in the Interdepartmental Task Force Report, namely, "an educational campaign aimed at users to assure proper disposal". The ANSI guidelines are expected to provide for high-temperature incinera of surplus PCS liquids (e.g., fluid discarded from a transformer) and disposal in properly-managed land-fill operations of solid material which has been saturated with PCB's (e.g., discarded capacitors)'. Three pertinent statements from the Task Force report may be noted in connection with these proposed procedures: (1) "Incineration at 2000 F or above for two seconds will destroy PCB's...." (2) "PCB containing material buried in soil is not expected to migrate but should remain in place." (3) "PCB's are being designated as hazardous substances under section 12 (of the Federal Viater Pollution Control Act), and the authority contained in the section could be used if an accidental spill of PCB's into water should occur." (The referenced authority concerns notification and clean-up responsibilities, etc.) Pending promulgation of the ANSI guidelines, those with a disposal problem are requested to contact the appropriate General Electric field sales office. 782046 NEL 000202 TECHNICAL RESOURCES GENERAL ^ ELECTRIC 1 RIVER ROAD. SCHENECTADY. N. Y. 12345 SUBJECT b i A-L ; C O MM 1" 8*235-2261 L ---------------------- PCB Caution Notices March 28, 1972 COPIES; EL Dobbins - PITTSFIELD JF McAllister - NEW YORK A. Poaefsky - HUDSON FALLS Mr. E. L. Raab Manager-Insulation Systems Section Materials and Technology Laboratory Building 11-223 100 Woodlawn Avenue Pittsfield, Mass. 01201 *- . .Dear E d : Confirming our telephone conversation, we would like to propose a change in the wording of the ANSI C107 PCB Caution Notice for transformers from that currently before the task "force. While agreeing with the information conveyed by the proposed notice, and the general intent of the phraseology, we feel that the use in the second sentence of the phrase "extreme care" might serve to attribute too much importance to an isolated instance of accidental spillage. "Extreme care", being undefined, could lead to environmentally unsound attitudes toward the application of PCB - transformers. We suggest deletion of "extreme.... any", with the resulting notice to read: '/ The insulating fluid in this transformer contains polychlorinated biphenyls, which some studies have shown may be an environmental contaminant. Care should be taken to prevent entry into the environment. In case of malfunction or leaks, consult the instruction manual or the manufacturer. We recommend that the same change be made with respect to the labels now being considered as a result of your March 20, 1972 letter to G.E. transformer marketing managers. Very truly yours, NEL 000203 James S. Nelson, ConsultantProduct Environmental Compatibility J S N :c v 782047 A*>A GENERAL ELECTRIC DIAL COMM* DATE* June 20, 1972 DEPT* Industrial & Power Capacitor Products ADDRESS* Hudson Falls, New York SUBJECT* c o p i e s . 1 2 Hart, Jr. J Sainz EL Raab-Pittsfield JF Repko-Syracuse J. S. Nelson SCHENECTADY In general, we are in agreement with your proposed information letter on PCB's dated June 2, 1972. Under Paragraph 1, PCBTs and the Environment, the word "Force11 has been omitted at the end of the first line. Paragraph 2* Applications in the Food Industry, should be updated in accordance with the Draft Environmental Impact Statement issued by the FDA on May 8, wherein'capacitors and' transformers are specifically exempted (Page 10, paragraph 3). I am not in agreement with D. M. Hoselton on the usefulness of the three statements you quote from the Task Force report. We do want to indicate the proper way for customers to dispose of obsolete capacitors. Incidentally, his June 12 letter indicates that Medium Transformer will continue to issue updates. Do they plan on continuing on their own? This would mean that many customers would be receiving two very similar updates from two different sources in the Company. Enclosed i s `a copy of the caution label we propose-affixing to capacitors containing more than 2 lbs. of Pyranol. I would appreciate your comments. A. Pozefsky Pg enc. -jsjBL 000204 782048 June 15, 1977 Industrial & Power Capacitor Products Kudnon Palin, Dev York }*C3 Caution Labeling I.F Hart, Jr. I>F eroso BJ llopklus i:b co * J7 FepJto-Syrncuac J. Sains Building-1-4 The A?B I Committee In definitely going to recommend the labeling of capacitors containing core than 2 lbs. of VCB. A3 you know, Kcstlnghouse has been labeling their power cnoociforo. The Vovet capacitor manufacturers on tho AKSI Ccsriiiictee -did not agree on the use of a standard label to be used unifotuly by the industry, nr.d distributed through ANSI. The reason being that the logel people in none conpanica eight inaiot on core Inforcation than on the A?ISI label. Attached la a copy of 'a proposed label. I feci we should nova ahead and Implement the use of cur c m Iohe I tier. You will notice that thin label epccificelly calls for disposal in dry landfill or in approved Incineration focili,tics. Thera arc iso such incineration faci litica available at tula titsa to handle scrap capacitors, but T suggest we keep thin phraseology in anticipation that Genetica In the future these facilities will bo available. Alco, noto that we recommend that further liiforaation be obtained from GK end do not Indicate A17SX cc an alternative ocurco of information. The reason for thio la that A!:T has yet to approva the Guideline and thin tnay tabe coca tine. Alco.l cea no added inconvenience to the Department In handling direct Inquiries and simply sending out the official Ah'S! Guideline when it does become available. Vg plan on a ninelc Guideline which has both a capacitor and transformer section. In the ^cantine the capacitor and trcnaforrier manufacturers on the ANSI Cornaittee have agreed to use the proposed '"uiceline on an Intarla bonis. I an forwarding a copy of this to !hr. Seo'r.o for his review. As noon ns his comments are received, could you please take the neccaoary oteps with TU Hopkins and F.B Cox to leplracnt a uniforn label for use in Fewer and Small Industrial. A. Foiefoky Pii ctt. NEL 000205 782049 General Electric Company ..PYRANOL CAPACITOR CAUTION This capacitor contains Polychlorinated Biphenyls (PCB's). To avoid possible environmental contamination, it should be disposed of only in.dry landfill areas meeting State' requirements,, or inC^pproved 'incineration facilities Further information, and Guidelines on handling and disposal can be obtained from General Electric Company, Hudson Falls, New York 12039. a 782050 NEL 000206 A - I U RCV ( I4 4 | GENERAL ELECTRIC MEDIUM TRANSFORMER DEPARTMENT LOCATION-- DATE Rome. Georgia June 12, 1972 SUBJECT PYRANOL INFORMATION // j s. NELSON JUN1-5 m COPIES: DIAL COMM 8 * 2 8 2 - 5 271 1 E. L. Dobbins J. F. McAllister E. L. Raab J. F. Repko A. Pozefsky J. A. Sainz E. L. Simons J. 0. Sweeny R. W. Frahm PITTSFIELD NEW YORK (570) PITTSFIELD SYRACUSE HUDSON FALLS HUDSON FALLS BLDG. 36 - SCHENECTADY PITTSFIELD OFFICE Mr. James S. Nelson, Consultant Product Environmental Compatibility Technical Resources SCHENECTADY We have reviewed the PCB statement attached to your June 2, 1972 letter and, in general, concur with its content. In Paragraph 5, "DISPOSAL", you quote three statements from the Task Force report. I question the usefulness of these statements since the first two may encourage users to dispose of PCB themselves. We have had customers in the food industry ask us questions about the proposed FDA rules governing PCB material. We agree with your interpretation of the March 18, 1972 Federal Register; however, it would be. better if there was an official ruling on the use of askarel transformers and capacitors. As soon as you obtain a response to your inquiry to the Department of Health, Education and Welfare, please let me know so we can issue another "Pyranol D. M. Hoselton, Manager INDUSTRIAL & CONTRACTOR SALES PRODUCT PLANNING Building 1-146 -abh NEL 000207 782051 TECHNICAL RESOURCES GENERAL ELECTRIC 1 RIVER ROAO. SCHENECTADY, N. Y. 12305 SUBJECT -- -'T------- - - D I AL COMM 8*235-2261 GENERAL PURPOSE PCB UPDATE STATEMENT COPIES: JF McAllister - NEW YORK A. Pozefsky - HUDSON FALLS July 7, 1972 Mr, E. L. Raab Manager-Dielectric Systems Lab. Insulation Systems Laboratory Operation 100 Woodlawn Avenue Pittsfield, Mass. 01201 Dear Ed: Attached, for review with your Rome confederates, is a revision of my June 2 PCD statement for use with customers. It is like the version you have already seen, except for a word change suggested by Ed Simons in the first paragraph (substituting "cognizant" for "relevant") and the addition of a quotation from the FDA Draft Environmental Statement, at the end of the second numbered section. You will note that the three statements quoted from the Interdepartmental Task Force (in my section 5) are retained, primarily to add credibility to the ANSI recommendations regarding disposal. It seems to me that the only steps required for release of this state ment for general use are: (1) agreement by you and Al representing transformer and capacitor interests, respectively, and (2) legal approval, which I would appreciate your seeking from Mike Dobbins. Very truly yours JSN:ev Enclosure J. S. Nelson, ConsultantProduct Environmental Compatibility 782052 ]SIEL 000208 TECHNICAL RESOURCES NERAL ^ ELECTRIC 1 RIVER ROAD. SCHENECTADY. H.Y. 12305 C11DIff*7 V V CVO; M aM.v 8*235-2261 STATUS REPORT TO CUSTOMERS ON FCB July 24, 1972 COPIES: J. F. Young J. F. McAllister J. S. Anderson C. H. Bascue J. V. Blake D. F. Cross L. L. Dengler E. L. Dobbins J. A. Donna1ley R. V. Frahro D. A. Franke U. B. Gaither C. M. Lowe W. F . Hamby W. T. Kinsey H. D. Laube 0. H. LeBlanc W. F. Marx W. F. Powell A. Pozefsky E. L* J. F. Repko W. M. Rodgers E. R. Ruterman E. L. Simons H. B. Williams Messrs. K. H. Christiansen - Agency & Distributor Sales Div. V. L. Clarke - Apparatus Sales & Service Dept. - Canadian GE S. V. Corbin - Industrial Sales Div. J. J. Farrell - Power Transformer Products Dept. G. H. Hupman - International Bus. Support Operations L. P. Hart, Jr. - Industrial & Power Capacitor Products Dept. ! R. T. Morris - Medium Transformer Products Dept. I. J. Petersen - Distribution Transformer Products Dept. D. F. Rankine - Power Transmission & Distribution Dept. - Canadian GE W. R. Tackaberry - Power Transmission & Distribution Sales Div. c. c. Thomas - Installation & Service Engrg. Business Dept. P. c. Van Dyck - Apparatus Services Business Div. !J General Electric customers were informed in 1970 of the environmental concern which had arisen over polychlorinated biphenyl materials (PCB's) through the wide spread distribution of the "Open Letter to Industrial Customers" and "Open Letter to Electric Utility Customers" and by other means. Since that time a great deal has been accomplished to bring this situation under control. In particular, the responses of cognizant agencies of the federal government have assumed a greater degree of predictability. Now that the Interdepartmental Task Force report has been published, we can give customers additional assurance that there will be a continued source of supply of Pyranol capacitors and transformers and that their application is consonant with the public interest. The accompanying statement has been prepared as a basis for such customer conmunication, and has been approved by legal counsel of the Transformer and Distribution Equipment Division and the Electronic Components Division. -''James S. Nelson, Consultant ^ ^ r o d u c t Environmental Compatibility JSN:ev Attachment NEL 000209 782053 ADVICE TO GENERAL ELECTRIC CUSTOMERS CONCERNING PCB (PYRANOL) (R) 1. FEDERAL GOVERNMENT REPORT SANCTIONS CONTINUED USE OF PCB IN TRANSFORMERS AND CAPACITORS General Electric customers may continue to purchase and apply General Electric Pyranol transformers and capacitors, secure in the knowledge that all cognizant US government agencies are parties to a report sanctioning the continued use of polychlorinated biphenyls (PCB) in such apparatus. The following paragraph is quoted from one of the findings in which the government's Task Force concurred: "6. The use of PCB's should not be banned entirely. Their continued use for transformers and capacitors in the near future is considered necessary because of the significantly increased risk of fire and explosion and the disruption of electrical service which would result from a ban on PCB use. Also, continued use of PCB's in transformers and capacitors pesents a minimal risk of environmental contamination. The Monsanto Company, the sole domestic producer, has reported voluntarily eliminating its distribution of PCB's to all except manufacturers of electrical transformers and capacitors." -- PCB's and the Environment, by the Interdepartmental Task Force on PCB's sponsored by the Departments of Agriculture; Conmerce; Health, Education, and Welfare; and Interior. Also sponsored by the Environmental Protection Agency, plus other partici pating agencies. Published May, 1972, distributed by NTIS, Springfield, Virginia 22151, under access number COM-72-10419. The report may be ordered for $6.00. 2. APPLICATIONS IN THE FOOD INDUSTRY The FDA has issued a proposed rule making concerning the application of PCB's in human foods, animal feeds, and food-packaging material (Federal Register, 37-54-5705, March 18, 1972). From our reading of the proposed rule, it does not appear to be the intent to outlaw either capacitors or transformers when applied in accordance with the manufacturer's ratings and installed separately from that equip ment which is in direct contact with the food, feed, or food-packaging material being processed. Ue have written to the Hearing Clerk of the Department of Health, Education, and Welfare with the suggestion that the exemption of capacitors and transformers so applied be made explicit in the final version of the proposed rules. We anticipate concurrence by the Department of HEW, in view of the following paragraph contained in their Draft Environmental Impact Statement of May 8, 1972, regarding the Notice of Proposed Rule Making, Polychlorinated Biphenyls: "3. An exception to the proposed special provisions eliminating certain industrial uses of PCB's will permit the continued use of electrical power equipment containing PCB's in regulated establishments. Tills use of PCB's is considered essential and presents only a minimal risk of accidental contamination of food and the environment." 782054 NEL 000210 2 3. ANTICIPATED LEGISLATION It will be noced Chat progress In controlling possible adverse environ mental effects from PCB's has come about largely as the result of private industry initiatives in limiting applications to situations which are controllable, i.e., the use of PCB's in sealed transformers and capacitors. As noted in the Task Force report cited above : "The government has no power to restrict imports of PCB's by foreign manufacturers and if it-disagreed with Monsanto's judgment on allowable uses it could not impose more stringent limitations on Monsanto or on any other potential manufacturer. "This regulatory gap would be filled by the Administration's proposed Toxic Substances Control Act...." Ue see no reason to anticipate that the passage of the Toxic Substances Control Act will affect che continued availability of 6E Pyranol transformers and capacitors. While more restrictive legislation was at one time proposed (by Congressman Ryan of New York), it was prepared before the findings of the Task Force were available, and has never come out of conmittee. A. APPARATUS FOR EXPORT Those intending to export PCB-containing apparatus to certain foreign countries are advised to check for possible import restrictions. Japan and Sweden, for example, are known to have enacted restrictive legislation and/or license requirements. A 5. DISPOSAL The electrical industry, having recognized that continuation of the public benefits resulting from the use of PCB's rests in part upon industry cooperation and success in keeping this material out of the country's water system, has formed Conxoittee C107 of the American National Standards Institute to erect guidelines for the proper handling of PCB's in manufacture and upon ultimate disposal. General Electric Intends to promote full compliance with these guide lines, thus helping to implement an additional recomnendatlon contained in the Interdepartmental Task Force Report, namely, "an educational campaign aimed at users to assure proper disposal." The ANSI guidelines are expected to provide for high-temperature incineration of surplus PCB liquids (e.g., fluid discarded from a transformer) and disposal in properly-managed land-fill operations of solid material which has been in caitact with PCB's (e.g., discarded capacitors). Three pertinent statements from the Task Force report may be noted in connection with these proposed procedures: (1) "Incineration at 2000 F or above for two seconds will destroy PCB's___ " (2) "PCB containing material burled in soil is not expected to migrate but should remain in place." 782055 NEL 000211 3 (3) "FCB's are being designated as hazardous substances under Section 12 (of the Federal Water Pollution Control Act), and the authority contained in the section could be used if an accidental spill of FCB's into water should occur." (The referenced authority concerns notification and clean-up responsibilities, e t c.)v Pending promulgation of the ANSI guidelines, those with a disposai problem are requested to contact the appropriate General Electric field sales office. 782056 NEL 000212 TECHNICAL RESOURCES RIVER ROAD. SCHENECTADY, N. Y. 12305 SUBJECT D I AL COMM 8*235-2261 COPIES: JF McAllister - NEW YORK July 28, 1972 Mr. James R. Squires 7777 - 14th Street, N.W. Washington, D. C. 20005 Dear Jim: Jack McAllister has requested that we send you a copy of the 6E statement on FCB's, "The Role of Polychlorinated Biphenyls in Electrical Equipment." The first three pages of this report constitute an executive summary. In additionj for your possible interest and for your information, we are enclosing our letter of July 24 on the subject of a status report to customers on PCB's. We trust this will meet your needs. Very truly yours JSN:ev Enclosures (James S. Nelson, ConsultantProduct Environmental Compatibility NEL 000213 782057 TECHNICAL RESOURCES GENERAL ELECTRIC 1 RIVER ROAD. SCHENECTADY. N. Y. 12345 SUBJECT D I AL COMM 8*235-2261 MONTHLY ACTIVITIES REPORT James S. Nelson__________ COPIES: FS Rothe July 28, 1972 Mr. J. F. McAllister NEW YORK IV-PRODUCT ENVIRONMENTAL COMPATIBILITY 1. PCB Modification in the wording of the ANSI C107 Guidelines was suggested to cover the subject of PCB leaks as a consequence of damage in transpor tation and handling. ` Appropriate marketing and business components have been provided with i a legally-approved statement as a basis for bringing GE customers u p to : date on the status of PCB_constraints, and to assure them of a continuing ; supply of Pyranol transformers and capacitors. redacted 782058 NEL 000214 GENERAL ELECTRIC 2 REDACTED 782059 G E N E R A L $ELECTRI C GENERAL ELECTRIC COMPANY. 1 RIVER ROAD. SCHENECTADY. NEW *'ORK 12305 Phone fc'B) 374-2211 TECHNICAL RESOURCES November 21, 1972 Japan Information Service Consulate General of Japan 235 East 42nd Street New York, N. Y. 10017 Gentlemen: We have read with interest the note in a recent issue of Japan Report, entitled "PCE Research Yie.ds Successes in Japan." We would be pleased to learn whether there is available in English a report describing further the accompli; hment of Professor Eto in removing chlorine from polychlorinated biphenyls by means of highintensity mercury-lamp light. The work of the Isotope Center in Tokyo, accomplishing the same purpose with radioactive isotopes, is also of interest. Very truly yours JSN:ev bcc: JF McAllister A. Pozefsky EL Raab James S. Nelson, ConsultantProduct Environmental Compatibility NEL 000216 782060 TECHNICAL RESOURCES GENERAL ELECTRIC 1 RIVER ROAD, SCHENECTADY, N. Y. 12305 SUBJECT -j D lA L: C O MM 8*235-2261 ----------- OECD Considers the PCB Problem C O P IE S : EL Raab - PITTSFIELD JS Anderson - Bldg. 36 EL Simons - Bldg. 36 OH LeBlanc - R&D December 14, 1972 Dr. Abbott Pozefsky Manager-Engineering Industrial Power Capacitor Department HUDSON FALLS, N. Y. Dear Al: We are indebted to Mr. Papageorge of Monsanto for the following information about the OECD's deliberations on PCB. Nothing on this subject has yet appeared in print, so the accuracy may be affected by the word-of-mouth transmission mode. The OECD has an Environmental Committee. The U.S. representative to this committee has arabassadorial rank. There is a subcommittee known as The Sector Group on the Unintended Occurrences of Chemicals in the Environment, and it is this Sector Group which met recently in Paris to consider PCB's. The Swiss led a determined effort to secure the banning of PCB's from small capacitor applications. The French wished to protect certain heat transfer uses, while the Germans wished to continue hydraulic applications in the mining industry. Apparently, everyone except the Swiss achieved what they wanted. The Sector Group's recommendation to the parent committee will contain the following recommendations: PCB use in small capacitors may be continued, but with intensified efforts to develop substitute technology. Continued use in large capacitors and transformers will be allowed. Certain hydraulic use in mines will be permitted. Those heat transfer systems where fire resistance is very critical will be allowed, but not in food, drug, animal-feed or veterinary applications. Controls will be applied to the manufacturer, the importer, and the exporter of PCB's. Provision shall be made for safe disposal. Uniform labeling shall be developed. NEL 000217 782061 G EN ERAL ! ELECTRIC Dr. Abbott Pozefsky 2 December 14, 1972 Safety specifications for containers and handling practices will be required. Material used to replace PCB'-s are to be reported by the member country as to identity, amount and application. The above provisions are to be considered soon by the full Coranittee on the Environment, probably in January. In this committee, agreements must be endorsed unanimously. Mr. Papageorge is not familiar with the mechanism for implementation and enforcement of adopted rules. One implication of the recommendations noted above is continued importation of heat transfer and hydraulic fluids into this country. Davies, of CEQ, hinted to Papageorge that the government is looking to the proposed Toxic "" Substances Act to put a stop to this. The above information has been obtained on an unofficial basis. It seems that nothing is to be published until the main committee has acted. Very truly yours, fi- JSN:ev James S. Nelson, Consultant Product Environmental Compatibility n e l 00218 782062 L '_ E T r & Z & O k TECHNICAL RESOURCES GENERAL ELECTRIC 1 RIVER ROAD, SCHENECTADY, N. Y. 12305 SUBJECT W "ai v;- D I a l ; COMM 8*235-2261 MONTHLY ACTIVITIES REPORT James S. Nelson_______ ___ January 2, 197^3 Mr. J. P. McAllister NEW YORK C O P IE S : FS Rothe redacted 2. PCB An effort within OECD to ban PCB from small capacitors was defeated at a recent subcommittee meeting in Paris. ?/ NEL 000219 782064 r TECHNICAL RESOURCES 1 RIVER ROAD, SCHENECTADY, N. Y. 12305 SUBJECT 1 8*235-2261 FDA Ruling on PCB in the Food Industry CO PIES: EL Dobbins JF McAllister A Peltosalo EL Simons ' JF Young - - v /' JF Repko - w/att. January 4, 1973 C Dr. Abbott Pozefsky y S Manager-Engineering Industrial Power Capacitor Dept. Hudson Falls, N. Y. 12839 Mr. W. F. Powell Manager-Engineering Ballast Department 1* 1430 E. Fairchild Street Danville, Illinois 61832 Mr. E. L. Raab Manager-Chemical & Process Section Building 11 - 313 Materials & Technology Laboratory Pittsfield, Mass. 01201 q -7 Gentlemen: Enclosed is a copy of the Final Environmental Impact Statement, Rule Making on Polychlorinated Biphenyls, issued by the Food and Drug Administration on December 18, 1972. This document contains a description of the revised Rule Making, which is to be issued "no sooner than 30 days" after the Impact Statement. We are gratified to note that the new rule clearly will not apply to transformers and capacitors: "The use in these establishments of electrical transformers and capacitors that contain PCB's are not expected to cause the contamination of (animal feed)(food-packaging material) (food) in these establishments and are exempt from the above-mentioned provisions." Very truly yours, { N EL 000221 JSN:ev Enclosure dames S. Nelson, ConsultantProduct Environmental Compatibility 782066 TECHNICAL RESOURCES GENERAL (fp ELECTRIC ! RIVER ROAO. SCHENECTADY, N. Y. 12305 SUBJECT * D ;I A L ;- C O M M 8*235-2261 ~\ MONTHLY ACTIVITIES REPORT James 5. Nelson January 30, 1973 Mr. J. F. McAllister NEW YORK C O P IE S : FS Rothe i it fi 3. PCB The Food and Drug Administration has decided favorably upon our request to exempt capacitors and transformers from their ban on PCB equipment in food processing plants and plants making food packaging, or preparing animal feed. NEL 000222 James S. Nelson ev 782067 TECHNICAL RESOURCES GENERAL @ ELECTRIC 1 RIVER ROAD, SCHENECTADY. N. Y. 12305 SUBJECT 8*235-2261 ] y COPIES: A. Fozefsky - HUDSON FALLS E. L. Simons - RECO-SCHDY. J. F. McAllister - NEW YORK (All w/att) February 20, 1973 Mr. Walter F. Powell Manager-Engineering Ballast Business Department 1430 East Fairchild Street Danville, Illinois 61832 ._ Dear Walt: Your attention is called to the enclosed letter from Dr. Griffith E. Quinby to. Dr. R. Emmet Kelly of Monsanto, in which Dr. Quinby essays to discuss failure rates in ballasts as related to FCB contamination. f f- We received this copy from Dr. Simons of RECO, who has been involved in some correspondence with Dr. Quinby in the past. You will note that the letter invites Monsanto to participate in the selection of an editorial review board to consider a paper on this subject to be submitted to SCIENCE. I'm sure Monsanto is capable of selecting a reviewer who understands failure rates, is acquainted with the proper application of threshold limit values, and is familiar with the dimensions of the PCB situation; but they might welcome your help on ballast technology and standards. Dr. Quinby has published an extensive bibliography on the health and environment effects of PCB's under the aegis of the Oak Ridge National Laboratory and supported by the National Library of Medicine (Publication IIRC-1, ORNL-EIS-72-20). Very truly yours, X JSN:ev Attachment James S. Nelson, Consultant^Product Environmental Compatibility NEL 000223 782068 loiicoloqy occupa (tonai modici* llorqy clinical pharmacoloqy communicable dtiaatts 'eie*) eh design GRIFFITH E. QUINDY, M.D., M.P.H, PREVENTIVE MEDICINE Poil O lii >01 (1)3 WENATCHEE, WASHINGTON 9C01 5 February 1973 J. S Met Afta Cod t SOI TEL: NO/mandr J- HS IL Bamet K e lly , M.D. Jiedical D irector Ib n s a n to Chemical Company COO li. L indbor gli B oulevard S t. Louie, ia eco u ri 63166 FEBZO 1973 Ile: F requency r a t e b u rn -o u t PCD b a l l a s t Lear Dr. K elly: As you and th e r e c ip ie n ts o f co p ies of- t h i s correspondence p robably re a li.s e , my co-w orkcrs ( i n EPA) and I (on my ova) have been a t nor): e v a lu a tin g th e p o te n tia l h asard s o f ?C3s in c lu d in g b a lla s ts burning o u t i n flu o re s c e n t l ig h ts . Ue a r e `w r iti n g a f i r s t r e p o r t o f p la n n ed a i r sam pling b e n e a th a b a l l a s t b u rn in g out spontaneously* I n tr y in g to p r e s e n t th e h i s t o r y o f t h i s n a t t e r a c c u r a te ly , I am t r y i n g to tra c e th e o rig in o f statem en ts quoted by Drs. Yip and K ies to th e e f f e c t th a t only one in a hundred m illio n b a lla s ts burn o u t o r o th e r vase f a i l . L r. Yip a ttrib u te d th ese to ib n san to . I havo seen sim ila r statem ents quoted elscv/hcrc a l s o . Our ovm uso e ::p e rie n ce i n d i c a t e s a much h ig h e r b u rn -o u t r a t e end p re lim inary surveys support a burn-out ra te a t le a s t a m illio n tin e s g reater th a n th e c i t e d one afc l e a s t d u rin g th e e n t i r e l i r e o r -no b a l l a s t . I "would g r e a t l y a p p r e c ia te y o u r f u r n is h in g mo \ j i t h any c i t a b l e s ta te m e n ts y o u r company h a s is s u e d about t h e - r e l a t i v e freq u e n cy o f f a i l u r e in c lu d in g , i f possible, separate ra te s for overheating or burn-outs of capacitors in general and/or b a lla s ts fo r flu o rescen t lig h ts sp e c ific a lly . . 4t 1* Our s e r i e s o f t h r e e p a p ers on t h i s s u b je c t i s b e in g p la n n ed fo r^ S d lilC E . T his jo u r n a l r e q u e s ts th e names o f up to d : : c o n s u ltin g e d i t o r s `to be named by th e a u th o rs w illin g to review th e m anuscript fo r -the jo u rn a l b e fo re p u b li c a tio n . Cut o f f a i r n e s s to i b n s a n to , we would l i k e to have j i t h o r you o r anyone e ls e your company d e s ig n a te s to se rv e a s j^ o n s u lti n g c. L tor f o r t h i s m anuscript to assu re accuracy of f a c t and lo g ic of opinions o::presscd th e re in . fi- To d i s p e l l th e c r e d u lity o f th e 1 i n 100 m illi o n fre q u e n c y o f b u rn - o u ts i n o th e r p e o p le 1s e rp e i'ic n c e b e s id e s o u rs , th e y sh o u ld c o n s u lt such documents as follow s: The Role o f P o ly ch lo rin ated B iphenyls in E le c tr ic a l Equipment, p u b lis h e d by G en eral E l e c t r i c C o., Feb. 4* 1972, p ag es 2 and 5, "F a ilu r e s a r e l im it e d to a p p ro x im a te ly 0.021 j* o f th e u n i t s i n s e r v ic e p e r y e a r" . The u n i t s r e f e r r e d to h e re in c lu d e As k a r e l - f i l l ed tra n s fo rm e rs and c a p a c ito r s . p . 29 - G.E. i n d i c a t e s f o r b a l l a s t s an a n n u a l re p la c e m e n t ra te of about 10^. F a ilu r e s a r e q u o ted a s " c o n s id e re d n e g l i g i b l e " a ls o on p . 51 o f th e I n te r d ep artm en tal! Task Force Deport on PC3s, Ib y , 1972, e n title d P o ly c h lo rin a te d D iphenyls and th e Environm ent, g iv in g two re fe re n c e s 13 and 15j both o f v lic h arc p riv a te communications from th e T ennessee V a lley A u th o rity and th e D epartm ent o f Power Ci W ater 782069 It. Ejmot Belly, M.D. 5 February 1973 Page 2 in Los Angelos. Surely these latter two references pertain to much larger cr.picators than ballasts. Ue need the c:mct date in I960 and complete citation after which ballasts had to have thermal controls as required by the Manual of national Electric Cod 1971 of which wo have seen no copy or satisfactory reference. As a related but separate question, I would appreciate your responses on tho opinions of HalddLnen et al. (Arch Environ Health 26, 70, Feb 1973) that Monsanto failed to appreciate the comparative occupational to:deity of diphenyl being incorporated into fruit wraps. Also we would appreciate as soon as possible your afterthoughts on the I960 TLV of 1 ng/ii'3 for diphenyl. This last is most important since our findings of PC3 emissions for Al hours from a burn ing (starting after 5 minutes) ballast has been below the same level 1972 TLV for PC3 (Aroclor 1242). We suspect that during cone shorter time, say 0 to 15 or 30 minutes after start of burn-out, that air concentration would be much higher than the TLV. f ' *** Repeating my interests of miniiaizing any adverse effects of recent developments in to:acology on Monsanto, it would be appreciated if you could provide any helpful data and responses as requested above. Very truly yours, GBQsldh CO: Dr. W, B. Papageorge, Mgr Environmental Protection Monsanto Chemical Co. COO II. Lindbergh Blvd* St. Louis, Ho. 63166 Dr. George Yip DtLv. of Chemistry Teclmology Food & Drug Administration .200 C St; 5.11. Washington, D.C. 2020A Dr. E. L. Simons, Mgr Dr. C. B.Schriver Engineer - Water Resources General Electric Co. One River Road Schenectady, H.Y. 123A5 Mrs. Aurora K. Reich 1H, Div. Biol. Standards Bldg. 29A, Iti. 1 A-21 Bcthesda, 1-Id. 2001/* Dr. Arthur H. Ides, Director Data Support Systems Div. Environmental Protection Agency Washington, D.C. 20/>60 Dr. Paul Larsen, Director Tree Fruit Research Center Wenatchee, Wash. 9CC01 Mr. Homer Wolfe, CM of EPA Pesticide Laboratory Wenatchee, Wash. 9CC01 Dr. Melvin Couey, Plant Physiologist Dr. Harold Schoner ...ySDAj: Bo:: 99, Wenatchee, Wash. 9CC01 USDA, Wenatchee, Wash. 9C-C01 782070 NEL 000225 f I TECHNICAL RESOURCES G E N E R A L ^ ELECTRIC 1 RIVER ROAD, SCHENECTADY, N. Y. I230S SUBJECT ;* : b j a l - . C OMM; 8*235-2261 n s' COPIES: El* Simons JF McAllister A. Pozefsky ) ) w/att. February 22, 1973 Mr. W. F. Powell Manager-Engineering Ballast Business Department 1430 East Fairchild Street Danville, Illinois 61832 Dear Walt: Supplementing my letter of February 20, attached is a letter from Dr. Kelly of Monsanto to Dr. Quinby. Presumably you and Al Pozefsky will wish to put your heads together on the proper strategy for supporting Dr. Kelly's editorial review of Quinby*s proposed article, and dealing with requests for information on ballasts which we. may expect to come from Quinby, directly or indirectly. Very truly yours, "" JSN:ev Attachment James S. Nelson, ConsultantProduct Environmental Compatibility NEL 000226 782071 Monsanto Monsanto Company 6 0 0 N. lindbargh Boulsvard S t. Louis, Missouri 63166 Phona: (3141 634-1000 February 14, 1973 R E C E IV E D FEB 1o 1973 Dr, Griffith E. Quinby P. 0. Box 1313 Wenatchee, Washington 98801 E. L SIMONS pear Dr. Quinby: You have brought up three items in your letter of February 5 which reached my office today. First, as far as frequency burn-out of ballast in fluorescent lights is concerned, I have no. idea of the frequency. I have seen no statement issued by Monsanto with regard to such frequency. Certainly if one exists it would surprise me, but I would be happy to see a copy if you find one is in existence. In this matter, however, I am asking Mr. VJilliam Papageorge, who has received a copy of your letter, to answer you. Your second topic refers to a consulting editor for your'proposed manuscript who would be willing to review it. I would be very happy to serve in this capacity. Your third question relates to the opinions of Fakkineri et al. concerning the occupational toxicitv of diphenyj It is my opinion that the 1968 TLV of 1 mg/M^ for dipheny.L is satisfactory. I, likewise, roust state that should levels reach one and two magnitudes larger than this I v:culd not be at all surprised if disability occurred. In animals, respiratory irritation occurs at approximately 5 mg/M^ and none of this has been reported in the United States In this connection, I think you should know that the patents held on these applications are not held by Monsanto and the development work on these applications was, like wise, not done by Monsanto. Sincerely, R. Emmet Kelly, M. D. REK/ln Medical Director cc: W. B. Papageorge cc; All carbonees of your letter of 2/5/73 - 782072 NEL 000227 TECHNICAL RESOURCES RIVER ROAD, SCHENECTADY, N. Y. 12305 DIAL. c o r.i rs SUBJECT 8*235-2261 KOHTlLY ACTIVITIES REPORT Ja:r.es S. Mc 1non__________ COPIES: FS Rothe February 27, 1973 Mr. J. F. McAllister NEU YORK /* ' 2. PCS Dr. Griffith Quinby, K.D., who describes himself as a practitioner of preventive medicine, is planning an article for Science about what he claims is the dancer of air pollution from the PCB in fTuorescent ballasts which fail in service. Our capacitor and ballast people have been alerted and will cooperate with Monsanto in providing editorial review prior to acceptance of the article by Science. redacted NEL 000228 782073 Mr. J. F. McAllister 2 February 27, 1973 J SN:ev REDACTED James S. Nelson f NEL 000229 782074 V TECHNICAL RESOURCES GENERAL ELECTRIC 1 RIVER ROAD, SCHENECTADY, N. Y. 12305 SUBJECT 'T D r A -L c OM M; 8*235-2261 Memo of Conversation with Dr. Terry Davies. CEO > COPIES: JF McAllister - NEW YORK JF Repko - SYRACUSE March 2, 1973 Dr. A. Pozefsky HUDSON FALLS, NY Dear Al: This note will give the gist of my conversation with Dr. Davies on March 1. Dr. Davies had called Jack McAllister, asking four specific questions, which Jack asked me to answer. We agreed on the appropriate statement, and the questions and answers are given on the attached sheet, which I had in front of me when talking with Davies. I explained to Davies that Jack had relayed his questions to me, but had not explained the background, i.e., why these particular questions at this time? Davies said that he was getting information for the State Department. State has received a number of telegrams from American Embassies, notably the ones in Stuttgart and Paris, inquiring about how U.S. industry is handling the Japanese action on computers. Japan has enacted, or is planning, a ban or restriction on t he importation of computers which contain PCB capacitors. 1 asked Davies if there are any new developments which would tend to invalidate the conclusions of the Interdepartmental Task Force. He said, "No...it's just this Japanese action." (Dr. Davies, it will be recalled, is the listed author of Appendix H, Regulatory Action on PCB's, of the 1TF report.) 1 then went through the questions and answers we had worked out. Davies wished to know what dielectric we are using -- is it a dry type? I said no, it is impregnated with a proprietary formulation. Davies attempted to get me to subscribe to a date when we would have full readiness to supply non-PCB capacitors, but I simply reiterated that we couldn't name a date, as too many unknowns are involved in the development. Additionally, he wished to know what portion of computers exported from the U.S. to Japan are using our non-PCB capacitors. I said I don't know, but that "we are working with one of the larger exporters." After completing the list of questions and answers, I asked him if he were satisfied that we had given him an adequate picture of the computercapacitor status, and he replied affirmatively. I then expressed curiosity about his approach, as to whether he was querying a number of manufacturers in this regard, and he said, "No-- you are the largest. I don't even know who the others are." NEL 000230 782075 GENERAL ELECTRIC Dr* A. Pozefsky 2 M arch 2 , 1973 In closing, I invited him to take down my telephone number for future information on capacitors, pursuant to the strategy we had evolved (to discourage "cold" calls to Hudson Falls). Very truly yours, JSN:ev Attachment James S. Kelson ' . NEL 000231 782076 CAPACITORS 3-1-73 QUESTIONS POSED BY TERRY DAVIES (PER MCALLISTER) AND ANSWERS FURNISHED BY POTEPSKY 1. Is it true that non-PCB capacitors are not suitable for use in computers? Ans. - Functionally, some non-PCB capacitors are suitable. GE is offering limited production quantities for computer and related applications, in cases where the customer insists he must have a non-PCB capacitor. No announcement of coinxiercial availability has been made as yet. 2. What portion of "small capacitors" do not contain PCB? Ans. - About 10Z (of impregnated types). Dielectric may be mineral oil, or castor oil, for example. 3. What is the non-PCB portion used for? Ans. - Energy storage, energy discharge, tuned circuits, and the like, where a flat temperature characteristic is desired and where a higher degree of flammability is acceptable. These are industrial applications. 4. We understand GE is working on non-PCB capacitors.. What are replacement aspects, i.e., how long would it be necessary to provide PCB replacements in retrofit? Ans. - Time is needed to prove reliability and safety, and to go through the process of application testing. We are aiming to achieve sizes compatible with existing installations. If we are successful, replacements could be made with non-PCB capacitors in older equipment, as well as new. Bear in mind, however, that the new capacitors now being furnished are being made on a pilot plant, batch-process basis. We are endeavoring to develop a viable production process. If we can achieve this, we would furnish the new capacitors, not on a crashprogram basis, but on a wear-out replacement basis. To sum up, we do not know if, for the high volume applications, we yet have a suitable product. We are not able to predict the timing of this program. 782077 J. S. Nelson NEL 000232 TECHNICAL RESOURCES GENERAL ELECTRIC 1 RIVER ROAD, SCHENECTADY, N. Y. 12305 SUBJECT PCB Spill ; dial; comm 8*235-2261 ~] COPIES: Dr. EL Simons - Bldg. 36-120 March 20, 1973 Mr. J. F. McAllister NEW YORK Dear Jack: The enclosed memoranda from Ed Simons to Ed Weaver will serve to supplement and update my note of March 16 to you. One Item 1 left out of my original chronology is the following: 9.5 - 3-7 or 3-8-73 - After learning of plans to drum 135 cubic yards of earth and ship it out of state, 1 called Bob Nelson (who was the principal contact in Rome for Chattanooga personnel) to discuss the possibility of local dry landfill as an alternative, citing the statement in the government's Interdepartmental Task Force report that PCB does not migrate through the soil, and equivalent statements in the ANSI Standard proposal. He said he would look into this. Very truly yours JS N :e v Enclosures James S. Nelson tfEL 000233 782078 Jf 5-5882 March 2 0 , 1973 J.S.N elson J.M. P h illip s SUBJECT: PCB SPILL IN TENNESSEE Dear Ed On t h e b a s i s o f t e l e p h o n e c o n v e r s a t i o n s y e s t e r d a y b e tw e e n me and Bob O s t h o f f ( P i t t s f i e l d ) and b e tw e e n Marv P h i l l i p s and Bob A rn o ld (Rome) I can suninarize th e c u rren t s itu a tio n as follow s: 1 ) 01m Kenney (Rome) h ad an a m i a b l e m e e t i n g w i t h EPA i n A t l a n t a on Friday. 2 ) H o u r ly p e r s o n n e l fro m Rome w orked a t t h e s p i l l s i t e t h i s p a s t weekend, f i l l e d up 600 drums w ith contam inated s o i l , and shipped 9 tra c to r t r a i l e r loads to the Texas disposal s it e m e n tio n e d i n ite m 10 o f 01m N e l s o n 's c h r o n o l o g y . 3 ) Some s a m p le s o f s o i l an d w a t e r from t h e s i t e w e re s h i p p e d by a i r t o P i t t s f i e l d and a n a l y z e d t h e r e t h i s w e e k e n d . EPA w i l l w a n t some m ore s a m p l in g and a n a l y s e s , b u t EPA seem s s a t i s f i e d with the clean-up process so fa r. S in c e re ly ELS:1 Dr. E. L. Simons, Manager Environmental P ro tectio n Operation NEL 000234 782079 COMPANY DIAL c o r.i ra 5-5882 R E AL E S T A T E amd CONSTRU OPERATION ' NELSON M A R 1 9 7373 SERVING PROGRESS March 19, 1973 SUBJECT: PCB SPILL IN TENNESSEE- Mr. Bid : J.S.N elson J.M. P h illip s D e a r Ed For your inform ation I enclose w ith th is l e t t e r a copy of the c h r o n o l o g y o f t h e PCB s p i l l i n T e n n e s s e e and i t s a f t e r m a t h t h a t I received"from J . S. Nelson la te Friday aftern o o n . -* The fo llo w in g in fo rm a tio n supplem ents t h a t in N e ls o n 's chronology. 1 . 3 - 6 - 7 3 - Upon my a r r i v a l a t t h e S t a t l e r H i l t o n H o te l i n W a s h in g to n ,D .C . f o r a m ee tin g o f th e Panel on E nv iro n m en tal Q u a l it y o f t h e E l e c t r o n i c I n d u s t r i e s A s s o c i a t i o n I r e c e i v e d an u r g e n t m e s s a g e t o c a l l my o f f i c e . When I c a l l e d , Dr. C. B. S c h r i v e r t o l d me o f a c a l l t h a t had come t o EPO t h a t m o rn in g from E. L. D o b b i n s , c o u n s e l f o r t h e T r a n s f o r m e r and D i s t r i b u t i o n E quipm ent B u s i n e s s D i v i s i o n , r e p o r t i n g t h e PCB s p i l l . 2 . 3 - 6 - 7 3 - B e c a u s e t h e s p i l l i n v o l v e d a GE p r o d u c t i n ' t r a n s i t and n o t a GE D i a n t o p e r a t i o n , I a s k e d D r. S c h r i v e r t o n o t i f y J . S. N e lso n im m ed ia te ly and t o a s k him in t u r n t o c a l l E. Raab, Manager - D i e l e c t r i c System s L a b o r a t o r y , P i t t s f i e l d , who i s t h e man i n t h e T r a n s f o r m e r D i v i s i o n who knows m o s t a b o u t PCBs. 3 . 3 - 6 - 7 3 - I t h e n c a l l e d R. A r n o ld a t t h e GE Medium T r a n s f o r m e r p l a n t i n Rome, G e o r g ia and r e c e i v e d a s s u r a n c e s from him t h a t no PCB s p i l l had o c c u r r e d a t t h e p l a n t i t s e l f a n d t h a t b e c a u s e I&SE was h a n d l i n g t h e tr a n s p o r ta tio n and i n s t a l l a t i o n of th e tran sfo rm er i t s personnel would n o tify the ap p ro p riate s ta te and fed eral environm ental ag en cies. 4 . 3 - 9 - 7 3 - Upon my r e t u r n fro m W a sh in g to n I c a l l e d Jim N e ls o n and l e a r n e d from him th e in fo rm a tio n in c lu d e d in item s 4-14 o f J im 's chronology. 5 . 3 - 1 4 - 7 2 - N e lso n in fo r m e d me o f t h e t e l e g r a m from EPA t o D obbins ( i t e m 15) and we a g r e e d t h a t t h e T r a n s f o r m e r o r I&SE p e o p l e s h o u l d r e p l y i n d i c a t i n g t h a t a c t i o n was u n d e r way on t h e f i r s t two EPA r e q u e s t s and t h a t a p r o n o s e d s a m p l in g p ro g ra m would be n r e n a r e d f o r s u b m i s s i o n t o EPA ( i t e m 1 6 ) . Jim N e ls o n s e n t me a copy o f t h e t e l e g r a m ' s c o n t e n t s on March 16 ( a t t a c h e d ) . NEL 000235 782080 GENERALELECTRIC COMPANY Mr. E. S. Weaver -2 - March 19, 1973 6 , 3 - 1 6 -7 3 - Dr. R. C. O s t h o f f , M a n a g e r - I n s u l a t i o n System s L a b o r a t o r y O p e r a t i o n , P i t t s f i e l d c a l l e d t o d i s c u s s t h e p ro b le m w i t h me and t o r e q u e s t EPO a s s i s t a n c e a s n e e d e d , ( t i e ! s o n ' s i te m 2 0 ) . O sth o ff had d isc u s s e d th e s i t u a t i o n w ith R. T. M o rris, General M anager, Medium T ra n sfo rm e r P r o d u c ts D ep artm en t and w ith T. L. M ayes, M anagerE n g in e erin g . The s i t u a t i o n was summarized as fo llo w s : 1 . EPA p e r s o n n e l fro m t h e R e gion IV o f f i c e i n A t l a n t a had t a k e n s o i l and stre a m bed sam ples on March 15 i n th e a r e a o f t h e sp ill. 2 . I&SE p e r s o n n e l ha d t a k e n s i m i l a r s a m p le s a f t e r t h e EPA p e r s o n n e l had taken t h e i r s . 3 . No s a m p lin g had b een do n e by Rome p e r s o n n e l . 4 . Mayes had s e n t J . Kinney from th e Advanced E n g in e e rin g Lab a t Rome t o m e e t w i t h a man named Dobbs a t t h e EPA o f f i c e i n A t l a n t a on F r i d a y , March 16. (As o f 5 PM F r i d a y I had r e c e i v e d no f u r t h e r word from O sth o ff re g a rd in g th e Kinney v i s i t . ) 5 . Because L. G. P o r t e r o f I&SE i n C h a tta n o o g a had b e e n h a v in g d i f f i c u l t y in g e ttin g lo ca l drums and la b o r to remove th e contam inated s o i l , t h e p l a n t a t Rome had b e e n a s k e d t o se n d some o f i t s own h o u r l y personnel to work a t th e s p i l l s i t e th e weekend o f March 17-18. Heavy ra in s were lik e ly to hamner o p e ra tio n s . 71/ yt/ 6. O sthoff had c a lle d Paul Bed'ignus o f Monsanto. Besfignus had not y e t been asked f o r h e lp in th e c le a n -u p and a f t e r m a th , b u t was w illin g to provide i t as soon as he could get th e necessary Monsanto leg al approval. 7 . 3 - 1 6 - 7 3 - A f t e r a 3 -way c o n v e r s a t i o n b e tw e en O s t h o f f , me and P h i l l i p s o f EPO* .Marvmade a number o f phone c a ll s and lea rn ed t h a t th e A pparatus S e r v i c e Shop a t K n o x v ille was h e l p i n g o u t w ith men and drum s. 8 . 3-16-73 - I gave you a summary r e p o r t of th e s i t u a t i o n by te le p h o n e , and you in tu r n n o t i f i e d Mr. Lewis by T e t t e r . The f o r e g o i n g i s , t o t h e b e s t o f my k n o w le d g e , t h e s t a t u s as o f t h e end o f F rid a y , March 16. ELS:1 S i n cAe r/e/*,ly <ra_ Dr. E. L. Sim o n s, Manager Environmental P ro tectio n Operation N E L 000236 782081 TECHNICAL RESOURCES G E N E R A L ^ ELECTRIC 570 LEXINGTON AVE. NEW YORK, N. Y. 10022 SUBJECT T. m I D I AL] comm: 8*235-2261 COPIES: FS Rothe MONTHLY ACTIVITIES REPORT James S. Nelson__________ April 2, 1973 4 Mr. J. F. McAllister NEW YORK IV-PRODUCT ENVIRONMENTAL COMPATIBILITY 1. PCB-CEQ Dr. Terry Davies, of CEQ, inquired about the use of non-PCB capacitors in computers. A reply, coordinated with Industrial and Power Capacitor Department, was given by telephone. 2. PCB Spill in Tennessee A transformer being shipped from Rome to Michigan developed leaks at the junction of the cooling pipes and the tank while in transit near Kingston, Tennessee, leaking some 1500 gallons of askarel fluid. At the suggestion of this component, an on-site review was held and assistance furnished with respect to press releases and negotiations with state and federal officials. r ed a c ted 782082 GENERAL ELECTRIC Mr. J. F. McAllister 2 April 2 , 1973 REDACTED James S. Nelson /ev ?*J NEL 000238 782083 TECHNICAL RESOURCES GE NE RA L ELECTRIC 1 RIVER ROAD. SCHENECTADY. N. Y. 12345 SUBJECT D IA L COMM 8*235-2261 PCB SPILL IN TENNESSEE: Chronoloev II COPIES: April 18, 1973 Mr. J. F. McAllister NEW Dear Jack:.. Taking up where my memorandum of March 16 left off, here are additional notes on the Tennessee PCB spill incident: 21. 3-16-73 - Dr. Simons informed us that- Rome had dispatched two men from Advance Engineering to Tennessee to oversee technical aspects of the clean up, .and that Dobbins had confirmed in a letter to Osthoff, with a copy to Peitosalo, that the Insulation Systems Laboratory Operation (a part of Group Technical Resources) would be responsible for matters concerning the environ mental aspect of the-spill. * 22. 3-16-73 - Later the same day, it was learned (again from Simons) that Rome had dispatched a man to Atlanta to talk to the EPA, seemingly at variance with the agreement recorded above. 23. 3-19-73 - Simons relayed the word that Kenney (Rome) had had an amicable meeting with EPA-Atlanta; that 600 drums had been sent to Texas, as nine tractor-trailer loads. Some samples of earth and water had been analyzed by the Pittsfield Laboratory, but the results were not related to the geography of the spill site. 24. 3-26-73 - Simons reported that he and M. Phillips of EPO had been asked to stand by to supply help in negotiating with EFA as needed. 25. 3-26-73 - I called Dr. Osthoff for a status report, and the tenor of his conversation was that the situation was rapidly worsening, and that Rome apparently preferred to handle matters themselves. 26. 3-26-73 - After telephone review of item 25 with JSN, JFM called Dobbins to suggest a review session involving Pittsfield people, Rome people, and a representative of Technical Resources. 27. 3-27-73 - The suggested review was set up by Dobbins, not in Rome, but in Knoxville, to permit site visits, etc. NEL 000239 782084 GENERAL Q ELECTRIC Mr. J. F. McAllister 2 April 18, 1973 28. 3-28-73 - The following were involved in review and planning sessions in Knoxville and at the spill site on 3/28 and 3/29: Russell T. Morris, General Manager, Medium Transformer Dept., Rome, Ga. Jim Kenney, Advance Development Engineering, Rome, Ga. Tom Nichols, " " " "" E. L. Dobbins, Division Counsel, Pittsfield, Mass. James H. Thayer, Mgr.-Environmental Protection, R&U Oper.-Pittsfield - J, Ken Wittle, Mgr.-Phila. Polymer Technology, Ins. Syst. Laboratory J. Marvin Phillips, Engineer-Waste Recovery/Reuse, EPO/RECO, Schdy. J. S, Nelson, Consultant-Product Environmental Compatibility, Technical Resources, Schdy. Art. Bruggeman, I&SE, Rome, Ga. Gaynor Coliester, Manager-Regional Public Relations, Atlanta, Ga. Robert Smales, Attorney, Electric Mutual, Lynn, Mass. Lew G. Porter, I&SE, Chattanooga Office A. L. Powell, I&SE, " " 29. 3-28-73 - In capsule form, the situation as of this date contained the following features. Rome had engaged a Knoxville laboratory, under the direction of Miss Peggy L. Stewart, President, Stewart Laboratories, Inc. Miss Stewart had engaged Deane F. Kent and Associates, a geological firm, with whose assistance a topographical map of the site had been made and marked with appropriate sampling stations. Samples were taken to Stewart Laboratories in Knoxville for electron capture gas chromotography analysis. Analyses were obtained on a one day basis to guide additional sampling and disposal work. Stewart and GE supervisory personnel (Nichols, Kenney, Powell primarily) were housed in a contractor's portable hut on the site. A backhoe and laborers were on the site. By this date, approximately 23 trailer loads of more or less contaminated soil had been dug up, placed in 35-gallon drums, and trucked to Texas. Nearby wells had not shown PCB's, but readings in the pasture below the site were said to reach a maximum of about 16 ppm. Soil by the side of the road assayed in the thousands of ppm initially, reducing to 100 and less as the clean-up progressed. Unfavorable publicity was resulting from news stories and pictures in the 7fif' NEL 000240 782085 GENERAL'Q electric NEL 000241 Mr, J. F. McAllister -3 - April 18, 1973 local newspaper (published twice a week) and on local radio. No Company statement had been issued, but people dropping by the site had their questions answered factually and courteously (insofar as 1 observed)* At a GE caucus on this date, the prepared publicity release, which had not been used, was laid aside and a new one devised, with contributions from Coliester, Nelson, and others. The final draft was produced by Dobbins, reviewed with the undersigned, okayed by Morris, and released to the local paper and radio station on 3-29. (Copy forwarded previously.) 30. 3-29-73 - A meeting with regulatory officials was held at a motel a few miles from the spill site on 3-29-73. Present from GE were: Morris Dobbins Nichols Kenney Nelson (designated by Morris as spokesman) From EFA: Allan Jennings, Washington Denny Dobbs, Atlanta From State of Tennessee: Earl C* Lenning, Water Quality Commission Bill Seawell, Fish and Game Commission Don A. Owens, Water Quality Commission Lee McClaran, Chemist, Food and Drug Division Eugene H. Holeman, Food and Drug Division, Nashville 31. 3-29-73 - Dr. Jennings was spokesman for the regulatory people, both state and federal. Although officially there as an advisor to the state, and speaking without federal statutory authority, he was, in effect, telling us what we had to do, and "how clean is clean." (As Jennings has since agreed, there are not any federal statutes applying directly to a spill of chemicals on land, and even if the spill had been over water, the EPA has not yet defined the types of materials subject to the provisions of the Federal Water Pollution Control Act. Section 12 of that act requires immediate reporting to EPA or the Coast Guard of any discharge of a hazardous substance from a vessel or an onshore or off-shore facility. At the time of the Interdepartmental Task Force report, it was stated that PCB's are "being designated" as hazardous substances under section 12, and "the authority contained in the section could be used if an accidental spill of PCB's into water should occur." Apparently, such designation has not been made. See Par. 36). The state, in the person of Mr. Lenning, said it would go along with whatever Dr. Jennings recommended. Dr. Jennings outlined, with reference to Stewart Laboratory sampling stations, a program of future monitoring and clean-up He wants the grass cut and removed from the pasture, and surface debris removed from the "draw" where heavy rains carried PCB from the spill. At the immediate site, digging is to continue until samples of soil contain no more than 5 ppm. Readings greater than that will be tolerated in more remote areas, where, in effect, nothing can be done about it (e.g., 15 ppm in pasture soil). Dr. Jennings regards this plan as a 782086 GENERAL ELECTRIC Mr. J. F. McAllister 4 April 18, 1973 concession to the "realities" of the situation. Monitoring is to continue for several months. (1 observed that Nichols vas taking detailed notes on required actions, so did not do so myself.) At this point, Mr. Lenning reiterated that Jenning's proposal would be the l state's plan, and Jennings asked for comments. In answer to my question as to the rationale of the limit of 3 ppm at the "digs", Dr. Jennings stated that the only applicable regulations he could find cover the application of the pesticide, lindane, to crop lands. The amount allowed to be spread on an acre of land approximates 1 ppm, so Jennings "generously" allowed 5 ppm.(Efforts to corroborate the arithmetic of this ecological legerdemain have been stymied by our lack of success in getting _ our hands on lindane standards. These are apparently in a state of transition between the responsibility of the Department of Agriculture and the EFA.) I pointed out there was no need to refer to pesticide applications to find a guide, as Food and Drug has already .published guidelines for FCB's themselves, in food and packsging materials. The limit Jennings was demanding for soil by the roadside was twice as restrictive as the FDA limit for food packaging material, e.g., breakfast food boxes. (That limit, as published in the FDA's Impact Statement, is 10 ppm.) To this, Jennings merely repeated that he was not requiring the whole area to be cleaned to this limit, but only the area which received the original gross contamination. We did extract agreement that, once we were dealing with a few hundred ppm, it should no longer be necessary to put the soil in drums, provided we can find a disposal agency which will take the soil by the truck load. Mr. Dobbs agreed to help us to find such a site, and mentioned Rollins Purle in Louisiana as a possibility. There followed some discussion of the monitoring program which had been outlined, with Jennings agreeing to withdraw one station which GE pointed out would probably be flooded by the Tennessee River at higher levels. Mr. Dobbins then requested that the Tennessee authorities correct the public record in regard to the condemnation of wells. (The newspaper-had reported such action, but Tennessee officials had denied it to us.) Mr. Lenning stated that no wells have been condemned. When asked how the newspaper made its error, he replied to the effect that he had "advised people not to drink the water" (.') Mr. Dobbs (EPA) agreed there had been unfortunate publicity, and suggested that another meeting be held to work out a joint press release. Mr. Morris replied that we had no objection to this, but that we were now in the process of releasing a statement already prepared. 32* 4-2-73 - Bob Osthoff called to describes now concern at the spill site: analysis of well water has disclosed the presence of 50 to 500 ppb (parts per billion) of trichlorobenzene and EPA has stopped the use of water from a number of wells. E. Simons is doing some study on the toxicology of trichlorobenzcne. Stewart Laboratories is doing more sampling; EPA now has its own geologist at the site. Our people are trying to determine what 782087 NEL 000242 G E N E R A L ^ ELECTRIC Mr. J. F. McAllister -5 - April 18, 1973 isomers -of trichlor are present. The product we use is a by-product of Hooker Chemical's production of hexachlorophene and the precise composition is;not known. Dobbins called, said the state had closed seven wells. 33. 4-2-73 - I called Lew Porter, who reported that the state of Texas had put a stop to further shipments of the waste into Texas for burial |at Texas Ecologist, Inc. Clarification is being sought on the status of} two trucks 5till in transit. Rollins Environmental Services (Wilmington, Delaware) states there is an imbibing agent for application to soil to soak up contaminants. He didn't know what the agent is, except that it is a Dow product. I inquired about the details of original notification of Federal authorities about the spill. Porter says the route "probably" was GE-Deputy SheriffTennessee water pollution people-U.S. E.P.A. Dobbs (EPA Atlantia) called Porter on April 6, the day following the spill, at which time Dobbs already . knew about it. He (Dobbs) said the Tennessee people had told him. 34. 4-3-73 - Jim Kenney (Rome) called me, reporting that Marv Phillips had suggested that they get hold of a charcoal filter and pass Mr. jHickey's well water through it to see if that would effectively eliminate the trichlorobenzene content. TVA had granted permission for GE to "park" contaminated soil on TVA property until a final disposal site should be arranged. Transportation is being handled by large truck, without the use of drums. 35. 4-5-73 - Simons reported upon a telephone conversation between Marv Phillips (EPO) and Jennings (EPA) in which Jennings reviewed his lindane computation, in slightly different form, but arriving at about the same conclusion. According to Jennings, Agricultural Department standards allow 1% lb./acre. Assuming a penetration depth of 2 inches, this equates to a soil density of 130 lb./cu.ft., or about 1% ppm. Jennings by this time had decided to approve well water if the concentration of trichlorobenzene is less than 25 ppb. As to the status of the PCB clean-up operation, it was learned, that Chem-Trol will accept the material, will require drums, but will charge a lower fee than Texas Ecologist, Inc. 36. 4-13-73 - Ed Simons called to report another transformer spill. This time, it was 10-C oil, not Pyranol, and the location was Charleston,|West Virginia. The transformer radiator had been damaged in an accident on the customer's premises and the transformer had been transported to the GE service shop without first draining it or stopping the leak. Some oil got into the river, was detected by the U.S. Coast Guard which traced the oil to the Service Shop and requested a written report. Allan Jennings, EPA (Washington) called EPO to ask about the spill, was relieved to learn it contained no PCB's. During his conversation with Simons, Jennings admitted that he had no statutory basis for the clean-up requirements he caused Tennessee to place on the Compan> NEL 000243 782088 GENERAL-^) ELECTRIC Mr. J. F. McAllister 6 April 18, 1973 and added that he and the Tennessee authorities feel that GE has done the best it could do under the circumstances. Simons reported additionally that on April 12, Harvey Briggs of his office attended a meeting at Region IV EFA headquarters in Atlanta. Also present were Tom Nichols (Rome), Peggy Stewart (Stewart Labs.), and the Tennessee authorities. The topic was reaching a decision on stopping the digging. There seemed to be general agreement that the digging had been completed, and that a public meeting should be held in Knoxville on the 17th at which the environmental authorities would explain the action taken and answer questions. 37. 4-18-73 - I called Bob Smales (Electric Mutual). He said things are relatively quiet on the claims front. He has spoken to the attorney for Hickey (on whose land the spill occurred) and to the attorney for the man who claimed PCB. in the eye as a result of driving behind the truck. The latter said that he anticipated, once the hysteria has abated, that things could be settled on a "reasonable basis." 38. 4-18-73 - AZ Pozefsky, expecting a visit from Gutoff, called for an up-date on the spill incident. 39. 4-18-73 - I called Marv Phillips, who reported that some digging is still in progress, to finish the badly contaminated areas, but that it is "winding down." The EPA has recommended, and the Tennessee authorities have agreed, that well water is approved provided neither the FOB content nor the trichlorobenzene content exceeds 25 ppb. On this basis all wells are free of PCB and all wells except Hickey's are free of trichlorobenzene. Experiments are under way to clean Hickey's well with carbon filtration, but we do not know the results. A community meeting was held in Kingston on April 16 (not Knoxville as mentioned in Par. 36). EPA and Tennessee people spoke. GE representatives were there, but did not speak. The community was told they could use their water. Phillips is personally negotiating with Tennessee to get permission for local burial of the remaining questionable soil. He has the approval of Leary Jones, head of the Water Commission, and is now working with the solid waste man. James S. Nelson /ev KEL 000244 782089 - TECHNICAL RESOURCES GENERAL 0 ELECTRIC 1 RIVER ROAD. SCHENECTADY. N. Y. 12345 D IAL c o r.i r.i SUBJECT 1 8*235-2261 | COPIES: OH LeBlanc - Corp. R&D-SCHDY JF McAllister - NEW YORK A. Pozefsky - HUDSON FALLS EL Raab - PITTSFIELD April 23, 1973 Mr. M. M. Masterpool Room 801 570 Lexington Avenue NEW YORK, N. Y. Dear Mr. Masterpool: Confirming our telephone conversation, enclosed Is a copy of a page from SCIENCE NEWS, 4/14/73, describing some research reported by Crosby and Moilanen of the University of California. I have asked Dr. LeBlanc of Corporate Research and Development to see what he can find out about the reception this paper received at Dallas and the merits of the case presented. Meanwhile, as suggested by Dr. Pozefsky of Industrial and Power Capacitor Department, a reporter for one of the wire services might find this a newsworthy item. While we are not in a position at present to endorse the reported findings of this paper, it is obvious that should they be borne out they would materially increase our chance for a continued acceptability for transformers and capacitors utilizing PCB's. Very truly yours fernes S. Nelson, ConsultantProduct Environmental Compatibility NEL 000245 782090 .> i:*- rv ii-lii-73 Vol. 103 # 15 G 'rm vA? 23 a, : W l!t'lilJj|i l t ^>a * /; v i ; O wJ VsV V;here PCB's come from Getting to the heart of NGC 253 Though scientist have known for a lone time that the The centers of galaxies arc of special interest because class of industrial compounds called polychlorinated hy- galactic nuclei appear to he places where a number of phenyls (rc u 'sj can have devastating environmental effects, strange astrophysical phenomena take place. In the A pril no one has known ju st how they got into ttc atmosphere I A si KOPitx stc m. J ournal l.ETTi.Rs E . E . Becklin and (S N : 10-24 70. p. 3321. Sow . in a paper presented to iGerry Ncugcfcauer of California Institute of Technology the American Chemical Society meeting this week in Dallas. 'and E . B. Fomalont of tl National Kad.o Astronomy Ob Kenneth Moilanen and Donald Crosby of tnc University servatory report observations in radio and infrared of the of California at Davis say they may have found an im central regions of the galaxy N G C 253. portant new source. At both the infrared and radio frequencies the galaxy \ H iJe ly used in manufacturing as plasticizers; solvents and coatings, t'cn's have been found in the atmosphere far exhibits a nuclear core that extends for about 10 second of arc across the sky. The nucleus shows a high infrared from obvious industrial sources. The solution to this mys iflux. so high that the observers believe it cannot be at tery. say Moilanen and Crosby, may lie in tnc breakdown tributed to a nonthermal -'urcc. They believe that it is of out through the action of sunlight. Unde, laboratory thermal radiation from do.' .hat has been heated by stellar conditions, the Davis team has shown that ultraviolet light ultraviolet light. If that is so. and if it is true at the same degrades out vapor mo products that eventually become time, as other observers maintain, that certain other galaxies pen's. have nonthermal infrared sources in their nuclei^ then a I f true, this explanation would also solve anotherpuzzle. V complication is added to the study of galactic nuclei: There "Since only a small fraction of the total amount of DDT \ must be more than one mechanism responsible fo r.th eir ever applied has been accounted for." the paper says, "our infrared emanations. results give clues about the eventual fate ot DDT in the j environment.** ddt apparently survives about four years in the atmo* ' > Mysterious motions in the Venus atmosphere k sphere, plenty of lime for the ultraviolet component of sun- Carbon dioxide is a major component of the atmosphere light to accomplish its degradation. Other studies have of the planet Venus, and therefore studies o f its behavior shown that pen may be twice as effective as ddt in causing^ can give information on large-scale happenings in the thinning of bird eggshells. For this and other reasons, the \ Venusian atmosphere. researchers frankly describe their work as "exceptionally Twenty years ago G . P. Kuiper noted day-to-day varia in: jortant." tions in the strength of the absorption by carbon dioxide of a particular band of wavelengths from sunlight. Now the Alternative power*souFce matter has been taken up by L . G . Young, A . T . Young, J . W. Young and J . T . Bergstralh of the Jet Propulsion \:i alternative power source that could become competi Laboratory in Pasadena. C alif. They report in the April I tive to existing fossil fuel and nuclear plants was proposed Astrophysical Journal Letters that there is a 20 per at the American Chemical Society meeting by United A ir cent variation of the strength of the carbon dioxide absorp craft Corp. fuel chemist Albert J, Giramonti. tion over a period of about four days. Called cogas. for Combined Gas and Sieam Turbine This appear to be evidence of a change in the level of Sy items, the technique would use gas obtained from low the cloud tops that amounts to more than one kilometer and quality coa! or residual oil. The gasification and desulfuriza occurs simultaneously all over the planet. The observers tion processes would make the fuel expensive by today's arc at a loss to explain this phenomenon since a great deal standards, but as pollution controls tighten and technology of energy is required for such changes, and they don't ad anccs, Giramonti said, cocas stations would be able to see where it come from on a pi anet that rotates as slowly compete economically with both nuclear and conventional a Venus and absorbs solar energy at a uniform rate at fossil fuel installations. all location. "We seem to be observing a fundamental Gasification involves partial oxidation of the raw material feature of the atmospheric dynamics that is no; explained in a h;gh-presviirc reactor, followed by various scrubbing by current theories of atmospheric circulation on Venus,*' and absorption operations. Valuable elemental sulfur is thev conclude. produced as a by-product. The lirst (o nxs slat ons could he built immediatelv with existing technolucy\ Giramonti said. Bode's (aw again NEL 000246 Progress against solid v/astes Two new methods of attacking the persistent problem of what to do with solid waste were introduced at the American Chemical .Society meeting. Koheri Groner. James Harbour and Virgil Freed of Oregon State University report siuccsslul laboratory translnrmatiun of wastepaper. straw ar.J municipal wastes into partiJehoarJ that, they say. can compete m price and quality with interior plywood. They were also ahie to create lertili/er and a plastic-like cellulose acetate Irmu solid wastes. ln another paper. Ronald Wolk of Hydrocarbon Research. Inc., reports a process to recycle old tires into fuel oil, naphtha and raw materials for use an making new ores, 1lie development voims none too soon, for recent pollution legislation lorhids burning tires, and piles of old tires have become a crowing nuisance. Bode's law is an empirical formula for calculating the distances ot the planets Horn the sun. Many attempt* base been made to explain it by some physical principle. In the March ?f) N x t u r e Myron Lecar of the Smithsonian Astrophys.cal Observatory and Harvard College Observatory suggests that Bode's Uw may he based on the fact that planets cannot form "too dose to one another." If, in the original soi.ir nebula, two planets had begun to form loo clove jo each other, they would have competed for the same matter and would either have coalesced or not have grown. I.ecar says Bode's taw can he determined by a sequence of random numbers subject to the closeness con straint. Satellite systems (such as Jupiter's or Saturn's) would have Ion ned with closer spacing, lie says, since they dul not grow to the size where they accreted gas and thus formed I rom less material and so could be closer together. 782091 TECHNICAL RESOURCES GENERAL ^ ELECTRIC 1 RIVER ROAD. SCHENECTApY. N. Y. 12345 - ^ .T T l1 C OMM SUBJECT L 8*235-2261 MONTHLY ACTIVITIES REPORT Janes S. Nelson__________ COPIES: FS Rothe May 1 , 1973 Mr. J. F. McAllister NEW YORK H! REDACTED i NEL 000247 JSN*:cv V ery tr u ly y o u rs , 782092 TECHNICAL RESOURCES GENERAL ELECTRIC 1 RIVER ROAD. SCHENECTADY. N. Y. 123AS SUBJECT - Y" D I AL COMM t COPIES: uc May 7, 1973 Dr. E. L. Simons Building 36-120 Dear Ed: Here are some observations on Dr. Quinby's paper. I would check the box "Should not be published anywhere" for the simple reason that Dr. Quinby doesn't know what he's talking about. Very truly yours, JSN:ev Att. james S. Nelson ? NEL 000248 782093 "PCB HAZARDS IN LIGHT BALLASTS" This is sheer nonsense. Of course, it has been known since the beginning of the application that the principal insulating fluid in ballast capacitors contains PCB's. This statement gives a false impression. The significant reduction in use has been in the non-electrical applications. Author states an "undesignated part" of the number of ballasts produced is for ballast applications (as though there were some dark secret) His reference (2) contains figures for fluorescent ballasts in the years 1967 and 1970. What does this statement mean? This informal survey hardly qualifies as scientific data. We also, happen to know that Dr. Quinby has selected experiences which build his case, ignoring, for example, a letter he received from the FDA stating that they had no experience of ballast failure accompanied by leaks. Furthermore, he fails to distinguish between ballast capacitors and ballasts, and leaves the reader with the impression that the only ballast failure mode is one involving rupture of the capacitor case. Dr. Quinby*s highest measurement was a small fraction of the TLV. He fails to point out that, while this was a transient phenomenon, TLV has no meaning except for continuous exposure, 8 hours per day, five days per week. Where is the evidence for the "dermal hazard" in electrician's occasional clean-ups? The statement is made that burning PCB's pollutes the atmosphere. Again if he had studied his own reference (2) he would have learned that incineration is an acceptable method of destroying PCB's, provided attention is paid to temperature and dwell time. Dr. Quinby*s recommendation does not follow logically from any evidence in his paper. The only hazard he has identified is the theoretically possible interference with certain tests or sensitive production processes, should there be a coincidental failure of a ballast unit involving liberation of PCB. Wouldn't it be simpler to protect such processes, rather than eliminate the small but finite possibility of such coincidences through replacement of billions of dollars worth of fluorescent lamp installations? 782094 NEL 000249 TECHNICAL RESOURCES 1 RIVER ROAD, SCHENECTADY. N. Y. 12345 SUBJECT D I AL COMM 8*235-2261 MONTHLY ACTIVITIES REPORT James S. Nelson__________ COPIES: FS Rothe May 30, 1973 V6 Mr. J. F. McAllister NEW YORK IV-PRODUCT ENVIRONMENTAL COMPATIBILITY PB Dr. Griffith E. Quinby, sorne-time consultant to ORNL, has written a paper entitled "PCB Hazards in Light Ballasts" and submitted it to Science for publication. This paper contains misinformation and potentially damaging viewpoints and recommendations. Editorial review board comments have been filed with the magazine through Dr. Simons and others, recommending non-publication. !J REDACTED NEL 000250 JSN:ev Jam es S . N e lso n O' 782095 ' TECHNICAL RESOURCES GENERAL^ELECTRIC 1 RIVER ROAD. SCHENECTADY. N. Y. 12345 SUBJECT DI AL C OMM 8*235-2261 REVIEW OF TRANSFORMER ASKAKEL PRACTICES COPIES: May 30, 1973 Hr. J. F. McAllister HEW YORK Dear Jack: You will be interested in the attached letter from Phillips (RECO) to Morris (Medium Transformer). Did anything come of your proposed discussion with Morris concerning a design-review type meeting on the control of PCB-containing designs? Very truly yours, JSN:ev Att. James S. Nelson X NEL 000251 782096 rn \ RAL E L E C T R I C COMPANY DIAL C OH M 1 REAL EST ATE ano CONSTRUCTION OPERATION May 15, 1973 SERVING PROGRESS Mr. R. T. Morris General Manager Medium Transformer Products Department General Electric Company Redmond Circle Rome, Georgia 30161 D ear Russ: Re: Prevention, Control of Soills You, Art Eruggerman, Tom Nichols, James Kinney, Bob Arnold, and others offered many good suggestions for preventing another "Hickey Farm" incident. Now that the digging operation is winding down, maybe we should document these suggestions into workable guidelines for dealing with any future spills. As you know, Congress is expected to pass solid wastes and toxic substances legislation this year. You, therefore, can expect more stringent control of the usage, storage, and disposal of hazardous substances. I propose that we prepare guidelines covering in-plant spills, spills while transferring to and from storage, spills while transferring to carriers, spills while en route, and spills while equipment is being repaired. The guidelines would cover PC3s as well as oil, trichlorobcnzcne, and ocher chemicals. Also, it is appropriate that wc also prepare a plan -for the "ultimate disposal" of PCBs and other toxic substances. P: NEL 000252 782097 G N R A L@ ELECTRIC COMPANY Mr. R. T. Morris Page Two May 15, 1973 Attached are the "Guidelines for Prevention, Control, and Reporting of Spills in Chemical Plants" as a reference document. Also attached is information on chemical type landfills and absorbents. We will be glad to work with you on preparation of "spill guidelines," and design of "ultimate disposal facilities," and related legal questions. Sincerely yours, JM?:mirih cc: B Arnold A Bruggerman CW Conklin EL Dobbins T Nichols RC Ostoff SM Richel EL Simons s/* JH Thayer J. M. Phillips Engineer-Waste Recovery/Reuse ENVIRONMENTAL PROTECTION OPERATION ?r NEL 000253 782098 GENERAL ELECTRIC GENERAL ELECTRIC COMPANY. 1 RIVER ROAD. SCHENECTADY, NEW YORK 12305 Phone (518) 374-2211 Building 36-505 o TECHNICAL RESOURCES June 14, 1973 Managing Editor Environmental Health Perspectives National Institute of Environmental Health Sciences Box 12233 Research Triangle Park, N. C. 27709 Dear Sir: Please send me the four issues of ENVIRONMENTAL HEALTH PERSPECTIVES and place me on your mailing list to receive information regarding this publication. Very truly yours, JSN:ev James S. Nelson, ConsultantProduct Environmental Compatibility f NEL 000254 782099 TECHNICAL RESOURCES 1 RIVER ROAD. SCHENECTADY. N. Y. 12345 SUBJECT D I AL C OM M Public Hearing on Effluents (FR 38-116-15866. June 18. 1973) COPIES: JF McAllister - NEW YORK ES Dunham - I&PCFD, HUDSON FALLS WJ Heerlein - WDBD, PROVIDENCE CE Hornaday, MD - Tube-0WENS30R0 I. Matelsky - Lamp-CLEVELAND J. Ponzio - EC&BFD, C0LUM3IA, S.C. A. Pozefsky - I&PCPD, HUDSON FALLS EL Raab - ISLO, PITTSFIELD RE White - WASHINGTON CORP. OFF. June 27, 1973 Dr. E. L. Simons Manager-Environmental Protection Oper. RECO BUILDING 36-120 Dear Ed: I am using this means to confirm our telephone conversation of yesterday and at the same time alert those receiving copies to the subject matter. The subject hearing (copy of notice attached) will embrace twelve materials, three of which appear as components in Company products: Cadmium - Nickel-cadmium batteries Mercury - Lamps, power tubes, wall-switch buttons PCB - Transformers, capacitors Thus, product environmental compatibility representatives of departments making these products have an interest in the outcome of this hearing. However, I believe we are in agreement that the main thrust of the hearings and the associated rule-making to follow is with respect to effluents from manufacturing processes rather than the possible pollution potential of end products, and that, therefore, yours is the predominant staff interest. I'm sure that if you wish him to do so, Russ White will arrange for monitoring the hearing. This notice was the subject of a telephone call from Bill Papageorge of Monsanto, who wished to confer as to probable action on either of our parts. After discussing this with you, I called Papageorge back and advised him that we in GE do not feel we have an appropriate platform from which to testify at the hearing, nor any particular credibility in the fields of toxicity and biodegradability. On the other hand, we feel that it is important for Ms. Sager's committee to understand the appropriateness of making distinctions between the various homologs of PCB in considering both toxicity and degradability, and in recommending effluent standards; and that the presentation given by Monsanto to the Interdepartmental Task Force on PCB's, May 15, 1972, would be most pertinent and useful in the committee's deliberations. I assured Papageorge that we would NEL 000255 782100 GENERAL ELECTRIC Dr. E. L. Simons 2 June 27, 1973 consider it helpful if Monsanto can arrange to repeat that testimony, or at least file it with the Sager committee. Papageorge said they had been thinking along the same lines. I will appreciate being keptv informed of any further developments with a possible product impact. Very truly yours JSN:ev Enclosure James S. Nelson, ConsultantProduct Environmental Compatibility NEL 000256 782101 ir.sGs NOTICES 41. Director of Public Affairs, Renton VTI, Administrator when proposing effluent ETHEPHON // Environmental Protection Aceney. 1735 Boltl- iin'W h m l , City, Mu c^ioa. I DtroSor oi l'lli'IIC A" a'.!".. ll<vmll VIII. F .viroiunenVn] l i i `011100 Armey. l.inoi*ln Timor, room SfiKIHOU Lincoln atn-et. Denver, Colo. 80203. J. Director of PuStte Affair*. Revlon IS . Fnvironnienitil ITi-icctTan Armey. 1110 Call- .'i rtutv Street, San Francifcsp^ Calif. 04102. K Director of Public Affivp, Roclon X, Environmental Protection Agebqr, 1200 Stb Avenue. Seattle. Wash. 98101. ' ' v | PR Doc.73-11902 Piled 6-15-73:8:4^*11*v. EFFLUENT STANDARDS AND WATER QUALITY INFORMATION ADVISORT COMMITTEE Agenda and Notice of Public Hearings Notice is hereby given of a public henr ing to be held by the Effluent Standards and Water Quality Information Advisory committee r*the Committee" estab lished pursuant to section 515 of the Fed eral Water Pollution Control Act, as amended, 33 U.S.CA section 1251 ct seq. ("the Act") . On June 6. 1973. the Acting Administrator of the Environmental Protection Agency notified the Commit tee of his intention to propose effluent standards lor toxic pollutants under sec tion 307(a) of the Act. The statute au thorizes the Chairman of the Committee to publish a notice of a public hearing within 10 days after receipt of such no tice. and to hold a public hearing within 20 days. The hearing noticed hereby will be held on Jiilv 16.1973. at 10 a.m. in the Old Angus ballroom. Holiday Inn, Crys tal City, Arlington. Va. The hearings will be open to the public. Although final de terminations have not yet been made v. ::h respect to the pollutants which will constitute the list of toxic pollutants re quired to be published under section SuTtai. the Committee is informed that the following pollutants, among others, ?r<2 being considered at the staff level for inclusion in the list: standards fnr toxic pollutants, it Ls antmp.iUd tb it the Aum:;:: ir;,mr may publph .1 r.e:,vi* >ttuip iurtii a prrprucd list of u>mi` ixilluiaiiLs in the Flplkal R egister pnor to July 16. If so. surli list and m tin- will be ccr-ridoreri at the hear ing not:<Tii !:t*re:n. If the lot has not been prope ni by that tune, the hearing will be hv'.d uii the bruis of this notice. The hcariiv* may be adjourned to sub sequent c.iti-s in order to obtain further information. Adduiona: information concerning the hearing may be obtained by writing Dr. Martha S.v*er. Chairman, Effluent Standard.* ;u:d Water Quality Informa tion A dv.sory Committee. Environmen tal Protection Aconey, room 21, Crystal Mall, Budding 2, Washington, D.C. 20460. Tiie hearing will be held pursuant to the direction of the Chairman and in accordance with hearing procedures published in the F ederal R egister on Wednesday, April 21, 1973. a t pages 9179-80. Certain persons or organiza tions may be invited by the Committee to appear and give oral testimony. Others desiring to appear and give oral testi mony should contact the Committee at 703-557-7390 or may request the oppor tunity to appear by telegraphic notice or letter to Dr. Sager at the address listed above. Due to limitations of time, it may be necessary to limit the number of wit nesses who may appear and give oral testimony. Witnesses will ordinarily be limited to 15-minute presentations to be followed by 15-minute periods of ques tions from the Committee. Although the opportunity to appear and give oral testimony must necessarily be limited due to the limitations of time available to the Committee to hold pub lic hearings and obtain additional infor mation pursuant to the provisions of section 515 of the Act. all persons desir ing to submit written statements or testimony to the Committee are encour Notice of Extension of Temporary Toii'tjnco ! In connection with Fc: ixide ivtition No. 201195, Ainchem Products. Inc,, Ambler. Pa. 19002. wax granted tem- posary to>:T.::res for n- of (S;e ;:i;itt remdatar etiwphi'ii 1 *2-eh!nro- ethil* phusplvmc arid* m or on the raw acnqultural commodities pineapples and tomiuoos at 2 parts per million on April 27. 2672 'notice was published In the F-ltA l F.eitstr of Apr. 29. 1972 37 FR 87u6 !). Theae temporary tolerances expircq April 27. 1973. A toTbrnr.ee was established for resi dues oftethephon in or on tomatoes at 2 parts V'cr milh*-n in connection with Pesticid Petition No. 3F1321. cn April 16. 1973 V notice was published in the F ederal R egister of Apr. 20, 1973 (38 FR 9815) )\ The fira\ has requested a 1-year ex tension of the temporary tolerance for residues of qthephon in or on pineapples to obtain additional experimental data. It is concluded that this extension of the temporary tolerance for residues of the plant regulator in or on pineapples will protect the public health. It is therefore extended as requested on condition that the plant regulator be used in accord ance with the temporary permit being issued concurreru.lv and which provides for distribution! under the Ainchem Products, Inc. name. This temporary tolerance expires April 27.1974. \ This action is taken pursuant to pro visions of the Federal Food. Drug, and Cosmetic Act (sec. 4p8(J), 68 Stat. 516; 21 U.S.C. 346a(Jl). me authority trans ferred to the Administrator of the Envi ronmental Protection Agency (35 FR 15623), and the authority delegated by the Administrator to tke Deputy Assist ant Administrator fon Pesticide Pro grams (36 FR 9038). \ 1. Aldrln (1.2.3.4.10.10-hexacbloro - 1.4.4, . 5,8.8a-hexaiiydro-1.4.4.5- endo - exodlmeihBnonaphtbaienel. 2 . Benzidine and Its salts (para-dlnmlaod phenyl). aged to do so. Such statements or testi mony should clearly indicate the pollu tant or pollutants concerned and should be addressed to the "Effluent Standards and Water Quality Information Advisory Dated June 5.1973. \ H ehrA j . K orp, Deputy Administrator for Pesticide Prorams. 3. Cadmium Ion. Committee" a t the address listed above. (FR Doc.73-12032 Filed 6-15\73;8:45 am) 4. Cyanide Ion. 5. DDD (TDE1 1.1-dlchlor0-2,2-Ms (parachlorophenyl) -ethane. C. DDE (dlchlorodlphenyldlchlorocthylcne) 1.1.1 - trlcbloro - 2.2 - bis(chlorophenyl)- elhylene. Statements presented at the hearing, or otherwise submitted to the Commit tee will be available to the public pur suant to section 10(b> of the Federal Advisory Committee Act (Public Law PENNWALT CORA Notice of Filing of Petition ^regarding Pesticide Chemicals! 7. DDT (dlchlorodlphenyltrichloroethane) 1.1.1 - trlcbloro - 2.2 - bU(Chlorophenyl)ethane, 8 . Dloldrln fl^.3,4.10.10-hexachloro-6.7epc'\-y-1.4,4a.5.6.7.8.3a-ociahydro - 1,4 - endo, e\n^i.8-dimethar,onaplithaIene. JL Endrln (1.2.3,4.10.10-hesachloro-6 .7eposy-!.4 .4a.5 .6 " .s.Sa - ccmhydro - 1,4-endoendo-5, 8-dlmethancnaplvthalene. 10. Mercury i:::cl;iding elemental, Ionic, r.mt'orsano mercury). 1_1^Polychlorinated biphenyls (PCB's). IC.Toxaphcr.e (chlorinated campbcne). The purpose of the hearings noticed hereby will be to Initiate consideration 92-463. 56 Stat. 770). subject to the assessment of reasonable reproduction charges. Requests for such information should be directed to Dr. Martha Sager. Chairman. Effluent Standards and Water Quality Information Advisory Commit tee, Environmental Protection Agency, room S21. Crystal Mail. Building 2. Washington. D.C. 20460. Dated June 12,1973. M artha S ager. Chairmen, Eftvc11i Standards Pursuant to provisions of tty Federal Food. Drug, and Cosmetic Act!'sec. 408 (d)(1). 68 Stat. 512: 21 U.S.C.\34a(d) (l>). notice is given that a petition iFP 3F136D has been filed by Pknnwalt Corp.. P.O. Box 1297. Tacoma.! Wash. 93401. proposing establishment of y.n ex emption (40 CFR pt. 180' from the re quirement of a tolerance for residues of the cross linked nylon type poA*mer formed by the reaction of a xnixtUK of sebacoyl chloride and polymetkne ne polyphenylisocyanate with a mixture of ethylenediamir.e and dictkylenctriamme of such scientific and technical Infor and Wafer Quchty Informa when used os on inert encapsulating ma mation as is pertinent to the determi tion. Advisory Co'.r.viitlcc. terial for formulations of methyl para- nations required to be made by the (FR Doc.73-12031 Filed 6-15-73;B:45 am] tliion applied to growing alfalfa; coru FEDERAI KEGISTE2, V O L 38, NO. 116-- MONDAY, JUNE 18, 1973 E L 000251 782102 ir TECHNICAL RESOURCES GENERAL ELECTRIC D I aT I RIVER ROAD. SCHENECTADY. N. Y. 12345 __________ C O M M SUBJECT 8*235-2261 MONTHLY ACTIVITIES REPORT James S. Nelson__________ COPIES: F . S . Rothe July 30, 1973 Mr. J. F. McAllister NEW YORK / REDACTED f 3. EPA List of Toxic Pollutants EPA has published a list of the materials it considers to be "toxic pollutants" for which standards will be promulgated. Among the materials are three of GE product interest -- mercury, cadmium, and PCB. We have concluded that no purpose is to be served by filing a comment on the inclusion of these materials on the list, but we anticipate monitoring the subsequent standards development activity. Meanwhile, Monsanto requested our views on their posture and we suggested that they consider filing with the Sager committee (which advises EPA on water quality matters) data which Monsanto has developed showing the need for according separate consideration to the various homologs of PCB. They responded by giving the committee "several pounds" of data. NEL 000258 782103 GENERAL ! ELECTRIC Mr. J. F. McAllister 2 July 30, 1973 6. FDA Exempts Transformers and Capacitors from PCB Ban On July 6, FDA published in the Federal Register its final ruling on the use of FCB and PCB-containing equipment in the food industry. In an action consistent with the earlier-published environmental impact statement, the FDA made an exception permitting the continued use of PCB transformers and capacitors. It would appear from the accompanying explanation that GE was the only party which pointed out to EDA the justifiability of such an exemption. Very truly yours, JSN:ev NEL 000259 782104 TECHNICAL RESOURCES GENERAL ELECTRIC 1 RIVER ROAD. SCHENECTADY. N. Y. 12345 SUBJECT ' D J A..L ; '- C O M M ' 8*235-2261 1 EPA LIST OF TOXIC POLLUTANTS COPIES: JF McAllister EL Simons RB Smith RE White July 20, 1973 ir Messrs. E. S. Dunham E. J. Heerlein C. E. Hornaday, M. D. SI. Matelsky . J. Fon z i o V J. F. Madole 5A. Pozefsky E. L. Raab 7 (b Since my letter of June 27, relative to the Sager Committee hearing on effluents, the EPA has brought out its proposed list of toxic pollutants. With the exceptions of omitting Dieldrin and combining three pesticides in one line item, the list is the same as that contained in the Sager agenda, and includes the same materials of interest to GE: mercury, PCB, and cadmium with relevance to end products and cyanide with reference to certain processes. As is usual in the case of proposed rules, EPA invites comment from interested parties. It is our conclusion that it would not be productive to question the inclusion of any of these four materials on the list. In the absence of any strong representation to the contrary from any of you, we shall initiate no comments on the proposed rule-making (a copy of which is attached). We shall, however, be on the watch for standards-setting activity with regard to mercury, PCB, or cadmium which could have an impact on the use of these materials in our products. Dick Smith, of the Washington Office, attended the Sager committee hearing and filed the accompanying report. While nothing much happened at that meeting, the data contributed by Goldwater, questioning some of the accepted positions n t h regard to mercury, is of interest. Copies of this material are included for representatives of the mercury using departments. ? J5N:ev Enclosures NEL 000260 782105 V . Saturday, July 21, lv 7 3 japon Tim e s g*t JL KJSlL ib-iai^Jb . 1 j Jl ^ ' y j S y i o Q r / <_ O * .Tp yk.itl/ vV .^f!-TT. piwt*'-'O -t., [ 7T>.*- s Jbh *JL*^Cx.^j7..vL J '$ Ne, Chronic PCB Ylefca. A <JG j J )/V /< OTSU (Kyodo) -- The Shiga jEruptions began to form on her Prefectural Government report-back and einer parts of her ed Friday that a former vom- bcdy :n 1SG5. an employee of Nichicon C2paci-| She said she would demand to? Ltd.'s capacitor pleat in that ftichiccn Capacitor pay her Kusatsu near here was suffer- jmedical expenses, ling from chronic PCS. (poly-1 The announcement shocked [chlorinated biphenyls) poison-many of her former co-workers 'ing. at t:io Kusatsu plant who were The woman .was identified as worried that they also might Mrs. Hironosuke Kitagawa. S3, be affected by PCE. a resident of Kusatsu. She work 'According to the workers ed at the plant from November union at the plant, a medical 135D to March 1S37. checkup last April found that Y She was the second confirmed the bleed ci ."o:nc workers con* case of chronic PCS poisoning tamed PC3 up to 30 times the in Japan, the prefectural gov normal level. ernment explained. The other More than 200 workers had* victim was a worker a: Toyobooeen exposed to PCS in the Co.'s plant'in Tsuruga, Fukuij manufacturing process at the Prefecture. | factory until the use of PCD was The announcement was made halted in March 1372. after an examination by doctors j Tne factory, built In 1350. pro* at the Otsu Bed Cross Hospital. | duces capacitors totaling about Her blood contained G.llSiV-J.COj million in value a year, ppm. of PCD and subcutaneous i It employs about 450 workers, fat contained 42.3 ppm. of PCD. \ Between lSSS end March last The blood and subcutaneous fa t!year, tiic plant used 2.43C tons of the average Japanese contain of PCD. Some of the PCB caus- 0.C2 ppm., and 9.G ppm. of PCS, | ed pollution of paddies around respectively, according to ihejths factory, prefectural government. j Eight* nearby farmers have She had'black eruptions on brought a damaged suit against her body, particularly on the the company, tiemending com* face, the announcement said. ;pensatia.i toiniing .'V22.533.QCfl Mrs. Kitagawa was singled jand replacement of iop soil In out for medical observation in a i the polluted paddies. medical' checkup for possible: ------------- -- PCD poisoning covering 455 local | residents in July last year. j She underwent a detailed ex amination after she was admit Additional information cories to: ted to the Bed Cross i>os,'iial June IS. | Doctors were inclined io be-i lieve tiiat she was cont:.:nimilcd| LP Hart A Pozefsky JF Kepko IScP Cap. Dept. EC Legal Operation by PCD through the respiratory j JF Ege Corp. Medical Cperation organs and skin while disposing! JF McAllister Staff Exec* - Prod* Qual of substandard capacitors. i "I never thouiil:; ii:ut I vasj affected by 7CB." Mrs. K ii> \ from J3 Nelson 8-1-73 jgawa said in u press conference i at the Kusatsu Public Health j Center 1*no oy utt^mcon. j Her face was covered by skin: eruptions which looked like! pimples. ; She said she had b an engaged! in work to break subsiar.cljrdj capacitors containing PCD. | NEL 000261 782106 I PRODUCT QUALITY STAFF GENERAL 0 ELECTRIC 1 RIVER ROAD. SCHENECTADY. H. y. 1:345 SUBJECT prirr 1 --- C O M M I 5*235-2261 * Government Intentions with Respect to PC3 Limits_____ bcc: JF McAllister EL Simons COPIES: DR Bair - PITTSFIELD AL Blackburn - HICKORY, N.C. JG Jewell - PHILADELPHIA UM Rodgers - ROME VM Nave - PHILADELPHIA August 29, 1973 Mr. E. L. Raab 7 Manager-Dielectric Systems Lab PITTSFIELD Dr. A. Poretsky :I Manager-Technology Planning Industrial Power Capacitor Prod. Dept. HUDSON FALLS At the first meeting of the Task Force - Pyranol Transformer, ve discussed the hypothesis that PCB effluent limits under Che Federal Water Pollution Control Act could, in theory, be set so low as to shut down the askarel transformer industry (even though the sale of such products would continue to be legal). Hearings have recently been held by the Effluent Standards and Water Quality Advisory Consoittee, and EFA is required by court order to come up with proposed standards for hazardous substances discharged into the water by December 3, 1973, and with final standards by year's end. Our concern arises in part from the fact that the only number which has been bandied about is so low as to be beyond the resolving capability of present analytical techniques: "to keep levels in fish as low as possible, and in any case from reaching the 5 parts per million established by FDA as an Interim action level for safety as food, concentrations in water should be less than 0.07 part per billion, or to allow some safety factor, 0.01 ppb." The quotation is from the Interdepartmental Task Force report of May, 1972. In addition to being difficult or impossible to measure, such a concentration is so low that stopping production in a given transformer or capacitor plant might well fail to clear up effluent to this degree, because of old residual contamination. A year ago, Mr. Papageorge of Monsanto discussed the latter aspect of the situation with Dr. John Buckley of EFA and received the impression that Buckley was more Interested in how plants are controlling their current production than in such residual problems, and that Buckley was not out to shut down plants that produce or use PCB's. (For a discussion of this interchange, sec Dr. Simons' Memorandum 72-5, April 18, 1972.). In an effort to get an up-to-date reading on EPA's intentions, I telephoned Dr. Allan Jennings of EPA' Office of Hazardous Material Control. Dr. Jennings, you will recall, was Washington's man on the scene who set the clean-up rules for the Kingston, Tennessee incident. Jennings confirmed the significant dates mentioned in our lead paragraph, stated that they are working on PCB standards, NEL 000262 782107 G E N E R A L S ! ELECTRIC Mr. E. L. Raab 2 August 29, 1973 but have not yet determined the form of standard or the analytical technique to be invoked, let alone being ready to quote a number. It remains to be determined whether the standard will be in the form of an effluent-concentration limit, or stated in terms of pounds per day. No number will be available prior to December 3. I referred to the Buckley position quoted above, and asked him if that thinking is still operative within EPA. His response was to assure me that EFA is striving for an "attainable" standard, and does not wish its standard to result in cutting off the use of PCB in transformers. Thus, with two readings a year apart, from different EPA people, we are probably justified in discounting the probability of being pre-empted from the continued use of FCB's through EPA actions alone. It is unfortunate from the standpoint of our confidence in this matter that we are scheduled to give our final report as a team the week before EPA is to publish its proposed standard. --- Very truly yours, JSN:ev James S. Nelson, ConsultantProduct Environmental Compatibility NEL 000263 782108 PRODUCT Q UALITY STA FF G EN ERA L ELECTRIC 1 RIVER R0A0. SCHENECTADY. H. Y. 12345 r ^ T T T l -1> C 0 M M j SUBJECT 8*235-2261 MONTHLY ACTIVITIES REPORT James S. Nelson COPIES: F. S. Roche August 29, 1973 Mr. J. F. McAllister NEW YORK REDACTED A. Task Force - Pyranol Transformer The Product Quality Staff is represented on a Task Force formed at the request of Art Peltosalo to study and evaluate risks associated with continued participation in the askarel transformer business. The study group is chaired by Bill Nave and is to make recommendations to Chuck Meloun by the end of November. One aspect of the Task Force work is to assess the continued availability of PCB and the possibility of effluent regulations being set so tight as to make it uneconomical to continue. In this connection, an EPA spokesman has assured Mr. Nelson that it is the agency's intent to produce an "achievable" standard. Very truly yours. J S N :ev 782109 NEL 000264 PRODUCT Q UALITY STA FF GENERAL | | ELECTRIC 1 RIVER ROAD. SCHENECTADY. N. Y. 12345 SUBJECT F d i a l COMM 8*235-2261 Company Policy: Participation in _______ Development of Standards 4 COPIES: DC Fleckenstein September 5, 1973 Mr. J. F. McAllister NEW YORK Dear Jack: It has come to my notice that a policy draft, 20.15, Participation in Development of Standards, is being circulated for comments. I have suggested to Don Fleckenstein that, after line 23 on page 4, it would be appropriate to insert a new paragraph 4, entitled "Environmental Protection", with the following wording: 4 Environmental Protection: Characteristics of products, procedures, and processes necessary to meet environmental protection requirements of Policy 20.13, Environmental Protection, including applicable mandatory codes and laws. A recent example of this type of standards activity Is furnished by the ANSI Committee CIO7 on PCB. In addition, ANSI has recently announced standards activity on the non-radiation environmental protection considerations involved in nuclear power plants. Very truly yours, JSN:ev james S. Nelson NEL 000265 782110 PRODUCT QUALITY STAFF G E N E R A L ^ ELECTRIC 1 RIVER ROAD. SCHENECTADY. N. V. 123 SUBJECT T al i c MM 8*235- 2261 Pyranol Transformers COPIES: JG Jewell - PHILADELPHIA RT Morris - ROME UM Nave - PHILADELPHIA September 14, 1973 Mr. Raymond W. Frahm Manager-Marketing Medium Transformer Products Department Redmond Circle Rome, Georgia 30161 Dear Mr. Frahm: X am writing in behalf of the Task Force - PyranolTransformer, chaired by Mr. W. M. Nave and working to an agenda which has been reviewed with Mr. Me loun, to request your help in assembling certain information needed in our study. Our work can proceed if you will kindly review and bring up to date the data in the attached 1971 letter from Mr. McCann to Mr. Raab and also fill out the enclosed data matrix sheet on applications and production quantities. For coordination with similar data being requested from others, please endeavor to get this back to us by September 28. Thank you for your cooperation. Very truly yours, JSN:ev Enclosures James S. Nelson, ConsultantProduct Environmental Compatibility NEL 000266 782111 E N E R A L O electric MEDIUM TRANSfOSMiR DEPARTMENT LOCATION-- DATE Redmond Circle Rome, Georgia 50161 December 15, 1971 SUBJECT INDUSTRY ESTIMATES FOR ASKAREL-FILLED TRANSFORMERS c o pies: 0 1A L. co a 8 * 2 8 2 - 5 559 R.K. Frahm - Office J.M. Major - Office D.M. Hoselton - Office Mr. E. L. Raab, Manager'' Insulation Systems Section Pittsfield Materials & Technology Laboratory PITTSFIELD WORKS This is in reply to your request of November 22, 1971, regarding askarel-filled transformers. Our best estimates to the answers to your questions are as follows: 1. For the industry in this country, there are approximately 5,000 askarel- filled transformers manufactured in a year. 2. The average gallons of askarel per unit is 250. - 5. A good average failure rate during manufacturing and test is less than 5 per year. 4. Our best estimate of the failure rate for units in service is less than 0.1 a per year. 5. Our best estimate of the total number of askarel transformers produced since 1952 is 67,000 units. Presumably, those units still in use would be slightly reduced from this figure based on such a low failure rate. These estimates are based on our figures since we have manufactured askarel-filled units in Rome and some Pittsfield statistics prior to that time. Confirming cur 12/13/71 phone conversation, we would guess that about 30,000 units would have been manufactured by General Electric since 1932. ,n NEL 000267 782112 MEDIUM TRANSFORMER PRODUCTS DEPARTMENT Pyranol Transformer Applications and Quantities Shipped Category Seconday Substation (including load center, motor control center, etc.) Master Unit Substation Transformer Fluid/Unit Units Shipped 1971 1972 Est. 1973 Primary Unit Substation Limit Amp Substation Total Production of Pyranol Transformers fi N E L 000268 782113 PRODUCT QUALITY STAFF G E N E R A L ^ ELECTRIC I RIVER ROAD. SCHENECTADY. H. Y. 123 SUBJECT f. ` . D ' A ! C 0M MJ 8*235-2261 | Pyranol Transformers COPIES: JN Boyle - PITTSFIELD JG Jewell - PHILADELPHIA VM Nave - PHILADELPHIA IJ Peterson - HICKORY September 14, 1973 Mr. Lawrence L. Dengler Manager-Marketing Distribution Transformer Products Dept. Hickory, North Carolina 28601 Dear Mr. Dengler: I am writing in behalf of the TadtForce - Pyranol Transformer, chaired by Mr. W. M. Nave and working to an agenda reviewed with Mr. Meloun, to request your help in assembling certain information needed in our study. Our work can proceed if you will kindly review and bring up to date (if necessary) the data in the attached 1971 letter from Mr. D. ? Strang to Mr. E. L. Raab and in addition fill out the enclosed data matrix sheet on your applications and quantities. For coordination with similar data being requested from others, please endeavor to get this back to us by September 28. Thank you for your cooperation. Very truly yours, JSN:ev Enclosures x/7anes S. Nelson, ConsultantProduct Environmental Compatibility NEL 000269 782114 Dial Coran 8-234-3A54 Distribucin T r a n s f o m e r Products Pictsield, Massachusetts Dccember 6, 1971 Department Copies: DF Haywood DJ Herdcr SUBJECT: Pvrnnol 28-3 28-3 Mr. E. L. Raab 11 - 223 In response to your letter of November 23 concerning the AMSI Committee on the use and disposal of askarel, we have made the following estimates_ for transformers within our product scope. 1. The yearly production of askarel-filled transformers in the United States is 1700 units filled with an average of 153 gallons of liquid, and an average of 1 percent of these failed in test. 2. For the total industry, there are about 30,000 askarelfilled transformers in service with an average of 166 gallons of liquid, and these fail at a rate of about 1/2 percent per year. For your information only, and definitely not to be divulged outside of the company, the attached table shows the breakdown of these numbers by product line for those products within the scope of Distribution Trans former Products Department. I call your attention to EEI Publication No. 63-71, published in 196-, entitled Network Operations 1959-1961 which contains interesting informa tion about the number of network transformers in service during that eriod, the percentage of those which were askarel-filled, and the average ailure rates. fi . ? . i t rang Dicg. .o -- j j O -es A 11acame n t a '*< c NEL 000270 782115 ASKAREL-FILLED DISTRIBUTION TRANSFORMERS ESTIMATES FOR ALL 1-.. INDUSTRY DECEMBER 1. 1^71 Foie & Station (500 kVA and less) Network Number/ Year Average/ Gallons Test Failure Rate - % Number in Service Failure Rate % / Year 330 40 1 15,000 1 500 365 1 10,000 .3 Precipitation Power Supplies Instrument Transformers (69 kV and less) 30 Pad (2500 kVA and less) 10 Pad 400 0 400 50 120 6 200 85 2 2,400 .5 - 500 .3 1 2,100 1 1 200 1 3*Jr ' Utooo T a H D. ?. Sir:r.; 12/0 '71 782116 DISTRIBUTION TRANSFORMER PRODUCT DEPARTMENT Pyranol Transformer Applications and Quantities Shipped Category Average Gallons of Transformer Fluid/Unit 1971 Units Shinned 1972 Est. 1973 Pole & Station Network Precipitation Power Supplies Instrument Transformers 3(3 Pad 10 Pad Total Production of Pyranol Transformers N E L 000272 782117 PRODUCT QUALITY STAFF 1 RIVER ROAD. SCHENECTADY. N. Y. 12345 SUBJECT Pvranol Transformers _ J. p jiu i'* ' D I A Lj t " C M M , L 8*235-2261 COPIES: JJ Farrell - PITTSFIELD JG Jewell- PHILADELPHIA VM Have - PHILADELPHIA September 14, 1973 Mr. W. B. Gaither Manager-Marketing Power Transformer Products Department 100 Woodlawn Avenue Pittsfield, Mass. 01201 Dear Mr. Gaither: X am writing in behalf of the Task Force - Fyranol Transformer, chaired by Mr. W. M. Nave and working to an agenda which has been reviewed with Mr. Meloun, to request your help in assembling certain information needed in our study. Our work can proceed if you will kindly supply the information indicated on the enclosed data format (supplemented as required if we have missed any categories). Thank you for your cooperation. Very truly yours ' fi; JSN:ev Enclosure James S. Nelson, ConsultantProduct Environmental Compatibility NEL 000273 782118 POWER TRANSFORMER PRODUCTS DEPARTMENT Pyranol Transformer Applications and Quantities Shipped Category Furnace Transformers Average Gallons of Transformer Fluid/Unit % Field Failure Per Year* Units ShipDed 1971 1972 Est. 1973 Rectifier Transformers Transportation Transformers a. Third Rail b. M-U Car c. Locomotive 1/ Total Production of Pyranol Transformers * Failure race expressed as per cent of units in service. Please make estimate if quantities involved are insufficient for statistical treatment. NEL 000274 782119 PRODUCT Q UALITY STA FF 0GENERAL ELECTRIC [ DIAL. 1 RIVER ROAD. SCHENECTADY. H. Y. 12345 ; ___ c o v. SUBJECT r-- chlonn^tu* 8*235-2261 ! Climate for PCB Regulations COPIES: .JF McAllister EL Simons . OH LeBlanc September 24, 1973 Messrs; A. Poz e f s k ^ v . .. . E.'L. * ; .. W. M. Nave * 7 ' --t.- " 7, _7> " *'' ' .. a ;'., ;, ,, ... On September 7, 1973; the EPA -published its List of Toxic Pollutants under the Federal Water-Pollution Control Act. It was, of course, no surprise- that PCB remains on this list; however, we did not expect the characterization as representing a "high order of toxicity to man.. ` Such classification, by the EPA's own rules, requires an LD50 of 50 mg/kg; yet the LD50 of PCB is 8560 mg/kg (Arodor 1242). X discussed this discrepancy 'With Mr. Papageorge of Monsanto in a recent telephone-conversation. He suspects the author of the EPA discussion is Dr; Allan Jennings (the man "Who established the ground rules for clean-up of the Tennessee; spill).' Papageorge intends to protest this language in the course of discussing"proposediregulations with EPA and with-Dr.v-Sager of the advisory conanittee. .... . . . . --- A disturbing discrepancy also appears in the draft by the National Academy of Sciences of "Water Quality- Criteria - 1972" as reported by the Bureau of National Affairs (Environment Reporter. 8-24-73). On page 700 of that publication, we read that NAS said it is not practical to make recommendations based on water concentration; and on page 705 we see that they have indeed made such a recomiendation -- 0.002 micrograms per liter, or 0.002 parts per billion.' The same article reports a recommendation for the body tissues of aquatic organisms not to exceeds0.*5 micrograms per gram. This is ten times as restrictive as the FDA action limit*for PCB in fish as food. Mr. Papageorge is intending to find out who are the authors of the NAS report. Meanwhile, marine biologists, ecologists, and others continue to search for and apparently to find evidence of PCB damage to living organisms -- see "Premature Births in California Sea Lions" in Science. Vol. 181, p. 1168. Copies of the-.three documents mentioned are enclosed. Here is more evidence, if any were needed, that it is going to cake a lot of vigilant effort to prevent over-reaction on the part of regulatory authorities. f NEL 000275 JSN:ev Enclosures James S. Nelson, ConsultantProduct Environmental Compatibility 782120 24312 rules an d regulations graph <c>(14) in S52.2123. paragraphs thdudfl * p robation of the discharge of examined In making this Judgment are (a) is) and ie)(l6) in J 22.2223. para such pollutants or combination of such pou set forth in Part 1 below. graph (d)(3) in 1 52.2(81. paragraph (bX9>(i)-(iili in ! 52.2524. paragraph lutauui) sectiaa. will bo established under this 2. The pollutant is discharged, or has the potential to be discharged, from (o (3) i n i 52.2738. As revised these That proposed list included aldrin- point sources and constitutes a very seri paragraplis read as follows: dleldrin. benridino. cadmium, cyanide. ous environmental threat. ' ' a * DDT (DDE. DDD>, cndrin. mercury, 3. Data arc available to establish e lu * ft) None of the above subpara- graphs shall, apply to .source which. Is., presently in compliance with applicable regulations compliance and to which has certified such., the Administrator by ' polychlorinated biphenyls, and toxaPlicne. Written comments on the proposed rulemaking were invited and received from interested parties and are on file with the Agency. All comments have October 1, 1973. The Administrator may been considered by the Envtronrr.cnt.il request whatever supporting information Protection A'er.cy and certain ones have he considers necessary for proper certi fication. (il) Any compliance schedule adopted by the State and approved by the Ad been adopted. These nr.d other principal changes are di.-eus.-ed below. Several comments dealt with the man ner in wliich the ir.or.;anlc components of the list were spicuted and argued ministrator shall satisfy the require that certain insoluble or innocuous forms ments o* this paragraph for the affected of these substances should not be in source. (iil) Any owner or operator subject to cluded in broad categories such os "all cadmium compounds." ESucnt stand ards which must be developed io r the &compliance schedule In this paragraph ' listed pollutants will include analytical may submit to the* Administrator no and sampling procedures which will dis later than October 1. 1973/ aproposed-tinguish between the toxic and innocu alternative compliance schedule. No such compliance schedule may provide for final compliance after the final com pliance date in the applicable compliance ous forms of the designated pollutants. . A number of commcnters expressed the opinion that the proposed selection criteria were vague and inadequate. It was obvious from the comments received schedule of this paragraph. If promul that a great deal of confusion existed gated b? the Administrator, such sched- as to what materials could potentially be ' *. ule shall satisfy the requirements of this selected as toxic pollutants. \ \ paragraph for the affected source. Accordingly, EPA tins refined these criteria to make them more specific. \HA " fF R*DOC.73*-18629 Ti'led.0.-.6-.73':8:43 a*m] These criteria entail two major advan tages. First, they will provide for more Informed public participation, by identi SUBCH*PTER&--WATERFnobRAMS fying. the. kinds of pollutants which the PART 129--TOXIC POLLUTANT EFFLUENTSTANDARDS Agency proposes to examine and the types of data which are sought for each pollutant. Second, dischargers will be List of Toxic Pollutants placed on notice concerning the class of On July 6, 1973. notice was published In the F ederal R egister (38 FR 18044) that the Environmental Protection Agency was proposing a list of toxic pol pollutants which may berome subject to standards under Section 307(a). It is our intent that the process of selecting pollutants for the list of toxic pollutants will be a continuing one; as lutants pursuant to section 307(a) (1) of additional evidence is developed, addi the Federal Water Pollution Control Act. tional pollutants will be added to the as amended (33 U.S.C.A. section 1317(a) list. ent standards meeting the requirements of the Act. 4. Standard-setting under Section 307 (a) is appropriate, and is necessary be cause the prospective timing ond effec tiveness of abatement actions under other provisions of the Act are not com mensurate with the nature and srnouir.ivs of tiie problems identified by the above criteria. I. ExrLAifJvnox or C n ircm * The first criterion concerns the actual or potential damage that a water dis charge of these materials may create by virtue of certain toxicological propertc-s. Detailed toxicological data are exam ined to determine whether one or more .of these types of effects are known: b:oaccumulattom carcinogenic, mutagenic and.teratogenic effects, and lush acute toxicity. Specifically, the following types of data arc reviewed: 1. Available data concerning whether a substance or its chemical or biological-- transformation product is bio.accumu lated through an aquatic mechanism to the extent that they result in: (a) Reproductive impairment in any important species, or (b) Concentrations in food sources In excess ol applicable Federally estab lished tolerance levels. -2. Data, concerning carcinogenic, mutagenic, and teratogenic effects. Ma terials likely to be carcinogenic, mutagenic, or teratogenic to man are further evaluated as to their* chemical, biologi cal. and physical stability in water. 3. Data concerning high order oftoxicity os measured by short-term lethality tests. In this connection a clas sification of a substance as "highly toxic" to man according to classifications es tablished by the Department of Trans portation and the Environmental Pro tection Agency (36 FR 2934, February 12, 1971. 40 CFR 162.8) and the Environ Supp 1973), (the Act) which provides in Pollutants were chosen for inclusion mental Protection Agency and the F c 'd part: on the Initial list In light of the follow and Drug Administration testing pro TSe Administrator shall. within ninety days after the d^u.-. oi enactm ent c i this title. puVii^h land Irrm lime u> time there after r erL 'c ) a u.--; which Includes any toxic pollutant or ccmhtnatiun of such pollutants ing criteria: 1. Data from laboratory or field studies Indicate that the pollutant could. If dis charged into water, constitute a serious, cedures (40 CFR 162.8 and 21 CFR 191.10) Is particularly relevant. Ac cording to the references cited above. : substances which have an oral LD` 0 of 50 mg. kg of body weight or less or h..vc ! for which an elbucat standard (u'hich may environmental threat. The types of data a dermal LD50 of 200 mg.-kg of body j p NEL 000276 FEDERAL REGISTER, VO L 38, NO. 173-- FRIDAY, SEPTEMBER 7, 1973 782121 t RULES AND REGULATIONS 2ISI3 weight of 1esa are defined as highly toxic to mammals and are examined trol measures available, including the use of rub?unite products, and possible high order of toxicity to aquatic e rraciims, potential concentrations in the further. The terra "oral LD3Q" means that single oral d u e which Is lethal to one-hali of the tost population witiun 14 days. The term "dermal LD50" means that dose dermany abiorbed.iri.C-l.hpurs effects upon ground water or outer en vironmental media. IL The PotLrrAjrrs Snarcrm The .emercency standards promul food web. and its widespread disci: ir.;". Some commenter objected to the in clusion of "Cadmium and all cadni-im comijounds" on the Ii-,t because seme relaitvely innocuous forms of tlie ele which is lethal to one-half,of-the t t : gated by the Department of Igibor for papulation within 14 days. occupational earcmocens i3$ FU 13329. . For tiie protection of aquatic *life, May 3. 1U73>. have forced a-shut in the substances proposed, to-be- classified as "highly toxic" according to the N ational Aead.'-my of Sciences wwter*'pdl!:it:rri .manufacture of bona:dine .from the pre vious producers to the end u. ers. The -resuhinif potential'icr-iue.-v^.-ed water rank:::?-system nay-b?-considered for ixjllutiun by t.us known Carcinogen and ment would be included. The tir-d c .u ent standards will distinguish among the various forms in which tlie element may occur. DDT. DDD. and DDE are on the ii,t beeauac of their acute toxicity to a::u:.t:c omuusms. and thc-ir bioaccum*.::. i. o Inclusion in the list. Such substances arc iSieve which arc toxic to aquatic life Lhe ucverso effects on the environment which may re-ult. requi:c the I..-tier of pr--pcrises. whicii are known to r.i*.:.'0 harmful effects in higher life as measured by a 33 hour LCSO of 10* benzidine. Public comments have indi such as birds. Tlie data arc subir.- for mg 1 or le.-s. Tlie term "LC.'t" means cated that--the material should be in the establishment of effluent star. i..:ds. that concentrat:on of a substance in water which is lethal to one-half of the cluded. and that discharges should be severely -coiitrulled. Other public com Public rostiense in favor of iiiclU'.-r. of DDT. DDD. and DDE noted tiie ex:..:-r.ee test population in the specified time ments indicated that tlie material does of much data on tlie harmful e::.vts of periods. Testing methods such as tko.'e not meet the selection criteria as pro these materials. One comtncnter Mated found. in "Standard Methods lor the posed July 6, 1973. Benzidine does meet tio t DDD degrades rapidly, and decs not Examination of Water, and .Waste- the criteria set forth herein. It was have many of the effects associated with water," 13th Edition, part 231. 1371. or their equivalent will he considered also asserted that the DOL standards would protect both tlie work place and QDT;. It was determined, however, th at DDD1should also be included because of adequate. -.* 'Ui the-environment. However, those stand its toxicity and bioaccumuiative pivpcr- The second criterion concerns the seriousness of discharges or potential ards ore designed to prevent occupa tional exposure, not to control discharges ties. Endrin is highly toxic to aquatic Ufo discharges of the pollutant 'from -point into water. at low concentrations. Considerable data sources. Relevant here are such;factors as the nature and extent of toxic ef Mercury is on the list because its or ganic form is known to bioaccumulate are available on endrin. and contrai of point sources is necessary at present. fects associated with the pollutant, the to the extent that it poses a threat to Those public comments that supported extent to which dic.-haries of the pol the health of man through concentration its inclusion cited considerable data, ar.d lutant have been identified, and the pro duction. distribution, and use pattern of the pollutant. Data must be available lro m , well documented field studies in feed sources, so as to exceed applica ble tolerance levels. Control of point source discharges is urgently needed, and available data are sufficient for.standard urged stringent control. One commcmer alleged that the sole manufacturing fa cility is under control, and that further restriction is unnecessary and redun showing damage to irr.portant orranisxs setting. Public comments noted that the dant, However, available technical and from discharges, of .the compound, into discliarge of this material should be se scientific data support inclusion. More waters, or tecfih:cally suCcieh t';o_shax verely restricted. Some comments were over. the manufacturer of the material the material has. the potential'-to-be'en- ' `received recommending deletion of the is not tlie only point source, since formu vlroxuucniaUy harmful-, after-i being dis- material from the list because of ques lators .also contribute endrin contami charged from point sources to' th .water. tions of solubility and demcthylation of nated wastes to the environment. I The third criterion roncerns1Jetting mercury and its compounds. It should be Polychlorinated, biphenyls .aro. on thg efluent standards for pollutants' on 'the noted, however, that all forms of mer list because of their high order of tox:vi_ list. The following arc representative of cury in tlie aquatic environment can be ity to man and aquatie_arsan:srps, and the categories of data useful in stand methylated t-o methylmcrcury. the most because of tlieir bioaccumiilalive poten ard setting for each m aterial.. hazardous form. tial. The data are adequate, and the 1. Toxicity to man and other orga Aldrir.-dieldnr. are on the list because point source discharges require prompt nisms: of their high order of toxicity to aquatic control. Public comments indicated that 2. Carcinogenicity, mutagenicity, and organisms and their bioaccumuiative the materials should be included be teratogenicity data: properties. Control is necessary now and cause of their widespread use. and tlieir 3. Transport paths of the material in there are adequate data to support ef demonstrated harm to aquatic life. tlie environment: "' fluent standards. Some comments in These commcnters urged that dischar-es 4. Eioaccumulation and bioconccn- dicated that ahh'in-dicldrin should be be as low as possible. No comments were tration: deleted because of possible conflict with received recommending deletion of poly 5. Chemical, physical..an d .biological transformations :n the environment: 6. Reliability and accuracy of-analyt on-going cancellation proceedings under the Federal Insecticide. Funiie:de. and F.odcnticide Act -FIFRA). The Admini chlorinated biphenyls. Toxaphcne is on tlie list because of its high order of toxicity to aquatic life. ical procedures: ` strator has an obligation to control toxic Considerable data arc available concern 7. Chemical characteristics;.-,!:- pollutants under FV.TCA which is lnde- ing this compound, and prompt control 8. Production and industrial or com- ixrndent of l::s authority under FIFRA. of known point sources is required. Pub mercf.il utthuation: There responsibilities cannot be abdi lic comments in sunport of the umierlal 3. Sources of the pollutant-to water: cated. Moreover, it is too early to ascer being included cited ninth of Lite avail 10. Environmental incident.-, attribut tain the precise determinations which able toxicity data. Some commento able to the material tfi h kills, etc.) : will be reqmred under the FWPCA. and argued that this material did nut meet 11. Presence of the material in the env:reamer.:, residue levels, tn .various the Impact on the FIFRA proceedings. Accorsingly. deletion of alarin-dieldnn the selection criteria published m con nection with the proposed list of July G. organ:.*ms. ambient concentrations in Is not coi./:tiered to be warranted a t tills 1373. Toxaphcne dors meet the criteria rr.vrr*. lakes. c:c.: tunc. set forth in this notice. 12. Sin: and redorai regulatory re- Cadmium is included on the list be Since toxaphcne has infrequently been quiremruLs concerns.: the: amitenji: 13. C ..w and characteristics of waters ir.ro which lire material u dis charged. The fourth criterion concerns the cause of toxicity to aquatic organisms. From our itud.es. 1*. wa.: determined that there are several hundred di.-chargers of cadmium, and controls arc urgently needed. Public comment supported the reported to he present in the environ ment, same commenter urged Its dele tion. However, controls ore necessary because the material continues to be overall environmental effect of the cua- inclusion of tins material Decause of Its manufactured, formulated, and distnb- No. 173--r t . I- FEDEIAl C U T I* . VOL. 38, NO. 173-- FRIDAY, SPTW 8U 7, 1973 NEL 000277 782122 2-1344 RULES AND REGULATIONS utod in larce quantities. Tims, the poten hydrocarbons. oreanophosphates. heavy ment Standards Administration, is ex tial for harmful discharges is consider netals, and materials U.-lcd as occupa cepted under Schedule C. able. tional carcinogens by the Department of Elective in September 7, 1973. S213.- Cyanide Is on the Ust-bccause of Its Labor i2B FR. 10339. May 3. 1973*. 3315(a) (36) is added as set out below. high order of toxicity to aquatic life. Persons interested m oasis: me the En There arc many different types of point vironmental Protection Agency in setting source disclurses and a variety ofreceiv- - standards fur the pollutants listed in 213.3315 Department of Labor, (a> O it cc o/ th Secretary. ing bodies of water wh;ch_must be pro Section IV arc invited to submit scien- *** tected from the di&ckar^e'oi tlus ma terial. The data are adequate to support ti:lc mu tcchnical.tl.ua. and other Infor mation concerning the listed pollutants, (36> Ohe Special Assistant to the Dep uty Assistant Socreiary, Employment effluent standards. The public-e^nimen- -to Dr. C. Kuch Th.ompson. Chairman. ters In favor of mviu^ionciied data on Hazardous and Toxic Substance Repuls.toxicity to aquatic life i:i.,vcry low con iion T.\.;k Force. Cilirc of Water Pro centrations. Those comintnicrs who rec gram Operation?. Environmental Pro- Standards Administration. (3 U.S C. w i . 3J1. 3302: E O. 10377. 3 CFIt 1034-53 Comp. p. 218) ommended deletion for the most part tevtion Agency. Waaiunston, D C. 30460: U nited S h i e s C ivil S erv objected to inclusion oL "all *cyanide In particular, the thirteen categories of ice Commission, compounds." It was arm ed th at only standard-setting data set forth in Sec-. (seal) J ames C. S i'RY. compounds which .dissociate In water to tiL'ii i above are >ought for all pollutants Esecutive Assistant to form toxic concentrations oi cyanide ion liued in Section Tv*. The Agency is also the Commissioners. or hydrogen cyanide should be included. imcresicd' m obtaining data on tech-The proposed eSucnt standards will take nolcgy for waste control treatment and IFB Doc.73-19078 Filed 9-6-73.8:45 .iq-.l these comments into account, and may disposal of the pollutants listed in Sec specify special sampling, analysis, and tion IV. Title 7-- Agriculture reporting requirements. . ....... in . .The Lzxcth o r ike L ist In addition, the Agency will review CHAPTER 1-- AGRICULTURAL MARKET* any data submitted'on pollutants.-pro ING SERVICE (STANDARDS. INSPEC posed to be placed on future lists. T h e . TION;- MARKETING PRACTICES), DE Several commenters " recomnieridifd pollutants listed above are merely rep PARTMENT OF AGRICULTURE 'that thefinal list include1 `larger num resentative of pollutants identified in PART 52-- PROCESSED FRUITS AND ber of pollutants than: were included on public comment which may be can VEGETABLES. PROCESSED PRODUCTS the proposed list, in addition, a number didates for selection. Data on those THEREOF. AND CERTAIN OTHER PHOC- of commcntcrs requested shortening the pollutants, and on other pollutants ESSED FOOD PRODUCTS list. Most of the latter recommended re which may be candidates for selection, moval of specific pollutants; these rec should be submitted to the Chairman, ommendations have been discussed in the Hazardous and Toxic Substance Regu preceding section. lation Task Force, at the address set Subpart-- United States Standards for Grades of Canned Ripe Olives Addition or S egmented S tyle As required by section 515 of the Act. EPA notified the Efliucnt Standards and Water Quality Information Advisory Committee on June- 6. 1973. of our in tention to propose, effluent standards for jtoxic pollutants..under'section' 3071a). The Committee held -'hearings'-on the "proposed list in Washington-DjOatJuly 16. Chicago. III. iJuly 30), New York, N.Y, (.Aunust D . and San Francisco, Calif. (August 3). The Committee has agreed to provide scientific and techni cal information concerning the listed pollutants, but has made no recom mendations to date concerning the length of the list. Pursuant to the consent decree en tered into by EPA in the case of SR DC v. Fri, Civ. Action No. 8-19-73 <D.D.C.), EPA must publish p.-qiwsod standards forth in the preceding paragraph. Dated August 31,1973. - J ohh Q uarixs, Acting Administrator. IV. T he List o r T oxic P ollutants P ursuant to section 307(A) ol th e Federal Water Pollution Control Act, as mended, effluent standards win be established ta r th e jyillutants listed below; 1. Aidrla (1,2.3.4.10.10-hexachloro-l.4,4a.S,8, 8a-bexahydro-1.4.S.8 endo-exodhnethanonaphtlialer.e). Oleidrln ( l.2h.4.I0.10-hexaehloro 8.7epoxy - 1.4,4a.5 G.7.8.B& - ociahydro - 1,4 eudo.exo-5.8*dirr.iha:ionaplur. Alee). S. Benzidine and us salts (pats-pors'-dl* am m oblphcr.yl). 3. Cadmium and all cadmium compounds. * 4. CvasiCc and nil cyanide compounds. 5. D D D (TD EU .l - Ciofcioro - 3.2 - blstpara- Notice is hereby given that the U.S. Department of .Agriculture is amending the United States Standards for Grades of Canned Ripe Olives. The amendment. which adds a "Segmented Style" is in accordance with the Agricultural Mar keting Act of-1946, as amended, and with 5 U.S.C. 553. which allows an agency to dispense with the Notice of Proposed Rule Making procedures under certain circumstances. Norcr.--Compliance w tth the provisions of these standards shall not excuse failure to comply with the provisions of the Federal Food. Drug, and Cosmetic Act or w ith appli cable state laws and regulations. Statement of consideration leading to the amendment There is an increasing market poten for all pollutants included on this inula! chlorophenyl) -ethane. tial for segmented style ripe olives--a list no later than December 3. 1973. DDE| dlchlorodiphe r.yIdichloroethylece) 1, style not recognized in the current U.S, Additional toxic pollutants -lists may be published in the future under section 307ia>. The Agency will examine a wide range of pollutants in constituting such I - d:ehicro-2.2 - bistpara-chlorophen}!) ethylene. DDT idivhW od :phe nyl trlehloroethane) 1.1, 1 trichloro-2.2-bis.'para-chIofephenyL) ethane. grade standards. To permit the market ing of this new* style, the rules and regu lations (7 CFR 932.108-932.101 > of the Marketing Agreement and Order No. lists. Among those which will be ex 6. Enar.n ( 1.2.C.4.10.I0-hexnehloro-6.7-cpoxy- 932, as amended (7 CFR. Part 932 >reiiu- amined are the followmg pollutants 1.4 4a.5 0,7.8.8a octahydro - 1.4 - endo - latmg the handling of olives grown In which were identified in public com endo-5 B-diuiv`.hanonaptuhatcuel. California were amended, effective De ments on the initial list: 7. Mecury and all morcury cempv.uulx. cember 12. 1972. arsenic SeleiiUtm cnlio-chlorophenol bvtft-uaphthol S. Polychlorinated biphenyls i l 'CU's). 9. Toxaphctic tchlorinated cam pheae). The Olive Administrative Committee, at Its July 18, IS73 meeting, voted unani chromium alpha- tixphihol [771 Doc.73-19mB Filed 9-6-7.1,845 am) mously to request tuat the U.S. Cand lend beryllium areis be amended to provide for the seg b tn to * evia ho rhlcrthm llntAi-n acrid ino hydruquinoD * mcfccl - antimony hepucnlor Civn.phor rretliTl parathloa pxrathwm dl-n-butyi pbUiaittc The Agency wii examine other pollu- Title 5---Administrative Personnel CHAPTER I-- CIVIL SERVICE COMMISSION PART 213-- EXCEPTED SERVICE Department of Labor Section 213.3315 Is amended to show that one position of Special Assistant to mented style. I t is hereby found th a t it is impracti cable and contrary to the public interest to give preliminary nonce, cdmc in public rule making procedure. n:id post pone the effective date of this amend m ent until 30 days after publication hereof in the Feosoal R egister < U.S.C. tanis in addition, lncludinc chlorinated the Deputy Assistant Secretary, Employ 553) because: FEDERAL REGISTER, VOL 3 1 , NO. 173-- FRIDAY, SEPTEMBER 7 , 1973 782123 NEL 000278 700 EN VIRO N M EN T REPORTER medium with minimum requirements of water quality. The major consideration is the water acidity be relatively low to prevent corrosion of equipment. However, many operations require use of large quan tities of water with quality `'requirements relating to impurity, type, and; leveHi These operations are froth flotation, mie dump lfetcKihg,s.!and' secondary oil re covery. _ 3ifi til Water quality requirements needed for the manufacture of cement are minimal, the .document.said. The major, consideration is the alkali, ctmtcnt of process water. Water Resources NAS SAYS KNOWLEDGE OF LOCALITIES ESSENTIAL TO APPLICATION OF STANDARDS Knowledge o f local".enxitamnental conditions is es sential prior to application' of any*-water quality recom mendations for marine life"and*wildlife, according to a National Academy " f Sciences' draft o f "Water Quality Criteria - 1972" .(Environment Reporter, August* 10, p: 5SS and August p. 669). The NAS document "dcaj^with 'maintenance of the marine ecosystem, fisheries, ' aquaculture, wildlife pro tection, and waste disposal. In developing recommenda tions, NAS also considered the effects of transportation, harbor development, dredging; and dumping of spoils. NAS said application ( o.^.rccbnuncndations to .a local situation is unique, because"it requires*.an understanding- o f the circulation *of Wa^Y and ,th resultant mixing and dilution o f porran,''a.'jinbwledge o f biological species, and`determination o f the "most sensitive species, and an evaluation o f the transport iof materials through the food web. iin;. . ...... Water Quality Change The introduction o f a chemical compound or a change in the physical environment can affect a natural marine ecosystem in several ways, the'report said. These changes include a reduction in the input of solar energy into the ecosystem, an increase hi-thc input'of organic matter and nutrients that might stimulate -growth of undesirable species, and a reduction in.the-availability o f nutrients by increased sorption and sedimentation.-. Changes also can create intolerable physical extremes for some organisms, kill- or reduce the success of in dividual organisms, eliminate -species, reduce species diver sity, decrease biomass, o r increase biomass. Fisheries General requirements for water quality in relation to successful fisheries include favorable environmental con ditions at every- location, which is required in the life history of each spCkies:-freedom hum tainting Nub'llanees: absence o f toxic conditions or substances; and jbieiicc o f suhlelhal deleteriou conditions,,........ Further, ihc:e AhonId.be water xufiicieut to num ijui the health o f the K* logical s>Atem\. whkh \i;ppon U'Clul species, and ab.enee ot environmental conditions, winch are exception..!!) I~*.oi.:l'ic to parantes. predators, and compet inis i'l use till species. Aquaculture Aquaculture is heavily dependent on high water quaiity, according to the NAS report. General recommendations for the quality o f water for use in culture include continuously adequate control of those materials and conditions, which are required for good health and efficient production of the species and absence o f deleterious chemical and physical conditions. Other recommendations included environmental stabili ty and prevention o f introduction of diseases. NAS said specific requirements for each culture effort must be with reference to the species involved, the densities desired, and tltc operational design o f the culture system. NAS said it is diiTieult to assess the potential yield from marine aquaculture, dependent as it is on a primitive art undergoing rapid technological development. However, introduction o f present methods into new, undeveloped part;' o f the world could at least double the present harvest within the next 10 years, the report said. J ' Marine Wildlife NAS said its recommendations for marine wildlife include all criteria formulated to protect fish. inver*_tebratc, and plant communities because wildlife can only be adequately protected, if the diversity and integrity of food webs arc maintained. Further, these recommenda tions must protect wildlife from pollutants that are relatively persistent in the environment, transponed by wind or water currents, and concentrated or recycled in food-webs. The report said die recommendations to protect wildlife dependent on fresh water ecosystems also may apply to estuaries. NAS said it is not practical to make recommendations for tfre_riaiivcl\i-pisis:oiu organic poiiuunts based on b water concentrations, especially when partition c o d '-' heients are unknown. Therefore, recommendations for the toxic organic compounds that arc tropiucallv accumulated by marine wildlife arc based on concentrations in fish. "Ts'AS recoinmehiiafions for marine wildlife are as fol lows: In the absence of data indicating that radionuclides released by human activities are accumulated by wildlife species, recommendations established for marine fish and invertebrates also should apply to wildlife. In the absence of data indicating that heavy metals are present in marine wildlife in concentrations above natural levels, recommendations formulated to protect other mjrinc organisms should apply. Polychlorinated biphenyl concentrations in any sample consol:;:.: ot j homogenate o f 25 or more whole fish nf any species that is consumed by fish-caring birds and mammals, within the same sire range as the lislt con sumed. should be no vre.iter than .5 milligram per kilo gram line kgl o f the wet weight. l)L>f concentrations in any sample c o n sisiiu g o f a homogenate o f 25 or more fish o f any species that is consumed b> loh-cjling birds and mammals. w itl:::i the same si/e range as the li>h consumed, should be no greater than 5u iniero g jjm vke o f the wet u e t/h i. The sum o f the concentrations o f aldtin. dieldrin. >? /? lr' f*'? NEL 000279 En*tienm nl RcpoOvr /o to* o. r 7 7 R0 1 0 A CURRENT DEVELOPMENTS 701 endrin. and hcplachlor in any sample consisting o f a homogenate of 25 or more whole fch of any species that is consumed by fish-eating birds and mammals, within the marine 96-hour LCS0 data for the appropriate organisms most sensitive to antimony. Concentrations o f antimony equal to or exceeding .2 mg/1 constitute a hazard. Data size range consumed by any bird or mammal, should be are not available for recommending a concentration which no greater than' five micrqgrams/kg of the wet weight. would present minimal risk o f deleterious effects. The concentration o f any chlorinated hydrocarbons, including lihdahe. chlordane. endosultan. mcthoxychlor, mirex. toxaphene. and hexachlorobenzcne, in any sample consisting o f a homogenate o f 25 or more whole fish of any species that is consumed by fish-eating birds and mammals, within the size range that is consumed by any bird or mammal, should be no greater titan 50 micro* grams/kg o f the wet weight. To reduce the incidence o f lead poisoning fresh water and marine waterfowl, NAS recommended that nontoxic shot be used or that no further lead shot be introduced into zones o f shot deposition if lead shot concentrations exceed one shot per., four square feet in the top two inches of sediment. NAS said the characteristics' of a receiving body o f water must be considered when evaluating the effects o f any pollutant upon the environment. An application factor o f .01 should be applied to marine 96-hour LC*o data for the appropriate oreanisms most sensitive to arsenic. Concentrations o f arsenic equal to or exceeding .05 mg'l constitute a hazard and concen trations less than .01 mg/1 present minimal risk o f deleter ious effects. An- application factor o f .05 should be applied to marine 96-hour LCJO data for the appropriate organisms most sensitive to barium. Concentrations of barium equal to or exceeding one mg/1 constitute a hazard and concen trations less than .5 mg/1 present minimal risk of deleter ious effects. An applicatiorv factor o f .0 1 -should be applied to marine 96-hour LCJ0 data for the appropriate organisms most sensitive to bery llium. Concentrations o f beryllium equal to or exceeding 1.5 mg/1 constitute a hazard and concentrations less than .1 mg/1 present minimal risk o f Mixing Zones deleterious effects. -- The report said that mixing zones should be considered Concentrations o f boron equal to or exceeding five on a case-by-case basis, because each proposed site in mg/1 constitute a hazard and concentrations less than five volves a unique set o f pertinent considerations. These mg/1 present minimal risk o f deleterious effects. An include the nature, quantity,. and concentration, o f ef application factor o f .1 was recommended for boron fluent material: the physical, chemical, and biological - compounds applied to marine 96-hour LCj0 data for sea characteristics o f the. mixing area and receiving waters; and the desired uses of .the .waten. However, ih^.qgademvV general recommendation was - that the total time-toxicity exposure history should not - water. Free bromine in the marine environment should not exceed .1 mg/1 and ionic bromine in the form o f bromate should not exceed- 100 mg/1. cause deleterious effects in affected populations of im portant species, inctoding:ihe post-exposure effects. An application factor o f .01 should be applied to marine 96-hour LCS0 data for appropriate organisms most Categories of Pollutants sensitive to cadmium. Concentrations of cadmium equal For temperature, NAS said the recommendations in cluded in the report on fresh water appear to be valid for estuarine and marine waters as well. However, additional studies arc needed on the temperature tolerances o f species directly involved. Inorganics The NAS recommendations for inorganic chemicals, including heavy metals and pH are as follows: The nomu! range of pH in either direction should not be extended by more than .2 units. Within the normal range, the pH should not \ary by more than .5 unit. Addition o f foreign -material should not drop the pH below 6.5 or raise it above S.5. to or exceeding .01 mg/1 constitute a hazard and concen trations less than .2 microgram per titer present minimal risk o f deleterious effects. In the presence o f copper and/or zinc at -one mg/1, the application factor for cadmium should be lower by at least one order o f magnitude. Cadmium criteria for aquatic life should also apply to wildlife. An application factor o f .1 should be applied to marine 96-hour LC<t0 data from sea water bioassays for the most sensitive species to be protected from chlorine. Free residual chlorine in sea water in excess o f .01 mg/1 can he hazardous to marine life. However, in the absence o f data, it is premature to advance recommendations. An application factor o f .01 should be applied to An application factor of .01 should be applied to marine 96-hour lethal 'concentration (LCU. nieJian) data - marine 96-hoiir LC,0 data for the appropnate organisms for the appropriate organisms most sensitive to aluminum. Concentrations of aluminum excccJing 1.5 milligrams per liter (mg.l) constitute a hazard and concentrations less than .2 mg/1 present minimal risk o f deleterious eifccts. An appiicarion factor of .1 houlJ be applied to marine most sensitive to chromium. Concentrations o f chromium equal to or exceeding .1 me;l constitute a hazard and concentrations less than .05 mg.'I present minimal risk o f deleterious effects. In oyster areas, concentrations should be maintained at less than .01 mg/1. 96-hour LC<,, data tor the appropriate organisms most An applieatiun factor o f .01 should be applied to sensitive to jtnmoma. Concentrations of un-toitcd am* marine `h'-liour LC0 data for the appropnjtc wrgahi.ms nuuiia equal to or exceeding .4 me I consiilute a hazard most sensitive to copper. Concentrations of copper equal and cnnccnlraiior.% l.-'S than 01 mg I present mmmu! risk to or exceeding .0* nig 1 constitute a hazard and vori.cn- o f dele tenons cirectv.*' tratious less than .01 n u e io g ta iu s per liter present iniim iu ! An application factor of .02 shouIJ be applied to risk o f deleterious effects. C o pyright i 1973 by T h * B urro w e l N otionol A d a ir , In c . 782125 NEL 000280 702 ENVIRO NM ENT REPORTER Cyanides .01)5 mg'l pu'wr.t minimal risk. if the pH is maintained An application factor uf.1 should be applied in iiurinc within j ran^. m`o.5 to S.5. LC\h daiJ lor .the appropriate oreanisriK nti^l Became pf the chronic effect o f long-term exposure of viiMlivc in cyjuiJc..Xauccmijiions..i>l evaniJe equal to fish to thallium, tests shoulj be conJuctcd for at least 20 i*r exceeding -D1 lu/qid and concent ra- dj>s im sensitive speeiev Techniques should measure tit't:'. L*>s ill .in .005 mg I present minimal nsk ofdeletcr- circulatory disturbances and other sublcthal effects. Con ii'U't vlfccts. __ .... . centrations equal to or exceeding .1 mg 1 constitute a An application fje^r.-uCil should be applied to marine hazard* and concent rations-less than .05 mg.1 present l,ifhitur LC*t) dal a -for -the; appropriate organisms most.. minimal risk. >.*iimlive to tiuoridc^ CVneerHJatiaus-of tlm*ride equal to An application factor o f :01 should be applied to or exceeding 1.5 mg'l constitute, a hazard and concent ra marine 9o*hour LCjo data for the appropriate organisms tions less than .5 mg.1 present minimal nsk of deleterious -most sensitive to uranium. Concentrations equal to or etiects. exceeding .5 mg. 1 constitute a hazard and concentrations Concentrations o f iron equal to or exceeding 3\m g'l less than .1 mg 1 present minimal risk. constitute a hazard -and. .concentrations less than .05 Concentrations o f vanadium in sea water should not `present minimal risk of-deleterious effects. .. exceed .05 o f the 96-hour LCj0 for the most sensitive Concentrations of-l,cad .in sea water should not exceed species. .02 o f the 96-hour LC,0;/or the' most sensitive species An application factor o f: .01 should be applied to and the 24-hour average' concentration should not exceed - marine 9o-houT LCS0 data for the appropriate organisms .01 or the 9o-hour'LCi 0 . Concentrations of lead equal to' most sensitive to zinc. Concentrations equal to or exceed or exceeding .05 mg/I .cqqsiituic, a Jtazard and concentra ing .1 mg/1 constitute a hazard and concentrations Jess tions less than .01 mg'l present .minimal risk of deleteri than .02 mg/1 present minimal risk. ous effects. Special efforts should be made to reduce lead Oil in Sea Water concentrations even further in oyster-crowing areas. NAS said no oil or petroleum products that can be An application factor of .02 of the 96-hour LCJ0 for detected as a visible film, sheen, or discoloration o f the the organisms most sensitive to manganese was recom surface, that can be detected by odor, that can cause mended. Concentrations o f .1' mg/I may.-.constitute a tainting of fish or edible invertebrates or damage the hazard and concentrations o f icss than .02 mg/1 present biota, or that can form "an oil deposit on the shores or minimal risk. lK 1 ' ''* * ............ bottom of the receiving body of water should be dis Concentrations of; mercury'equal to or exceeding .10 charged into estuarine or coastal waters. microcrams per `liter'constitute1'a -hazard. Recommenda ` Accidental releases -o f oil TO the marine environment tions established to protect aquatic'Iife and public w ater' /should be reclaimed or treated as expeditiously as possible supplies also shoiiltf'apply'to wildlife.1 using procedures at least equivalent to those provided in Concentrations of molybdenum in sea water should not ` ; the 1970 National Contingency Plan.- exceed .05 of the 96-hour'LCSo .for the most sensitive To protect marine wildlife, a monitoring program species and the 24-hour average should not exceed .02 of should follow long-term trends in petroleum tar accumula the 96-hour LCS0- tion in selected areas o f the oceans, no oil exploration or An application factor o f .02 should be applied to drilling should be permitted within existing or proposed 96-hour LCS0 data on the organisms most sensitive to sanctuaries, parks, reserves or other protected areas, and nickel. Concentrations of nickel in excess of .1 mg/I oil exploration or drilling should not be conducted in a would pose a hazard and'^ concentrations o f .002 mg/1 manner which could deleteriously affect species subject to would pose minimal risk. - - interstate or international agreements. An application factor- of .01 should be applied to To minimize damage to the marine biota, oil on the sea marine 96-hour LCi0 data"for die appropriate organisms surface should be contained by booms and recovered by most sensitive to elemental phosphorus. Concentrations use o f surface skimmers or similar techniques and oil on equal to or exceeding one micrograin per liter constitute a beaches should be mechanically removed using straw, peat hazard. moss, or other appropriate techniques that will produce An application factor of .01 should be applied to minimal adverse effects on the biota. In the event o f a marine 96-hour LCS0 data tor-appropriate organisms most tanker wreck, oil remaining in the hulk should be off sensitive to selenium. Concentrations equal to or exceed loaded , ing .01 mg/1 constitute -a hazard and conccntraiions less' Failing recovery o f ail from the sea surface or from a than .005 m rl present minimal "risk o f deleterious effects. wrecked tanker, efforts should be made to bum it in Concentrations of silver in marine water should not place. Dispersants o f minimal possihle toxicity should be exceed .05 o f the 96-hour LCJ0 for the most sensitive used only when necessary to avoid even greater hazard to species. Concentrations equal to or exceeding five micro- the environment. NAS did not recnmmcnJ sinking o f oil. crams per liter constitute a hazard and concentrations less NAS said the concentration o f radioisotopes in sea Ilian one microgram per lit-'r present minimal risk. water should be low enough so that the concentration in An application factor of .1 should be applied to marine any marine species will not exceed the Federal RaJiation 90-hour LC$o data for the appropriate organisms most Council's radiation protection guides for organisms har sensitive to sulfide. Concentrations equal to or exceeding vested for use as human food. This recommendation is .01 mg/1 constitute a hazard and concentrations less than based on the assumption that radiation concentrations. Environment Roportor NEL 000281 782126 CURRENT DEVELOPMENTS 703 which are acceptable as human food, will not injure Water Resources / /i ^ aquatic oiganisms. including wildlife. NAS REPORT URGES STRINGENT METHODS Sewage and Nutrient! TO CONTROL WASTE INPUTS, LAND DRAINAGE NAS said untreated or treated municipal sewage dis* More stringent methods to control and/or treat waste c h a fe s.should..bc~-recognized as a major source o f toxic inputs and land drainage should be applied to improve substances.- Recommendations for these pollutants will water quality as demand for use increases, according to limit the amount o f sewage eftiuent that can be dispersed the National Academy of Sciences' draft of "Water Quali into estuaries. Reduced degradation rates o f highly dis ty Criteria -- 1972.'' persed materials, should be considered if the effluent NAS said that another general recommendation, which contains refractory organic material. would apply to a wide variety of receiving systems and NAS said that while undegradable synthetic organic pollutants, is that consideration should be given to provid compounds do not cause oxygen depletion, they can ing reserve capacity in recognition o f the limitations of adversely affect an ecosystem. 5 peciHe quantitative water quality management programs. analyses should be done to identify and assess the Further, bioassays and other appropriate tests should abundance of these compounds. be made to obtain scientific evidence on the effect of The addition of any organic waste to the marine waste water discharges on the environment and a survey environment should be controlled to avoid decomposition of receiving systems should be made on a regular basis to which.would reduce the oxygen content of the water . assess the impact of discharges on the biological com below limits.recommended for oxygen. Further, neither munity. organic' matter nor fertilizers should be added that will induce production o f organic, matter by normal biota to an extent causing an increase in the size of any natural anoxic zone in the deeper waters o f an estuary. NAS said the natural ratios of available nitrogen to total phosphorus should be evaluated under each condi tion and the element actually limiting plant production . -should be determined.. Disposal of sludge into coastal waters should be ^recognized-as.a.temporary' practice, because such dumping can adversely, affect aquatic organisms. NAS said disposal o f organic'wasteV" into, the deep sea is not recommended until further studies on their fate, on their effect on fauna, and on the controllability o f such a procedure have been conducted. The study said that disposal of waste materials at sea should be controlled. Disposal should be permitted only when reasonable evidence is presented that tire proposed action will not seriously damage the marine biota, inter fere with fisheries operations or other uses o f the marine environment, or cause hazards to human health and welfare. ' Fresh Water Life NAS said that an essential objective of fresh water quality is the protection o f fish and other aquatic organ isms for sport or commercial harvesting. Although water quality characteristics in mixing zones can differ from those in receiving systems, to protect uses in both regions mixing zones should be free of materials which form objectionable deposits; floating debris, scum, oil and other matter; substances producing objectionable color, odor, taste, or turbidity; and conditions which produce objectionable growth of nuisance plants and animals. 1 NAS said mixing zone characteristics should be defined on a case-by-casc basis to avoid potential biological damage or interference with othet uses o f a receiving system. This action should be taken only after determina tion that the assimilative capacity of the receiving system can safely accommodate the discharges. To protect populations of nonmobile benthic and sessile organisms in mixing zones. NAS recommended that the area of their habitat exposed to water quality poorer than recommended receiving system quality be minimised Dredging by discharge design. An alternative would be to define In connection with dredging operations or other physical modification o f harbors and estuaries which intermittcm time exposure history relationships for the organisms* well-being. would increase the suspended sediment load, NAS made several recommendations. These included evaluation o f the range and types o f particles to be resuspended and To protect drifting and both weak and strong swim ming organisms in mixing zones. NAS recommended that scientifically valid data be developed to demonstrate that transported, where they will settle, and what substratum changes or modifications could be created by proposed die organisms can survive the integrated time expi'^ire history based on maximum expected residence time. activities in both the dredged and disposal areas. NAS said application factors should be incorporated NAS also recommended determination of the biological into bioassay extrapolation procedures to provide an activity o f the water column, the sediment-water inter adequate margin of safety when summations of short-term face, and the substrate material to depths which contain exposure arc developed. burrowing organisms; estimation of die potential release When two plumes arc contiguous or overlap and syn- into the water column of seaments; and establishment of the expected relationship between properties of the sus lernstic effects do not veur. NAS said aquatic life should be protected if the sum o f the fraciiiM.s of pended load and the permanent resident species of the integrated time exposure effects for each plume i: the area and their abi'.itv to repopttlare tire area and the total is equal to or le^ than .5. Alternatively, prut.*,, nil transitory species which use the arca only at certain seasons o f the year. should be provided if the sum of the tractions lor h >;li plumes is equal to or .levs than one. ol No"ono1Copyright C 1973 by T h * Bvri lne- N F .T n n m o ,, 7B2127 704________________________________________ _ ENVIRONMENT REPORTER If, however, summation effects of the integrated time For Uigli and moderate levels o f fish protection, NAS exposure history cannot be provided, a conservative, prescribed numerical formulas. tingle figure.eoncenti^liorTqbutd be used for ail parts.of a Total Dissolved Gases . -riuxingzanc.Lintil additional datais~pttDvidcd. ;"v _ ' L" NAS said-^lraliJRe JU*uLareaJof_a receiving system - assigned to mixing zones should be fimited to "that which will not interfere with..biological communities or popula* lions of important speefei/ or" will not *diminish-, other - beneficial uses disproportionately. It is not possible to make a single-value recommenda NAS'said available data for salmonid fish suggest that aquatic-life will be protected only when total dissolved gas pressure in water is no greater than 110 percent of the existing atmospheric pressure. NAS said any pro longed -artificial 'increase in total dissolved gas pressure should be avoided in view o f an incomplete body of tion on the percentage of river width necessary to allow passage of critical free-swimming and-drifting organisms information. Carbon Dioxide because of varying local physical and chemical conditions While the report did not include a specific recom and biological. phenomena, die report said: A guide, mendation for carbon dioxide, it stated that fish are able however, would be thaf.no more than two-thirds the to detect and respond to slight gradients and that many width-of a waterway should be devoted to mixing zones. avoid free carbon dioxide levels as low as one to six mg/1. NAS said.fish adopt to increases in carbon dioxide _t Biological Monitoring lexi'cls'tt-higb as .60 m g/l. However, concentrations of free NAS said a biological monitoring program is csse&tiahin carbon dioxide above 20 mg>'l rarely occur. determining synergistic or~-antagonistic'-interactions ofcomponents of waste discharges and resulting effects on living organisms. However, the report stressed, biological monitoring should not replace chemical and physical monitoring. The report said an ideal biological monitoring program consists of field surveys, in-plant biological monitoring, bioassays, and simulation techniques. . " PH NAS said that selection o f the amount o f protection afforded aquatic-life as regards pH is a socio-economic *-- decision rather than a biolocical one. For nearly maximum protection, NAS said. pH should be within the range of 6.5 and 8.5. There should be no change greater than 5 units above or below die estimated natural seasonal maximum. Dredging For high protection, pH should be within the range o f NAS said there are''-three basic-aspects which should be considered in evaluating the.' impact of dredging and disposal on the aquatic environment.--,/These- arc the six and' nine.: There should* be no change greater than .5 units outside the estimated natural seasonal maximum and minimum. The range o f pH for moderate protection is the amount and' nature" of the dredging/* the nature and - same, but NAS said no change greater than one unit quality of the environments of removal and'disposal, and outside the estimated natural seasonal maximum and the ecological responses. minimum should occur. Because all aspects vary widely in different environ For low protection, pH should be within a range o f 5.5 ments, NAS said it is not possible to identify an optimal and 9.S. No chance greater than 1.5 units outside die dreddug and disposal system. Hence, the most suitable estimated natural seasonal maximum and minimum should program should be developed for each situation. occur. Color The combined effect of color and turbidity should not change the compensation point more than 10 percent, from its seasonally established norm, the report said, nor should a chance place more, titan 10 percent of the 'biomass of pholosynthetic organisms below the compensa tion point. Suspended Solids NAS said aquatic communities should be protected if the following concentrations o f suspended solids exist: high level ol" protection - 25 milligrams per liter (m e'I), moderate protection - .'*0 nig t. low level of protection - 400 r.ig`1. and very low level o f protection - more Additional requirements for all degrees of protection are as follows: If a natural pH is outside the stated range o f pH for a given decree of protecticrvno further change is desirable. The extreme range o f pH fluctuation in any location should not be greater than two units. If natural fluctua tion exceeds this. pH should not be altered. The natural daily and seasonal patterns of pH variation should be maintained although the absolute values could be altered within the limits specified. The total alkalinity of water should not be decreased more than 25 percent below die natural concentrations. Dissolved Materials titan 400 mgT. NAS said total dissolved materials should not be Dissolved Oxygen NAS aid that lor nearly maximum protection of fish and other _,.;*:.utc life, the minimum d is h e d oxygen in any season should not he L*vi than the e-tin-icJ natural seaM<ii.il minimum concent ration clurocterotic. In olini.il* ing ii.rtur.il minima, H i%a-'mured llut water' jie vilur.iied uule'v -cieniiiic evidence indicates thev were lower in the changed to the extent that biological communities characteristic of particular habitats are significantly alter ed. When d:<M-|\cd materials arc chanced, the report said. bnu%suvs and field studio can determine concentrations w h iJi can be s teraied without endangering the structure ar.d fund ion of an aquatic system. Oil licence ot nun-nude inilucnces. NAS >aul aquatic life and wildlife di-ndd be protected A NEL 000283 Environr-**!! S'tpotf** 782128 CURRENT DEVELOPMENTS 705 where there is no visible oil on the water surface and where emulsified oils do not exceed .05 of the 96-hour lethal conccntrjticn (LC*o< median). Further, die concentration of hexane extractable sub stances in air-dried sediment should not increase abort 1,000 milligrams per kilograms on a dry weight basis. This statement does not apply to elemental sulfur. Tainting Concentrations of chemical compounds in water that can cause tainting of the flesh of fish and other aquatic organisms are as follows: Acetophenone -- 0.5 mg/1, acrylonitrile -- 18 mg/1, crescl - 0.07 mc/I, m-cresol - 0.2 mg/1. o-cresol - 0.4 mgU, and p-cresol --0.12 rr.cT. eresvlic acid (meta para) -- 0 2 mg/1, N-butylmereapian - 0.06 mg lV o-sec. butylphcnol - 0-5 mg/1, p-tert. butvlphenol -- 0.03 mg/1, o-chlorophenol - 0.0001 to 0.015 mg/1. and p-chlorophenol - 0.01 to 0.05 mg/1. Others are 2,3-dichlorophenol - 0.0S4 mg'l. 2.4 dich* lorophenol 0.001 to 0.014 mg/1, 2.5-dichIorophenol -- 0.023 mg/1, 2.6-dichlorophcnol - 0.035 m g/l, 2, methyl, 4-chlorophenol -- 0.075 mg/1, and 2, methyl, 6-chIoro* phenol - 0.003 mg/1, O-phcnylphcnoI - one mg/1, 2,4,6-trichlorophenol - 0.003 to 0.05 mg/1, phenol one to 10 mg/1. phenols in polluted river - 0.02 to 0.15 mg/1, diphenyl oxide -- 0.05 mg/1, and B.B-dichlorodiethvl ether --0.09 to 1.0 mg/1. O-dichlorobenzene -- 0.25 mg/1, ethylbenzene -- less than 0.25 m g/l. ethanethiol --0.24 mg/1, ethylaerylate -- 0.6 mg/1, formaldehyde -- 95 mg/1. and kerosensed -- 0.1 mg/1. Kerosene plus kaolin - one mg/1, isopropyl-benzene less than 0.25 mg/1, nephtha -- 0.1 mg/1, naphthalene -- one* mg/1 napluhol -- 0.5 mg/1, and 2-naphthol - 0.3 mg/1. Dimethylamine -- seven me/1, alpha-methvlstyrcne -- 0 2 5 mg/1, oil, cmulsifiablc - less than 15 mg/1, pyridine -- five to 2S mg/1, pyrocatcchol - 0.S to 5 m g'l, and pyrogallol -- 20 to 30 mg/1. Quinoline -- 0.5 to one mg/1, p-quinone - 0.5 mg/1, styrene --0.25 mg/1, toluene -- 0 2 5 mg-T, outboard motor fuel, as exhaust -- 2.6 gal/acre-foot. and ruaiacol - 0.0S2 mg/1. To prevent tainting of fish and oilier edible aquatic organisms, NAS recommended dial substances, which cause tainting, should not be present in water in concen trations that lower the acceptability of such organisms as determined by exposure bioassay and organoleptic tests. NAS said the former listing could be used as guidelines for' determining what concentrations of wastes and sub stances in water can cause tainting of the flesh of fish or other aquatic organisms. Temperature Criteria for temperature should consider both the multiple thermal requirements of aquatic species and requirements lor balanced communities, accnrJinc to NAS. The report said that currently definable requirements include maximum sustained temperatures that arc con sistent with maintaining desirable limits of productivity and maximum of metabolic acclimation to warm lemjvr.itmes that will permit return to ambient winter temperatures. H uiiilicul Sources of heat ceaie. Other requirements include temperature limitations for survival of brief exposures to temperature extremes and restricted temperature ranges for various stages of repro duction. Further, there should be thermal limits for diverse compositions o f species of aqu3tie communities and thermal requirements o f downstream aquatic life where upstream warming o f 3 cold-water source could adversely affect downstream temperature requirements. The report emphasized that thermal criteria must be formulated with knowledge of how man alters tempera- tures, the hydrodynamics of the changes, and how the biota can reasonably be expected to interact with the thermal regimes produced. NAS said important species should be protected if the maximum weekly average temperature during winter months does not exceed the acclimation temperature (minus a two C safety factor) that raises the lower lethal threshold temperature of such species above the normal ambient water temperatures for that season. Also, crite rion for short-term exposures should not be exceeded. The recommendation applies especially to locations where organisms could be attracted from the receiving water and subjected to rapid thermal drop, as in the'lcTw velocity areas of water diversions, canals, and mixing zones. Nuisance Organisms The report said there should be careful evaluation of all factors contributing to nuisance growths at any site before establishment of thermal limits. Temperature limits should be set in conjunction with restrictions on such other factors as eutrophication and nutrients. p Toxic Substances The NAS recommendations for various toxic substances are as follows: Selected species of fish and predatory aquatic organ isms should be protected, if the concentration of total mercury does not exceed a total body burden of .5 micrograms per cram wet weight in. any aquatic organism, if the total mercury concentrations in unfiltered water do not exceed 2 micrograms per liter at any time or place, and if the average total mercury concentration in unfiltcr- ed water does not exceed .05 micrcgrams per liter. Until a more detailed evaluation is made of toxicolod- cal effects of phthalatc esters on aquatic ecosystems, a safety factor of .1 was applied to data for " Daphnia magna" toxicity. Concentrations not exceeding .3 micro- grams per liter should protect fish and their food supply. The maximum concentration of total polychlorinated biphenyls in unfiltered water should not exceed .002 micrograms per liter at any time or place. Residues in the general body tissues of any aquatic organism sitout J not exceed .5 micrograms per cram. 7 co) "Metals O .S 'ff* The report said that water quality criteria for a given metal should be based on the total amount of it tn the water, regardless of the chemical state or form of the metal. Tins statement does nut cover settlcablc solids. The NAS recommendations are as follows: Careful examination of toxicity problems should be made to protect aquatic life in situations whe:e the Copyright C 1973 by Tho Bureau of National Affair, Inc. NEL 000284 /O'* 007 rrbJ 7R919Q 703 presence of tunic a]u:ttiniim is sti'pectod. Aluminum could luit* considerably greater toxicity than ha* been uxxumcd. Cadmium limits shnulj not exceed 0..' mg'I in water Inning total hardness above 100 me 1 as CaCO.i or .004 me I in waters with a hardness o f 100 mg/1 or below at a:i> lime or any place. Total chromium in water shunld not exceed .05 mg/I at any time or place. After a Qtchuur LCS0 has been detemtined using: the receiving water in question and die most sensitive impor tant species in the locality as the test organism. a safe concentration of copper can be estimated by multiplying the %-huur LC0 by an application factor o f . l . Concentrations of lead in water should not exceed .03 rng'l at any lime or place. After a 96-hour LCS0 has been determined, using the receiving water in question and the most sensitive impor tant species in the locality as the test organism, a safe concentration of zinc can be estimated by multiplying the 96-hour LC50 by an application factor of .005. Pesticides The NAS recommendations for pesticides are as fol lows: Organoehtonnes Aldrin - 0.01 micrograms/l, DDT -- 0.003 micro grams/1, TDE -- 0.007 micrograms/l, dieldrin -- 0.005 micrograms/1, chlordanc - 0.04 micrograms/l, cndosulfan -- 0.003 micrograms/l, endrin - 0.003 micrograms/1, heptaclilor -- 0.01 micrograms/l, lindane -- 0.02 micro grams/1, mcthoxychlor -- 0.01 micrograms/l, and toxaphene - 0.01 micrograms/l. Organophosphstes Azinphosmethyl -- 0.001 micrograms/l, ciodrin -- 0.1 micrograms/l, coumaphos -- 0.001 micrograms/l, diazinon -- 0.002 micrograms/l, dichlorovos -- 0.001 micro grams/1, dioxathion -- O.OS micrograms/l, disulfonton -- 0.05 micrograms/l, dursban - 0.001 micrograms/l, cthion - 0.02 micrograms/l, EPN -- 0.06 microerams/1, femhiun - 0.05 micrograms/l, malathion - 0.008 micro grams/1. Mevinphos - .002 micrograms/litcr, naled --.08 micro grans,T. oxydemeton methyl -- 3 micrograms/l, phos- phamidon - 0.3 micrograms/l, paraihion --0.001 micro grams/1. TEPP -- .4 micrograms/l, and trichlorophen -- .002 micrograms/l. Carbamates Carbaryl - .02 micrograms/l and zeetran - 0.1 micro grams/1. Herbicides Aminotriazolc - 300 micrograms/l, dalapon - 110 microcrams/1, dicamba - .2 micrograms/1. dichlobcnil -- 37 micrograms/l, dicldone -- .7 micrograms/l, diquat -- .5 micrognms/I, diuron -- 1.5 micrograms/l. 2-4,D (BEE) -- four inicrocrams/1. fenac (sodium salt) - 45 micro grams/1, silvex (BEE) -- two micrograms/l. silvex (PCBE) -- two micrograms/l, and siniazine - 10 micrograms/l. Botanical! Allethrin - .002 micrograms/l, pyrethrum -- .01 micrograms/l, and rotenone -- 10 micrograms/l. en vir o n m en t repo rter Tlie rccommendalions for residues in whole fish are: DHT - m e mg he: aldrin. dieldrin. endrin. heptaclilor, ehhudjue, lindane, bcn/enc hexachlonde. toxaphene, and cndosulfan - .1 mg. kg. either singly or in combination. Other Toxicants The NAS recommendations for oilier toxicants are as follows: After a 96-hour LCi0 has been determined using the receiving water in question and tlie most sensitive impor tant species in the locality as the test organism, a safe concentration of un-iuni/cd ammonia can be estimated by multiplying the 96-hour LC*o by an application factor of .05. However, concentrations should not exceed .02 ntc/l. Residual chlorine in the receiving system should not exceed .003 mgM at any time or place. Total residual chlorine should not exceed .05 mg-'l for a period o f up to 30 minutes in any 24-hour period. After a 96-hour LC$0 has jeen determined using the receiving water in question and the most sensitive impor tant species in the locality as the test organism, a safe ~concemration of free cyanide could be estimated by multiplying the 96-hour LCSo by an application factor of .05. Concentrations should not exceed .005 m&Tl at any time or place. After a 96-hour LCS0 has been determined using the receiving water in question and the most sensitive impor tant species in the locality as the test organism, a safe concentration of linear alkylate sulfonates can be estimated by multiplying the 96-hour LCS0 by an application factor o f .05. Concentrations should never exceed 2 mg/1 at any time or place. Safe concentrations of phenolic compounds can be estimated by multiplying the 96-hour LCSo by an applica tion factor of .05. Concentrations should never exceed .1 mg/1 at any time or place. Concentrations of total sulfides should not exceed .002 mg/1 at any time or place. Wildlife The NAS recommendations for protection of wildlife are as follows: Aquatic pianis of greatest value as food for waterfowl thrive best in waters with a summer pH range o f seven and 9.2. Salinity should be kept as close to natural conditions as possible. Rapid fluctuations should be minimized. Settleablc substances should be minimized in areas expected to support waterfowl. There should be no visible floating oD to protect waterfowl. Tlie total DDT concentration on a wet weight basis should be less than one mg/kg in any aquatic plant or animal. Body burdens of PCBs in birds and mammals should not be permitted to increase and monitoring programs should be instituted. Fish-eating birds should be protected, if mercury con centrations in fish do not exceed .5 micrograms per gram. The safety o f this recommendation should be re-evaluated as soon as posible. Rtporl 782130 NEL 000285 !/ Premature Births in California Sea Lions: Association with # High Organochlorine Pollutant Residue Levels Abstract. Premature pupping in California sea Hons has been noted on the breeding islands since 2968. Orgonochlorine pesticides and polychlorinated biphenyl residues were two to eight times higher in tissues o f premature parturient femcles and pups than in similar tissues of fulUterm parturient females and pups collected on San Miguel island in 1970. The California sea lion (Zalophus californianus califomianus) breeds on California's Channel Islands and on islands off the Pacific and G ulf coasts of Baja California. Mexico. In the Channel Islands normal pupping occurs between 15 May and 30 June and breeding between 20 June and 20 July. We have observed early termination of pregnancies among animals on several breeding rookeries,'including those on San Miguel Island, since- 196S. Prema ture births were reported by Simpson and Gilm anin (J) on San Miguel Island and by Odell (2) on San Nicolas Island, and were discussed by Brownell and LeBoeuf (5 ). An earlier investigationinto the causes of these premature births was inconclusive ( i ) . The work, reported here was conducted to deter mine whether environmental pollutant residues may be related to premature partus in the California sea lion. In the Channel Islands premature, births occur as early as January and ap pear with- increasing frequency until mid-May. We observed live premature pups from February through mid-May, and saw no pups which were dead at birth. The early pups are- not furredand appear to- die soon after birth. The premature pups bore in M arch, April, and early May a/e furred, but they lack motor coordination, their breathing is short, and only portions of the lungs have been aerated. Late premature pups appear to live from a few hours to possibly as long as several days. There is no apparent temporal break between the end of premature births and the onset of the normal pupping season. About 15 May the death rate decreases and some pups survive. In mid-May both live premature and full-term pups are present; full-term pups are easily distinguished as they have full motor coordination. The quantitative incidence of premature births has not been well established. On San Miguel Island wo courted 242 dead prc:ca2ure pups on 25 A pril 1970 and 34g on 18 M ay 1971 from an estimated total popula tion of 10,000 to 15,000. On San Nicolas Island, Odell (2 ) repotted 442 premature pups from a female popula tion of 5,500 between 17 January and 3 M ay 1970. In 1970 we collected two groups of postpartum female California sea lions within 24 hours after parturition on San Miguel Island. The premature parturient group of six females and their premature pups were collected be tween 20 and 24 A pril. The full-term parturient group of four females and their live pups were collected between 24 and 26 June, late in the normal pupping season. Ages of adult females were- deter mined by counting growth layers in the demine of Iongirc;l:r^i2y sectioned canines (4). The liver, brain, and blubber from cows and pups were ana lyzed for D D T compounds (p.p'-DDT, p.p'-DDD, and p .p '-D D E), dieldris, and polychlorinated biphenyls (PCB's) (5). Identification of PCB's was based on the characteristic profiles of peaks on the gas chromatograms ob tained with a DC-200 column; quanti fication was achieved through a com parison of the height of the peak emerg ing between the peaks for p.p'-DDD and p.p'-D DT with the height of the corresponding peak in chromatograms of the standard (ArocJor 1254, Mon santo C o .) (tf). Blubber and liver tissue from females were analyzed as they represent a storage and metabolism site for organochlorine residues. Brain tis sue from pups was analyzed to gain some insight into the behavior of the premature pups. Organochlorine pesti cide and PC B residues were found in all tissues collected and tested (Table 1 ). The most prevalent metabolite was found to be D D E (80 to 93 percent of. the total D D T ). A ll analyzed tissues front females which gave birth prematurely in 1970 contained higher concentrations than, the tissues from females which gave birth to full-term pups. The mean totaL D D T residues in the blubber and liver of premature parturient females were8.0 and 3.8 times greater, respectively,. than the concentrations in the same tissues of normal parturient cows. The brains of premature pups contained twice the residue concentrations as the brains of full-term pups. The PCB levels in blubber, liver, and brain of the premature parturient group were 6.6, 4.4, and 2.4 times higher than those in the full-term group. In neither blubber nor liver did the ranges of resi due values of total D D T or PC B in premature and full-term groups- over lap (Table 1 ). Dieldrin residues were not detected in all samples and when present, were low. Figure 1 is a histo gram of the D D T and PC B residues in the two groups of animals, showing the relative differences in tissue pollutant concentrations. Histological sections of liver tissue revealed normal tissues from all prema- NEL 000286 Table 1. Coocemrition of pollutant residues in tissues of parturient California sea lion females and pups, in pans per million (ppm ), v e t weight; ft, cumber of animals: X. mean of r%o (Praia, li*er) ana three i blubber) residue determinations on rash tissue of each acrm L The rasas is 6 to 12 >ean for premature parturient females and 10 to IS yean for full-term p a rtu rsat female*. Tbs numben in p a r theses are standard deviations. Tissue Blubber (female) L:-rr i (.-mule) Brur. (pu?| Clobber (female) Li-.rr (fimais Brain ir-?> Mean Fat ( y (years) Mean Haase DOT (total) X (p r m) Ranee (ppm) Premature 6 1W 77-87 S24.4 ( 167.8) 625-1039 3 S 1.7 1.3 25.24 (4.1) 22-30 6 3J 3---3.4 2.34(1.27) O .il-U J Full-term 4 12 S3 84-- 103.2 (60.7) 31-203 ' * -4 12 - 4.4 2.9 -5.3 6.67 (5.1) 2.4-13.6 4 4 8 4.6-3.1 1-0(1.10) 0.25-242 PCB'l X (ppm) Racxe (ppm) 112.4 (24.4) 5.74 0.451 0.43 (0 J2 ) 17.1 (6.1) U 2 (0 76) 0.19 (0.03) 85-MS 3 .^ .7 0.23-1.03 12-23 0.22-2 16 0.12 0.23 H U SCIENCE. VO t- l i t 782131 rure partus females except one. The served difference in organochlorine resi liver of this animal showed a few mid- due concentrations could be accounted zcoai foci of mononuclear and poly for by the premature parturient females morphonuclear cell infiltrates. These abnormal findings apparently are not sim ilar to histological changes in rats * organochlorine pesticide (7) or .ents fed PCB compounds (5 ). Sero logical analysis revealed no antibody titers to Leptospira species or Brucella abortus in the six cows of the prema ture parturient group. Bacteriological analysis of the uteri of this group yielded isolation of Escherichia coli from two of the six. Liver mercury residues (wet weight) is the three premature parturient fe males ranged from 38 to 64 parts per million (ppm) and in their pups ranged from 0.4 to 1.8 ppm. None of the tis n **$ 5 i L 21 l< ? 1 \I .1n X. 2 i !inn ! ! ! ! bum bMW D>M> Fig. 1. Histogram of mean concentrations of total DDT and PCB's in ttssrea of Cal ifornia sea lions delivering prematurely (cross-hatching) and at full term (stip pling). being collected 2 m rrifh* before the full-term females. Five sea lion females collected randomly from the San Miguel Island population in July 1969 had total D D T metabolite residues in the blubber ranging from 17 to 988 ppm (1 8 ), which indicates that some females can be expected to have high residues at any time of year and that a profile of the population probably ranges from animals with low to those with very high concentrations of organochlorine residues. Unfortunately, nothing is known about the fat dynamics in ges turing female sea lions or about changes in organochlorine residue storage de pendent on hormone cycles. Net mo sues from full-term animals were ana bffization of fat to meet increasing lyzed for mercury. energy demands would be expected to The difference between the concen have not been possible because of the increase residue levels in the blubber, trations of organochlorine pesticide and cost of maintaining, large breeding col yet we found that the full-term females PC B residues in the premature and onies of sea lions in captivity. However, had lower organochlorine residue con full-term groups- indicates a possible considering *h- magnitude of the differ- - centrations. .. cause and effect relationship between cnees in residue levels found in the two Robert L . D eL ono* high levels of these pollutants and early groups sampled from the wild popula Marine M am m al Division, termination of pregnancy in California tion, we feel that the possible cause and N ational M arine Fisheries Service, 'sea lions. High concentrations of or-- effect relationship cannot be.ignored . \ Seattle, Washington 98115 ganochiorine residues are implicated in A possible explanation for the differ W illia m G . G ilm akttn reproductive failure in ranch mink fed ence in pollutant residue levels in the John G . SiM w ont fish from Lake Michigan (9 ). Experi tissues from the two groups of sea N aval Undersea Center, mental feeding of PCB compounds has lions is utilization of differed, feeding, Bio~Systems Program, _i in shown to cause reproductive fail areas. It has loog been known that after San Diego,. California 92132 ure and death in -adult ranch mink the breeding season male California sea - {10). There is also experimental evi dence that p.p'-DDT induces premature parturition in rabbits ( i f ) . Some or ganochlorine insecticides - and'P C S compounds induce hepatic microsomal enzyme activity- resulting in increased metabolism of progesterone and estra diol in pigeon livers {12). Similar en zyme induction has been demonstrated in the rat (7 ). Definitive knowledge of the combined toxic or synergistic effects of organochlorine pesticides, PCB's, and mercury is lacking. LeBoeuf and Bonnell (13) reported high residue levels from three "apparently healthy1* female California sea lions collected in September 1970 at San Miguel Island. Apparent good health of the female does cot exclude a history of premature parturition. Since they did not report the reproductive histories of those ani mals, tt is impossible to relate their find ings to the premature parturition phenomena. The exact relationship of pollutants premature births and the mecha nisms involved cao only be elucidated through laboratory experiments. Such experiments with California sea lions lions'move northward. It is bilicved by some that many females of the Channel Islands population move south and win ter-in waten off-southern Baja Cali fornia {14), while a portion remain in the general art* of the Change1, Island*. O rg sn o ch lcrin ^ resfd u ss-u i-a-in aiin e crab ( /J ), marine fish (1 6), and the : brown pelican {17) are higher around Los Angeles, California, than in Baja California or in northern California. Thus, female sea lions wintering in the southern areas would be feeding on fish having smaller amounts of organochiorine pesutides and would therefore assimilate smaller quantities of the pesticides than females wintering in the Channel Islands area. The mean age of premature parturi ent females is less than that of fullterm females (Table 1), but the age ranees of the groups overlap. Because of the small sample sizes and the over lap in age ranges it is not possible at this time to relate the observed differ ence in organochlorine residues or the premature parturition phenomena to age. We think i: is unlikely that the ob I. J. G. Slmpao end W. O. GOsutio. Al S rinc* a*. 291 (1970). L D , K . Odali. la A oew dbu* e t tk* 7th A m im i Bteeenar end DtvOir M m d Conte*n w * (Stasfocd R cm reb legnate. M odo Park, CaiT. 1970). 3. R. L. S toraci! esd fi. J . ZnBotnC la Mio*. lotica! etiti- Octanerraptiieal Jurvev e t lAr Sante - C a ta re- C hm m i OH Spiti, J9ST-. 1970. D. StntiBhaa. Ed. (U oireniir of Southern California. Las Aayclce, 1971). voL L PP. 257-305. 4 V. B. ScU -r. Seienee I t i. 309 0950): X. M . L i r a Sature 109, 972 (1932). 3 n e DOT compound ra re p.a'-DDT (1,1.1- trlchlor2J-bit(cli)omihenrncihenc). P.VDDD [l.l-dlchlQr^aZ-btfp-chimphmTlktlfc. anc|, and p.p'-DDB II,l-djshlorZZ-biKp efaloropoetiylktbyteoel. The a n a l m for ih n e compound*, eieWrtn. aod PCD'i tre nuda b? th Wiieonain Allumi Research Foraci*, con. Madison, co rtin a to tur e a a d a ttu s e teetraque* tieni in: Food and O ra? Ao so , istnuoa. Fetneide A m ivnsat M arnai ( O r n i m n t of Health, Educano. and Wetfam, Wathiitfton. D C . WS--19*91. ol. 1, k m , lesi. 6. D. W. A d d erai. J. I. Hickrr. IL W. Kb, broufb. D, F. Huehev R. E. C utaB oeo. Con. F ltU Sarvr. U . 19 7. L. G. Harr and I. R, Forni ,Venirne, SeMmmJetteen Aie*i. C ip. fo tn o i. Fkwmmkei. Xl*. 4*6 imi. I. J. W. Mi"tr. Puh. Hrelt* Rrc. 9*. 1CBJ (19441. 9, R. J. Auirnch. R. K. Kaiser. II. 1_ S e a tn a . w - G. Youirt, Con. J. Zool. 49, < n M97|). 10. R. K. Resser, R. J. Aulenti), M. Z u.Jt. lo r-errrm ni rasers eri o r:ed m , Mih saucnal mrcuna of Lle A n r n c n Vherrical Stx:err. Dinuoa of U'm . Air. and Wicm G em iu rr. Ne V.iffc. ZS A n n a to t Se, teaoer 1V72. ro. 14^-154. It. M. M. Man. R. fi. Adamami, s. Fabro, d o * . Imi. F irn mmeom. Tker. 192, 3 1 ( 1971). 21 SEPTEMBER 1973 110 782132 N E L 000287 fi PRODUCT Q UALITY STA FF GENERAL ELECTRIC 1 RIVER ROAD. SCHENECTADY. N. Y. 12345 SUBJECT PCB and the CEQ D IA L( c o r.: r.i 8*235-2261 I COPIES: JF McAllister E L Simons October 22, 1973 Dr. A. Fozefsky Manager-Technology Planning Industrial Power Capacitor Products Dept. Hudson Falls, N. 7 Mr. E. L. Raab Manager-Dielectric Systems Laboratory /_J. Bldg. 11-315 Pittsfield, Mass. 01201 Warren Muir-CEQ Staff 202/382-6854 Mr. W. M. Nave Manager-Group Manufacturing Support Oper. Power Delivery Group 6901 Elmwood Avenue Philadelphia, Pa. 19142 Gentlemen: The Fourth Annual Report of the Council on Environmental Quality contains the following statement: "...EPA announced that it would reject water quality permit applications from any industry whose discharges raised ambient PCB levels in rivers and lakes to 0.01 or more parts per billion. 141" The footnote reference is to the Interdepartmental Task Force on PCB's, Polychlorinated Biphenyls and the Environment (1972). What the Task Force actually said is: Under a program of limitation on the sale of PCB's, the electrical industry will continue to be the principal user of PCB's; it, as well as industries now holding inventories of PCB's, have a special responsibility for monitoring and controlling their wastes. In this connection, the Environmental Protection Agency will restrict industrial liquid discharges of PCB's from PCB users. To keep levels in fish as low as possible, and in any case below FDA's interim action level of 5 parts per million, concentrations in rivers or lakes from all sources should not exceed 0.01 parts per billion." I believe any reasonable person will agree that these are not equivalent statements. EPA has not made the statement attributed to it in the CEQ report, in the Task Force report or anywhere else, to our knowledge; furthermore, they are now considering what action to take with respect to PCB limits under the NEL 000289 782134 GENERALO ELECTRIC 2- Federal Hacer Pollution Control AcC. I discussed che discrepancy with Ed Simons, and he called Terry Davies, formerly with CEQ and now with Resources for the Future, Inc, Davies apologized for the error, saying he had had an opportunity to review this material, but failed to catch it. He suggested we talk to Mr. Warren Muir of the CEQ staff. I called Mr. Muir oh 9/28 and he readily agreed that an error had been committed. He said he himself had not made the final editorial changes, and he didn't know who had...that there was no attempt to "break new ground." We discussed the possibility of a press release from CEQ to correct the impression given by the report, but agreed that such action would merely call undue attention to the situation. He apologized, and expressed assurance that the_ statement would not influence the current deliberations within EFA. Very truly yours, JSN:ev james S. Nelson, ConsultantProduct Environmental Compatibility NEL 000290 782135 6 PRODUCT QUALITY STAFF 1 RIVER ROAD. SCHENECTADY, H. Y. 12345 SUBJECT p ] A 'L I f ' * '* C U M 8*235-2261 j MONTHLY ACTIVITIES REPORT James S. Nelson__________ COPIES: F. S. Rothe November I, 1973 Mr. J. F. McAllister NEW YORK IV-PRODUCT ENVIRONMENTAL COMPATIBILITY 1. EPA Toxic Pollutant Regulations As noted previously (June, July letters) mercury, cadmium, and PCB are among the materials identified by EPA as ntoxic pollutants". EPA is to publish effluent limits from point sources on December 3. It has been learned that EPA Water Programs Office is seeking input from industry as to the cost of meeting various emission standards which might be proposed for PCB and that the Water Quality Advisory Committee is seeking a statement on the economic impact of a standard which would be tantamount to a ban. In cooperation with Monsanto and concerned GE operating components, the proper way to exploit this opportunity is being sought,' with the end in view of influencing the forthcoming guideline away from the politically expedient (but environmentally unjustified) zero effluent standard. 2. Pyranol Transformer Task Force Two meetings of the Pyranol Transformer Task Force were attended. Progress was reported on the assessment of liabilities associated with continued participation in this business. Final reconznendations will be affected by the outcome of the work reported above, among other factors. REDACTED N E L 000291 Very 'truly yours TQO-iQC fyr a n o l tr a n sfo rm ers DISTR. TRANSF. PROD. DEPT. Pole & Station Network Precip. Pwr. Supp. Instr. Transf. 3 0 Pad 1 0 Pad Total PCB Content at 45% Units Shipped 1971 1972 1973E 377 300 280 186 179 200 170 370 549 000 131 110 50 5 4 ___ 2 869 963 1081 Gallons of Transformer Fluid in Shipments 1971 1972 1973E 15 080 67 890 20 400 0 26 200 425 129 995 58 498 12 000 65 335 44 400 0 22 000 340 144 075 64 834 11 200 73 000 65 880 -0 10 000 170 160 250 72 113 POWER TRANSF. PROD. DEPT. Furnace Rectifier (ind. 3d Rail) M-U Car Locomotive Total PCB Content at 45% 200 27 13 10 2 40 120 000 31 53 130 1 200 16 2Q0 260 0 17 660 7 947 0 7 800 5 200 0 13 000 5 850 0 6 000 15 600 0 21 600 9 720 F MD. TRANSF. PROD. DEPT. Secondary Substation Master Unit Sub. Primary Sub. Limit-Amp Sub. Total PCB Content at 55% DIVISION TOTAL Total PCB Content in Transformers Shipped 836 812 757 29 26 15 61 123 98 89 3 935 969 864 1835 1985 2075 179 740 26 100 18 605 3 015 227 460 125 103 174 580 19 500 37 515 6 000 237 595 130 677 162 755 13 500 80 100 795 257 150 141 433 375 115 394 670 439 000 191 548 201 361 223 266 NEL 000292 J. 5. Nelson October 4, 1973 782137 PRODUCT Q UALITY STA FF I RIVER ROAD, SCHENECTADY. N. Y. 12345 SUBJECT DIAL c o :r-i 8*235-2261 1 COPIES: J. F. McAllister - NEW YORK W. Fessler - PITTSFIELD W. M. Nave - PHILADELPHIA November 15, 1973 Dr. R. C. Osthoff Manager-Insulation Systems Laboratory Operation Group Technical Resources Operation 100 Wood lawn Avenue Pittsfield, Mass. 01201 Dear Dr. Osthoff: During our meeting on November 7 in your office, when we were discussing candidate materials as possible transformer liquids, the subject of environmental screening and evaluation was raised. Some indication of a minimal screening program which might be acceptable to EPA in some circumstances is contained in the attached letter from G. H. Baise of the EPA to Senator Tunney. This letter, though undated, was apparently written in April or May of this year and is reproduced from the report of the Senate Committee on Commerce on S. 426, Toxic Substances Control Act of 1973. As I interpret it, a procedure such as described in the letter would be applicable to the general situation where there was no reason to expect adverse environmental impact. More extensive (and more expensive) procedures would be required of materials noted for persistence in the environment or toxicity. We should also bear in mind that the statements in Baisefs letter are in no way binding upon EPA. Very truly yours, JSN:ev Enclosure James S. Nelson, ConsultantProduct Environmental Compatibility 2! r ooo to VO 782138 64 Hon. J ohn V. Trorairr UJS. Senatej Washington, D.C. Deab Senator T enney : I am writing in response to your letter of April 18,1973 to Administrator William D. Buckelshaus. Your letter referred to a ``catch-all" procedure which might be used with respect to testing new chemical substances whose hazards cannot be predicted, and asked for our estimates of the types of information that might be required to be submitted under such a procedure and the costs of developing this information. I should..preface my response by indicating that we have not yet determined with any firmness the situations under which a sort of "catch-all" or residual set of information requirements would be im posed. There will be chemicals, perhaps many, that will not warrant any statutory testing at all. We intend to administer the Toxic Sub stances Control Act selectively, with attention to the types of tests and information suitable to require of the manufacturer and for us to review for different chemicals and chemical groups. Principal focus, will be on those that appear to have the greatest potential for harm. Thus, we cannot say at this time whether a "catch-all" procedure would be a suitable adjunct to other testing requirements, and when and under what circumstances it should be used. I can, however, provide you wtih an example of the sorts of basic information and testing that might be comprised in a "catch-all" re quirement, and the costs of acquiring the information: (a) Physical-chemical properties and chemical stability. This cate gory would include melting point; boiling point; vapor pressure; solubility and partition coefficients in water and non-polar solvent; specific gravity; pH in solution; COD; BOD; and acid, base and thermal stability. Estimated cost: $500 or less. (b) Thirty-day toxicity test in two species. This would be a short term, sub-chronic toxicity test to provide an indication of the capabil ity of the chemical to produce cumulative toxic effects. Estimated cost: $2,400. I would like to add a comment We would anticipate that most if not all of the information in item (a) would currently be required and obtained by a manufacturer of a new chemical in any case. I t would also be likely that a manufacturer of a new chemical would conduct the sub-chronic toxicity test identified in item (b), though this is less common practice. In effect. we would expect that a large part of this work, if not all of it, would be done in the absence of any legal require ment under the Toxic Substances Control Act. The less-than-S3.000 total figure for testing would thus not represent additional costs. I trust the foregoing information is useful and responsive to your request. Please let us know if we can be of further assistance. Sincerely yours, Gary H. Baise, Director, Office o f LeyielatiorL o I I II I ft -J NEL 000294 782139 GEHEALC ELECTRIC GENERAL ELECTRIC COMPANY, ONE* Rl'VER ROAO, SCHENECTADY, NEW YORK '12345 \ Phono (518) 374-2211 REAL ESTATE AND CONS TRUCTI ON OPERATION November 21, 1973 Dr. C. Hugh Thompson, Chairman Hazardous and Toxic Substance Regulation Task Force O ffice o f Water Program Operations Environmental P ro te c tio n Agency W ashington, D.C. 20460 SUBJECT: COMMENTS ON TOXIC POLLUTANT EFFLUENT STANDARDS (38 FR 2 1 3 4 2 , S e p t . 7 , 1973) Dear Dr. Thompson: In the above Federal R egister announcement, th e Environmental P r o t e c t i o n Agency i n v i t e d comments t h a t m i g h t a s s i s t a i t `in . s e t t i n g ....... *= e f f l u e n t s ta n d a r d s f o r t h e p o l l u t a n t s on EPA's f i r s t l i s t ^ u f -to x ic .-H : . p o l l u t a n t s . On b e h a l f o f t h e General* E l e c t r i c Company, I am p l e a s e d t o s u b m it f o r y o u r c o n s i d e r a t i o n t h e f o l l o w i n g comments t h a t we b e l i e v e are relevant to the establishm ent of efflu en t standards fo r polychlorinated b ip h e n y ls (PCBs). The G eneral E l e c t r i c Company i s a m a jo r m a n u f a c tu r e r o f s e a l e d c a p a c i t o r s a n d t r a n s f o r m e r s t h a t i n c o r p o r a t e PCBs a s i n s u l a t i n g liq u id s . COMMENTS In p r o m u l g a t i n g i t s l i s t o f t o x i c p o l l u t a n t s , EPA s t a t e d t h a t " P o ly c h lo rin a te d b ip h e n y ls are on th e l i s t b ecause o f t h e i r h ich o rd e r o f t o x i c i t y t o man and a q u a t i c o r c a n i s n s , and b e c a u s e o f t h e i r b i o a c c u m u la t iv e p o t e n t i a l . The d aca a r e a d e q u a t e ,. and t h e p o i n t s o u r c e discharges req u ire prompt c o n tro l." (underlinings added! In an e a r l i e r s e c tio n o f t h is sam e.prom ulgation ( I , 3 ) , which explains the c rite ria of to x ic ity , appears the statem ent th at "substances w hich h a v e an o r a l LD50 o f 50 m g/kg o f body w e i g h t o r l e s s . . . a r e d e f i n e d as h ig h ly t o x i c t o mammals . This d e f in itio n would seem to exclude PCBs, b e c a u s e th e LDSO's o f a l l com m ercial p r e p a r a t i o n s a r e many t im e s , g r e a te r , t h a t o f a ty p ic a l m a te ria l (A roclor 1242) being 8650 mg/kg L U . ^ ) P C B s and t h e E n v i r o n m e n t, I n t e r d e p a r t m e n t a l T a s k F o r c e on PCBs. Mav 1 9 7 2 . P.13Y. srvi'G PROGRESS 782140 NEL 000295 ' I: GENERAL O ELECTRIC Dr. C. Hugh Thompson -2- November 2 1 1 9 7 3 The low o r d e r o f t o x i c i t y t o man i s s u p p o r t e d by s e v e r a l d e c a d e s o f e x p e rie n c e in the- U.S,, e l e c t r i c a l i n d u s t r y . . . In a d d i t i o n , t h e f o r e g o i n g s t a t e m e n t s a b o u t PCBs q u o t e d fro m th e prom ulgation re c e iv e l i t t l e su p p o rt from EPA's subsequent p u b lic a tio n in October o f i t s ^"Proposed C r ite r ia fo r Water Q u ality - Vol. These c r i t e r i a "are defined as th e acceptable lim its of c o n stitu e n ts in r e c e iv in g w a te rs based upon an e v a lu a tio n o f t h e l a t e s t s c i e n t i f i c inform ation by the Environmental P ro te c tio n Agency" (p. 12) and "are based upon c u rre n t knowledge of th e e f f e c t s on h e a lth and w e lfa re of the presence of various p o llu tan ts in receiving w aters" (p. 18). C r i t e r i a f o r PCBs a r e d i s c u s s e d u n d e r f o u r c a t e g o r i e s o f w a t e r u s e (pages 121, 180, 224, and 320) along w ith the ra tio n a le f o r th e recommended l i m i t s . None o f t h e s e d i s c u s s i o n s s u g g e st? b i o l o g i c a l e f f e c t s t h a t c o u ld be d e s c r i b e d as a " h ig h o r d e r o f t o x i c i t y t o man and a q u a tic organism s"; most o f the r a tio n a le s re p re se n t f a r from "adequate" d a ta ; and none of them leads to th e conclusion th a t "p o in t source discharges req u ire prompt c o n tro l." - The o n ly n u m e ric a l v a l u e s u g g e s t e d i s a maximum a c c e p t a b l e c o n c e n t r a t i o n o f PCBs i n f r e s h w a t e r o f 0 .0 0 2 / f g /1 ( 0 . 0 0 2 p p b ) ( p . 1 2 1 ) The r a t i o n a l e giv en f o r t h i s le v e l i s b ased upon an e x c e e d in g ly ten u o u s c h a i n o f r e a s o n i n g b e g i n n i n g w i t h a PCB r e s i d u e l e v e l t h a t h a s b e e n suggested (not dem onstrated) as th e th re s h o ld fo r salmon egg m o rta lity and con tin u in g through sev eral o th e r vaguely d e fin e d m u ltip lic a tiv e f a c to r s . F u rth e r, t h i s number has ho o p e ra tio n a l s ig n if ic a n c e because no a n a ly tic a l techniques are a v a ila b le fo r th e r e lia b le d eterm ination o f s o low a c o n c e n t r a t i o n o f PCBs i n w a t e r . S ectio n 304 (a) (1) of The Federal Water P o llu tio n Control Act Amendments o f 1972 r e q u i r e s t h a t c r i t e r i a f o r w a te r q u a l i t y s h o u ld a c c u ra te ly r e f l e c t th e l a t e s t s c i e n t i f i c knowledge "on th e kind and e x t e n t o f a l l i d e n t i f i a b l e e f f e c t s on h e a l t h and w e l f a r e . . . w hich may be expected from th e presence of p o llu ta n ts in any body of w ater . . . " . We s u b m i t t h a t none o f t h e w a t e r q u a l i t y c r i t e r i a p r o p o s e d f o r PCBs, which presum ably r e f l e c t th e l a t e s t s c i e n t i f i c know ledge, p ro v id e s an a d e q u a te b a s i s f o r e s t a b l i s h i n g e f f l u e n t s ta n d a r d s f o r PCBs. O th er b a s e s t h a n w a t e r q u a l i t y s h o u ld be u s e d and a r e d i s c u s s e d l a t e r on i n th is l e t t e r . In our o p in io n , however, the recommendation th a t "the body burdens o f PCB's in b i r d s and mammals s h o u ld n o t be i n c r e a s e d o v e r p r e s e n t levels in order to m aintain acceptable lev e ls" does rep resen t a reasonable g o a l f o r any PCB c o n t r o l p ro g ra m ( R e f . 2 , p . 1 8 0 ) . The Proposed C r ite r ia f o r V/ater Q u a lity acknowledge (Ref. 2 , pp 17*18) th a t o th er considerations are im portant in "estab lish in g p a rtic u la r s t a n d a r d s and c o n t r o l m e a s u re s " f o r p o l l u t a n t s t h a t "may be l i s t e d as to x ic p o llu ta n ts under su b se c tio n 307 ( a ) ." ^ Proposed C rite ria fo r Water Q u a lity , Vol. I , U.S. Environmental P ro te c tio n Agency, October 1S73. NEL 000296 782141 GENERAL O ELECTRIC Dr. C. Hugh Thompson -3- November 21, 1973 "Some o f t h e more i m p o r t a n t c o n s i d e r a t i o n s a r e : (1) The n a tu re o f th e environm ental e f f e c t o f th e presence of p o llu ta n ts in w ater ( e .g .t long or sh o rt term , temporary or permanent, lo calized or w idespread, e tc .) . (2) The economic a n d -s o c ia l im pact o f th e s ta n d a rd s and c o n tro l m easures and th e im pact o f th e environm ental damage to be a lle v ia te d . (3) The p r a c t ic a li t y and e n f o r c e a b ility o f th e stan d ard s and c o n tro l m easures, in c lu d in g th e a v a i l a b i l i t y of tech n iq u es and instrum entation fo r determ ining whether p a rtic u la r standards are being m et." R e g a rd in g t h e t h i r d c o n s i d e r a t i o n , we have a l r e a d y i n d i c a t e d t h a t th e re is no p r a c tic a l method o f e n fo rc in g a sta n d a rd based upon t h e recommended maximum c o n c e n t r a t i o n o f 0 .0 0 2 ppb o f PCBs f o r f r e s h w ater. The f o ll o w i n g a d d i t i o n a l p o i n t s , w hich we b e l i e v e s h o u ld be considered in e s ta b lis h in g e f f l u e n t sta n d a rd s f o r PCBs, a re germane to the o th er two c o n sid e ra tio n s. (1 ) In 1971 t h e Monsanto Company ( t h e s o l e U.S. p r o d u c e r o f PCBs) be g a n a p ro g ra m t h a t h a s l e d t o a t o t a l ban on s a l e s o f PCBs fo r a ll uses except the m anufacture o f sealed e le c tr ic a l equipment ( c a p a c i t o r s a nd t r a n s f o r m e r s ) . As a r e s u l t t h e r e h a s b een a l a r g e d ecrease in th e number o f p o in t so u rc e d is c h a rg e s o f PCBs. Since t h e r e a r e p r o b a b l y n o t m ore t h a n 25 m a j o r u s e r s o f PCBs t h r o u g h o u t t h e c o u n t r y , c u r r e n t p r o d u c t i o n - t y p e d i s c h a r g e s o f PCBs a r e no l o n g e r a s u b i q u i t o u s a s when PCBs w e re a c o m ponent o f p a i n t s , i n k s , p l a s t i c s , adhesives, t e x t i l e c o a tin g s, h y d rau lic and h eat tr a n s f e r f lu i d s , e tc . In d ee d , " p r o d u c tio n and s a l e s f i g u r e s f o r PC3s in 1971 w ere ro u g h ly h a lf of th o se f o r 1970, when th e s e volumes were a t t h e i r peak . . . ( a n d ) p r o je c tio n s f o r 1972 i n d ic a te an even lower volume " (R ef. 1 , pp. 5 -1 0 ). Thus,, even a p a rt from th e in tro d u c tio n of improved control measures by p re s e n t PCB-users, th e r e has been a m ajor decrease in th e amount o f PCBs t o w hich t h e e n v i r o n m e n t can p o s s i b l y be e x p o s e d . A lth o u g h c u r r e n t PCB d i s c h a r g e s can and s h o u l d be more c a r e f u l l y c o n t r o l l e d , t h e s itu a tio n is one whose m agnitude is d e c re a sin g . There i s , th e r e f o r e , no need f o r em ergency-type c o n tr o ls , which m ight be r e f l e c t e d in te c h n ic a lly in fe a s ib le standards and compliance schedules. NEL 000297 782142 QG E N E R A L E L E C T R I C Dr. C. Hugh Thompson -4- November 21 1973 ( 2 ) PCBs a r e n o t a u n i q u e c h e m ic a l s p e c i e s : . More th a n -,1 0 0 isom ers a r e p o s s i b l e , and m a jo r commercial p ro d u c ts may c o n t a i n 'a s many a s 18 d i s t i n c t com pounds. As p o i n t e d o u t by t h e I n t e r d e p a r t m e n t a l Task F o rce on PCBs: "Full evaluation of actual or p o ten tia l e ffe c ts in the environm ent is hampered by th e complex n a tu re o f th e m ix tu re s t h a t compose PCBs, and by th e i n c l u s io n o f c o n t a m i n a n t s i n t h e s e m i x t u r e s . As e x p e r i m e n t a l s t u d i e s have been conducted w ith the u n altered p ro d u cts, as so ld , t h e r e s u l t s may n o t p r o p e r l y r e f l e c t t h e e f f e c t s o f t h e components as they e x is t in th e environm ent." (Ref. 1 , p. 19). F urtherm ore, i t was re p o rte d to th e In te rd e p a rtm e n ta l Task Force " . . . t h a t a l l PCB p r o d u c t s c a n n o t be lum ped t o g e t h e r i n t e r m s o f e ith e r th e ir environmental impact o r p e rsiste n c e ." O th er p o i n ts made in t h i s r e p o r t t o t h e Task Force a r e : ( 1 ) As t h e d e g r e e o f c h l o r i n a t i o n ( o f PCBs) d e c r e a s e s , t h e b acterial degradation rate increases. (Ref. 3, p. 4 ). (2) The re s id u e s to r a g e l e v e l s (in a lb in o r a t s ) d e c re a se exponentially as the weight percent chlorine decreases. (Ref. 3, p. 6) ( 3 ) PCB r e s i d u e s f o u n d i n w i l d l i f e a r e d o m i n a n t l y p e n t a - , h e x a -, h e p ta -, and o c ta - chloro b ip h en y ls. (R ef. 3 , Chart 4 ). In r e c e n t y e a r s t h e M onsanto Company has d e v e lo p e d a s p e c i a l p r o d u c t , A r o c lo r 1016, which i s t h e o n ly g r a d e o f A r o c lo r now u se d i n c a p ac ito r m anufacture. Although i t s gross ch lo rin e co n ten t is alm ost th e same a s t h a t o f A ro c lo r 1242 ( i . e . a b o u t 42 o f C l ) , A ro c lo r 1016 has been s p e c ia lly d i s t i l l e d to remove most o f th e h ig h er b o ilin g homologs, which a re found in w ild l i f e r e s id u e s . In d eed , more than 99* o f A ro c lo r 1016 ccm prises homologs w ith 4 o r l e s s c h lo r in e atoms p er biphenyl (Ref. 3, Chart 1 ); and th ese homologs have not been found in w ild l if e residues. In l i g h t o f t h e f o r e g o i n g we recommend t h a t t h e s p e c i f i c c o m m e rc ial p r e p a r a t i o n , A r o c l o r 1 0 1 6 , n o t be c o n s i d e r e d a s a t o x i c p o l l u t a n t . We are encouraged to see th a t in promulgating i ts l i s t of to x ic p o llu ta n ts, EPAhas re c o g n iz e d t h a t not a l l compounds o f cadmium and cyanide a re to x ic and has s t a t e d t h a t d i s t i n c t i o n s w ill be made when th e f i n a l w Tucker, E .S ., "Assessment of the B iological P ersisten ce o f P o lychlorinated B i p h e n y l s , " fro m P r e s e n t a t i o n t o t h e I n t e r d e p a r t m e n t a l T ask F o r c e on PCBs by M onsanto Company, May 15, 1972, p. 2 . NEL 000298 782143 GENERAL ELECTRIC Dr. C. Hugh Thompson -5- November 21, 1973 e f f l u e n t s t a n d a r d s a r e p u b l i s h e d . We recommend t h a t s i m i l a r d i s t i n c t i o n s be made i n w r i t i n g e f f l u e n t s ta n d a r d s f o r PCBs. (3) The "economic and s o c ia l im pact" ( c o n s id e ra tio n number 2) o f a un ifo rm e f f l u e n t s ta n d a r d would be much more s e v e r e uoon an e x i s t i n g p l a n t th a n upon a new D ia n t. Most o f th e e x i s t i n g p l a n t s t h a t m an u factu re s e a l e d e l e c t r i c a l e q u ip m e n t c o n t a i n i n g PCBs w e re i n o p e r a t i o n f o r many y e a r s b e fo r e t h e r e was any r e c o g n i ti o n o f th e p o s s i b l e e n v iro n m en ta l hazard s o f PCBs, and during th e s e y e a rs no s p e c ia l p re c a u tio n s were taken concerning the handling and disposal o f th e se liq u id s . Thus, a c c u m u l a t i o n s o f PCBs o v e r t h e y e a r s i n and a r o u n d t h e d r a i n a g e s y s te m s o f t h e s e p l a n t s c o u l d r e s u l t i n c o n t i n u e d d i s c h a r g e o f PCBs e v e n i f t h e p l a n t s w e re t o e l i m i n a t e PCBs fro m t h e i r c u r r e n t o p e r a t i o n s . E l i m i n a t i o n o f su c h r e s e r v o i r s o f PCBs m ig h t w e l l r e q u i r e a m a j o r and p r o h i b i t i v e l y e x p e n s i v e r e n o v a t i o n o f p l a n t and s i t e . H ow ever, w i t h t h e i n s t i t u t i o n of~ in te rn a l c o n tro l measures such as d e scrib ed in proposed American N ational _ Standard G uidelines W , o ld er p lan ts are preventing fu rth e r build-up of such re se rv o irs. WHAT EFFLUENT STANDARDS ARE FEASIBLE FDR THE ELECTRICAL MANUFACTURING INDUSTRY? We h a v e a l r e a d y n o t e d t h a t t h e M onsanto Company now s e l l s PCBs o n l y t o m a n u f a c tu r e r s o f s e a l e d e l e c t r i c a l e q u ip m e n t, su c h as c a p a c i t o r s anB tra n s fo r m e r s . The soundness o f t h i s d e c is io n i s su p p o rte d by th e f in d in g s o f t h e I n t e r d e p a r t m e n t a l Task F o rc e on PCBs ( R e f . 1 , p . 4 ) a nd t h e r e g u l a t i o n s p r o m u l g a te d by t h e Food and Drug A d m i n i s t r a t i o n (3 8 FR 1 8 0 9 6 , J u l y 6 , 1 9 7 3 ) . These documents recognize th e unique com bination o f f i r e s a fe ty and design e f f i c i e n c y t h a t t h e u s e o f PCBs i m p a r t s t o c a p a c i t o r s a nd t r a n s f o r m e r s and th e minimal ris k o f environm ental contam ination a s so c ia te d w ith such u se. We b e l i e v e t h a t t h e s p e c i a l c o n d i t i o n s p e r t a i n i n g t o t h e p a s t and p r e s e n t u s e o f PCBs i n t h e e l e c t r i c a l i n d u s t r y w a r r a n t r e c o g n i t i o n i n t h e s e ttin g o f e ff lu e n t discharge sta n d a rd s. These should not n e c e s s a rily be id e n t ic a l t o th o se deemed a p p ro p r ia te f o r th e chem ical i n d u s tr y . The m anufacture o f tra n sfo rm e rs and c a p a c ito rs in v o lv es a m u lt ip l ic i ty o f o p e ra tio n s in c lu d in g vacuum im p reg n atio n , h e a t tre a tm e n t, f i l l i n g , s e a l i n g , w ashing o p e ra tio n s and th e l i k e . P r o v is io n m ust be made f o r th e handling o f la r g e a p p a ra tu s c o n ta in in g up to 1500 g a l l o n s / u n i t (in th e ca se of tran sfo rm ers) and fo r the f i l l i n g and se a lin g of m illio n s o f sm all u n its per year (in the case of cap acito rs). C o n t r o l o f PCB d i s c h a r g e s i n s u c h e l e c t r i c a l m a n u f a c t u r i n g p l a n t s re q u ire s a com bination of process design and good housekeeping. For exam ple, w a ste l i n e s and o p e r a t in g p ro c e d u re s may be d e s ig n e d t o e l i m i n a t e c o n t a c t b e tw e e n PCBs and w a t e r n o t d i r e c t l y u s e d i n t h e PCB o p e r a t i o n s t h e m s e l v e s ( e . g . c o o l i n g w a t e r ) . No e f f e c t i v e e n d - o f - l i n e t r e a t m e n t h a s b e e n dem onstrated on a p la n t s c a l e . t 4 ) O ffic ia l Standards P roposal. Proposed American N ational Standard G uidelines fo r Handling and CiSDosal o f C ap acito r- and T ransform er-G rade A skarels Containing P olychlorinated B iphenyls, C107.1- ( ), National E lectrical M a n u fa c tu re rs A s s o c ia tio n Pub. No. CP-P1-1973 and Pub. No. TR-PG-1973, January 25, 1973. 782144 N E L 000299 GENERAL 0 ELECTRIC Dr. C. Hugh Thompson - 6 - November 21, 1973 Segregation of operations and waste lin e s is fe a s ib le in the d e sig n .and c o n s t r u c t i o n o f a new p l a n t b u t w ould be p r o h i b i t i v e l y e x p en siv e f o r an o ld p l a n t . I f such c o n tr o l s a re in c o r p o r a te d i n t o a new t r a n s f o r m e r o r c a p a c i t o r p l a n t on a new s i t e , i t s h o u ld be p o s s i b l e t o l i m i t t h e d i s c h a r g e o f PCBs t o l e s s t h a n 5 p o u n d s p e r day depending upon th e volume and com plexity o f th e p ro d u ctio n p ro c e sse s. The a t t a i n a b l e d isc h a rg e from an e x i s t i n g p l a n t t h a t had a lr e a d y been in p r o d u c tio n b e fo r e th e m id - 6 0 's may be as much as 15 pounds h ig h e r as th e background l e v e l , depending on th e s i z e o f t h e p l a n t , i t s a g e , and th e n a tu re of i t s e a r l i e r o p e ra tio n s, a ll o f which would have a f f e c t e d th e lo c a tio n and e x te n t o f i t s r e s e r v o i r s o f PCBs. Such a p la n t could in s ta ll th e control measures m entioned above and s t i l l be u n a b le t o reach th e d is c h a rg e l e v e l s f o r a new p l a n t a t a new s i t e . We b e l i e v e t h a t t h e f o r e g o i n g n u m bers c a n p r o v i d e t h e b a s i s f o r r e a lis tic e fflu en t standards because they r e f le c t th e actual technology o f t h e c a p a c i t o r and t r a n s f o r m e r i n d u s t r y . As we h a v e m e n t i o n e d e a r l i e r , th e recommended w ater q u a lity stan d ard s p ro v id e.n o p r a c tic a l b a sis f o r efflu en t standards. -- SUMMARY In t h e f o r e g o i n g comments we h a v e r a i s e d t h e f o l l o w i n g p o i n t s : 1 ) A v a i l a b l e d a t a do n o t s u p p o r t c a t e g o r i z i n g PCBs a s a " h i g h l y to x ic " m a t e r i a l , n o r s e t t i n g s ta n d a r d s on th e b a s is o f t h i s a r b i t r a r i l y assigned hazard ratin g . 2 ) The maximum recommended c o n c e n t r a t i o n o f 0 .0 0 2 ppb o f PCBs in f re s h w a te r i s an o p e r a tio n a lly m eaningless number t h a t i s unsupported by c o n v i n c i n g e c o l o g i c a l d a t a . Any e f f l u e n t s t a n d a r d s b a s e d upon s u c h a w ater q u a lity standard could n o t be a tta in e d in e x is tin g p la n ts and could lead to shut-down o f c a p a c ito r and tran sfo rm er o p e ra tio n s. 3 ) A c t i o n s a l r e a d y t a k e n by M onsanto and PCB u s e r s i n t h e e l e c t r i c a l industry have s u b s ta n tia lly reduced the exposure o f th e environment to . PCBs a nd s h o u l d r e s u l t i n a d e c r e a s i n g i m p a c t o f PCBs i n t h e e n v i r o n m e n t . 4) E x is tin g d ata su g g e st t h a t A ro clo r 1016 should n o t be co n sid ered a toxic pollutant. 5) Older p lan t s ite s w ill continue to have s ig n ific a n t background l e v e l s o f PCBs i n t h e i r d i s c h a r g e s b e c a u s e o f a c c u m u l a t e d r e s e r v o i r s from years of operation before anyone recognized the p o ssib le environm ental h a z a rd s o f PCBs. These background l e v e l s s h o u ld be c o n s id e r e d a p a r t from those le v e ls c o n trib u te d by c u rre n t o p e ra tin g p ro ced u res. NEL 000300 782145 GENERAL Q : ELECTRIC Dr. C. Hugh Thompson -7- November 21, 1973 We a p p r e c i a t e t h e o p p o r t u n i t y t o s u b m i t t h e s e comments arid hope t h a t t h e y w i l l be o f a s s i s t a n c e t o EPA i n s e t t i n g e f f l u e n t s t a n d a r d s f o r PCBs. Very t r u l y y o u rs , . :^y ELS: 1 / Dr . E. L. Sim ons, Manager Environmental P ro tectio n O peration F NEL 000301 782146 1 ELE C TP.IC GENERAL ELECTRIC COMPANY, 1 RIVER ROAD. SCHENECTADY NEW YORK 12345 ' Phone (518) 374-2211 ' Subject: Affluent Limitationsfor Items on 'Toxic Substances List; Economic - Impact1of~a Ban on FCB PRODUCT QUALITY STAFF November 21, 1973 Dr. Martha Sager Chairman, Effluent Standards and Water Quality Information Advisory Coimnittee Environmental Protection Agency Room 821, Crystal Mall, Bldg. #2 Washington, D. C.;..20460.. _____ Dear Dr. Sager: With: reference T.to your forthcoming meeting (38FR30577) and pursuant to our understanding, that the Committee has expressed an interest in knowing the economic impact of a possible ban of polychlorinated biphenyls (or a restriction tantamount: to a ban),..we have the following comments..to offer: ... The value of the annual production of PCB transformers in the U.S. is approximately $45 million and that of capacitors $140 million.= Neither of these figures forms an appropriate base for assessing the socio-economic effect of' regulations having-the. force of a ban on further production. Should such a ban .occur in the near future (i.e., within five years) the impact.of PCB transformer unavailability would be felt primarily in:terms.of disruption of building construction, electric distri bution,, and railroad equipment projects; and interruption of the supply, of PCB capacitors would impact most heavily on the electrical supply situation, exacerbating the "energy crisis." : Most PCB:transformers are installed in industrial, commercial, and residential substation applications. A considerable number are installed on electric railway passenger commuter cars serving major metropolitan areas. In.all applications, these tranformers distribute electric power reliably without risk of fire and explosion, and in compliance with specific lavs, codes, and insurance restrictions mandating non-flammable liquid content. There is no readily available alternative for many applications where construction is under way or plans are complete. As much as $1 billion of construction projects could be seriously delayed, involving schools, factories, office buildings? apartment houses, and commuter trains. NEL 000302 782147 GENERAL 0 ELECTRIC Dr. Karcha Sager 2 The PCB capacitors produced in the U.S. annually have a major effect in reducing the electric current which would otherwise have to be generated to serve industrial and public needs. The saving may be approximated by summing up the incremental cost of oversize generators and that portion of transmission and distribution system equipment which is thermally limited. Equipment in these classes, corresponding to the 44 million kilovars of new capacitors installed annually, has a value of approximately $1 billion. A forced conversion to a non-PCB capacitor would be hampered by shortages of basic capaci- _ tor materials and factory production capability, thus placing in jeopardy about half of this annual saving. Additionally, there would be serious dislocations in the lighting and air-conditioning industries due to shortages and mismatches of capacitors required in those systems. The enclosed paper, "The Role of Polychlorinated Biphenyls in Electrical Equipment", February 4, 1972, was prepared originally for the Office of Science and Technology and is included here for further information on the economic value .of these devices.' In. addition,"we have updated the information about capacitors and addressed ourselves specifically to the consequences of unavailability of PCB capacitors in the enclosed new study entitled, "The Impact of a 'Ban* on the Use of PCB in Capacitors," November 19, 1973. Important as are economic considerations, we feel that the case for continued use of PCB's in capacitors and transformers rests less on these factors than upon the lack of substantiated need for ny tighter constraints oh the handling of these materials than those already in use or assumed as goals by the electrical industry. These aspects are discussed in the enclosed letter from Dr. Simons of General Electric to Dr. Thompson of E.P.A., commenting upon toxic pollutant effluent standards (reference, 3SFR21342). We hope this discussion will be of use to your committee. Very truly yours, JSN:ev Enclosures Jamies S. Nelson, Consultant-Product Environmental Compatibility cc: Dr. C. Hugh Thompson Chairman-Hazardous and Toxic Substance Regulation Task Force Office of Water Program Operations Environmental Protection Agency Washington, D. C. 20460 782148 NEL 000303  * THE IMPACT OF A "BAM" OS THE USE- OF PCB IS CAPACITORS SUMMARY The PCR-impregnated capacitors produced in the U.S. annually have a major effect in reducing the electric current which must be generated to serve industrial and public-needs for power. The annual saving may be viewed as equivalent to 44'-large electric generators, each of the 1000 megawatt size, which do not need to be installed -- an aggregation comparable to the nation's annual growth -- -- requirement. The following consequences will result from a PCB effluent standard ~ so strict as to have the effect of a ban: - If the industry is forced to convert to a non-FCB impregnant, low dielectric-constant liquids, such as mineral oil, offer the best initial fallback position. - Mineral oil would roughly double the pounds of capacitor grade dielectric paper and aluminum foil needed to produce present capacitor requirements. Current world-wide shortages of capacitor,paper and foil would not support this. -'"Materials availability would support about 50Z of the current capacitor requirements, using mineral oil. - If adequate materials supplies were somehow attained, current capacitor manufacturing facilities could produce at best only 50Z of-capacitor unit requirements. - Forced conversion to a non-PCB would result in capacitor shortages and major production cutbacks in the lighting, air conditioner, and power supply industries, and in their customer operations. - Doubling the size of capacitors would present serious replacement problems where PCB capacitors had been used. - Ballast and air conditioner manufacturers would have to redesign .certain products to accept the larger capacitors. - Power system stability would be adversely affected by a shortage of .capacitors, and black-outs could be expected. - Hew non-PCB's, such as G.E.'s Ei&nol, could subtantially reduce the magnitude of the materials problem. However, Ecohol still represents an unknown risk in reliability and safety in the major consumer application areas. A mass conversion is not Justified at this time. 782149 NEL 000304 -2 I. INTRODUCTION This.is a forecast of the consequences of a FCB effluent standard which cannot be met by capacitor manufacturers, and consequently becomes an effective ban. It is submitted by the General Electric Company to assist in the determination of appropriate effluent standards relative to capacitor grade FCB. II. BACKGROUND In the U.S., an impregnated capacitor can be very simply described as: ._ - Aluminum foil (around 0.22 mil thick) which serves as the electrodes. - Sheets of dielectric consisting of capacitor grade paper or combinations of this paper with plastic film. The dielectric is positioned between the aluminum electrodes as it is wound into rolls. - An appropriate liquid impregnant. - A sealed container for the capacitor roll and impregnant. The choice of dielectric materials, the number of sheets, and their thicknesses are all the result of many years of research and testing for reliability and consumer use safety. About 90-957. of liquid impregnated capacitors contain FCB, and are critical components to the fluorescent and mercury vapor lighting, the electric motor and air conditioning industries, and power transmission by electric utilities. The dielectric paper and plastic films (primarily polypropylene), aluminum foil, and FCB have all been specially developed and controlled for capacitor use and are produced as "specialty" materials. Capacitor grade FCB is Aroclor 1016, manufactured only by Monsanto. It is primarily trlchlorobiphenyl. It differs from all previously used formulations in that practically all of the higher boiling homologs-which have given rise to reports of FCB in wild-life residues-- have been removed. Introduced in 1971, it is now the only PCB used by the U.S. capacitor industry. Compared to other formulations, - it has a higher degree of biodegradability; - it has a lower degree of persistence in the environment. f- NEL 000305 782150 3 III. CONSEQUENCES OF:iA "BAN" TO THE CAPACITOR INDUSTRY evaluation addresses itself to the situation wherein the capacitor industry is effectively banned from using PCB's. A. Alternative Imprgnants-. Alternative.imprgnants are unproved in the U.S. capacitor industry. Mineral oil was the major imprgnant before PCB's, and it appears to represent the best innnediate fallback position. Even though mineral oil technology would put the industry back 30-40 years in progress, it still represent^tKe"best combination of known technology, materials availability, and reliability. For these reasons, mineral oil imprgnant has been selected at this time as the basis of comparison with FCB's. There have been a number of very active programs to develop non-FCB imprgnants, especially after the environmental problem was recognized. These programs are continuing in the industry, and it is expected that an improvement.will.be found which would be more acceptable than mineral oil. As an example,.Gterai Electric-is using a phthalate ester as the base for its non-FCB Eeonol imprgnant.'Econo1 capacitors are being sold commercially where special situations require a non-FCB. This is the case where U.S. electrical equipment, such as computers, is to be shipped to Japan where FCB's are banned. E c ^ o l has a higher dielectric constant (see next Section B for discussion of this property) than mineral oil, and consequently will require less additional materials and manufacturing capacity. However, limited availability of the phthalate ester, lack of appropriate manu facturing facilities, need for developing new efficient manufacturing processes, and particularly the unknown factors of reliability and safety in the broad consumer use areas such as lighting and air conditioners are some of the problems that prevent a near-term substitution. Unless considerable time for the development and evaluation of alternative liquids is permitted, the most suitable immediate stratagem appears to be the use of mineral oil. The virtues of FCB imprgnant and the disadvantages of mineral oil have been discussed in detail in a number of recent documents. Among these documents are the report of the Interdepartmental Task Force on FCB's (COM-72-10419), a paper titled, "The Hole of Polychlorinated Biphenyls in Electrical Equipment" presented by General Electric on February 4, 1972, and NEMA's Official Standards Proposal CP-P1-1973/TR-P6-1973, dated January 25, 1973. - All of these documents .have pointed out that PCB-impregnated capacitors are significantly smaller, more reliable and safer than mineral oil impregnated capacitors and that use of mineral oil would return 782151 NEL 000306 4 capacitor technology to its pre-1932 level. The substitution of mineral oil for PCB imprgnants would necessitate redesign of end equipment to utilize the larger capacitors, large increases in capacitor manufacturing facilities (both plan t and equipment) and would result in increased use of basic materials which are presently in short supply. The following is an attempt to quantify some of the consequences related to the use of mineral oil as an alternative imprgnant. B. Capacitor 'fifmifacturine Capacity M in e r a l oil impregnated capacitor sizes relative to PCB capacitors are shown in Table 1. Table 1 - Relative Size Comparisons Types* AROCLOR 1016 Mineral Oil Small Industrial Power 1.0 1.0 2-2.5 2.5-3.2 *Small Industrial - Used in lighting, air conditioning, motors and electronics. Power - Large capacitors used by electric utilities and by industry for induction furnaces and power factor correction. The dielectric constant of a capacitor's dielectric system is the ratio of its ability to store electrostatic energy relative to air. The dielectric constant of PCB imprgnant is 5.85 while that of mineral oil is 2.25. Use of the lower dielectric constant mineral oil in a paper dielectric system, assuming no change in the thickness of the paper dielectric, would result in a capacitor which is 60% larger than the PCB impregnated design. Additionally, however, use of mineral oil requires that the thickness of the paper dielectric be increased to reduce the operating stress on the system if equal life and reliability are to be attained. In the case of lower voltage industrial type capacitors, such as those used in fluorescent ballast and air conditioning applications, the dielectric thickness must be increased 10 to 25%. In power capacitors operating at higher voltages, the dielectric thickness must be increased 25 to 40%. The larger increase in the high voltage units is related to the fact that corona initiation and extinction voltages of mineral oil impregnated dielectric systems are lower than those of PCB impregnated systems. The approximate doubling of physical size results in about half the throughput of capacitors in existing manufacturing equipment. The capacitor industry currently has little if any excess capacity to handle this, even if adequate capacitor materials supplies are assumed to be available. 782152 NEL 000307 5 CONSEQUENCE - THE CAPACITY AND OUTPUT OF THE CAPACITOR INDUSTRY WILL BE CUT APPROXIMATELY IN HALF. C. Capacitor Materials Availability The following Table 2 estimates the capacitor industry requirements for paper, foil, and inpregnant based on the currently used AROCLOR 1016 and for mineral oil. - Table 2 - 1974 Capacitor Materials Requirements (lbs. in millions) Paper A1 Foil Imprgnant AROCLOR 1016 26 18 26 Mineral Oil 52-65 32-36 35-42 % Chanee 100-150% 80-100% 35-60% - There is a worldwide shortaee of capacitor grade paper and aliimimpB foil. The capacitor paper supply i-s -expected to ^continue at its present level of availability. Mineral oil impregnation will require at least twice the amount of materials to produce the same capacitance as with PCB's. Using the most optimistic of the above numbers, the total capacitor industry's requirements of Kraft paper dielectric, all of it using imported pulp for its production, would increase by 2 to 2.5 times and its requirements for aluminum electrode foil would increase by 1.80 to 2 times. f Total industry requirements in 1974 for paper dielectric in PCB impregnated capacitors is estimated at 26 million pounds. Based on recent experience, this requirement is the limit that suppliers of this type of paper can produce with existing equipment. Adding facilities to more than double the present domestic output of paper is a task that could not be completed in less than 4 to 5 years and the total investment required by the paper manufacturers is estimated to exceed $200 million. It is questionable that the paper industry would make this invesdnent, facing the probability that future impregnant and design developments would negate its need. Aluminum foil is also in short supply. Some investment in foil-rolling equipment is already under way at General Electric to alleviate the shortage, but an adequate continuing supply of reroll aluminum stock from which the thin gauges of aluminum electrode material are made cannot presently be assured. The supply of dielectric-grade mineral oil required to replace FCB impregnants is also unassured. Doubling the size of capacitors would NEL 000308 782153 6 approximately double the volume of imprgnant required. The sole manufacturer of dielectric-grade mineral oil has recently announced that its manufacture is being discontinued. The feasibility of supplying the capacitor industry on a timely basis with 35 million pounds annually, starting from a production rate of zero, is doubtful to say the least. CONSEQUENCE - THE CAPACITOR INDUSTRY WOULD BE ABLE TO SUPPLY ONLY ABOUT 507. OF THE CURRENT CAPACITOR DEMAND BECAUSE OF MATERIAL SHORTAGES. D. Costs U.S. impregnated capacitor sales for 1974 ere shown in Table 3. Table 3 - Estimated 1974 Total Impregnated Capacitor Sales S Millions Small Industrial 100 Power 55 ' About 90-952 of these are PCB impregnated capacitors. It is estimated that the cost of capacitors would increase by at least 1002 in going to mineral oil. It is likely that there would be an added inflationary force with demand far exceeding supply. ;, CONSEQUENCE - COST OF CAPACITORS WOULD AT LEAST DOUBLE. AT CURRENT PCB CAPACITOR SALES LEVELS, THIS WOULD ADD ABOUT $145 MILLION IN CAPACITOR COSTS TO EQUIPMENT MANUFACTURERS. TO THIS WOULD BE ADDED AT LEAST ANOTHER $200 MILLION IN COSTS AT THE END-CONSUMER LEVEL. NEL 000309 E. Reliability and Warranty The life expectancy of capacitors exceeds 10 years for lighting applications and more than 20 years in electric utility power transmission applications. Although capacitors are considered long-lived products, there is an ever present danger of short life and early failure. This can be caused by a number of factors such as poor process control, materials quality, mis-application, and new product introduction with inadequate knowledge and experience of reliability. The General Electric Company warrants its capacitors for one year, and has extended this warranty where capacitor failures have been excessive and due to shortcomings in capacitor quality. The major reliability and warranty problems lie in the small industrial type capacitors 782154 -7 such as used for lighting, motors, and power supplies- The capacitor industry produces in the order of 100 million capacitors per year* The majority of these units sell in the price range of 50c to $4. The service cost for replacing a failed capacitor is $20 to $25. The in-warranty failure rate of General Electric capacitors during the first year is well under Q.5Z. We believe that this reliability is typical of the capacitor industry in general. This performance has been attained after many years of developing the FCB capacitor, and establishing expected norms for failure rates and service life. The capacitor industry historically is very careful in introducing product and process changes because small changes in failure rate, which are extremely difficult to determine without years of service experience and statistics, could result in excessive complaint and replacement costs. For example, Table 4 shows the replacement cost If the failure rate during the warranty period increased by different levels. Table 4 - Replacement Costs for Early Failures Z of Annually Installed Capacitors Failing, over Existing Rate Increase in Percentage Points 1.0 2.0 Millions Replaced 1.0 2.0 Cost at $25/Service Call $25 million $50 3.0 3.0 $75 " In order to avoid the consequences of such warranty costs, the capacitor industry would design any new non-FCB products on the conservative side. However, there would still be a substantial risk associated with a mass changeover to a new imprgnant, especially in the end-consumer product area, with essentially no experience on reliability and safety. CONSEQUENCE - IF THE FAILURE RATE OF THE 100 MILLION CAPACITORS PRODUCED IN ONE YEAR WERE TO INCREASE BY 1 TO 3 PERCENTAGE POINTS, THE REPLACEMENT COSTS AT $25 PER SERVICE CALL WOULD RUN FROM $25 to $75 MILLION. THIS IS THE MAGNITUDE OF THE CAPACITOR INDUSTRY'S EXPOSURE IN GOING TO A NEW, UNTRIED IMPREGNANT ON A MASS BASIS. I V . CONSEQUENCES OF A "BAN11 TO CAPACITOR USERS This section estimates the effect of a PCB ban on customers and users of capacitors. NEL 000310 782155 8 CRITICAL COMPONENT AVAILABILITY Capacitors are a critical and necessary component in end-user equipment, particularly in small industrial applications. Without the capacitor, the end product would not operate as designed. The capacitor shortage resulting from a "ban" on PCB capacitors would force a reduction by at least half from the normal production rate in the plants of capacitor users. CONSEQUENCE - INCREASED LAYOFF AND UNEMPLOYMENT AS MANUFACTURERS ADJUST TO THE SHORTAGE. ELECTRIC POWER SYSTEM SAVINGS The magnitude of the energy levels under discussion can be assessed from the following: ~~ - The U.S. capacitor industry produces the equivalent of 55 million kilovar per year. - A kilovar is equivalent to at least 1 kilowatt of generating capacity (some estimates place this ratio of kilowatt/kilovar at up to 1.4). /*- About 20% of the capacitors are for replacement purposes, and the remaining 80% are for new service. Thus, 44 million kilovars are installed on new systems. Without.these capacitors, the steam turbines and fuel requirements would be relatively unaffected, but generators would be larger to handle more current, and certain components of transmission and distribution systems (e.g., step-down transformers) would have to be larger to prevent burn-out. The additional generating capacity for 44 million kilovolt-amperes, priced incrementally, would amount to about $300 million; the additional transmission and distribution equipment would amount to about $700 million. CONSEQUENCE - REDUCED AVAILABILITY OF CAPACITORS WOULD ADD FURTHER SUBSTANTIAL BURDEN TO THE ENERGY SUPPLY SITUATION. NEL 000311 POWER SYSTEM STABILITY The preceding discussion indicates that electrical energy requirements could theoretically be met by using fewer capacitors and building oversize generation, transmission and distribution components (at a severe economic penalty). Such a system would be operating at low power factor -- or, in other words, the system would be carrying a large component of useless reactive volt-amperes in addition to the in-phase component that represents 782156 9 energy delivery. Systems studies have shown (see Economics of Kilovar Supply by Campbell, Ros, and Tice, General Electric Company, June 20, 1972) that low power factor severely limits the capability of a power pool to import power from its neighbors during a loss-of-generation emergency. CONSEQUENCE - CAPACITOR SHORTAGES WOULD MAKE LARGE POWER SYSTEMS SUBJECT TO CASCADING OUTAGES, OR "BLACK-OUTS." SIZE AND REPLACEMENT As pointed out earlier, the size and cost of mineral oil impregnated capacitors would be at least twice that of PCB capacitors. The lighting industry has designed their ballasts for the small size PCB capacitors.~ Approximately 20Z of ballast capacitors are used in the replacement market. Many room air conditioners have no space for a larger capacitor if a replacement is required. The capacitor industry has continually moved to reduce the size of capacitors. Equipment manufacturers have taken advantage of these size reductions, and have no room for size increases. In certain cases, size limitations in the replacement market would force the scrapping of good light fixtures and air conditioners. CONSEQUENCE - UNAVAILABILITY OF SMALL SIZE CAPACITORS WOULD FORCE THE EARLY OBSOLESCENCE OF GOOD, FUNCTIONAL EQUIPMENT. fi- General Electric Company November 19, 1973 NEL 000312 782157 GENERAL ELECTRIC COMPANY. 1 RIVER ROAD, SCHENECTADY. NEW YORK 12345 Phone (516) 374-2211 Subject: Toxic Pollutant Effluent Standards PRODUCT QUALITY STAFF November 21, 1973 Mr. William Fapageorge Monsanto Company 800 North Lindberg Boulevard St. Louis, Missouri 63166 Dear Mr. Papageorge: Enclosed is a copy of our communications to the EPA (Thompson) and the Water Quality Advisory Committee (Sager) vhich are being mailed today. Please note our claim that Aroclor 1016 should not be considered a "toxic pollutant." Very truly yours, f, JSN:ev Enclosures cc: Dr. E. L. Simons General Electric Company bcc: A. Pozefsky - HUDSON FALLS EL Raab - PITTSFIELD James S. Nelson, ConsultantProduct Environmental Compatibility NEL 000313 782158 -V 1 J % PRODUCT QUALITY STAFF GENERAL ^ ELECTRIC 1 RIVER ROAD. SCHENECTADY. N. Y. 12345 SU BJEC T t------- ----- *i J" 1 b ; D .! A L 1 C O F*1 M - 8*235-2261 | Remylet 10-2-73, PCB and the CEQ COPIES: November 26, 1973 Hr. J. F. McAllister NEW YORK Dear Jack: Referring to your note (see attached): I believe any reasonable person will agree that these are not equivalent statements because-- the CEQ statement implies that a regulatory program has been determined and announces specific action to be taken on a streamstandard basis; while the Task Force statement, in the original version, is concerned with private responsibilities and governmental intent and uses language (l.e., "should not exceed..*1) more appropriate to a statement of a goal than to a rule-making. Very truly yours, JSN:ev Att. Jams S. Nelson j f NEL 000314 782159 r PRODUCT Q UALITY 5TAFP GENERAL ELECTRIC 1 RIVER ROAD. SCHENECTADr. H. Y. 12345 ' -- -- T-l i DIAL; i - - nC_ HO s..*.r.s i SUBJECT 8*235-2261 PCB and the CEQ ^ .,,ut VU COPIES: JF McAllistei EL Simons ` ' ` i /,tli frV s rs ~r . -- L*I.I * October 2 ,' 1973 RECEIVED Dr. A. Pozefsky Manager-Technology Planning Industrial Power, Capacitor Products Dept. Hudson Falls, N. 1. Mr. E. L. R a ^ Manager-Dielectric Systems Laboratory Bldg. 11-315 Pittsfield, Mass. 01201 Mr. W. >M. Nave Managex-Group Manufacturing Support Oper. Powey Delivery Group 690V Elmwood Avenue Philadelphia, Pa. 19142 Gentlemen: OCT 31973 I McAl l is t e r M f i i\ " / ; >!.'(&xLcL J: C- t & X P* The Fourth Annual Report of the Council on Environmental Quality contains the following statement: "EPA announced that it would reject water quality permit applications from any industry whose discharges raised ambient PCB levels in rivers and lakes to 0.01 or more' parts per billion. 141" The footnote reference is to the Interdepartmental Task Force on PCB's, Polychlorinated Biphenyls and the Environment (1972). What the Task Force actually said is: .Under a program of limitation on the sale of PCB's, the electrical industry will continue to be the principal user of PCB's; it, as well as industries now holding inventories of PCB's, have a special responsibility for monitoring and controlling their wastes. In this connection, the Environmental Protection Agency will restrict industrial liquid discharges of PCB's from PCB users. To keep levels in fish as low as possible, and in any case below FDA's interim action level of 5 parts per million, concentrations in rivers or lakes from all sources should not exceed 0.01 parts per billion." I believe any reasonable person will agree that these are not equivalent statements. EPA has not made the statement attributed to it in the CEQ report, in the Task Force report or anywhere else, to our knowledge; furthermore, they are now considering what action to take with respect to PCB limits under the NEL 000315 782160 PRODUCT Q UALITY STA FF GENERAL ELECTRIC 1 RIVER ROAD, SCHENECTADY. H. Y. 12345 SUBJECT dial c o r.~ 8*235*2661 MONTHLY ACTIVITIES REPORT James S. Nelson__________ COPIES: F. S. Rothe November 29, 1973 Mr. J. F. McAllister NEW YORK IV - PRODUCT ENVIRONMENTAL COMPATIBILITY 1. PCB's The Pyranol Transformer Task Force has met with Osthoff in Pittsfield to review alternative technologies and with Hart in Hudson Falls to review possible interaction between capacitor and transformer strategies, particularly as these involve the governmental sector and supplier relationships In connection with the forthcoming EPA Toxic Pollutant Regulations, PQS worked with RECO and departmental personnel to generate a letter of comment which Dr. Simons dispatched to Dr. Thompson of EPA. In a related move, PQS wrote to the Water Quality Advisory Committee (EPA) answering their query on the economic impact of a ban on the use of PCB's. These letters have as their ultimate purpose influencing EPA toward attainable standards and away from impractical "stream standards" with fractions of a part per billion as a criterion. ?- r ed a c ted NEL 000316 JSN:ev Very truly yours, James S. Nelson 782161 J PRODUCT. QUALITY STAFF I RIVER ROAD. SCHENECTADY. H. Y. 12345 SUBJECT r --'-- - ------- -- --J DIAL co: I 8*235-2261 I COPIES: JF McAllister EL Dobbins LP Hart EL Simons November 30, 1973 Mr. W. M. Nave Manager-Group Manufacturing Support Oper, Group Technical Resources Operation 6901 Elmwood Avenue Philadelphia, Pa. 19142 Dear Bill: Confirming our telephone conversation, it appears from information Dick Smith picked up in Washington yesterday (at a Water Quality Advisory Committee Meeting) that EPA is not going to honor its pledge to propose an "attainable" standard for the discharge of PCB's. The limit they are set to publish on Monday the 3rd of December is 0.06 pounds per day into a river carrying at least 10,000 cubic feet per second. This is unjustifiable, unattainable, and probably not even measurable. We'll have 90 days to comment on the proposal when it issues. Final promulgation is not expected until June, 1974, followed by an effective date of June, 1975, Attached are two recent letter which Indicate the possible scope and direction of the comment strategy we could follow in the period following publication. One is from Ed Simons to Dr. Thompson of EPA and the other is from me to Dr. Sager, Water Quality Advisory Committee. Additional suggestions will be welcomed. Very truly yours JSN:ev Enclosures James S. Nelson, ConsultantProduct Environmental Compatibility NEL 000317 782162 PRODUCT Q UALITY STA FF GENERAL ELECTRIC 1 RIVER ROAD, SCHENECTADY. H. Y. 12345 SUBJECT D I l "! c o :.i M 8*235-2261 COPIES: Dr. E. L. Simons December 3, 1973 Mr. J. R. Vincent Power Transformer Engineering Bldg. 16-210 PITTSFIELD, MASS. *'- Dear Mr. Vincent: Enclosed per your inquiry is a copy of the bulletin concerning oil spill procedures Issued by RECO's Environmental Protection Operation. It gives the hot line numbers for notification of EPA. ' I have seen a copy of a letter from D. B. Anderson (Apparatus Transformer Sales) to A. P. Engle, Erie, October 19, 1973 (with a long list of copies, including one to you) which indicates that a caution tag, including the requirements to notify Pittsfield immediately, "will shortly be added to all new shipments of Pyranol-filled Pittsfield Transformers". Please advise whether or not this is being done. I would appreciate a sample tag if the final form has been determined. ^ ?J Very truly yours, JSN:ev Enclosure James S. Nelson, ConsultantProduct Environmental Compatibility NEL 000318 782163 PRODUCT QUALITY STA FF GENERAL I ELECTRIC 1 RIVER ROAD. SCHENECTADY. N. Y. 12345 SUBJECT r DIAL c o :.i ri 8*235-2261 | MONTHLY ACTIVITIES REPORT James S. Nelson________ __ COPIES: FS Roche December 17, 1973 Mr. J. F. McAllister NEW YORK IV-PRODUCT ENVIRONMENTAL COMPATIBILITY 1. New York State Department of Environmental Conservation The New York Environmental Conservation Law, Article 37, calls for the development of a list of substances "hazardous to the environment." The D.E.C.1s proposed list contains 213 substances, including a number that are of interest to 6. E. PCB's are on the list, and also D.O.P. (the "safe" substitute material for capacitors). Also listed are mercury, cadmium, lead, and ethylenediamine (the last name being used at Selkirk). Associated Industries of New York has empanelled a subcommittee to review this list and any proposed rules concerning it, and GE is represented on this activity by S. M. Riche1 of RECO. We are working with Mr. Richel in an effort to safeguard our product interests. As a follow-on to the submission of comments on the latest proposals concerning noise control in New York State, plans are being laid for an informal discussion with the Noise Bureau. Participants are to include representatives of Con Edison and G. E. 2. Environmental Protection Agency The Federal EPA, under court order to produce toxic pollutant effluent control limit proposals by December 3, has not as yet published anything in the Federal Register. GE's Washington Office is seeking an under standing of the hold-up. According to various reports, the draft document will contain PCB limits which are neither justifiable nor attainable. We are on record with objections, both with EPA itself and with the Water Quality Advisory Committee, and are poised to follow up during the anticipated period for public conment following public disclosure of the proposed limits. redacted NEL 000319 JSN:ev Q S T U ^ - r tU i/ a m e s S. Nelson 782164 i\lb) - '`orpff TS PRODUCT Q UALITY STA FF GENERAL ^ ELECTRIC 1 RIVER ROAD. SCHENECTAOT. H. Y. 12345 SUBJECT L'' c0 oI BA Lirj 8*235-2261 Response to EPA's Proposed Toxic Pollutant Effluent Standards COPIES: EL Dobbins - PITTSFIELD JF McAllister - NEW YORK JF Repko - SYRACUSE SM Richel - Bldg. 36-SCHDY. EL Simons - Bldg. 36-SCHDY. January 21, 1974 Mr. William N. Nave Manager-Group Manufacturing Support Operation Group Technical Resources Operation Power Delivery Group 6901 Elmwood Avenue Philadelphia, Pa. 19142 Dear Bill: At your request, we have prepared the enclosed statement on the status of our planning for GE's response to the toxic pollutant effluent standards, with particular reference to PCB's. For your general information, the other materials on the list were reviewed by EFO with respect to their use by GE, the feasibility of meeting the proposed standard, and the presence of GE activities on the list of affected categories of point sources, with the result that an intention to testify on cadmium has also been filed. It is my understanding that you intend to use the PCB statement in connection with your preliminary report of the Task Force - Pyranol Transformer, on January 31. Prior to that date, we will have attended the opening of the public hearings on PCB and may have additional information to pass along. Very truly yours JSN:ev James S. Nelson, ConsultantProduct Environmental Compatibility NEL 000320 782166 EPA LIMITS FOR PCB AND GENERAL ELECTRIC'S PLANNED RESPONSE Under the Federal Water Pollution Control Act Amendments of 1972, Section 307(a), EPA is authorized to define and control the emission of "toxic pollutants." The list promulgated September 7, 1973, contains (along with three other materials of interest to GE and five of no interest) polychlorinated biphenyls (PCB's). On November 21, 1973, GE filed two letters of coranent to assist EPA in establish ing effluent standards for PCB. One of these letters was from Dr. Simons to Dr. C. Hugh Thompson, Chairman - Hazardous and Toxic Substance Regulation Task Force and addressed the subjects of toxicity and biodegradability of various grades of PCB and the feasibility of measuring and controlling to the concentrations mentioned in EPA literature. The other was from Mr. Nelson to Dr. Martha Sager, Chairman - Effluent Standards and Water Quality Information Advisory Committee and concerned the economic importance of the use of PCB in transformers and capacitors, and the impact of a standard so restrictive as to constitute a ban. Both letters have been widely circulate< through the industry by NEMA and by Monsanto to its customers. The EPA published proposed effluent standards on December 27, 1973, embodying two types of limitations on discharge: a concentration limit, intended to avoid acute toxicological effects, and a total weight limit, intended to avoid chronic toxicological effects. GE plants potentially affected are the transformer plants at Pittsfield and Rome, the capacitor plants at Fort Edward and Hudson Falls, and Apparatus Service Shops. In addition, our sole source of PCB, the Monsanto plant at St. Louis, is affected. The proposed limits, which take into account among other factors the nature and flow rate of receiving waters, amount to zero discharge at Rome, near-zero at Pittsfield, and a value said to be beyond the capability of the highly-engineered facility of p Monsanto at St. Louis. January 18, 1974 was the deadline for requesting to be heard at the public hearings commencing on January 25. G.E. has filed its intention to give testimony, and our present information is that Monsanto, NEMA, Westinghouse, and orapugjwill also appear. Because of the late availability of a key EPA document, the Statement of Basis and Purpose, we understand that no substantive testimony is to be taken on January 25. The meeting on that date will take the form of a prehearing conference, with formal testimony to be scheduled later -- presumably late February and March. * We will be (were) represented at this meeting by Mr. Richel, Dr. Simons, and Mr. Nelson. By agreement between the affected Divisions, the Company spokesmen for our formal testimony will be Mr. Farnsworth and Dr. Simons. The team of Simons, Richel and Nelson, with support from operating comporents, is gathering material for the testimony. Currently under way are three main tasks: critical analysis of the Statement of Basis and Purpose; assembly of technical feasibility and cost of treatment data for affected plants; and development of a legal basis for establishing relevance of information on economic impact, technical feasibilit; and cost. It is planned that G.E. testimony will emphasize the paucity of data upon which EPA based its proposed standard, question the validity of EPA's extrapolation from the data, and characterize the proposed standard as unnecessarily stringent. We will seek appropriately different rules for the different grades of PCB (exemption of capacitor grade) and the exemption of residual PCB's (inescapably present at existing plants) from the proposed control measures. JSN 1-21-74 N EL 000321 7R2167 PRODUCT Q UALITY STA FF GENERAL ELECTRIC 1 RIVER ROAD. SCHENECTADY. M. Y. 12345 SUBJECT EPA Hearings on PCB D I A Li '`"AA :- " C O M flfl i 6*235-2261 COPIES: EL Dobbins - PITTSFIELD JF McAllister - NEW YORK JF Repko - SYRACUSE SM Ri che1 - SCHDY. EL Simons - SCHDY. January 28, 1974 Mr. William M. Nave Manager-Group Manufacturing Support Operation Group Technical Resources Operation Group Staff Components Division 6901 Elmwood Avenue Philadelphia, Pa. 19142 _ Dear Bill: Ed Simons, Stu Richel, and I attended the EPA hearing on January 25 -- which was really a pre-hearing conference. Monsanto, Westinghouse, NEMA, and GE were the only manufacturing people indicating an interest in PCB. EIA appeared, but filed no formal objection. In addition, the Michigan Department of Water Resources and two environmental activist groups indicated intent to testify on PCB. About thirty parties filed formal objections, with interest running highest in cyanide, cadmium, and mercury standards. Attorneys for several participants asked questions, or made motions, consistent with preparation for filing lawsuits in the event that EPA fails to respond with significant revisions in the proposed standards. Testimony will be taken in the form of written affidavits, due March 15. Hearings, which will take the" form of cross-examination on portions of the written testimony, are to begin April 8 and conclude on flay 10 (with May 3 as a target date). One surprise at the pre-hearing conference is the stated readiness of both the presiding officer (Mr. Sweeny, a federal judge) and an EPA spokesman (Mr. Eckert, an attorney) to 'accept statements concerning economic impact and feasibility. Anticipating that you may wish to make direct use of a memo on this subject, I have revised and updated the one furnished on January 21. Very truly yours, JSN:ev Attachment amps S. Nelson, ConsultantJroduct Environmental Compatibility NEL 000322 782168 EPA LIMITS FOR PCB AMD GENERAL ELECTRIC'S P L A N E D RESPONSE Under the Federal Water Pollution Control Act Amendments of 1972, Section 307(a), E?A is authorized to define and control the emission of "toxic pollutants." The list promulgated September 7, 1973, contains (along with three other materials of interest to GE and five of no interest) polychlorinated biphenyls (PCB's). On November 21, 1973, GE filed two letters of corment to assist EPA in establish ing effluent standards for PCB. One of these letters was from Dr. Simons to Dr. C. Hugh Thompson, Chairman - Hazardous and Toxic Substance Regulation Task Force and addressed the subjects of toxicity and biodegradability of various grades of PCB and the feasibility of measuring and controlling to the concentrations mentioned in EPA literature. The other was from Mr. Nelson to Dr. Martha Sager, Chairman - Effluent Standards and Water Quality Information Advisory Committee and concerned the economic importance of the use of PCB in transformers and capacitors, and the impact of a standard so restrictive as to constitute a ban. Both letters have been widely circulate through the industry by NEilA and by Monsanto to its customers. The EPA published proposed effluent standards on December 27, 1973, embodying two types of limitations on discharge: a concentration limit, intended to avoid acute toxicological effects, and a total weight limit, intended to avoid chronic toxicological effects. GE plants potentially affected are the transformer plants at Pittsfield*and Rome, the capacitor plants at Fort Edward and Hudson Falls, and Apparatus Service Shops. In addition, our sole source of PCB, the Monsanto plant at St, Louis, is affected. The proposed limits, which take into account among other factors the nature and flow rate of receiving waters, amount to zero discharge at Rome, near-2 ero at Pittsfield, and a value said to be beyond the capability of the highly-engineered facility of Monsanto at St. Louis. January 18, 1974 was the deadline for requesting to be heard at public hearings t . scheduled to commence January 25. Because of the tardy availability of key EPAfurnished documents, especially their Statement of Basis and Purpose, the January 25 meeting was transformed into a prehearing conference, with no substantive testimony being taken. G. E., Monsanto, KEMA, and Uastinghouse were the only manufacturing-related organizations signifying an intent to testify on FCB. An EIA representative put in an appearance, but failed to file a formal objection. Two environmental-activist groups indicated an interest in all of the pollutants on the list, and a representative of the Michigan Water Resources Department also indicated an interest in FCB. Testimony is to be received as written affidavits, due March 15. Hearings, in the form of cross-examination on the written testimony, will begin April 8 and conclude by May 10. By agreement between the affected Divisions, the Company spokesmen at the hearings will be Mr, Farnsworth and Dr. Simons. The team of Simons, Richel, and Nelson, with support from operating components, is gathering material for the testimony. Currently under way are three main tasks: critical analysis of the Statement of Basis and Purpose; assembly of technical feasibilit and cost of treatment data for affected plants; and development of a legal basis for establishing relevance of information on economic impact, technical feasibility, and cost (the latter to be used in the event of a challenge to the relevance of such inform ation -- which the presiding officer and an EPA attorney have announced they will accept It is planned that G.E. testimony will emphasize the paucity of data upon which EPA based its proposed standard, question the validity of EPA's extrapolation from the data, and characterize the proposed standard as unnecessarily stringent. We will seek appropriately different rules for the different grades of PCB (exemption of capacitor grade) and the exemption of residual PCB's (inescapably present at existing plants) from the proposed control measures. JSN 1/23/74 N EL 000323 782169 PRODUCT QUALITY STAFF GENERALELECTRIC 1 RIVER ROAD. SCHENECTADY. H. Y. 12345 SUBJECT r D IA oo : a hi 8*235-2261 EPA Hearings on PCB 6 COPIES: UR Kruesi WA McAdams JF McAllister /. January 30, 1974 Mr. J. F. Young NEW YORK Dear Jim: - Bill Kruesi has shared with me a copy of your January 24 memo to Mr. W. D. Dance. To fill out the record, you should know that Company components are not only working with NEMA, but have already established status as a party to the(hearings. Dr. Ed Simons, Stu Richel and I attended a prehearing conference in Washington on January 25. By agreement between Mr. Meloun and Mr. Farnsworth, the latter will be the formal Company spokesman, assisted by Dr. Simons. The attached memorandum, dated 1/28/74, gives additional information concerning the planned response. Very truly yours, ft JSN:ev Attachment 782170 N EL 000324 e?a limits Fon pen a n-.':~'\\L electric's planned response Under the Federal Water Pollution Control Act Amendments of 1972, Section 207(a), EPA is authorised to define and control the emission of "toxic pollutants." The list promulgated September 7, 1973, contains (along with three other materials of interest to GE and five of no interest) polychlorinated biphenyls (PCB's). On November 21, 1973, GE filed two letters of cormnent to assist E?A in establish ing effluent standards for FC3. * One of these letters was from Dr. Simons to Dr. C. Hugh Thompson, Chairman - Hazardous and Toxic Substance Regulation Task Force and addressed the subjects of toxicity end biodegradability of various graces of PCS and the feasibility of measuring and controlling to the concentrations mentioned in EPA literature. The other was from Mr. Nelson to Dr. Martha Sager, Chairman - Effluent Standards and Water Quality Information Advisory Committee and concerned the economic importance of the use of PCB in transformers and capacitors, and the impact of a standard so restrictive as to constitute a ban. Both letters have been widely circulate through the industry by NEMA and by Monsanto to its customers. The EPA published proposed effluent standards on December 27, 1973, embodying two types of limitations on discharge: a concentration limit, intended to avoid acute toxicological effects, and a total weight limit, intended to avoid chronic toxicological effects. GE plants potentially affected are the transformer plants at Pittsfield -find Rome, the capacitor plants at Fore Edward and Hudson Falls, and Apparatus Service Shops. In addition, our sole source of PCB, the Monsanto plant at St. Louis, is affected. The proposed limits, which take into account among other factors the nature and flow rate of receiving waters, amount to zero discharge at Rome, near-zero at Pittsfield, and a value said to be beyond the capability of the highly-engineered facility of Monsanto at St. Louis. ft January 18, 1974 was the deadline for requesting to be heard at public hearings * scheduled to conctence January 25. Because of the tardy availability of key EPAfurnished documents, especially their Statement of Easis and Purpose, the January 25 meeting was transformed into a prehearing conference, with no substantive testimony bein; taken. G. E., Monsanto, NEMA, and Westinghouse were the only manufacturing-related organizations signifying an intent to testify on PCB. An EIA representative put in an ' appearance, but railed to file a formal objection. Two environmental-activist groups indicated an interest in all of the pollutants on the list, and a representative of the Michigan Water Resources Department also indicated an interest in PCB. Testimony is to be received as written affidavits, due March 15. Hearings, in the form of cross-examination on the written testimony, will begin April 5 and conclude by May 10. By agreement between the affected Divisions, the Company spokesmen at the hearings will be Mr. Farnsworth and Dr. Simons. The team of Simons, Riche1, and Nelson, with support from operating components, is gathering material for the testimony. Currently under way are three main tasks: critical analysis of the Statement of Basis and Purpose; assembly of technical feasibili and cost of treatment data for affected plants; and development of a legal basis for establishing relevance of information on economic impact, technical feasibility, and cost (the latter to be used in the event of a challenge to the relevance of such inform ation -- which the presiding officer and an EPA attorney have announced they will accept It is planned that G.E. testimony will emphasize the paucity of data upon which EPA based its proposed standard, question the validity of E P A fs extrapolation from the data, and characterize the proposed standard as unnecessarily stringent. We will seek appropriately different rules for the different grades of PCB (exemption of capacitor grade) and the exemption of residual PCB's (inescapably present at existing plants) from the proposed control measures. JSH 1/28/74 NEL 000325 782171 PRODUCT QUALITY STAFF GENERAL ^ ELECTRIC ` 1 RIVER ROAD. SCHENECTADY, H. Y. 12345 SUBJECT [ 8*235-2261 MONTHLY ACTIVITIES REPORT James S. Nelson__________ COPIES; FS Roche February 4, 1974 Mr. J. F. McAllister NEW YORK r ed a c ted 2. Proposed Standards for Toxic Pollutants The Issuance of proposed standards for toxic pollutants during the Christmas holidays appears to have caught some interested parties napping. It is entirely plausible that without our initiative, only 6E would have appeared at the hearing to object on the part of the users of PCB. In the event, objections were filed by 6E, Westinghouse, and NEMA (as well as Monsanto, the producer). By agreement between the interested Divisions, Mr. Farnsworth is to be the GE spokesman at the forthcoming hearings, assisted by Dr. Simons. Simons, Richel and Nelson are coordinating the formulation of the written testimony, to be submitted by March 15. Proposed standards for Mercury, Cyanide, and Cadmium are also of interest, but neither the direct impact on our business nor the technical case against the proposals compares with the situation on PCB's. It is felt that the many industrial objectors to these three materials may be counted upon to raise the relevant issues without our participation. Hence, although the Company got on record with an objection to the Cadmium standard, present plans do not call for following up with further testimony. N EL 000326 782172 GENERAL ^ ) ELECTRIC Mr. J. F. McAllister 2 February A, 1974 4. Pvranol Transformer Task Force Mr. Have discussed the preliminary findings of the Fyranol Transformer Task Force with Mr. Meloun and staff, and the consensus of the ensuing discussion was that it may already be too late to start on a major program for dry-type transformers, and that the outlook for a FCB fluid substitute is uncertain, so that in effect the Division is preempted from any course other than vigorous defense of the Pyranol programthrough the EPA hearing process, and in the courts if necessary. At Mr. Wave's suggestion, Mr. Lee Hill will join the task force as it moves into more detailed delineation of Transformer strategy. JSN:ev VJames/S. Nelson NEL 000327 782173 PRODUCT Q UALITY STA FF GENERALES ELECTRIC 1 RIVER ROAD. SCHENECTADY. H. Y. 323 SUBJECT L. MONTHLY ACTIVITIES REPORT J. S. Nelson__________ 5*235-2261 COPIES: FS Rothe March 1, 1974 '1 Mr. J. P. McAllister NE;,T YORK IV - PRODUCT ENVIRONMENTAL COMPATIBILITY 1. Proposed Standards for Toxic Pollutants Uork continues with EPO personnel and operating components to prepare testimony and in other ways to seek modification of the proposed EPA Standards for Toxic Pollutants as they pertain to the use of PCBs. Significant steps in this process during February included: a. The engagement (by Dr. Simons in behalf of Messrs. Keloun and Farnsworth) of an aquatic biologist as a consultant. The scientist selected is Dr. Gerald Lauer of the NYU School of Environmental Medicine. He is preparing a critique of the EPA's "Basis and Purpose" document which is expected to show that there is no reasonable way to reach the EPA proposed standards from the data base EPA claims to have used. He is also reviewing the literature to help us to determine whether a more reasonable alternative standard can be proposed. b. A meeting in St. Louis with Monsanto and several other registered objectors and users of PCB. At this meeting, toxicological, biological and other pertinent data were reviewed and strategies for countering the EPA proposal were evaluated. c. A meeting in Schenectady with Dr. Osthoff and others was held to plan Company participation in the preparation of a "position paper" on PCBs to be published under auspices of the Power Engineering Society of IEEE. d. After consultation with this office and with counsel for the Transformer Division, the Transportation Division (MacMonagle) has decided to urge participation by the Department of Transportation in reviewing the hazard to the transportation industry which would be a consequence of the unavailability of PCB transformers for MU cars and locomotives. e. GE was urged at the St. Louis meeting to seek the intervention of the Federal Energy Office in the PCB regulations by sharing with that office information similar to our November mailing to Dr. Sager, discussing the economic impact of the proposed regulations and their predictable exacerbation of the energy crisis. This suggestion is to be implemented. f. The Report of the Task Force - Pyranol Transformers was given to Mr. Meloun under the date.of February 22. It is reported that the Transformer and 7R917A NEL 000328 GENERAL 3 ELECTRIC Kr. J. F. McAllister -2- March 1, 1974 D is t r ib u t io n E q u ip m e n t B u s in e s s D iv is io n s t a f f h a s c o n c lu d e d fro m t h is re p o rt th a t it s p re fe rre d co u rse o f a c tio n is a v ig o ro u s d e fe n se o f th e c o n tin u e d u se o f FCB in tra n s fo rm e rs . 2, Annual Reports Activity is under way in compliance with the annual reporting requirement of Policy 20.13, and the first report has been received. J S M :ev J. S. Kelson FfiJ NEL 000329 7R2175 PRODUCT Q U ALITY STA FF 1 RIVER ROAD. SCHENECTADY, N. Y, 12345 SUBJECT 3*235-2261 COPIES: Jr McAllister - NEW YORK SM Eichel - Bldg. 36-SCHDY. EL Simons - Bldg. 36-SCHDY. March 11, 1974 Mr. L o m e L. MacMonagle Manager-Prod. & Systems Safety Transit Systems Products Department 2901 East Lake Road Erie, Pa. 16501 Dear L o me: In line with your telephone request for additional information on the PCB situation, for use in your coming discussions with FRA and with Mr. Tomasetti, we have enclosed copies of the following: 1. GE's letter to the Hearing Clerk, January 15, 1974, (Including copies of earlier lettezs to Sager and Thompson.) 2. Monsanto's letter to the Hearing Clerk, January 13, 1974 (with attachments). 3. A draft of GE's proposed formal testimony, sent out to a limited GE list for comment, March 8, 1974. If, in addition, you require copies of the testimony of other parties to the hearings, we suggest you write to the Hearing Clerk, US Environmental Protection Agency, Washington, D. C. 20460 and request copies of the testimony to be filed with respect to 40 CFR Part 129, Subpart I, on PCBs. If we may be of further help, please let me know. Very truly yours NEL 000330 JSN:ev Attachments 782176 PRODUCT Q U A LITY STA FF GENERAL ^ ELECTRIC 1 RIVER ROAD. SCHENECTADY, N. Y. 12345 SUBJECT General Electric Testimony on PCBs COPIES: SM Richel EL Simons March 15, 1974 V Messrs. C. E. Reed : J. F. Young 7 J. F. McAllister i J - Gentlemen: Enclosed is your copy of the-formal Company testimony transmitted today to the Presiding Officer for the hearings on EPA's proposed toxic pollutant effluent standards for polychlorinated biphenyls. The testimony is prepared in the form of affidavits over the signatures of Mr. George B. Farnsworth, Dr. Edward L. Simons and Dr. Gerald J. Lauer. Dr. Lauer is an aquatic biologist engaged as a consultant for this purpose. It is our understanding that no oral testimony will be taken from the objectors, but that they should be available for crossexamination on their written testimony at an appropriate stage in the hearings. The GE testimony was prepared by a team consisting of Dr. Simons, Mr. Stuart Richel and the undersigned, in accordance with arrangements made with the cognizant Divisions. It has been reviewed and approved by the management and counsel for both the Transformer and Distribution Equipment Business Division and the Electronic Components Business Division. Very truly yours, JSN:ev Enclosures James S. Nelson 782177 NEL 000331 i PRODUCT Q U ALITY STA FF G E N E R A L ^ ELECTRIC 1 RIVER ROAD. SCHENECTADY, N. Y. 123 SUBJECT 8*235-2261 NEMA Statement on PCB's and IEEE Statement on PCB's; Government Relations -' ./ 7 ?-j ~ t ^ COPIES: March 28, 1974 ~/ Mr, J. F. McAllister NEW YORK Dear Jack: We have recently taken advantage of opportunities to gain support for established Company policy on PCB's through participation in the evolution of statements to be sent by NEMA to EPA and by IEEE to a selected list of govern ment agencies and legislators on the subject of the proposed toxic pollutant effluent standards for PCB's. Company policy has been established through a succession of activities, reviews, and approvals over the past several years, including the NIPCC state ment, the letter to the Office of Science and Technology, participation in the Interdepartmental Task Force, the Interservices Task Force, the Ames Task Force, formal comments to the Food and Drug Administration, the Company Bulletin EPS-4.1, the Transformer Task Force on Pyranol Transformers, and the preparation of formal testimony submitted to the current EPA Hearings. All of this work has been conducted in close collaboration with EPO and the cognizant product divisions and with legal approval at every appropriate point. NEMA has mailed a letter of comment to Dr. C. Hugh Thompson, March 25, copy attached. It follows verbatim a version we dictated in collaboration with Mr. William Van Wart of NEMA headquarters. Our participation in this activity came about at the request of Mr. Lee H. Hill, Manager-- Large Transformer Strategic Planning Operation and a member of the NEMA Ad Hoc Committee to Prepare a Statement on PCB's. We attended a meeting at NEMA headquarters on March 20. In attendance were Hill, Pozefsky and Nelson (GE); Sheppard (W); McGee (Sangamo); Rowe (McGraw Edison); Doty (PR Mallory and EIA); Salazar and Van Wart (NEMA). At this meeting an outline was prepared and agreement reached for Nelson and Van Wart to collaborate in Schenectady the next day on a draft statement based on the outline. After discussion with Van Wart, and in his presence, I dictated the draft on March 21, had it read by counsel for EPO (Stu Riche 1) and put it on the Telecopier to New York so NEMA headquarters could accomplish the necessary reviews in time to mail the letter before the March 25 deadline set by EPA for public comment. You have been kept informed of our participation with NEMA through our letter of January 30, 1974, addressed to Jim Young and through the expense account routine. (We have previously discussed our role in involving NEMA in the defense 782178 N E L 000332 GENERAL E L E C T R I C Mr. J. F. McAllister 2 March 28, 1974 of PCB's: see Monthly Activities Report, dated February 4, and also the attached letter from Dobbins to Sweeny). Our participation in the preparation of an IEEE Position Paper on PCB's began at the request of Bob Osthoff. He informed us that the Power Engineering Society of IEEE (of which Tom Lee is president) was planning a position paper and that he (Bob) had been asked by Lee to secure GE input to such a paper. Accordingly, a meeting was held at the Research Laboratory on February 27 with George Moore, Bob Anderson, Bill Feisler, Bob Osthoff, All Pozefsky, Ed Simons, and the writer present. This was reported to you in my Monthly Activities Letter of March 1, 1974. At this meeting, it was agreed that the product departments would collaborate on the business impact part of the story and that -- ` an environmental assessment would be supplied by Nelson and Simons. At the latter's request, I represented both of us in a session with Osthoff on Friday, March 20, in my office, at which we presented approaches consistent with the GE testimony. A draft of GE's input to the IEEE paper is not yet available, but I expect to have an opportunity to review it before it is forwarded. With regard to government relations, various parties have put forth the suggestion that key home-state congressmen be briefed on the PCB situtation. f Dr. Simons and I have discussed this with counsel and have recommended holding up until the package of GE testimony was made available. Now that this material is in published form, the onus of making recommendations in this regard is felt to lie with Dobbins and Repko, attorneys for the cognizant Divisions. Ed Simons has let them know that both he and I would be available for any assistance they might require, should they decide to go this route, and we understand from Mr. LeVine of the Washington Office that he has made a similar offer.' With regard to other government agencies, the Transportation Division has very effectively involved the Department of Transportation, whose Federal Railway Agency is concerned over the safety of possible substitutes. You have seen my letter of March 11 to L o m e MacMonagle, supporting this activity. My March 1 Activities Letter mentioned the possibility, of involving the Federal Energy Office. Nothing has been done on this b y us at the present writing; however, we have seen a copy of a letter from Aerovox, a capacitor manufacturer, to Mr. William Simon, that makes some of the same points we would propose to make. Please rest assured that I am making an effort to keep you abreast of developments in this area and a party to any policy-related discussions; that I reject most firmly any suggestion that I have moved independently of established Company policy with respect to PCB negotiations; and that everything I do is part of a cooperative effort involving appropriate staff and operating components. Very truly yours, JSN:ev Enclosures James S. Nelson NEL 000333 782179 PRODUCT Q UALITY STA FF GENERAL ELECTRIC 1 RIVER ROAD. SCHENECTADY. H. Y. 12345 SUBJECT ! 1" v a d - c p o -iiit: 8*235-2261. ,, COPIES: J AJ March 29, 1974 Mr. J. F. McAllister MEW YORK ... Dear Jack: Supplementing my letter of yesterday, enclosed is a copy ' o f o d r a f t for an IEEE "White Paper". This was transmitted by Osthoff today to an IEEE Committee, which was presumably to meld . this.,draft,.with material from other sources and. produce therefrom its final document. Very truly yours Barnes S. Melson NEL 000334 782180 dirH'sr I Ir1 J '^ ^ V }& ** c& nwJfc**- f a j i y TH E R O LE OF POLYCHLORINATED BIPHENYLS ______ IN e l e c t r i c a l E Q U IP M E N T ___________ iS J . P o ly ch lo rin ated biphenyls (P C B 's) have been u se d in m any applications fo r over 40 y e a rs , but only re c e n tly w as evidence d isc o v e re d th a t th ese m a te ria ls a re w idely d isp ersed in the environm ent. S ystem atic investigations of th e toxic and b io lo g ical effects of P C B 's have b een u n d e rta k e n w ithin the p ast few y e ars in attem pts to e sta b lish the effects of sp ecific form ulations upon.specific sp ecies. In spite of the fact that scien tific evidence has not d e fin itiv e ly , sh o w n P C B 1s to h a v e a d v e r s e e ffe c ts on th e e n v ir o n m e n t, U . S. in d u stry sta rtin g se v e ra l y e a rs ago re s tric te d th e u s e of P C B 's to clo sed system s such as cap acito rs and tra n sfo rm e rs* . The M onsanto C hem ical C om pany is th so le U. S. p ro d u c e r of P C B 's, and h as d isco n tin u ed supply ing the m a te ria l fo r all o th e r applications. T he EPA has recen tly proposed "Effluent S tandards fo r Toxic P o llu tan ts" in w hich the lim its on the d isch arg e of p o ly ch lo rin ated biphenyls (P C B 's) a re so low as to be w idely re g a rd e d as u n a tta in a b le . W e believ e th at no stan d ard th a t je o p ard ize s the continued ap p licatio n of P C B 's to tra n sfo rm e rs and cap acito rs should be undertaken u n til c ritic a l ap p ra isa l has been m ade of the need fo r the stan d ard and of the public safety and econom ic penalties asso ciated w ith discontinuance. We find that: the only rem ain in g applications a re in se a le d ap p artu s; the la rg e st volum e application (capacitors) h as been changed to a m o re biodegradable form ulation; *> NEL 000335 * P C B 's u sed in tra n s fo rm e rs and c a p a c ito rs a re d e sig n a te d by th e in te r n a tio n a l t e r m " a s k a r e r 1. 782181 -2- o e sta b lish e d evidence in d ic a te s that F C B 's as th ey a r e found in th e-en v iro n m en t a re not toxic to m an; 0 - th e o r i g i n a l fin d in g of h a r m to b ir d s v ia th e th in n in g o f egg s h e l l s 1w a s e r r o n e o u s l y a t t r i b u t e d to P C B 's ; # o voluntary in d u stry action has produced a m a jo r red u ctio n 6n the environm ental burden. D E F IN IT IO N O F F C B 'S F C B 's c o n stitu te a fam ily of ch lo rin ated o rg an ic liq u id s th at a re elec trica lly in su latin g and nonflam m able. T h eir u se confers unique c h ar- a c te ris tie s to e le c tric a l equipm ents, nam ely cap acito rs and tra n s fo rm e rs . B E N E F IT S O F USING F C B 'S L. T h e in s u la tin g f lu id in a s k a r e l - i n s u l a t e d t r a n s f o r m e r s w ill n o t -........ :.. , *. ". , . b u rn . In the event of arcin g and re su lta n t tank ru p tu re, burning of the d ie le c tr ic flu id does* not c o n stitu te a h a z a rd as in th e c a s e of o il-fille d tra n s fo rm e rs . Thus ask a'rel-filled tra n sfo rm e rs a re id eally su ited fo r u se inside of buildings. 2. A sk ar e l-filled pow er and in d u strial cap acito rs a re significantly sm aller, m o re reliab le, m ore durable, and safer than o il-filled capacitors. The capacitor grade a sk a re l is also nonflam m able. As a re su lt, a sk arels h a v e s u p p la n te d m i n e r a l o ils in m o r e th a n 90% o f th e p o w e r a n d i n d u s tr ia l cap acito rs m ade today. O ver the p a st few decades m o st of the equipm ent th at in c o rp o ra te s such cap acito rs has been configured to take p a rtic u la r advantage of the size, safety and reliab ility benefits of a sk a re l capacito rs *Pf NEL 000336 782182 -3- (e. g. m a n y ty p e s a r e to d a y l e s s th a t 14% o f th e s i z e o f e q u iv a le n t o il capacitors and h isto ry indicates that ask a re l-filled cap acito rs have p e r f o r m e d s a t i s f a c t o r i l y f o r 10 to m o r e th a n 20 y e a r s . ) E X P E R IE N C E IN U SE O F P C B 'S In the U nited S tates, m ed ical re c o rd s show th a t over a n e a rly 4 0 -y e a r p erio d the only a d v erse health effects ex p erienced by U. S. w o rk e rs exposed to P C B 's, e ith e r during the m an u factu re of th e se liq u id s o r of e le c tric a l equipm ent containing th ese liquids, have been lim ited to o ccasio n al cases of nonchronic chloracne o r other tem p o rary skin lesio n s o r irrita tio n s . A ll r e p o r t e d e n v ir o n m e n ta l i n c i d e n t of- a p u b lic h e a l t h n a t u r e w e r e th e r e s u l t of n o n - e l e c t r i c a l a p p lic a tio n o f th e ty p e s d e s c r i b e d i n th e fo llo w in g s e c t i o n #- p i m i i`i H y~1. i l i f t r f li 111 pi iy n ; i j l u p i l, , iL .effe.cts _ jc a h e r - t h a n - l e t hal-L u j u . l 1Lyr 1 ^ - INDUSTRY ACTIONS TO RED U CE TH E ENVIRONM ENTAL BURDEN T he th r e e broad ty p es of a p p lic a tio n s of P C B 's hav e b e e n : (a) "o p en ended" ap p licatio n s.. .fo r exam ple, in paints, sp ecialty inks, p ap er coatings, p la s tic s , e t c . , (b) " n o m in a lly c lo s e d " a p p lic a tio n s . . f o r e x a m p le , a s th e w o rk in g flu id in h y d ra u lic o r h e a t tr a n s f e r s y ste rn s ; an d (c) " c lo s e d e le c tr ic a l system " a p p licatio n s.. specifically, as the insulating fluid in c ertain types of tran sfo rm ers and capacitors. The M onsanto Com pany is the sole U. S. p ro d u c e r of P C B 's, and h as d isco n tin u ed su p p ly in g th e m a te r ia l fo r a ll a p p lic a tio n s of ty p e (a) an d (b). 782183 N EL 000337 H. -4- The only-uses a re confined to tra n s fo rm e rs and c a p a c ito rs . The re s u lt is th a t on ly a b o u t 50% sls m u c h P C B 's w e re p ro d u c e d on a n a n n u a l b a s is in 1973 c o m p a re d to 1970. 0 : 7.' -- / T he c a p a c ito r in d u s try Tias cofireT ed, s ta rtin g in la te 1970, to a . m o re b io d e g ra d a b le g ra d e of P C B 's know n a s .A r o c lo r 1016, f r o m w h ich h ig h er ch lo rin ated P C B 's have b een a lm o st elim in a te d . It is th e h ig h er chlorinated (g reater than four ch lo rin es p e r m olecule) com ponents of P C B 's th at have b een found in th e en vironm ent and re p o rte d to be m o re ` p e rs iste n t. ^ T ra n sfo rm e rs have changed to the u se of P C B 's th a t contain m ate ria ls w ith lo w er degrees of chlorination. ...... ____ ---- H ousekeeping in a ll m anufacturing operations h as been im proved to elim in ate p a st p ra c tic e s and su b sta n tia lly red u ce d isc h a rg e of P C B 's to the environm ent. ANSI stan d ard s have been issu e d fo r the handling and d isp o sa l of a s k a re ls (C107.1 - (1974)). A PPL IC A T IO N S IN E L E C T R IC A L EQ U IPM EN T W hen a sk arels w ere firs t introduced as d ie le ctric fluids fo r u se in co m m ercial e le c tric a l equipm ent, am ong o th er p ro p e rtie s that m ade them uniquely valuable fo r som e applications w as th e ir v itu al nonflam m ability. A ltogether the p ro p e rtie s of th ese liquids could not and s till cannot be m atched by any other fluids, and they have thus rem ained in fa irly gen eral u se fo r about 40 y e ars in those applications in w hich flam m ability w as an im portant consideration. A serio u s possible consequence of a failu re NEL 000338 782184 -5- in a liq u id -co o led tra n s fo rm e r w ould be an ensuing fire that could involve o ther s tru c tu re s and equipm ent. A sk ar els have no fir e point to the boiling point and, th e re fo re , they do not b u rn even at elev ated te m p e ra tu re s . T h erefo re, they a re used, in tra n sfo rm e rs th at a re in o r n e a r public, co m m ercial o r in d u stria l buildings w here o il-in su la te d tra n s fo rm e rs w ould p re se n t a p o ten tial d anger to life an d .p ro p erty b ecau se of th e flam m ab ility of oil. The v ital ro le that ask arel-in su lated tra n sfo rm e rs and capacitors have played in the safe, re lia b le , an d efficient d eliv ery of e le c tric pow er is reflected in various, stan d ard s, codes, and regulations th at now effectively re q u ire o r encourage th e ir continued u se. A sk ar e l-filled tra n sfo rm e rs and cap acito rs a re d eliv ered to cu sto m ers as sealed units fro m w hich th e re is no escape of a sk a r el u nder n o rm al o p eratio n . W hile c e rta in types of equipm ent fa ilu re s can ru p tu re the case and p e rm it lo ss of som e a sk a r el to the environm ent, such fa ilu re s a re lim ite d to a p p ro x im a te ly 0. 02% of th e u n ts in s e r v ic e p e r y e a r . In a d d itio n , F C B ^ can get into the environm ent during the m anufacture, delivery, im p ro p er u se, m aintenance, re p a ir and d isp o sal of tra n sfo rm e rs and cap acito rs. Specific control m e asu re s have alread y been in stitu ted by individual m an u factu rers and a re supplem ented and strengthened by n ational stan d ard s and p ro ced u res developed by a C om m ittee of the A m erican 782185 NEL 000339 -6- N ational Standards In stitute. T hese standards a re designed to p rev en t the in a d v e rte n t lo ss of F C B 's to the en v iro n m en t a t a ll sta g e s fro m equipm ent m anufacture through u ltim ate d isp o sal. A sk ar el tra n sfo rm e rs alread y in stalled cannot be rep laced by oil tra n s fo rm e rs and equivalent ratin g w ithout m ajo r co n stru ctio n changes in buildings and asso ciated equipm ent req u ired to com pensate fo r the safety fe a tu re s of the a sk a re l u n its. W hile d ry -ty p e tra n s fo rm e rs can rep lace a sk a re l-fille d units fo r certain applications in som e locations, the ._ d ry type tra n sfo rm e r is not a u n iv e rsal rep lacem en t fo r a sk a re l-fille d u n its. T he p rin cip al altern ativ e to a sk a re ls fo r cap acito rs is m in e ra l oil. D ire c t su b stitu tio n of m in e ra l oil fo r a sk a re ls in p re s e n t c ap acito rs w ould r e d u c e th e ir r a tin g b y a b o u t 50% a n d w ould n e c e s s ita te r e d e s ig n a n d r e p la c e tP* m ent of such w idely u sed equipm ent as flu o rescen t lig h t fix tu res and rack s fo r pow er and induction heating cap acito rs. The co st of a sk a re l liquids is about five tim es the co st p er gallon ii ,ri frwl o f m i n e r a l o il. T h u s , lo n g b e f o r e t h e r e w e r e a n y e n v ir o n m e n ta l co n cern s about F C B fs, th e re w as a strong-econom ic in cen tiv e to find o th er le ss expensive in su latin g liquids w ith the d e sirab le c h a ra c te ristic s of a s k a r e l s . ' S in c e th e 1 9 3 0 's , a t l e a s t 10 m a j o r c h e m i c a l o r e l e c t r i c a l com panies have in v ested la rg e am ounts of tim e and m oney in this search , a ll w ith no su c c e ss. W hile p o ten tial su b stitu tes th a t a re m o re costly th an F C B 's a re u n d er in v estig atio n (e. g. flu o rin ated liq u id s), little is NEL 000340 782186 known about eith er th eir electrical perform ance or p o ssib le ill effects upon the environm ent. T h ere a re today no fluids that can be u sed as o n e-fo r-o n e re p lacem en ts fo r P C B 's. ENVIRONM ENTAL CONSIDERATIONS A bout five y ears ago, a sk a re ls w ere b eliev ed to have an ad v erse e ffe c t ozi th e e n v ir o n m e n t by v i r t u e o f th e a c c u m u la tio n o f P C B c o n s t i t u e n t s in the food chain. C ertain species of b ird s th at p re y on P C B -containing fis h w e re o b serv ed to lay eggs w ith s h e lls so th in th a t th e y w ould b re a k p rio r to hatching, th ereb y endangering the continued ex isten ce of the sp ecies in question. T his thinning w as in itia lly a ttrib u te d to P C B 's but m o re re c e n t evidence show s th a t P C B 's do not co n trib u te to s h e ll th in n in g . (P ro p o se d C rite ria fo r W ate r Q uality, EPA , O cto b er 1973, V ol. I, p . 321). In 1970, at the fir s t indication of the environm ental alleg atio n s, M onsanto, the only m a n u fa ctu rer of P C B 's in the U n ited S ta te s, a le rte d its custom ers of the potential problem of environm ental contam ination. The e lec trica l m an u factu rers in tu rn a le rte d th e ir c u sto m ers to th e p otential p ro b lem . ' L a te r in 1970, M onsanto in itia te d its w ith d raw al fro m p a rticip atio n in all PCB m a rk e ts, except for use in sealed tra n sfo rm e rs and cap acito rs. O ther u se s, such as in p la stic iz e rs, in coatings, in ad h esiv es, in hydraulic fluids, and in heat ra n sfe r fluids w ere term in ated . T hese actions resu lted in a r e d u c tio n of a b o u t 5 Oft in th e q u a n itity o f P C B 's m a n u f a c t u r e d l a s t y e a r c o m p a re d to 1970, and th e r e m a in d e r g o es on ly in to s e a le d a p p a r a tu s . T h is 782187 NEL 000341 -8- w as follow ed by the introduction of a sp ecial grade of cap acito r a sk a re l, having a lo w er d eg ree of c h lo rin a tio n ^ It has been shown that th e low er the d eg ree of chlorination of biphenyl, the le s s p e rsiste n t the liquid is in the environm ent. T ran sfo rm ers also em ploy a sk a re ls w ith a low er degree of chlorination thaftform erly. In O ctober of 1970, the P e stic id e s R egulation D iv isio n issu e d PR N otice 70-25 to the effect th at "F o rm u lato rs and m a n u fa c tu re rs of econom ic poisons containing polychlorinated biphenyls and polychlorinated terphenyls should change th e ir form ulations to e lim in ate such chem icals eifh er as activ e o r in activ e in g red ien ts". As noted ab o v e, M onsanto f- e lim in a te d th e s a l e o f F C B Ts f o r s u c h a p p lic a tio n s . S u b seq u en tly , in Ju n e of 1971, the N a tio n a ljn d u s tr ia l P o llu tio n C ontrol C ouncil (E le c tric and N u clear Subcouncil) p u b lish ed "T he U se NEL 000342 and D isposal of E lec tric a l Insulating L iquids" and included in its re p o rt reco m m en d atio n s to m in im ize the p o ssib ility of en try into th e environm ent of P C B fs u se d in tra n s fo rm e rs and c a p a c ito rs. T h e se reco m m en d atio n s w ere la te r developed by a com m ittee of ANSI into a n atio n al stan d ard th a t in c lu d e s th e d isp o sa l of a ll s c ra p P C B 's by in c in e ra tio n to en v iro n m en tally h arm less m aterials. T hen in M ay 1972, the In te rd e p a rtm e n ta l T ask F o rc e on P C B 's, rep resen tin g five F e d eral A gencies, issu ed its fin al re p o rt, "P olychlorinated B iphenyls and the E nvironm ent". Among other co n clu sio n s, the re p o rt 782188 -9- found ju stific a tio n fo r continued u se of P C B 's in tra n s fo rm e rs and c a p a c ito rs . In D ecem ber of 1972, the Food and D rug A d m in istratio n announced (in an en v iro n m en tal im p a c t statem en t) te m p o ra ry to le ra n c e s fo r P C B 's in food (to b e co m e p a rt of a new " P a r t 122"). In D ecem ber of 1973, the EPA proposed effluent stan d ard s fo r v ario u s pollutants including P C B 's, th a t it had d e sig n ated as toxic P C B 's. As applied to one m a jo r tra n s fo rm e r m an u factu rin g p lan t, they w ould lim it ( th e d isch a rg e to 0. 00009 pounds (eal 1/2 drop) of P C B 's p e r d ay , w hich ___ is below the low er lim it of detection in the plant effluent. It is b eliev ed th a t the E n v iro n m en tal P ro te c tio n A g en cy 's p ro p o sed effluent sta n d a rd fo r P C B 's is u n ju stifie d . In d u stry e ffo rts to c o n tro l the d isse m in a tio n of P C B 's in th e environm ent have b een su c c e ssfu l. 4 F o r exam ple, stu d ies conducted at the W oods H ole O cean o g rap h ic In stitu te have shown th at th e PCB concentration in the e a ste rn and w e ste rn N orth A tlantic O cean have d e c re a se d fro m 30 p a rts p e r trillio n to 1 p a rt p e r trillio n fro m 1972 to 1973. F u r th e r , th e FDA h a s fa ile d to find any q u a n tifia b le r e s i d u e s o f P C B 's in fo o d s in i t s 10 l a s t m a r k e t b a s k e t s u r v e y s . E n tirely a p a rt fro m any question of the ap p ro p riaten ess of the proposed effluent re g u la tio n s, P C B 's a re d im inishing sig n ifican tly and ra p id ly in the environm ent. T h e re re m a in s som e question as to the in c lu sio n of P C B 's on a lis t of toxic p o llu tan ts. C ertain ly P C B 's a re not "highly tosdc to m an " as. p NEL 000343 782189 -1 0 - charact erized in the docum ent prom ulgating the lis t of toxic pollutants (38 F R 21342). The to x ic ity o f th e in d u s tria l fo rm u la tio n s h a s b e e n shown by the re p o rt of the In te rd e p a rtm e n ta l T ask F o rc e to be m any tim es le ss than the crite rio n referen ced by EPA fo r such classificatio n . SUMMARY It is v ita l th at th e u se of P C B 's in th e e le c tric a l in d u stry be *# continued. The u se of th is m a te ria l is req u ired fo r safety , fo r efficient e le c tric a l equipm ent, to m in im iz e the im pa'ct on th e e n e rg y c r is is , and to p rev en t costly and d isru p tiv e effects on th e e le c tric u tility in d u stry . F u rth erm o re, it has been shown th at the in itial a sse ssm e n t of environ m ental effects w as exaggerated. The to tal in d u stry has rea cte d vigorously to contain P C B 's and has achieved d ra m a tic re s u lts . It is reco m m en d ed th a t th e p re s e n t p ro p o sed EPA stan d a rd s fo r P C B 's should b e abandoned. In th e ir stead , w e w ould p ro p o se action to give th e tem pcaw ry san ctio n of reg u lato ry authority to the m e a su re s alread y taken by in d u stry to m aintain d i s c h a r g e s a t t h e i r c u r r e n t lo w l e v e l s , a n d tjo d e t e r m i n e th e n e e d f o r revision on a so u rce-b y -so u rce b a sis. ' NEL 000344 3-29 -74 782190 j J- V TI A ;C * N -J- ^ ;. p ',, ' .. S U 'i i J * 1 V '* /-/.* ' ^ in J>* 4 .0 'sJ R A L E L E C .T n iC CO M PAN Y, 1 P.'VcR ROAD. SCH EN ECTAD Y. .NEW Y O R K 123-15 Phom 51S 274-2211 PRODUCT GUALJTY STAr ? ?coj-jS2d PCB Standares bcc: A. *ozesky SM Richel ) JF McAllister)v/att. April 3, 1974 Mr. Richard L. Rollins Jard, Inc. P. 0. Bo:: 650 Bennington, Vermont 05201 Bear Mr. Rollins: Enclosed for your information is a copy of the letter sent to EPA by the Air-Conditioning and Refrigeration Institute, on the subject of the proposed standards for PCBs. Very truly yours, JS N :ev E n clo su re James S* Nelson, ConsultantProduct Environmental Compatibility NEL 000345 782191