Document vVg0B3Zy5ky5yE9OkKYa9z5Db

EPRI Electric Power Research Institute Topic*: PCB Chemical analytit Fir** Transformer* Pollution control tnaulating oil* EPH) EAIEI.-S612 Project 2028 ProcMdinga January 1988 Proceedings: 1987 EPRI PCB Seminar r Prepared by Elaetrlc Power Reaearch Institute Palo Alto, California HONS 217109 REPORT SUMMARY SUBJECTS Hazardous and toxic watt* management / Riak assessment and management methods / Transmission substation assign and opsration t Distribution substations TOPICS PCB Chemical analysis Firss Tranalormars Pollution control Insulating oils AUDIENCE Envlronmantal managers t Distribution anginaars Proceedings: 1987 EPRI PCB Seminar An EPRI-sponsored seminar explores the Increasingly complex issues of PCB menegement. This year, retrofit! and decontamina tion technologies discussed at the last ssminar are reaching maturity or are commercially available. Participants also ad-^ dretaed the necessity of spilt cleanup and methods that meat : that need. (PRt EA/EL-SItZ* BACKGROUND EPRI ragularty sponsors an industrywida samlntr to updats utllitiss on the nswast aquipmant and procasaaa tor managing tha complex problama poaad by potychtorlnatad blphanyl (PCB). Discussion topicj rangad from initial development of aquipmant and msthoda to procsasss now commar. dally avaliabta. OBJECTIVES lb provide a forum for discussing aquipmant and mathods for PCB managsmsnt; to avoid duplication of Fsstarch affort through an information exchange; to Inform aquipmant supplisra of utility PCB managamant nssda. APPROACH Approximataly 325 rapraaantatlvaa of utllitiss, govarnmant agancias, rastarch groups, and prfvata Industry from around tha world attsndtd a PCB ssminar hald Octobar 6-9. 1967, in Kansas City, Missouri. Mora than 60 prasantatlons aummartzad rasaarch in such artss as PCB dastruction, analysis, spill claanup, risk analysis, and firas, as wall as mintrai oil dacontamlnatlon and rttroflll and raplacamant fluids. PCB daatructlon discussions focuaad bn thtrmal traatmtnt ot PCB and PCB-contaminattd soils, as well at sampling and analysis criteria tor avaluatlng dastruction msthoda. Othar araas of discussion includad procaatat for rtmoving PCB from contaminatad trsnsformar oil and coolants, aquipmant for tasting PCB-contamineted soils, PCB tnvironmental transports, and pyrolysis and combustion of PCB' contaminattd trsnsformar fluid*. Stvtral papar* dascrlbad pilot plant projacta, cats atuditt damonttrating naw aquipmant, procattaa and claanup mathods, and commtrcial PCB removal procaatat. RESULTS Soma ttchnotogias dascrlbad at pravlout samlntrs hava advancad to com mercial or samicommarciai stag**. On* such.tachnology la rslrofilllng, rapiacing either PCB or contaminated oil with frash oil to raduc* PCB con tent, usually to below th* strictest EPA regulatory isval ot 50 ppb. improved techniques for decontaminating mineral oil containing PCB ar* commercially MONS 217110 available. Spill cleanup and disposal ot atkarei transformer carcasses are areas that stilt require improvements. Ongoing EPRI work (protect RP2028-19) is studying disposal techniques for detanking transformers and dismantling and cleaning components for scrap or disposal. epri perspective The large number ot people attending the 1988 PCS seminar reflects the need of those Involved In PCS management to discuss common problems and goals. Participants--nearly 125 of whom were from mem ber utilities--came from the United Stales, Canada. Great Britain, Bel gium, Mexico, and Japan. They represented many disciplines, including PCS analysis, risk assessment, and disposal, as well as research and development of equipment to facilitate these tasks. EPRI reports EL-2572, EL-3581, and CS/EA/EL-4460 present proceedings from ihe 1981, 1983, and 1985 seminars.. PROJECT RP2026 EPRI protect Managers: Vic Nlemeyer; GH Addis Environment Division; Electrical Systems Division for further information on EPRi research programs, call EPRI Technical Information Specialists (415) 855-2411. HOMS 217111 Proceedings: 1987 EPRI PCB Seminar EA/EL-5612 Research Project 202B Proceedings, January 1966 Kansas City, Missouri October 6-9. 1967 Edited by G, Addis Electrical Systems Division Prepared tor Electric Power Research institute 3412 Hiliview Avenue P(0 Alto, Caliiornia 94304 EPRI Project Managers V, Niemeyer Environmental Risk Management Program Environment Division G. Addis Transmission Substat'ons Program Electrical Systems Division *0*5 217112 OROERING INFORMATION RftgutSi lor cop># oi lh<t 'oon thould bo directed lo Research Report* Center (RAC). Box 50X90, Palo Alto. CA M303. (415) 065-4081. Thara <i no charge tor foporti reoueaed by EPRI memoer uiihtwt and efiMiait*. U.3. utility aaaocrabona, U.S government igancrat (iederel. Mte. and local), madia, and foreign organization* with which EPRI hat an irtornwtion exchange agreement On raquaat. RRC win *and a catalog of EPRI r*porta CMite Foi^r Amirai mawiae ana E*n art rtgiawtd tamct mar** <* monte hum hoeoortn InaniM me Copyignt 1MI Emerne Xonei hoeoaror mama* me. M ngnu reeervod. NOTICE Titi* report waa praoaraa ay me Eieone ^er Amirdi mamma. me (tear). Mannar tail, memoen el IPM. nor any pawn eating on ma* benax |a| manta any mnany. exprea or vnpaed. awn ratoee* to in* uao e* ary irtemtauen. tppowue. mamod. or oreeow oneioaao m iri recon or mat tueft uaa may noi rtrmga pnvaiaiy owned ngn or (0) aairrn any taWWaa wrim ceeoee to Iho uaa el. or lor oemaeea retuane Horn nta uaa . any mrormwon. aooerewe. mamod, or prosou oieooeod m inm report or <C| raaponawia Kn eewnera maoa or oenona oxpriaod Oy mennoual aviatort. ` MOWS 217113 ABSTRACT The 1987 PCB seminar continued EPRl's series providing timely Information on PCB research to utilities, regulators, and contractors. The papers In this seminar showed a significant Increase In technical level over those presented In the 1961, 1983, and 1985 meetings. Subjects covered In the three and one-half days meeting were: PCB Destruction Mineral Oil Decontamination Analytical Techniques for PCB* Spill Cleanup and Management Risk Analysis and Management PCB Fires and PCDF Analysis Retroflll and Replacement Fluids Miscellaneous Subjects 111 HONS 217114 1 V HONS 217115 ACKNOWLEDGMENTS We'would like to acknowledge the help of our session chairmen who kept the long meeting on schedule throughout. Claudia Runge again did a superb job on meeting arrangements and administration. Roseanne Frank and Yolanda Gale contributed both to the preparations for the meetings and these proceedings. Thanks to all. HONS 217116 HONS 217117 CONTENTS Section Prt Part 1: REGULATIONS Chair: Gil Addis. EPR1 1 UPDATE ON PCS REGULATIONS - Toni K. Allan ]-] 2 EPA ANO STATE REGULATION Of NON-PCB ELECTRICAL EQUIPMENT: 1-4? THE MYTHS ANO THE REALITIES Timothy S. Hardy 3 CURRENT STATUS ANO OPTIONS FOR HANDLING ANO DISPOSAL 1-47 OF PCB'S WITHIN CANADA - R. Baagla PART 2: RETROFILL A DISPOSAL Chair: Coray Tranch and John Woodyartf 4 AUTOMATED PCS TRANSFORMER FLUSHING AND SOLVENT RECOVERY 2-1 SYSTEM - K. C. Athlay 5 PCS RESIDUE IN ASKAREL AND CONTAMINATED OIL-FILLED TRANSFORMERS - T. 0. Rouse, W. A. Faailar, C. T. Raymond and G. Addis 2-5 6 PCS CONTAMINATED DISTRIBUTION TRANSFORMER RECLASSIFICATION STUDY - Paul J. Fray 1 CONTINUOUS COLUW TREATMENT OF PCI CONTAMINATION IN MINERAL OIL E0U1PHENT - Robert 0. Fox 2-6 2-14 I DESTRUCTION AND SALVAGE OF LARGE PCS TRANSFORMERS TO END 2-16 OWNER LIABILITY - F. J. Graham and W. H. Martin 9 OPTIONS AVAILABLE FOR ASICAREL TRANSFORMERS - T, Luby 2-20 vii HONS 217118 SUCCESSFUL FIELD PROCEDURES IN THE RETROFUL OF EUROPEANDESIGNED TRANSFORMERS Harry Clarke ?-27 IN-SERVICE RECLASSIFICATION OF ASKAREL FILLED TRANSFORMERS 2-31 UPOATE - Murray D. McMahon and Thores C. Venable SYSTEM 50*1* PROCESS FOR RETROFILL INS OF ASKAREL 2-41 TRANSFORMERS Michael J. Massey end David R. Hopper PROBLEMS ASSOCIATED WITH RECLASSIFIED PCB TRANSFORMER DISPOSAL * J.8. McOenwtt, R.K. Kufl end C.L. Cocelo 2-50 RETROFILL IN A REMOTE LOCATION OF NETWORK TRANSFORMERS USING THE WESTINGHOUSE SYSTEM * J.P. McPartland 2-57 EXPERIENCES FROM RETROFILLING ASKAREL TRANSFORMRS A TWO-YEAR SERVICE DATA PROGRAM - G. R. Atwood and W. H. Martin 2-60 ENVIRONMENTAL ALTERNATIVE TO LANDFILLING PCB TRANSFORMERS 2-61 - Dana S. Meyerj PART 3: MISCELLANEOUS Chair: Mitch Erickson THE FATE DF PCI's IN SOIL ANO WATER - John F. Brown, Jr., Robert E. Wagner, Donna L. Bedard, Jews C. Carnahan and Ronald Untennan 3-1 PCI-RELATED ACTIVITIES AT EPRI, 1986-1917 - Mery E. MeLearn TRANSFORMER LIFE EXPECTANCY - Steven C. Vick and Oennls F. Tulloh 3-5 3-9 ASKAREL TRANSFORMER RETROFILL - AN ANSWER TO COMMON 3-14 MISCONCEPTIONS - Dennis F. Tulloh and Steven C. Vick vlll - HONS 217119 Section Pace PART 4: DESTRUCTION Cnilr: Mary McLetrn SMALL-SCALE DESTRUCTION OF PCB FLUIDS BY ELECTRICALlARGE OISCKARGE PLASMAS * Richard W*. Tock end Don Ethlngton 4*1 21 TESTING OF TSCA INCINERATOR FOR DESTRUCTION OF PCB'S 4-11 IN URANIUM CONTAMINATED WASTES R. N. Anderson 23 ARC PYROLYSIS PROJECT - A PROGRESS REPORT Bruce Meyer, J. Kenneth wlttle tftd Chtrles Titus 24 ULTRASONIC PROCESS FOR THE DESTRUCTION OF PCB'S IN OIL AND SOIL * Marcus Slttenfleld 4*15 4-19 25 THE USE OF LIQUID REAGENT FOR IN-SITU TREATMENT OF PCB'S 4-21 IN CONCRETE ANO ON SURFACES - John P. Woodyard and Enzo M. Zoratto 26 PLASMA ARC DESTRUCTION OF HAZARDOUS HASTES 4-24 M. F. Joseph, T. B. Barton, S, C. Vorndran and W. h. Reed 27 CATALYTIC HYDROGENATION OF POLYCHLORINATED HYDROCARBONS 4-26 - K. J, Youtsey tnd D. R. Hedden PART 5: HEALTH EFFECTS AND RISK ASSESSMENT Chair: Jim Llngle 26 PCS TRANSFORMER FIRES: THE RISK IH NUCLEAR POWER PLANTS 5-1 - Kirk Blackmon 29 RISK ANALYSIS OF PCB SPILL CLEANUP OPTIONS S-5 - Oonald S. Wilson, Kurt D. Runke, Oavld Cohan, and Katherine Kahle Ik HONS 217120 Sctio p*Pe 30 POSSM: A TOOL FOR RISK ASSESSMENT OP RGB SPILLS SITES 5-9 - JIm Llngle 31 EMPLOTEE 8LOOO SCREENING FOR PCB EXPOSURE AT NORTH- 5-14 WESTERN RURAL ELECTRIC COOPERATIVE, INC. Mlchtel D. Tlrplk . 32 PCB MANAGEMENT IN A HILT I-PLANT CANADIAN CORPORATION 5-19 - H. Tcrossltn 33 CORROSION AND ITS COSTLY EFFECTS AFTER THE PCI FIRE 5-23 - Kirk BTtekiton, Ltrry Wood tnd HtuMe* Pumt 34 PCB-CONTAM1NATEO TRANSFORMER OIL SPILL EXPOSURE ASSESSMENT - S. M. Brown tnd W.J. Sh11dt 5-26 PART 6: SPILL CLEANUP Chtlr: R*1ph Kontl 35 THE PCI SPILL CLEANUP POLICT OF 19B7: SUMMARY AND IMPLICATIONS - Josopft E. Shofchok 6-1 36 ATTENUATION OF POLTCKLORIMATEO 11 PHENYLS - 0. C. Glrvln, 6-6 0. S. Skltrtw tnd A. J. Scott 37 EVALUATION OF DECONTAMINATION OF SOL 10 SURFACES EXPOSCO 6-11 TO PCI'S - Ann Btfley tnd Ktthlttn Kr*p* 31 RETROFILL REDUCES LIABILITIES RESULTING FROM A NETWORK 6-1B TRANSFORMER FAILURE - M*rt1n L, Hartley 39 CLDR-N-OIL TEST KIT AS A RISK MANAGEMENT TOOL AN UPOATE - Klrt W. Rhotds 6-27 HONS 217121 Section Ptoe 0 COMPARISON BETWEEN ESTIMATED AND ACTUAL PCB vapor EXPOSURES OURING A SOIL EXCAVATION PROJECT Janes Neeley and Colin Moy 6-31 41 STATISTICALLY VALID SAMPLING STRATEGIES FOR PCB CONTAMINATION - E. Ublnger 6-37 . PART 7: PCOF AND RELATEO COMPOUNOS Ch1r; Edo Pelllzzarl tnd Marcus Cooke 42 ANALYTICAL AND SAMPLING TECHNIQUES FOR THE DETERMINATION 7-1 OF ULTRATRACE QUANTITIES OF POLYCHLORINATED OIBENZOFURANS ANO OIBENZOOIOXINS - Mtrcut Cooke. Joseph A. Httchel, Jetn M. Czuezwt tnd Karen Degner 4} PYROLYSIS ANO COMBUSTION OF PCB ANO TCB AS CONTAMINANTS 7-9 IN TRANSFORMER aulOS - G. Etdon, R. Ntrtng, A. Ntrtng tnd K, Swanl <4 ULTRA-SENSITIVE BIOASSAY FOR DIOXIN - Richard F. Schuman 7-11 tnd Kenneth W. Hunter 45 BACKGROUND CONCENTRATIONS OF POLYCHLORINATED BIPHENYLS. 7-15 POLYCHLORINATED DIBENZD-P-DIDXINS. ANO POLYCHLORINATEO OIBENZOFURANS IN OFFICE BUILOINGS IN SANTA FE. NEW MEXICO - John R. Komlnsky, Warren T. Slade tnd Robert Mooring i 46 EVALUATION OF POTENTIAL HEALTH HAZAROS FROM FIRES 7-27 INVOLVING LIQUIO ANO SOLIO UTILITY MATERIALS - Philip H. Taylor, Sue L. Mazer, Debra A. Tlrey, B. Lawrence Fox, John G. Stalter, and K. Barrett Dellinger 47 FIRES INVOLVING LIQUIO ANO SOLIO UTILITY MATERIALS: 7-32 A POTENTIAL UTILITY CONCERN (II) PVC - ThoiMS M. Sick xl MOMS 217122 Sectl on Paoe 4B INTERLABORATORY COMPARISON OF PCDD ANO PCOF ANALYSIS 7-36 - E, 0. Pelllzzerl, K. Perrltt and T. Hartwell 49 PRODUCTION OF PCOF'S ANO RELATED PRODUCTS FROM PCB'S - 7-43 AN OVERVIEW - Mitchell 0. Erickson 50 DETECTION OF 2,3,7,B - TETRACKLOROOIBENZOFURAN ACTIVITY 7-4B IN DIELECTRIC FLUIDS BY AN EPITHELIAL CELL CULTURE BIOASSY - John F. Glerthy end David W. Lincoln PART B: RISK MANAGEMENT Chalriaan: Vic Nlemeyer 51 PRELIMINARY ANALYSIS OF RISKS ASSOCIATED WITH USE OF B-l PERCHLOROETHYLENE IN TRANSFORMERS - J. W. Hlrzy 52 MANAGING PCB RISKS IN POWER PLANTS Michael S. Johnson, 8-4 Donald S. Wilton and David Cohan 53 PCB RISK ASSESSMENT USING THE ASK MOOEL - Wesley A, Sprouse, Jr. 6-8 54 RISK ANALYSIS OF USING PCB FILLED TRANSFORMERS IN INDUSTRIAL ANO RESIDENTIAL APPLICATIONS * R. Bel nans, K. Hesel. A, Peytltr, W. Geyson B-12 PART 9: OECONTAMINAT ION OF OIL Chair: Ton Rouse 55 GE'S NON-SODIUM PROCESS FOR CHEMICALLY DECONTAMINATING 9-1 MINERAL OIL OIELECTRIC FLUID C. W. Horneek end C.L. Coccio 56 THE VALUE OF OEHYDRATION PRIOR TO RETROFILL OF LARGE 9-8 PCB-CONTAINING TRANSFORMERS Felix F. Velazauez xll MOWS 217123 Section P*oe 57 COMMERCIAL NON-SODIUM TREATMENT OF PCD CONTAMINATED 9*12 . MINERAL OIL - John p. Woody*rd *nd Jurgen Exner 5B GEORGIA POWER'S SOLVENT EXTRACTION PLANT TO REMOVE PCB'S 9-1B FROM MINERAL OIL - P.F. Way PART 10: PCB ANALYSIS Chair: Jacoues Guertln 59 PCBA-IOZ UPDATE Eugene A. Burnt 10-1 60 CHROMATOGRAPHIC ANALYSIS OF PCBS IN TRANSFORMER OILS: 10*5 A MINI-ROUND ROBIN - G. Addis end T. Route 61 INCREASING THE ACCURACY OF THE GC/ECO AND GC/HECD QUANTITATION OF PCB'S USING A NEW PCB ANALYTICAL STANOARD - Steve T. Turner ind Robert Scuderl 10*8 62 PCB SYSTEM INVENTORY: TO PREDICT PC8 CONTAMINATION 10-14 IN ELECTRICAL EQUIPMENT - C. Col Ten Meroultt 63 FIELD DETERMINATION OF PCBS IN GAOUNOCOVEA - Luciano A, Gontaltx and James S. Ferrle APPENDIX LIST OF ATTENDEES ID-22 A-l HONS 217124 xi 11 PART 1: REGULATIONS r r HONS 217125 UPDATE OK PCS REGULATIONS An Addrttt by TOKI K. ALLEN Piper & Mtrbury Wnbington, D.C. EPRI PCB Senlntr Kama* City, Mlaaouri October 6( 1967 M HONS 217126 I. II. III. IV. Arai ta bm Addrea<l PCS Spill Cleanup Requirements Change* In the Rule* Affecting the u*e of pcs Transformers - 92 Fed. Reg. 3173# {Aug. 24, 1987) Chtng** in th* Rules Affecting th* U** of PCB* In Concentration* Under 50 ppm - 52 Fed. Reg. 25B3S (July B, 1987) Disposal of PCB*: to bo or dot to Bo Undor RCRA Material* Attached 1. H.R. 2685 submlttod by Rop. MeCloskey 2. H.R. 3070 submitted by Rop. Syntr 3. Tho coalition group's regulatory proposal to EPA 4. EPA's response to the coalition 1-2 HONS 21712? For the*# of you who do not know mo, J must begin by stating that for the past B yaars J hav* been legal counsal to tha alactric utility Industry on FCB lssuas. It is a wondar to saa all of you hara this morning, still faselnatad with PCBs alavan yaars aftar tha passaga of Section 6(a) of tha Toxic Substances control Act which specifically regulated tha substance. This turnout Is either a great tribute to EPRX and Oil Addis or a reaffirmation that in 1976 congress created yet another relief act for lawyers, consultants, regulators, vendors and assorted others. Oil Addis asked me to open the program by updating what has happened to PCBs on the federal regulatory front since the last seminar in early 1916. Given the longevity of the PCB regulatory program, one might think that such a review would be quite short. Surely, by now, you would think the program must be fairly regularised and unchanging. The opposite is true in fact. A fair amount has happened over the last 20 months. These activities fall roughly Into four areas: 1) establishment of i 1'3 HONS 217128 pacific tplll cleanup requirement*; 2) changes to tha 1985 regulation* affecting the uae of pcs* In PCS Transformer*, 3) change* to the regulation* affecting the use of PCS* In concentrations under 50 ppm, and, finally, 4) the apparent resolution of the question whether the regulation of PCS disposal would be transferred from T6CA to the Resource Conservation and Recovery Act (RCRA). A faw of thasa matter* will be addressed in detail by latar speakers! I win therefore try to restrain my remarks so as not to intrude unduly into their efforts. However, to sat tha staga for thasa spaakars and provida a backdrop for tha weak's presentations, I will run through thasa four significant actions. Spill Cleanup Requirement* EPA's PCB spill cleanup requirements under TSCA were signed by the Administrator on Karch 20, and published April 2, 1957, in the Federal Register (52 Fed. Rag. 10588). This action ended a lengthy period of negotiation, agitation and frustration that began about four years ago when the issue of spill i 1-4 MQNS 217129 cleanup wa first discussed by the utility industry with the Agency. Early In those discussions, th* electric utility industry presented s study to EPA urging s performance standard approach to cleanup. EPA listsnsd, but thst was about sll. Thsn in Mty 1965, the utility group joinad in the development of s consensus proposal with NEKA, CMA, EOF and NRDC in which the clsanup requirements wars bassd on the mass of ths PCBs spilled and tht locstion of ths spill, including a performance-based approach for contsminatsd mineral oil spills -- that Is. for spills of fluid containing a PCB concsntrstion of 90 ppm and over. EPA did not act on ths proposal until ths lats spring of 1966. st which tints ths Agency raised concerns about several of ths provisions in ths consensus. Further discussions ensued with EPA during the summer of 1966. followed by additional discussions among the consensus groups. A revised 1-5 MONS 217130 consensus egreement ves submitted to EPA in October 19S6 in en ttmpt to deel with torn#, but not til, of EPA's concerns. Thus, elthough ctrtsin chenges were mede in ths October 1986 Agreement, the beslc structursl spprosch remeined the stme, including continustion of performence-besed, visible ttece/vesh-vipe clesnup requirements for contsminsted minersl oil spills (sgsin only those from s source contsminsted with SO ppm or more of PCB), The EPA requirements reflect the bssic structure proposed by the consensus group by imposing different clesnup requirements bssed on the mess of PCBs spilled end the locstion of the spill, in eddition, other very importsnt sspects of the consensus slso were sdopted, such ss: the visible trece/double vesh-vipe spprosch for contsminsted oil spills; the soil clesnup stenderds for most substetions; the svoidsnce of penslties for improper dispossl if there is good fsith complience with the clesnup requirements, end imposition of nstionsl clesnup stenderds for the vest mejority of spills. 1-6 MOWS 217131 Along with th* good, of court*, cu>* tom* chtng*t which w*r* not welcome; but mor* of this lat*r. In brl*f, th* mor* tignlfietnt r*gulr*m*ntt cov*r th* following matters: Scop*; Th* r*gulr*m*ntt became *ff*ctiv* May 4, 1987, and apply to th* cleanup of now tpillt from tourc*t contaminated with PCS* In concentration* of 50 ppm and abov*. Spill* directly Into water, t*w*rt, v*g*tabl* garden* and animal grating land are not covered and will be contidered by th* region* on a site-by-sit* basis. Thlt approach varies somewhat from th* consensus agreement which only excluded spills into water and sewers. Definition of Spills; Adopting th* language contained In th* consensus proposal, a weep is not a spill. 1-7 MOMS 217132 Mae* of FCB* Spilled: Th* requirement* dlstingulah between apllla Involving at laaat 500 ppm or more than on* pound of FCB* varaua thoa* balov 500 ppm and on* pound. Thia demarcation la not exactly aa propoa*d In th* conaenaua, but It la largely th* earn* aa a practical matter. Low Concentration soillet A vlalbl* trace/doubl* vaah-vlp* atandard appll** to all apllla under 500 ppm, aaaumlng lea* than one pound by weight of FCB* 1* apllled, wherever located a* propoaed In th* contenaut. Mineral oil equipment that 1* not teated can be atauaed to contain leaa than 500 ppm at eet forth in th* current regulation*. One important change, however, i* that cleanup muat be completed within 48 hour*, where**, under th* coneenaua, cleanup only had to be Initiated within that time. There are exception* for bad weather condition*, operating emergenciea, etc., a* propoaed in th* contenau*. in addition, if the aplll reach** an indoor, retidential turface, that aurfac* muat be cleaned to 10 ug/100 cm'. 1*8 HONS 217133 HiqhT Concentration Spills: The cleanup requirements foe spills of 500 ppm sniJ greeter (or more thsn one pound of PCBs by weight) vtry depending on location, Sows changes have been mtde In both the definition of the various locetlons and the levels of cleanup required. The beslc distinction among substations, other restricted trees and non-reetrlcted areas (residential/commerclal area In EPA'S parlance) are retained, but with some changes that still may be significant. For example. EPA accepted the consensus soli standard of 25 ppm or 50 ppm with a posted notice for the outdoor substations, but removed the wash-wipe (plus notice) performance standard option for solid surfaces, reguiring instead cleanup to 100 ug/100 cm*. EPA also adopted the alternative of getting regional guidance if meeting these standards would jeopardize the structural integrity of the substation. EPA. however, defined outdoor substations to Include only those that are at least 0.1 km from a residential/commerclal area, Similarly, other 1-9 217X34 Because of their concern about such a result, tht utllitlta approached EPA on this issue. Specifically, wa urged EPA to tat aside the 0.1 km limitation. EPA, however, had bated this limitation, at least in part, on its risk assessment and would not delete the 0.1 ka limitation until further analyses are made. The Agency, though, did recognise the problem and clarified that for purposes of measuring the 0.1 km distance, the measurement can be taken from the actual spill site to the building in which people live or work. Thus, measurements from property lines, roadways and fence lines need not be made. We obtained a letter from EPA confirming this clarification just before the requirements became effective. 1-10 HONS 217135 Another major chan?* from the consensus agreement involves the cleanup standard for Indoor vaults. Under the consensus, all of these vaults would have bssn classified as restricted access areas snd the owner of the equipment would have the option of using s triple wash/wlpe approsch to solid surface clesnup or to sample snd clesn to a level of 100 ug/l00cm'. EPA, however, classified all of the vaults in a way that requires additional cleanup and removes the performance bssed option. Under EPA*s approach, if the vault is in an industrial location, there is an option, but the option is to clean up to 10 ug/100 cm' or to 100 ug/100 cm1 plus encapsulation. If the vault is within a residential/comnercial area, there is no option and cleanup is to 10 ug/100 cm'. Encapsulation is not yet defined, but EPA has indicated that encapsulation includes painting, although its clear preference is for an epoxy-typ* application. Another change from the consensus involves the cleanup level for soil in residential/commercial areas. EPA'e standard if set at 10 ppm plus a 1-11 MOHS 217136 10-inch cap. This change was on* we expected, but do not welcome. In addition, solid surface cleanup requirements for reaidentlal/commercial areas are more stringent than proposed by the consensus group and largely require clean up to 10 ug/loo cm1. These requirements are confused by adding distinctions based on whether the area is low-contact or high-contact, indoors or outdoors, and whether the surface is impervious or non-impervious. All of these terms are specifically defined; however, in general terms, cleanup to 10 ug/100 cm* is required for sidewalks and most everything else in or around a house or populated building. An option is provided to clean up to 10 ug/100 cm* or 100 ug/100 cm' plus encapsulation for wooden utility poles, roofs, and asphalt or concrete roadways. Reporting; One change that initially appeared to be significant seemed to require a report to the regional offices for all spills over 50 ppm involving at least 10 pounds of PCS material (i.e-, 10 pounds of contaminated oil). This provision may have been based on the OTS office's misunderstanding 1-12 MOMS 217137 of the Superfund reporting requirement!> or something more elnlcter may have been Intended. Whatever, CPA clarified that lte "Intent'1 waa to carry forward the Superfund requirement; thue only apllla Involving 10 pound! of PCB! by weight are reportable. Thle "clarification'* alao la included In the letter I received. The reporting requirement!, however, nonetheleee expand previoua standard! by requiring a report to the EPA regional office of apllla gf any alte (SO ppm and greater) into surface waters, sewers, drinking water, grazing lands and vegetable gardens. Ability of Regions to impose Wore Strleent Requirementst For industry, one of the more advantageous provisions involves the Issue of compliance and what the regions and the enforcement offices can and cannot do. Thus, for spills covered, a region cannot impose a more stringent requirement unless it first consults with the director of the Office of Toxic Substances in Washington, makes a 1-13 MONS 217138 t pacific finding regarding tht naad for tht addad claanup and notifiat OTS of this finding prior to implamanting tha claanup. On tha othar hand, ragion* can allow las* stringant claanup* in particular situations; hara, all tha ragion naad do 1* notify OTS of its dacision and tha raason tharafor. finally. If tha claanup ragulramants ara followad, thara can ba no anforeamant against tha spill itsalf as impropar disposal. futura Us a.* As a last ltam, lat ma want ion what happana whan tha usa of tha land changas. Our lntarpratatlon Is that this should lnvolva a changa in ownarship as wall as usa, but tha provision could ba raad much more narrowly. Tha consansus proposad that whara tha uaa changad, tha proparty would ba claanad to tha laval astoclatad with that usa. EPA modifiad tha provision to raguira claanup to tha most strlgant standard whanava: tha usa changad. Thus, as I raad It, if a substation wars sold for industrial usa, tha land would hava to ba claanad down to 10 ppm. 1-14 HONS 217139 Miscellaneous; Other aspects of the requirements largely incorporate the concensus approach, *.9., definition of spill area, recordkeeping requirements end ssmpllnq methods. While EPA edopted some of the consensus qroup's proposal*1 several of the requirements are provinq to be infeasible. Most notable are the standards for cleaning vaults and substations. In addition, EPA has raised the question of whether these or other uniform standards should be adopted for cleanup of old spills. The utilities are therefor* again gearing up for another round of data gathering, argument, persuasion and negotiation. Use of PCf Transformers The next two areas of activity affecting the use of PCB Transformers, on the one hand, and the use of PCBs In concentrations below 50 ppm, on the other, both emanate from judicial challenges to rules earlier adopted. 1 will discuss each of these actions in turn. 1-15 HONS 217140 As you may recall. In July 19S5, EPA issued new rules substantially restricting the use of PCB Transformers in or near commercial buildings -- here we are talking only of transformers that contain PCBe in concentrations of 500 ppm or more. Those rules also grew out of an earlier challenge to the 19S2 use rules, which in turn were issued in response to a challenge to the original 1979 use rules. To bring the matter a little more down to earth, let me only go back to the 19B2 rules in which, with one exception relating to food and feed facilities, EPA permitted the continued indefinite use of PCB Transformers. An appeal of that determination was filed by the Environmental Defense Fund and the Natural Resources Defense Council. That appeal eventually was settled when EPA agreed to hold a new rulemaking relating to the use of PCB Transformers and the effects of their involvement in fires. 1-16 HONS 217141 That rulemaking culminated In July 1985 when EPA ieeued amended rule* teverely restricting the use of FCB Transformer* in or near commercial building*. In brief, the changes: - Prohibited the installation of a PCB Transformer in or near commercial buildings as of October 1985. Prohibited the use of higher secondary voltage network PCB Transformers in or near commercial buildings as of October 1990. - Required the installation of certain protective equipment on lover secondary voltage network PCB Transformers and all radial PCB Transformers in or near commercial buildings as of October 1990, and - Provided certain registration requirements to building owners and fire departments by December 1985. 1-17 HONS Judicial review of these cult* was sought by Mississippi Power Company. Negotiation* ensued to resolve several issues for nearly year. These matters Included the prohibition on th* reinstallation of PCS Transformers after October l. m3, the requirement to install certain protective devices on lover secondary voltage network PCI Transformers in or near commercial buildings by October 1*90, and the absence of a time schedule in which to comply with many of the requirements if a mineral oil transformer assumed, as allowed under the rules, to contain under 300 ppm of PCBs, later was determined to have a concentration above that level. The negotiations were concluded in the fall of 19S6 and a settlement agreement between Mississippi Power, SPh and the Department of Justice was submitted to the court. The settlement covered a number of areas. 1-18 MOMS 217143 For example, tvo provisions in the July I9s$ rules posed particular practical and technical problems. The first concerned the prohibition on the installation of a PCB Transformer after October l, 1*$3. The seeond involved the requirement to provide electrical protection for lovar secondary voltage network PCB Transformers. A third major concern focused on the failure of the rules to provide any time frames for complying should a mineral oil transformer later be determined to be a PCB Transformer. Tvo important concerns were raised regarding the prohibition on installing a PCB Transformer in or near a commercial building as of October 1. 19S3. The first involved a situation where an outrage could oeeur depriving customers of service if a replacement PCB Transformer could not be installed. The second involved the "Catch-22" circumstance of retrofilling a PCB Transformer for purposes of reclassifying it and yet being unable to place it into service so that it could meet the 90-day in-service requirement to 1-19 HONS 217144 qualify for such reclassification. EPA recognized both of these practical concern* and was affirmatively recpontlvo on thaaa issues. The Agency`a willingness to change the requirement for additional protective equipment for the lover secondary voltage network transformers was somewhat less enthusiastic. Much Information was submitted to show the addition of this protective equipment is in most esses technically and economically infeasible. The dispute therefore focused on the time frame in which this equipment will be phased out and resulted in a different schedule applying to network transformers in sidewalk vaults ts opposed to such equipment inside buildings. In the latter case, non-sidewalk vaults, there is a choice: protective equipment by October 1990, or removal or retrofill of the PCS Transformer by October 199). PCS Transformers in sidewalk vaults are to be removed or retrofilled to below $00 ppm by October 1993. 1-20 HONS 217145 The third principal area of concern, as I id, focused on the question of vhtt you have to do vhn, after you discover thtt minor*1 oil transformer, permitted under the rules to be considered to be PCB-Contaminated Electrical Equipment, actually contains PCBs in a concentration of 500 ppm or more. This problem, of course, has always existed in terms of complying with the marking and inspection requirements, but the matter became more acute with the changes imposed by the July 1905 rules. A reasonable schedule was agreed upon that addresses each of the added requirements that would attach to the continued use of sueh a transformer. A number of other concerns also were raised regarding the practical application of the rules. For the most part, satisfactory elsrifieations have been made in Q and A form published in the Federal Register on December 31, 19ftt. The provisions include the definition of residential property, the notification required to be made to building owners, the storage of combustibles, the question of whether a fuel oil storage tank is a combustible material as i-a HONS 217146 that term la used in the rules -- it la not -- and the question of whether an offlea facility vithin an induatrial plant la a commercial building -- it may ba dapandlng on eartaln factora. To furthar implement tha aattlamant, EPA publlahad propoaad changaa to tha rulaa in tha federal Register on August 21, 1987. Tha proposal tracked tha provlalona agraad upon, but EPA raiaad tha poasibility of modifying a eoupla of tha propoaala and aought commont on thoaa mattara. for axampla, tha aattlamant would require nawly-dlacovarad PCS Tranaformara to ba ragiatarad vithin 30 day* of idantificttion. Tha question of whathar thia tima frame ia too long la raiaad. In addition, EPA aakad whathar a deadline ahould ba placed on tha tima period allowed for raclaaaifieation of a PCS Traneformer. Commenta on tha propoaad rule changaa vara due October 3. Tha utllitiaa have opposed changing tha 30-day ragiatratioa requirement and have argued that no deadline ba placed on tha time period allowed for reclaasification, or if one ia imposed, that it ba no ahortar than 3$ months. l-ZZ HONS 217147 Under the settlement final rule is expected in lste spring 19M. Even with the settlement, though, the reel impaet of the July 1985 use rules is thet s large proportion of PCB Transformers vill be removed from service over the next several years at great cost. I only hope that the materials used in substitution are free from the problems that have been perceived about PCSs. Under 50 ppm Changes affecting the use of PCBs under 50 ppm also have been proposed recently to implement a settlement reached following a judicial challenge to the July 1984 incidental generation rule. The proposal was published July 8 in the Federal Register and the comment period closed September s. Tim Hardy, who speaks next, will talk broadly about the myths and realities of EPA and state regulation of so-called non-PCB electrical equipment. Let me. therefore, just outline some of the changes EPA proposed and the reaction of the utility industry to those changes. 1-23 HONS 217146 In brief, the current proposal expands the category of materials that are excluded from regulation and addresses several conditions that will and will not apply. Thus, EFA proposes - to eliminate the requirement for workers to wear Viton elastomer gloves when working on heat transfer or hydraulic systems j - to exclude from the TSCA bans, produets containing less than so ppm PCBs and to allow the continued use and distribution in commerce of component parts derived from the rebuilding or salvaging of electrical equipment containing PCBs at levels less than 30 ppm. and - to allow the recycling and burning of used oil containing less than $0 ppm pcBs, subject, however, to certain conditions. The utilities were generally supportive of these proposals, with certain exceptions. 1-24 HONS 2171*9 Specifically, th* utilities urged EPA to exempt from *11 regulation th* burning of used oil containing concentration* of PCB* lets than 50 ppm in utility boilers and to *xpand th* product exclusion to p*rmit th* us*, processing and distribution in commerce of component parts from PCB-Contaminated Electrical Equipment, i.*., parts from equipment that contained PCBs in concentrations between 50 and 500 ppm. EPA generally proposes to exclude used oil containing under 50 ppm PCBs from the prohibitions of TSCA Section 6(e), by including such material within the elass of "excluded PCB products." The Agency conducted a comprehensive analysis of th* risks posed by these materials and correctly, the utility industry believes, determined that the minimal risks presented by materials containing less than 50 ppm PCBs are far outweighed by the enormous costs associated with regulating these materials. To fall within th* exclusion, however, burning of under-50 ppm used oil must be oonducted in 1-25 MOWS 217150 certain units, Among these units would be "qualified incinerators," which include high stridency boilers thst operate under the conditions now set forth in the TSCA regs, ss well ss lndustrisl boilers end furneees allowed to burn off-specificstion used oil fuel under the RCRA rules. Notwithstanding EPA's findings thst the burning of used oil in '`qualified incinerators" and industrial boilers and furnaces does not pose an unreasonable risk to health or the environment, the Agency nonetheless proposed to Impose certain notice and certification requirements on owners and operators engaged in these burning setivities (1.a.. "burners"). Specifically, the proposed regulations would require that before a "burner" accepts the first shipment of used oil containing less than $0 ppm POs from a marketer, the burner would have to provide the marketer with a one-time written and signed notloe certifying that the burner had complied with the "notification requirements" applicable to (1) qualified incinerators under TSCVs PCB control program or (2) industrial furnaces or boilers under ItCItVs used oil burning rule. 1-26 MQNS 217151 The utilities believe thet requiring qualified burners of used oil containing less than SO ppm PCBs -- particularly owners and operators of utility boilers -- to notify EPA of their burning activities is not only unwerranted from n environmental perspective, but equally important, will significantly deter otherwise quelified burners from engaging in used oil recycling activities. Indeed, the Agency itself acknowledges that such controls may be unwarranted; it states that the submission of comments "regarding actual boiler combustion conditions and overall impact of the proposal on the recycling of used oil" may persuade EPA not to impose any controls on the burning of used oil containing under 50 ppm PCBa, including the above-*referenced notification requirements. The Ageney's primary concern underlying the proposed controls on burners is the potential for the formation of polychlorinated dibenzofurana ("PCDFs") resulting from the incomplete combustion of used oil. As the Agency itself recognizes, however, the potential for PCDF formation during the burning of 1-27 MOMS 217152 used oil containing under 50 ppm PCBs in qualified combustion units is insignifiesnt. In ftct, in s study conducted by EPA's Offlc* of Toxic Substsncss v*lusting tht influsnts And sfflusnts from ssvsn coal-fired utility boilers, th* Agsncy detected na level of PCDFs from sny of ths msdis ssmplsd from tht stvon utility boilers analysed. This result is to be sxpocttd in view of the fset thst temperstures in the mein furnsce chsmber of utility boilers generally sre in excess of 1,500 degrees centigrade, far above the 270 to 700 degree centigrade range where PCBs have been shown to be precursors to PCDFa. Moreover, temperatures in the furnace outlet of utility boilers range anywhere from between 1200 to 1300 degrees centigrade, sgain, far above the temperatures where PCB combustion mey lead to the formation of PCDFs. Finally, the residence time of fuel in the combustion sone of a coal-fired boiler is approximately 1.57 seconds, with an additional 3.22 seconds to the base of the superheater platens under maximum operating conditions. 1-28 MONS 217153 In short, duo to high boiler tomporituros and relatively long rtsidtnco tints, tht potential for PCDF formation from tht burning of ustd oil containing undtr 50 ppm PCBs in utility boiltrs is virtually nil, snd etrtainly dots not "prtstnt an unreasonable risk to htalth or tht tnvironmtnt." Not only is tht propostd notification rtguirtmtnt unwarranttd from an tnvironmtnta1 ptrsptctivt, but such controls would also havt a "chilling tfftct" on utilitits wishing to tngagt in ustd oil rtcyeling activities. Simply put, tht Imposition of any additional rtgulstory controls -- including notification rtguirtmtnts -- on ustd oil burning activitits may wtll strvt as a disincentive to tngagt in such practices. Specifically, tht industry is wary of tht fact that a purportedly innocuous notification rtguirtmtnt (such as exists today to burn S0-500 oil) can and hat been ustd as a "hook" by regulatory authorities to impost operating controls on PCS management operations which go far beyond tht scope of tht applicable regulations. Thi over-reaching on behalf of enforcement personnel has 1*29 HONS 217154 resulted in many utilities shying away from the use of their boilers to burn used oil containing PCBs in concentrstions between 50 to 500 ppm, although they otherwise easily meet sll of the criteria specified in the regs. In addition, s simple notification submitted to EFA declaring thst s fsellity is engaged in the burning of used oil contslning PCBs -- no metter how small the concentration or how safe the practice -- is often the basis of unwarranted public outcry and the genesis of groundless litigation. In sum. there is no reason to require notification from an environmental perspective and every reason to withdraw such a requirement. The imposition of a notification requirement on utilities burning used oil containing less than so ppm PCBs will serve as a significant deterrent to qualified utility boilers recycling this valuable material. This result is completely antithetical to EPA's stated goal of encouraging used oil recycling in qualified combustion units. Accordingly, USWAg urged 1-30 HONS 217155 SPA to Abandon the proposed burner notification requirement aa it applies to utility boilara burning used oil containing undar so ppm PCBa. Looking now at tha propoaal regarding component parts EPA propoaas to extend tha dafinition of "excluded PCB products" to thoaa products which eonaist of eomponant parts darivad fton tha rabuilding or salvaging of alactrical equipment containing PCBs at lavals lass than $0 ppm, Tha proposal doss not go far enough, however. EPA acknowledges that "recycling activities involving thesa component* Ido not] present any significantly greater risks than other activities connected with tha unrestricted use of 'non-PCB' alactrical equipment." Tha same conclusion applies to the recycling activities involving components darivad from tha unrestricted use and servicing activities of PCB-Contsminated Electrical Equipment. EPA previously has determined that the unrestricted use and servicing of PCB-Contaminated Electrical Equipment does not pose an unreasonable risk of 1-31 HONS 217156 Injury to human health or th# environment. Therefore, no reason exists to restrict th* use and distribution in commerce of components dorlvod from such activities. Th# utilities, therefore, urged EPA to #xp#nd th* final rul# to lnelud# within th# definition of H#xclud#d PCS products'* tbos# product* whieh consist of components/psrts d#riv#d from th# rebuilding or salvaging of PCB-Contaminsted Electrical Equipment. Raoulation of PCB Disposal: To # or Mot to B# RCAA7 L#t m# clos# this report by briefly commenting on an upcoming matter, the question of whether the regulation of PCB disposal would be transferred from TSCA to RCRA. About one year ago, EPA established a working group within the Office of Solid Kaste to develop regulations that would transfer the regulation of PCB disposal from TSCA to RCTA. It was generally understood that the impetus for EPA's action stemmed from statements made by Lee Thomas, 1-32 HONS *17157 when he was Assistant Administrator for Solid waste, to tha Committee of Conference on the 1984 RCRA amendments that PCBs vould be brought into tha RCRA program. In addition. Congrasslonal inquiries during tha summer of 1986 eoncarning a faw facilitlas handling PCBs raisad concarns that tha T8CA program might not ba adequate. Spaclfically. haarings had baan hald by Rap. Synar of Oklahoma eoncarning disposal practieas and tha Rosa Chamical facility in Missouri and by Rap. McCloskty of Indiana eoncarning tha siting of Unison's plant in Kandarson, Kentucky. At about this sama time, a combination of industry and environmental groups vara eomplating discussions with EPA eoncarning PCS spill claanup requirements. Tha eonvarsations inavitably turnad to tha question-of what, if anything, EPA was going to do in rssponsa to tha concarns raisad in Congrass and statamants by thosa within tha Agancy that tha regulation of PCS disposal would ba brought into RCRA. While tha consensus group had diverse views on tha ultimata resolution of the spill cleanup requirements, there was unanimous agreement within 1-33 HONS 21715Q th* group that not on* of thorn was anthuaiaatic about moving th* PCB diapoaal program to RCRA and aotn* war* outright oppoaad to auch an *nd*avor. Thara alao appeared to b* a willingness on EPA'a part to diacuaa th* iaauea on a cona*naua baa la, in part drawing on th* procedure* followed to addreaa the apill cleanup iaauea. As a result, beginning aome time laat fall a aerie* of informal diacuaaiona ensued, principally at the regueat of industry, to review the gueation* of whether the PCB disposal program should be transferred to RCRA, what problems auch a transfer would cause, and whether there were alternative solutions to th* perceived deficiencies -- putting said* whether those problems ware genuine from an environmental perspective or merely political. Over the next several months -- really into the spring of this year -- a number of exchanges too* place with EPA concerning th* myriad of issues arising from any proposal that would transfer the PCS disposal program from RCRA to TSCA. Suffice it to 1-34 HONS 217159 aay, th*t many of theae probleraa were major and were recognized at auch by EPA Thar* emerged qulta toon from thata dlteuttiont a dacldad narrowing of vhat tha raal conearnt wara; thay includad, manifmating, idantification of brokert, financial retponaibility, and parmitting raguiramanta. In addition, it vat claar that changat would hava to ba mada in tha EPA anforcamant program to avoid or at laatt minimize tha conearnt that davalopad following an axamination of tha hiatory of anforcamant at tha Rota Chamical aita and at a faw othar facilitiaa. For axampla. Rap. Synar again hald haaringa in April 1987 focuting on tha Rota Chamical cate. While tha attempt to cauaa a aanaation with an unidentified, maaked, aacrat witneta later backfired whan tha vitnett recanted hit tettimony, it vat navarthalaaa claar that anforcamant afforta had parhapa bean laaa forceful than required. 1-35 HOMS 217160 All though this period the utility industry and others urged PA and interested members on tha Hill to act undar TSCA to implement any naadad modification* tinea this approach would provide an orderly and cott-affactive accommodation to tha concerns raised. At time want on, w* began to receive signals that EPA was seriously changing court* back to TSCA. Congressional staffers to whom I spoke clearly wanted n*w initiatives from EPk on manifesting and permitting, but they teemed lest concerned over what statute underlay those controls than the need for timely action. While no specific announcements have been made by EPA, the matter seems to rest squarely on the TSCA side of the house today. The leader of the RCRA working group hae been reassigned, and the Chemical Control Branch within the Office of Toxic Substances is developing new regulations. On the Kill, things are less clear since new measures proposed go in .diverse directions. 1-36 HONS 217161 H.R. 2685, submitted by Rep. McCloskey, would apply >11 of the regulations under Sections 3004 end 3005 of RCRA relating to the siting of disposal, storage or treatment facilities to all new and existing facilities treating, storing or disposing of PCBs. The bill, in my view, would create an impossible, if not chaotic, situation, if adopted without change, it imposes, rather than confronts and solves, most of the major and minor problems recognised early on when a possible wholesale transfer of the FOB disposal program from TSCA to RCRA was discussed. The bill was referred on June 24 to the Subcommittee on Transportation, Tourism and Kasardous Materials of the House Committee on Energy and Environment. The Subcommittee is chaired by Rep. Luken of Ohio; Rep. Dingell of Michigan chairs the full committee. The second bill, H.R. 3070, was submitted in August by Rep. Synar. It seeks to fill certain perceived gaps in the TSCA regulatory program by requiring manifesting, permitting of intermediaries -- that is, brokers and others who arrange on a 1-37 MOMS 217162 commercial batia for remuneration for tho tranaportation, treatment, storage or diapoaal of PCB waata for others, and tha implementation of financial responsibility requirements for thaaa middlemen. Thia bill, too, waa rafarrad to Mr. Luken's aubcommittaa. Turning back to EPA, activities at the Agency roughly fall into two categories. Tha first activity, known as the National Evaluation Plan (HEP), involves a review of enforcement initiated by the Office of Toxic Substances last October. That effort was an attempt to respond to external criticisms of EPA'a enforcement program and the aotivities, or lack thereof, of the regions. The program was completed in Hay. Mhile I have not seen the report, it is my understanding that the most significant recommendation is that the headquarters office maintain closer oversight of the regions, particularly regarding implementation and enforcement of disposal facilities. Steps, 1 understand, are being taken to implement this recommendation. 1-38 HONS 213163 The second activity was triggered -- or at least prodded if not triggered -- by the submission of suggested regulatory language by the industry and environmental coalition. These proposals cover manifesting, permitting for intermediate activities, identification of commercial storage facilities and an attempt to regularise permitting conditions for disposal facilities by requiring implamentation of certain training programs, the establishment and implementation of closure and post-closure plans, and a demonstration of financial responsibility in connection with closure and post-closure activities. In large measure these proposals are similar to the changes contemplated in Rep. Synar's bill, but they would provide a bit more flexibility for the regulated community. The coalition recently received a response to its proposal from ERA. The Agency expressed its agreement with the group "that the necessary changes can be accomplished more expeditiously through . regulatory amendments based on existing. TSCA authority than through mandated changes." EPA also 1-39 MONS 217164 Indicated that It hat formad a working group within tha Offica of Toxic Substances to addraas thaia mattara and tailor RCRA-type requirements to tha "uniqua attributaa of tha RCB waata universe...." Tha Agency thaii turnad to tha coalition's proposal and flrat noted that it conaidara "manifaating and notification regulations to be tha highaat priority among tha araaa which tha....[coalition) idantifiad aa candidataa for regulatory amandmanta." I will leave for another time tha commenta ERA addreaied to aavaral apaclflc aapacta of tha coalition'a proposals a Inca tha whole matter ia in a atata of flux. However. In a aaparata communication, EPA haa indicated that it intanda to propoae new TSCA rules next Kerch or April to cover many, if not all, of these areas. Tha OTS staff haa bean thinking about these mattara for quite soma time. Therefore, while ERA'S response to tha coalition'a suggested language may ba somewhat indicative of tha direction in which tha Agency will go, the actual proposals may reflect a fraah view by OTS and wall may contain soma surprises. HONS 217U*5 1*40 In conclusion, then, 1st me drew on s phrase tntde famous in Congressional hearings years sqo -- while there once may hive been en intention on EFA's pert co regulite the dispose! of PCBs under RCRA. there is not now end tney never be such e program, 1-41 HONS 217166 HONS 217167 EPA ANO STATE REGULATION OF NON-PCB ELECTRICAL EQUIPMENT: THE HYTH5 ANO THE RFA^lTl^ Presentation for EPRI PCB Seminar October 6, 1957 Timothy S, Hardy. Esq, . Kirk lend 1 Ellis 655 Fifteenth Street, N.W, Washington, O.C, 20005 Despite unique and sweeping Congressional declarations In 1976 on jj_ polychlorinated biphenyls (PCBs), when the Environmental Protection Agency {EPA} Issued In 1979 the comprehenslve regulatory scheme mandated by the Toxic Substances Control Act (T$CA), Its controls applied only to ataterlals containing SO parts-oer-mllllon [owe) or more PCBs. Over the last eight years, concerns have arisen about the viability of the 50 ppm cutoff -- leading som to question whether such low-concentration mate rials are truly unregulated. Review of the history of EPA's PCB regula tions and their Interpretation, and of state regulations that supplement the Federal rules, shows the answer Is yes. I. A SHORT HISTORY OF TSCA PCB REGULATION In 1976, with the passage of TSCA, Congress banned future manufacture of PCBs and directed EPA to regulate comprehensively all processing, dis tribution In commerce, use, and disposal of previously manufactured PCBs.1 In 1978, In Its disposal rules, and again In 1979 In Its rules for processing, distribution In commerce, and use, EPA determined that no such regulation was required for materials containing less than 50 ppm PCBs. 1 EPA's 1979 decision not to regulate less than 50 ppm PCB-contalnlng ma terial (but not Its 1978 disposal decision) was challenged by the Envi ronmental Defense Fund (EDF) In the U.S. Court of Appeals for the 01strlct of Columbia. * Although agreeing that some cutoff might be Jus tified, the Court, In 1980. found EPA lacked substantial evidence to Justify the 50 ppm cutoff.* The Court thus remanded to the Agency the 1979 rules. Thereafter, In each of the Agency's subsequent five PCB rules, the SO ppm cutoff has been reiterated as an Important part of the regulatory framework: Published with permission of Kirkland and Ellis. 1-42 HONS 2171^8 ' . ' : i ` First, th* disposal regulations hive always applied only to materials containing 50 ppm or greater PCBs. Second. EPA's new national spill cleanup guidelines apply only to spills of material containing 50 ppm or more PCBs. ' Third, the TSCA regulations of various types of equip* went containing PCBs, as Issued In both the 1982 Elec* trlcal Equipment Rule that addressed spills and leaks and the 1985 Transformer Fire Rule that addressed com* bustlon by-products, are keyed to the 50 ppm Cutoff, For example, while authorizing use of PCBs "at any con centration" In transformers, EPA Imposes a number of controls on all transformers containing 50 ppm or more PCBs, up to and Including prohibition of use In certain locations of transformers containing more than 500 ppm PCBs. * EPA, moreover, permits transformer owners to avoid these regulatory controls and prohibitions by servicing transformers to reduce PCB concentrations below 50 ppm ** labeling such reclassified transformers "non-PCB." ' Such less than 50 ppm aqulpment is not only authorized for use and reuse, but also for dis tribution In commerce, * Fourth, EPA's rules allow products with concentrations of Inadvertently generated PCBs below 50 ppm to be man ufactured, processed, distributed In commerce, and used without being subject to TSCA rules. ' Finally, EPA's marking and recordkeeping regulations apply only to materials with more than 50 ppm PCBs. *' In Its most recent regulatory action on PCBs -- proposed amendments pur suant to a settlement agreement of Judicial challenges to the Inadver* tent Generation rule ** EPA reaffirmed that: "The 'non-PCB* status of [alectrlcat] equipment Is a favored status under the TSCA PCB regula tions." " The Agency continues: "Indeed, the regulations encourage owners and operators of electrical equipment to perform servicing that 'reclassifies' their mora highly contaminated equipment as 'non-PCB' equipment, which equipment Is essentially free from TSCA regulation." The Agency goes on to discuss the Inapplicability of the PCB disposal regulations to "non-PCB" equipment. It notes that any disposal, IndudIno salvaging, that terminates the life of non-PCB fluid or equipment falls outside the TSCA disposal regulations. It further notes that al though salvaging that leads to reuse of "non-PCB" equipment Involves both "use" and "disposal," the reused parts are "excluded PCB products" that can "be freely Incorporated Into other electrical equipment, or distributed In commerce for the purpese of reuse In electrical equip ment. " The only TSCA restrictions relevant to non-PCB fluids are the two mixed use/dlsposal requirements, one prohibiting use of waste oil with any detectable PCBs as a coating, sealant or dust control agent, 11 and the other considering the burning of waste oils for fuel recovery as an 1-43 HONS 217169 unauthorized use. In the recent proposed revisions, EPA clarified the latter Interpretation by proposing to prohibit burning of used oil con taining quantifiable levels of PCBs In nonlndustrlal boilers, while au thorizing such burning In qualified TSCA PCB Incinerators and high effi ciency boilers or RCRA Incinerators. In sum. seven years after the Court of Appeals told EPA It had not con* piled substantial evidence to Justify an across-the-board SO ppn cutoff, the Agency has Issued five new najor regulations and proposed another that each factually Justifies and retains the cutoff. II. CONCERNS ABOUT THE 50 PPM CUTOFF Despite the continued recognition of the 50 ppn cutoff In EPA regula tions, a number of questions have arisen. First, fears are heard persistently that EPA Is planning to reduce the 50 ppm cutoff for reclassification of electrical equipment as non-PCB. Such fears are unwarranted and should be quieted by the Agency's recant declaration that It "has no plans at present to regulate the use of PCBs ... In transformers containing lass than 50 ppm." ** Second, questions also began to arise about the viability of the 50 ppm cutoff when EPA Issued Its 19B4 Inadvertent Generation Rule. That rule deleted from the T$CA regulations the previously Included definition that PCB means only materials containing 50 ppm PCBs or more. '* When confronted with the problem created by the 1994 regulations, EPA admitted It had not fully considered the widespread Implications. The Agency agreed to roll back the 19B4 prohibition on use and distribution In commerce of less than 50 ppm material. EPA, moreover, made It clear that the 1984 rule amendments do not apply to authorized electrical equipment, EPA's proposed revisions of Its PCB rules this summer were consistent with the Settlement Agreement, ** Third, more recent questions about the viability of the 50 ppm cutoff have arisen at several "PCB Symposia" where the position has been taken that EPA's antl-dllutlon rules prevent fluids and carcasses that were once "PCB" from being outstde the disposal rules once they have been reclassified non-PCB," To the contrary, EPA has strongly encouraged reclassification, and part of the Intended encouragement Is the author ization for such transformers, once reclassified, to avoid not only the use regulations for higher classifications, but also the corresponding disposal rules. The Agency has just recently reaffirmed that once re classified) a non-PCB transformer "shall retain that reclassification status for the remainder of Its useful life, even at the time of Its ultimate disposal." 11 Finally, EPA has announced on several occasions since 1984 that it Is contemplating transferring PCB disposal regulations to the Resource Con servation Racovery Act (RCRA) hazardous wasta regulatory systam. A num ber of Industry and environmental groups have urged the Agency not to transfer the PCB disposal rules to RCRA. It Is. moreover, quite unlike ly that disposal regulation revisions will alter the 50 ppm lower limit. Writing to EPA In support of Industry's position In opposition to RCRA 1.44 HONS 217170 trtntftr the Environmental Dtfon** Fond and Natural Resources Defense Council no tad explicitly that thayar.oppotad "reopening every stn- *1. issue regarding the disposal of PCBs, such at tha 50 ppm cotoff." Marcia Williams, head of EPA's RCRA Offlct of Solid Waste, alto hat noted that "[1]t's vary likely we won't open" tha SO ppm Ittue. *' III. STATE REGULATION OF PCBS Datplta tha comprahantiva system of Federal PCB regulation, a few ttatat have found It appropriate to Ittue their own unique regulation!. Almoit without exception, thote ttate regulation! however, alto apply only to above SO ppm PCB material. Approximately half of th ttatat have no PCB regulation! and thut leave PCB regulation entirely up to the Federal TSCA rulet. Several ttatet have lltted material! containing more than SO ppm PCBt at hazardous wastes under their state administered RCRA programs. One state regu lates materials with SOO ppm or greater PCBt at RCRA hazardous wastes. A few other states enacted laws In the mld-1970't, and others did so more recently, paralleling TSCA Section 6(e). Some, like TSCA, Impose bans on manufacture and controls on use, processing and distribution In commerce. Others are limited to disposal regulations. Each of these states have, however, Implemented these statutes In a fashion loentlcal to, or paralleling, the Federal regulations and, accordingly, following the 50 ppm cutoff. Questions arise In only a few states about regulation of PCB concentra* tlons below 50 ppm. California has listed as RCRA hazardous wattes liq uids containing more than 5 ppm PCBt. Washington and Wisconsin have Implemented disposal rules for less than 50 ppm material. And Texas, although having no PCB regulations or statutes, considers any spill con taining more than 1 ppm PCBt as reportable If It endangers state's wa ters. In each of these four states, the rules are of limited practical signif icance to owners of non-PCB, lets than 50 ppm, electrical equipment. Washington and Wisconsin, for example, basically exempt equipment owners from disposal and spill cleanup requirements that otherwise apply to lest than 50 ppm material. California and Txas, although Imposing cleanup requirements on such fluid, recognize the requirements are not difficult to achieve for such low concentration material and that the other benefits of non-PCB status still essentially apply. CONCLUSION Ore consistent thread runs throughout the history of PCB regulation. EPA has consistently concluded that it need not regulate materials con taining lets than SO ppm PCBs based on findings that such materials do not peso unreasonable risks. State regulations -- with few exceptions -- follow the same pattern and thus do not alter the baste EPA conclu sion that less-thin 50 ppm PCB material It "estenttally free" of regula tion. If electrical equipment Is non-PCB, or is reclassified as "non-PCB," It Is unregulated just at new transformers are unregulated. 1-45 HONS 217171 REFERENCES 1 Section 6 (t) of the Toxic Substances Control Act, 15 U.S.C. I 2605 (c). ' 43 Fed. Reg. 7150 (Fob. 17, 1978); 44 Fed. Reg. 31514 (May 31 1979). . * EOF v. ERA, 636 F.2d 1267 (O.C. Clr. I960). * EOF v, EPA, 636 F.2d *t 1279-84. 52 Ftd. Reg. 10688, 10689, 10705 (April 2, 1987). 40 C.F.R. f 761.30 (). ' 40 C.F.R. $ 761.30 (a)(2)(v). * 40 C.F.R. 6 761.20(c)(4). 40 C.F.R. 6$ 761.1(f), 761.3 & 761.20 (b)(1). ' 40 C.F.R. H 761.40, 761.180. II 52 Ftd. Rtg. 25838, 25854 (July 8, 1987). '* 40 C.F.R. 6761.20(d). n Lttltr from Htrtln P. Helper, Director, Exposure Evaluation Divi sion, EPA Office of Toxic Substances, to Timothy 5. Hardy (Feb. 27, 1987). ** 49 Fed. Reg. 28172 (July 10. 1984). 11 52 Ftd. Reg. 25838 (July 8, 1987). " Letter from John J., Heylan III, Director, Policy and Grants Divi sion, EPA Office of Compliance Monitoring to Timothy S. Hardy (July l. 1987). *' Letter from Jacqueline Warren to Marcia Williams (April 24, 1987). '* ini "Pesticide 6 Toxic Chemical News," at 6 (May 20, 1987). 1.46 HQNS 217172 MOMS 2L7173 R. Beagle Power Engineering Service* Limited Electrical AlaR Management Dlviaion 44 Mobile Drive Toronto, Ontario M4A 2P2 ABSTRACT Thl* paper waa generated to provide an overview of the optlona available to Canadian* for the handling of their PCS waatea. without going into the merit* of apeeiflc technology available for each option, it ia meant to ahow that progreaa is being made to formulate a long range, permanent aolution for the control of Polychlorinated Biphenyl waate material within Canadian border*. 1-47 217174 CURRENT STATUS AND OPTIONS TOR HANDLING AND DISPOSAL OP PCB'S WITHIN CANADA As recently as tha early I960'a. Canadian opinion aurvaya designed to datarmina ganaral knowledge of polychlorinated biphanyla inavitably would evoke a raaponaa ranging from total Ignorance of tha aubatanca to mara mild intaraat. sinca that time, howavar, thara haa baan a dramatic incraaaa in public eoncarn and knowladga of P.c.B.'a. Thia public awaranaaa haa baan initiatad by tha madia covaraga of tha April. 1985 apill of PCB waata matarial on Highway *7 in Northarn Ontario naar tha city of Kanora. Thia inatanca involvad tha ahipmant of PCB contaminatad tranaformara from tha Provinca of Quebec to a atoraga aita in tha Province of Albarta. Madia covaraga of thia avant draw a vary larga raaponaa in tha public aactor dua to tha fact it involvad a larga atratch of wall travallad highway and tha diraet involvamant of a family who had baan following tha tranaport truck aa tha liquid waata waa laaking, Although thara had baan mora aarioua inatancaa involving p.C.B.'a prior to tha Kanora apill. notaably tha Daeambar 9, 1977 Toronto fira involving aoma 450 litraa of aakaral, tha raaponaa to thia particular madia avant actad aa an ancouragamant for aimilar futura covaraga of P.C.B.'a and thair ralatad hazards. Far from baing a critiqua of tha madia, it waa. and ia. covaraga auch aa thia which haa anhanead public awaranaaa (although not naeaaaarily complete), of Polychlorinated biphanyla and particularlly thair biprodueta Polychlorinated dibenzofurana (PCDF's) and Polychlorinated dibanzo-p-dioxina (PCDD'a). Recently there haa baan a apata of daily nawa report* concerning PCB apilla and tha long term affacta of tha compound. Each of thaae report* inavitably questions what ia to ba dona with thia matarial, if not today than in tha vary naar futura. Thia constant exposure to tha public aye haa heightened awareness of 1 -Aft MOMS 217175 fth* problem and In turn Increased the pressure on the polltlcana to up with an answer, and soon. It should be stressed at this point that the particular problems ^Involving PCB's, especially with regard to distribution and handling, 'have been a major concern of Environment Canada as well as the provincial Ministries of the Environment since the early 1970's, 'originally conducted In response to the results of studies carried out in connection with the PCB contamination of rice oil in Yuaho, Japan in 1968, Environment Cenada's research culminated In the enectment of the Environmental Contaminants Act on April 1, 1976, in its initial form this act required the full disclosure of all equipment containing PCB's (primarily for cataloguing purposes). ECA has been expanded upon since its Inception to includet a The specification to the type of equipment in which PCB's could be used (1977)r the overall ban of the importation or manufacture of new equipment containing PCB's (19B0); prescribing the maximum concentration of PCB's in new equipment sold in Canade (i.e. 60 ppm) (1984)t and the restriction of the quantity of PCB's that can be released into the environment (1984). Another vary important piece of legislation is the Tr&nsporatlon of Dangerous Goods Act (TDGA) , The TDCA was passed in 1985 to regulate the documentation, handling and control of dangerous goods for all intarprovinelal and international transport. Due to the spill of PCB's near Kenora in 1985 the TDGA was ammended to include specific requirements for the pecKaging of PCB material. As well, each province has legislation, of varying severity, restricting and regulating shipment of PCB material within its' own Jurisdiction. The coetoination of the enactment of this legislation with the increasing stadia reports on "CRISIS" situations has led to a general belief that the only thing that can be done with PCB waste material in Canada is to "SIT ON IT". This, however, is not the only option which la sellable. Currently ws, in Canada, have been presented with basic options for the P.C.B. problem! 1*49 HONS 217176 1. Maintenance of the Statu* Quo 2. Removal and Storage 3. Removal for destruction Hiirt9D3BSr.gI-.VtH. St<tpe.J2^g This option, although seemingly static, is in fact rather progressiva within a limited framework. It encourages the proper care of all PCB equipment still in operation. To do this It ia now necessary to adhere to all legislated guidelines pertaining to the containment and maintenance of this apparatus, in addition to this, various Provincial Departments of Labour have issued guidelines for the education and training of operating peraonnel a* well as the recommendation for the formulation of contingency plans to allow for prompt and proper reaction to a P.C.B. releeae. At its best, however, this option represents only e stopgap measure. It certainly does not address an ever more common scenario of an owner of such apparatus facing inereaalngly stringent requirements to qualify for liability insurance coverage with the underlying threat of total disqualification in the future. This option is designed to maximize public safety while waiting for a more satisfactory end, hopefully, permanent solution to the problem. Removal and Storage This option constitutes the next step to the status quo solution. Jurisdiction over P.C.B. waste falls within Provincial legislation. For this reason Provincial Guidelines have been issued to allow for the storage of out of service contaminated equipment at an approved storage location. These storage sites would be presented in two forms. They could either be an "on site" location or a general public storage compound. "OH SITX" storage constitutes a location set up according to the Provincial Guidelines which would still be within the same property linee as when the equipment was operational. A public storage location, on the other hand, would involve transportation to an approved location specifically designed for long term storage of P.C.B. waste. Simple sounding solutions with only one drawback. As of today there 1*50 HONS 217177 Knot on* public storage sit* within Canada which la abla to aceapt watt* material from any or *11 con earned. Thar* ar* a few in life* planning *tag* - but non* ar* within two yaara of being able to RTcapt waat* material. Bacaua* th*r* are no public facilitlaa Available If you wiah to ator* a spent transformer or capacitor bank K' will b* nacaaaary to do ao "ON SITE". One* again, aa with the ^atu* Quo option, thia response will not alleviate the owners of !6u apparatus of their obligation to protect the public te well aa ^their property from exposure of P.C.B. emission. For this reason, ^this too, remains as an interim and not at all satisfactory solution. m f. rptrw*i for Destruction AS with the storage option th* destruction process can be carried out either "ON SITE" or at an approved destruction facility, ascent, technological advance* now would allow for the destruction of low _jT level ti.e. below 6000 ppm) liquid waste material on an nON SITE* basis. This destruction could be carried out with either the Westinghous* Mobile Plasma Arc System or by Chemical Decontamination using a Sodium Filtration process, such as the unit being developed by Ontario Hydro. Extensive studies are being conducted as to the accuracy and reliability of these two processes. The time frame for full implementation of these technologies apperars to be approximate ly two years away. The final option would be to remove P.C.B. contaminated equipment end transport it to an approved destruction facility. Unfortunately, as in th* storage option, Canada doe* not have an approved destruction facility. There is a site located at Swan Hills in Northern Alberta scheduled to comnc* operation in late 1987, however, the acceptance of P.C.B. waste material will not be allowed until poaaibly 1989 and then probably on an "Alberta First" program. Thia program would see PCS waste materials from the Province of Alberta given priority over similar material from other Provinces. It would appear therefore that access to thia facility, for the purpose of P.C.B. destruction, on a Canada wide basis would not be available for several years past the 1989 schedule. There have been hints of other proposed destruction facilities being planned for Ontario and Ouebee but, once again, there have been no firm dates given for their opening. The only other option for destruction would appear to be transport to 1*51 HONS 217178  deatructlon facility out*Ida of Canada. As of thla data the Unite Stataa era not availabla to Canada dua to a lack of a reciprocal agreement on P.C.B. waste management. Under present legislation transportation of P.C.B. waste material to an overseas destruction site is possible although the process for approval is complicated. Not only must the owner meet all requirements under the TDGA but also the accepting site must fall within the Guidelines as set out by the ECA and thouae of the various provinces involved. Under no circumstances would a shipment be allowed for storage purposes only. It would appear, tharfora, that if tha option of deatructlon it deemed the moat acceptable by the owner of contaminated equipment to limit their increasing liability, the only immediate relief would be to ship their equipment to an approved overseas deatructlon site. i Having Hated the options the queetion must now be asked i why does Canada not have an operational destruction facility for P.C.B. waste materials? Given the technology available today why can't a decision be reached? . To formulate an answer to these questions an understanding of tha Canadian public ia necessary. Canadians can bs Just as rssctionary as any othsr group of peopls. Therefore, when constantly bombarded with headlines such sat "Hit by Cancer, worker claims major cover-up over PCS'a" "Mother'! milk still safe for babies despite traces of PCB's, expert eaye" their kneeJerk response ia to call for an immediate solution. However, historically speaking, in situations such as this, whsn prsaented with a seemingly satisfactory solution we tend to be very conservative In our approach. An example of this would bs ths announcement in April of this year of the creation of a P.C.B. destruction facility in Tracy, Ouebec (.Just outside of Montreal} . On the surface this ia what everyone had been asking for, howsvtr, within 72 hours, ths Honorabls Clifford Lincoln, Minister of the Environment for Ouebec, had to retract his statement and cancel plans for this facility. Local pressure was applied by the citizens because they did not went the solution to be implemented in their backyard. This ia the type of response which should ba expected by every Ministerial suggestion 1-52 HONS 217*79 KT| destruction facility. Because of this expectation. Federal end R provincial, Ministries have taken the long, slow route to Bpertaln what the bast technology and locations ara for such a (Bchnology and locations ara for such a destruction facility. Public Kput into this process is invited and in fact encouraged. Therefore, Kgn a site does appear to be possible the chances for approval and Cnarel public acceptance are greatly enhanced. ^ conclude, it would seem that we, in Canada, have assumed the long, slow, plodding process for a solution despite growing external pressures for an immediate response. Taking all factors into account this would appear to be the most satisfactory approach as well as the one which will ultimately lead to a permanent solution without fear of having to start over from scratch. In the meanwhile, legislation is in piece to assure the safe, ongoing operation of euch equipment as well as provisions being given to accomodate those owners who, due to growing liability pressures, can not wait for a long term solution within Canada. REFERENCES 1. Environment Canade, Environmental Protection Service, Handbook OH PCB't In Electrical Equipment. Revised edition December, 1982. 2. Trensport Cenede, User'* Guide for the Hazardous waata Manifest. Transportation of Dangerous Goods Act. Fsbruary. 1985. 1. Environment Cenede, Manuel for the Management of Wastes Containing Polychlorinated Biphenyls (pcb-s). February, 1967. 4. Ontario Ministry of Labour, Occupational Health and Safaty Division, Guidelines on the Prevention and Control of Occupational Exposure to Polychlorinated Blnhenvis fpca>.l, July, 1986. 1-51 HONS 217180 HONS 217181 PART 2: RETROFIIL AND OlSPQSAl HONS 217182 K. C. Ashley Quadrex HPS Inc. 1940 N.W. 67th Place Gainesville, Florida 32606 An operating system Is described for flushing (and soaking) the Interiors of distribution transformers scheduled for disposal or servicing. The system has practical application In utility transformer and equipment repair centers and In similar contractor service operations. Mineral oil dielectric PCS concentrations can range from 499 ppm to 50 ppm or less. For dielectrics having 500 ppm PCS or more, or of the Askarel type, the system automates the IB-hour solvent-soak requirement. The flushing solvent Is recovered for reuse by a PCB-separatlon process. In addition, salvageable transformer parts, l.e. bushings, and contami nated hand tools can be recovered In an optional decontamlnation-cleaning chtmber. This chamber Is a satellite unit as Is supported by the main system. Major system features Include recovery of the flushing solvent, minimum labor requirements for operation, and reduced worker exposure to PCB's and solvents. Reuse of the flushing solvent results In significant reduction of waste volume requiring disposal. APPLICATION 1ACK6ROUNO A utility serving a major metropolitan area can typically replace from one to ten thousand distribution transformers annually1. Thesa transformers are predominantly pole-mount types with a smaller proportion being pad mounted units. While the replacement transformers are PCB-free, some unlit being replaced contain various concentrations of PCB's in the dielectric fluid. Most concentrations are below 500 ppm PCS*. The transformers removed from service may be scrapped outright, rebuilt, or serviced depending on size, value, condition, and PCB classification. 2-1 HONS 217183 1 A transformer's PCB classification governs servicing and salvage options and carcass disposal requirements. Under tha Toxic Substances Control Act (TSCA) the U.S. EM has established transformer PCB classifications and disposal requirements for carcasses. These are: * Non-PCB; mineral oil dielectric contains less than SO ppm PCS; carcass disposal not regulated under TSCA*. ' PCB contaminated: mineral oil contains 50 ppm to 49B ppm PCB; transformer to be drained of all free-flowing liquids; carcass disposal not regulated under TSCA*. . PCB: dielectric contains 500 ppm or greater In mineral oil or Is ' Askarel; the transformer Is to be drained of all free-flowing liquids, filled and soaked with solvent for 18 hours, then thoroughly drained; TSCA regulates carcass disposal to chemical waste landfill or Incinerator. *These drained carcasses (non-PCB and PCB-contaminated) must be disposed of In accordance with other applicable federal and state regulations. REGULATORY TRIPWIRE The PCB disposal requirements under TSCA do not exempt transformer disposers from actions or liability under other environmental laws. A triggering event could be spillage or leakage of residual dlelactrlc, containing detectable PCS's, from carcasses at a salvage or disposal site. SYSTEM DEVELOPMENT Several utilities were surveyed and responded that lacking secure and commercially viable disposal alternatives, pottntial environmental liability could be mitigated by first flushing the Interiors of transformer carcasses (to remove residual dlelactrlc) prior to approved landfill or other disposal options1. The flushing operation could be performed by a utility Itself or available from a service contractor. Further, for transformers scheduled for detanking (servicing or rebuild), a prior flush would mitigate potential employee health and safety con cerns regarding exposure to PCS's. 2-2 HONS 217184 SH DESCRIPTION l depict* system designed for use by utility repelr centers or contractor frvlc* operations. The system is designed to solvent flush one or more dlstriItlon-type transformers (<500 ppm PCS) simultaneously, and recover the solvent for %tus*. Solvent flushing effectively removes free surface and residual dielectric {Tjqulds from the interiors of transformer carcasses. For transformers with 500 ppm r mere PCS or Askarel dielectric, the system automates the 18-hour solvent-soak processing requirement, prior to regulated carcass disposal. 5 The flushing system Is composed of sis major components: (1) a 1500 gallon solvent supply tank containing less than 2 ppm PCS, (2) apparatus for the solvent filling nd draining of transformers, (3) a control panel, (4) a 1500 gallon contaminated solvent tank, (5) a solvent recovery (PCS seperatlon) subsystem, and (6) a 150 . gallon holding tank for the separated PCB's and dielectric liquids. Solvent/ recovery {<2 ppm PCS) Is achieved using a physical separation process or dlstllla-' tlon. Recovery rate is a nominal 60 GPH. No form of PCS destruction occurs in the system. Figure 1 shows two pad-mount transformers being flushed using an auto-stop filling nozzle and connections to the drain valves. Smaller pole-mount units (lacking such access ports) are filled and drained using a wand attachment inserted through a hole punched in the top cover. Not shown is an optional cleaning chamber (24"W X 18"D X 24"H) used to remove PCS contaminants, oil, grease, and dirt from salvageable transformer parts and power and hand tools. The chamber is of the sealed glovebox design, thus completely isolating the operator from contaminants, solvent and vapors during operation. Cleaning action is a jet spray of pressurized (100 psl nominal) solvent and is directed by a hand-held spray gun. This satellite unit Is completely supported by the main system. APPLICATION CONSIDERATIONS This system Is designed to mitigate potential environmental liability by providing an economical means to remove dielectric residues from distribution transformers prior to carcass disposal or salvage action. While this measure does not entirely remove the basis for potential liability associated with carcass disposal, it should be viewed at an Interim option until secure and commercially viable trans former salvage (metal recycle, PCS destruction) operations are'widely available. Nevertheless, the system makes solvent flushing affordable by providing a means to 2-3 HONS 217185 rtcovtr flushing solvent for route. Avoided Incineration costt ere significant, since solvent disposal volume Is reduced 50:1 or more when compared to non-recovery approaches. To operate the system, a permit Is required from the U.S. EPA and perhaps other regulatory agencies. Current u,5. EPA regulations require permit approval since the PCS separation process used Is considered an alternative to the required incineration of PCS contaminated flushing solvent. The system has received operating permit approval at one or more locations. The flushing solvent Is Freon* 113 or TF, a liquid at room temperatures. In addition to Its Ideal application properties. It was selected primarily from a health and safety viewpoint. The solvent Is three to four times higher in cost than other solvents and may Incur a surcharge for its disposal. However th^system was designed to minimize solvent losses to the atmosphere and as a still bpitom,' Operating data shows solvent losses are within design criteria. nuMOPOOWMUumen Mflinu*uhmiuoma sMoUlvMcn,twomf cwoavirmn r erercM itOMrnuc ACKNOWLEDGMENTS The author wishes to acknowledge the Electric Power Research Institute, Florida i Power and Light Company, Georgia Power Company, Hydro Quebec, Potomac Electric Power Company, and the General Electric Company for their support and cooperation. REFERENCES 1. Utility Industry survey data, Quadrex HPS Inc., July 1986. 2. USWAG Study, Vol. Ill, Resource Planning Corporation, February 1982. 3. Quadrex HPS Inc. survey, February 1987. 2-4 HONS 2171B6 HONS 217187 PCB RESIOUE IN ASKAREL AND CONTAMINATED OIL-FILLED TRANSFORMERS TO Rout* HA Ftttltr CT Raymond* General Electric Company IOO Hoodlawn Ave, Pittsfield, ha 01201 6 Addis Electric Power Research Institute 3412 Hillvlew Ava. palo Alto, CA 14303 abstract Tht tllnitiatlon of PCBs from alectrlcal equipment It of contlderabl* concern today. This rtport discusses th* ratultt of m*atur*m*ntt mad* to characterize th* amounts and locations of PCB residues In transformers during and aftar disassembly. /: Savaral askarel trantformart war* dralnad, f11 lad with trlchlorotrlfluoroathan* (R113) for eighteen hours, dralnad again and th* core-coil assemblies war* untankd. Th* clamps war* ramovad, th* eor* laminations war* saparatad, and th* colls war* unwound. Th* matarlals In th* various substructures war* accumulated separataly and th* matalllc and caramlc parts war* saparatad from th* calluloslc and othar polymarlc parts wharavar posslbl*. Th* walghts of tha various componants war* maasurad during dlsassambly and wlp* samplas for PCB analysis war* taken from surfacas such as th* tank wall aftar th* RH3 toak, th* saparatad cor* laminations, and tha unwound high and low voltaga conductors. Samplas of cor* laminations and conductors war* savad for furthar daanlng and samplas of Insulation componants war* sat asldt for latar maasuramant of PCB conttnt and porosity. In soma casas. th* ramalnlng laminations, conductor langtht. Insulations, ate war* soakad sepa rately In weighed amounts of R113 which war* latar analyzed for PCBs. The retained metallic componants war* cleaned by Insertion In an R113 dagreasar for up to two hours and wipe samples war* taken. PCB contaminated oll'-fllled units war* torn-down following this same procedure, but with two differences. Initial R113 soaks and th* last cleanings of metallic parts war* omitted. Three companion units war* refilled with fresh PCB-fra* oil and allowed to Stand, on* loaded continually to a top oil tamparatur* In excess of 50*C and ona energized, Th* three war* regularly sampled to compare th* buildup of PCBs to tit* amounts of residue estimated from th* tear down results. Th* weights and analytical results war* used to reconstruct th* distributions of PCBs In th* various substructures as th* tear-down progressed. These distributions ar* presented and tha Implications of these results to disposal and ratrofllllng of transformers containing PCBS are discussed. 1 River Road, Schanactady, NY 1 2345 2-5 HONS 217188 tHv-A MOHS 217189 PCB Contaminated Distribution Transformer RtSltfUlCfltlOD-StoaY Paul J. Fray Baltimore Cas and Elaetric Company Elactrio Taat Department P.o. Box 147S Baltimora, MD 21203 ABSTRACT In August, 1986, a study with tha following objactivas was bagun: 1. Datarmina what affact, if any, tha loading of transformars has in tha proeass of ramoving PCB from tha cora and coil of a drained, flushed and refilled distribution transformer, 2. To datarmina tha loading required to achieve tha 50C oil tmmparatura specified in 40CFR761.30a.2.V,3 3. To datarmina whether tha use of temperature sensitive labels on tha tank is an adequate method to monitor oil temperatures. 2-6 HOMS 217190 jn order to conduct tho study, 12 transformers, In for rapalr, were solsotsd. All 12 units wsro Generel Electric: 6 vrs IS kVA and 6 wsra kVA. Thoir original PCB content ranged from 62 to 245 ppm. fhe transformers were handled routinely in so far as the draining of the old oil, flushing the core and coil and refilling with new oil. The transformers were delivered to a substation yard for testing. Six of the transformers (3-15 kVA and 3-2S kVA) were mounted on poles and six were placed on the ground beneath. Test reference numbers FI thru F6 (on poles) and Cl thru G6 (on ground) indicate their loca tions. In order to monitor transformer temperatures, thermocouples were used. In October, 1986, the transformers were energized as follows: FI thru F6 Primary and secondary at rated voltages 7620V end 120/240V respectively FI, F3, P4 and F6 Primary and Secondary at rated voltages with 80% full load current circulated Cl thru G6 Mot energized Zn order to achieve the 50c specified, current was raised from 80% load current to 120% load current on December 3, 1986, Attached is a diagram of the circuit used. The circuits were metered as shown in the diagram. A record of the meter readings was kept. 2-7 HONS 217191 ii Oil staples war* drawn weekly (at first) from the transformers. Saaplaa wara drawn using tha following precadurai 1. Yard waa de-enargized and 480/240V supply awitoh waa epanad. 2. Transformer tank hand hola cevara wara removed, 3. Saaplaa wara drawn from top oil using disposable plaatio pipattaa. 4. Pre-labeled diapoaabla aaapla bottlaa wara uaad to dalivar aaaplaa for in houaa PCB analyaia by gaa chroaa t ography. Results of tha PCB analyaia ara includad in graphic fora. Tha raaulta thua far indieata vary littla changa in PCB concantration. ztaaa of intaraat to nota, 1. Tha PCB contamination of Transformer G4 aaaaa to ba aoaavhat outaida tha normal diatribution although it haa to thia point ramainad balov tha SO ppm laval, 2. Two individual aampla concantration (C5 on day 102 and P3 on day 42) appaar to ba anomalous. Tamparatura data for. tha air ambiant aa wall aa tha top oil temperaturaa of tranaformara P3 and PC hava baan includad. Tha data ia raportad in tha form of a graph of tha 24 hour avaraga tamparatura. It ahould ba notad that four tranaformara (PI, P3, P4 and P6) did achiava tamparaturaa in axeaaa of S0C. klao, all twalva tranaform ara hava maintainad PCB lavala wall balow tha SO ppm specified. As a result, four tranaformara (Pi, P3, P4 and P6) hava met tha criteria specified in 40 ent 761.30a.2.v for reclassification aa Non-PCB transformers. 2-8 HONS {Ob'January 1M7 (Day Number 102), the even numbered transformers gjr. ^changed (P2 was deenergized and placad on the ground, 02 was on tha pola and energized. Likewise, P4 and P6). Thia exchange dona to ravaal whathar tha loading will incraaaa tha PCB lavala \n 02, 04 and G. Results indieatad that PCB lavala did not change significantly. f^ftar conaultation with tha EPA, it waa dacidad to bring in a largar :sapplino of tranaforaara. Aa a raault, aix transformers of various 'manufacturer and aiza, labalad XI thru X6 wara drained, fluahad and refilled with nav oil. Thaaa tranaforaara wara uaad to raplaca aona of thoaa tranaforaara that had alraady mat tha raclaaaifieation requirements. On Kay IS, 1987, tranaforaara XI, XJ, X4, X5, and X6 wara anargizad at full load along with 02. All of tha tranaforaara hava alraady raachad tha S0 C raquiraaant. Again, tha raaulta to data do not ahow aignificant incraaaaa in tha laval of PCB in tha tranaforaar oil. Aa of thia data tha coaplata raaulta of thaaa tranaforaara ara not available. Coneluaior.a 1, To thia data there hava bean no aignificant differencea between tha changa in PCB lavala in tha varioua unite regardleaa of tha tranaforaara loading. That ia, all of tha unite hava remained wall below tha SO PPM laval. By inference tha experiment haa proven that no large quantities of PCB lie hidden in the tranaforaar core and coil. Logic dictates that where aver the PCB aoleculea travel, the oil eolvent used in the flushing process aay also enter. Zn ay opinion this indicates that tha "leaching" process is more or lass tha straight forward result of mixing two solutions of different concentration. It ia also my opinion that in view of tha above conclusions, tha regulations 2-9 HONS 217193 should ba aodifiad to allow for tha raclassi float lor. of PCB-contaainatad transforaars on tha basis of tha draining of tha oil, a flushing of tha unit with nav oil (0 PPM PCB), and rafilling tha unit with nav oil. 2. This axpariaant was axtandad froa tha fall of tha yaar through tha auaaar. In ganaral tha rasults indieatsd that tha tranforaars axparianca approxiaataly a 90*c taaparatura risa ovar aabiant at approxiaataly 1001 full load. This is what would ba axpactad. 3. Tha usa of tasparstura sansitiva labals provad adaquata. Ravisad 7/16/B7 2-10 HONS 2i?i9* z-n WINDY EDGE nwiSrCRMBI ICELUenGAHON opi * n *n * p* xn WINDY EDGE miNtPCRUBI muaBROLIUM v OOI + 03 7 GS A Od X at 7M 2-12 HONS 217196 WINDY EDGE I i HONS 217197 2-13 CONTINUOUS COLTON TREATMENT 07 PCS CONTAMINATION IN MINERAL OIL EQUIPMENT Robert D. FOX IT CorporAtion Technology Development Department Knoxville, TN 37923 ABSTRACT one of the biggest problems In re-olassifying transformers to nonPC8 stetus is achieving and maintaining a PCS concentration of less than SO ppa after 90 days of service, current technologies, require repeated flushings end fluid replaeeaents over an extended period of tiae to reach the so ppa goal. IT has available e variety of technologies for the electrical power distribution industry. One of these is a technology that removes PCBs from mineral oil fluids continuously end destroys the PCBs. it was originally developed end tested by en electrical transformer service company in Italy end is now licensed by IT for use in the U.S. - The continuous treatment technology is based on an adaptation of potential end proprietary reagent formulations that use phase transfer technology to destroy the PCBs. Phase transfer components in the reagent facilitate transfer of the PCBs from mineral oil to the reagent where they can react end be destroyed. The continuous treatment of PCB contaminated fluids is achieved by circulating the fluid through e cartridge containing the reagent in e solid form. The reaction by-products remain in the reagent phase. Use of the reagent in this mode enables simple equipment to be used. Treatment can either be dene continuously or periodically to remove PCBs from individual transformers. pPeilrofotrmseeda.ls developmental testing of this technology has been Ninerel oil containing 1800 ppm Aroclor has been treated by circulating it through e one Kilogram bed of reagent for approximately 90 hours. At the end of the run the Aroclor 1380 concentration in the mineral oil was reduced to less then 10 ppa. Trichlorobenzene was also reduced to <100 ppa. 2-14 HONS 217198 fgyt*a *av baan designed for use in treating individual [tranit1**1*' Attar connacting tha aolid reagent ayatan to tha [transformer drain, tha contaminatad mineral oil ia circulatad 'through tha reagent until tha pcBa ara raduead to tha daairad Concentration. Tha system ia aiopla in design and requires littla oparator attantlon. y Treatment costs ara expected to be lass than ona-hair tha coat of transformer replacement. HONS 217199 2-15 I DESTRUCTION AND SALVAGE OP LARGE PCB TK*ft5WnMflt6 bibftfritift LfAMtttttf by r. j. Qrahsa and W. H. Martin IMI9CN Tranafocsnr Services, Inc. 133t fendrad Oaks Drive OwrXottt, NC 28217 ABSWCC Disposal of rapUcad transformers hat long pcaaantad the cwnar with a dilenB. Currant o regulations alia* for landfill of KB tranafomera in TK> landfills, but only aftar draining and an 18 hour rinaa. Although landfill la authorised, this diqpoaal aathod is not without substantial, pocantial for long tan liability. Tha arenas can still oontain to of its nawfOata vohae (20 to 100 Iba) soaked within its internals and tha original owner mains responsible, jointly and severally, under tha Coaprehensiva Environmental Raaponaa Oopanaaticn and Liability Act (CBECA or "Suparfund"). Ownera aay attaapt, by contractual aaane, to raoaivo indsmificatione frae, or txanafar tltla to, paraons who hava arraogad for eu<*i dlapeaal. Contractual indaanifieationa, title tranafar and legal il'ipail are not allmoble dafanaaa in ttqaarfixtd acticns and will not promt the original owner froa being held liable. TMNBHBOP* Service, introduced by 90901 Transformer Services, Inc. (a subsidiary of Onion Qsrbida Corporation) solves this dll -- by thermally destroying transformer cc^onents and liquids in S8A authorised destruction facilities. Slnoa tha ttanafomar and all KBa era destroyed under controlled conditions by i m permitted destruction procaaa, they no longer exist. ' Therefore, all future liability casaaa and risk reduction has bean complete and permnant. The technology, developed by 6 ( L Recovery Systems, Inc. of Ashtabula, Ohio, under fUO Authorisation ttm Ok Region V, has bean dmnatretad on hundreds of ssharsl and FCB-ocntaminated oil transformers. A T9CA Operating Permit 1a aapartad by lT^i< eSur 1987 and full oosaarclal operation la planned to begin in tha fourth quarter of this year. IWtfffFIB Osteen In tbs lata 19dds and early 1970s about potential PCB smlrcimmnU] hasards, copied with its long*tare stability, resulted in the 1978 O.B. Ctangraaeional ban on KB manufacture and uat. Today, over ten years later, liquid aoolad transformers main aa tha largest single souros of PCB aapoauca and as a result, tha D.S. Environmental Protection Agency (fflA) has prcasilgetsd several sets of rules vrdch severely regulate and reatrict tha uas of alactrlol trsnafonara containing Ida. 2-16 HONS Z17ZOO To avoid th* publicity, liability and ooata associated with continued use of PCS containing transform* and Maintaining ooiplianae with tha** rulan, thar* art only two viable cptions either retrofill or replaoanent. While retrofill of existing equipment is the least aostly and easiest to option lmploront, for oil and askarel transformers, it my not be suitable in all cases. Transformers i poor aondition, or which have failed, or changes in electrical system require replacement and disposal of the rereo/ed carraetas. Recent regulatory and oangraseional initiatives have been to encourage nor* permanent disposal tePv^logiee. In its interpretative guidelines to the BA following the 1984 Hasardram end Solid testa Anentants, Cbngreee uqslained that thane new provisions were necessitated by its finding that land disposal should be niniaiaed or eliminated, and land disposal, particularly landfill and surface inpoundaent should be the least favorite netted for managing hazardous waste*. Itas, it is understsndsbl* ytiy mny owners of POB transformers, particularly those with the deepest pockets, have bsen hesitant to replace and landfill tranafocmera. 1HWB-BO* Service was developed to process saonomleslly and safely th* larger dietributio^.class aquipmnt of 100 to several thousand KVA in sis*. ntANSHNj* Service is aonducted with nzmrous controls, a rigorous QVOC program, and extensive analytiml protocol to nonitor tbs prograss and status of each transformer throughout the process. Liquid and lnclnarablas (paper, linen, wood, etc.) are sant to ons of several permitted PCB incinerators for destruction, while the metals (tank, Iminstions, windings, etc.) ere advent washed cleaned until each is shown by wipt saoplas to be FCB-fres. Diaasaanbly and daoonteminaticn of an sverags 750 KVA transfocmar is achieved in less than eight hours. Analytical results naadofl to classify mstala as PGB-fre* are available th* next day. ttte Salvage telicy adopted by the (8 BA in 1976 allows PCO-fre* mstala to be eant to e meltar and rsowersd. This astal value dLCstts th# additional floats of dastruetian over burial. Ttes, DUWS-Ocr1 Ssrviaa quickly, aocncnlemlly and safaly loses transformer idantity in a an authorisad manner with anelyticd docvnantaticn provided. Current BA regulations require * T9CA permit and nuaarous control* to disassam>l and daoantmLneta tranafocmers grastar than 500 {pa PCB (i.s. PC* transformers). Transfotmars lass than 500 ppm PCB (PS-Contaminated), however, can be decontaminated without * TSCA permit. While deoontamination ot PCB-contmainatad transformers is legal, mcontrolled practioaa have lad to the oantaainaticn of amny scrapping operaUons in th* pest, making thos potential Scpsrfund claim? sites and again exposing th* transformer owners to further liability. Therefore, it is raoamwndsd that both PS-oontamlnated and PCB trMSfonmrs be destroyed throu#i BA autterlsad prwmam sod) as TRM6-BO Service h-- ot the controls and extra assurances aud> authoriaUon and permits provide. LESAL FRJDCIFLES RBMDXN8 UKYILLBB PCB The public, Ocngress and regulatory agencies are moving increasingly to and landfilling of substances such as FCBs. Argument* against landfilling toxic chamical* have often been neda by ecpert scientific group* and BA. 2-17 HONS 21720 Ttie coaprahensiue 1983 report on cent rolling hasardous tuti by the Congressional Offloe of Tectrolcgy Asaesenent (OEA) noted, for x^le. thftt "...and dl^ioeal, even if in otxqilianoe with KSA, probably poeee eome prewitable risks both in the near tern and for the future." on concluded, giving PCBa aa an enspla, that "none untraatable s wetea are ao highly toxic that land disposal ahould not be uaed." This poeition waa echoed by the National Itaaeartfi Oouncil (MV), whitfi concluded that "..the uae of landfills should be ainladasd since oonatituents will very likely migrate over long periods (acre than 100 yeara) into groun&eter. Persons responsible for sending PCBa to landfills have been naoed aa defendants In lawwita at mnerous Gtperfund sites. Although parsons uo transport rarnaaraa to landfills My taka title to the oaroaesea, such actions do not prevent the original caster frea being held liable for the oast of clearwp should the disposal site be involved In a hgarfund action. OBOA holds both the original owner of the wastes and the t ransporter liable. A transformer owner nay also obtain, by contract, Indawdticatlon fras person* who have arranged to di^oae of the transformer caraeaa. Such contractual indamnlfieaticn, however, la not a daftnae to govermarit St^aarfund actions, Indemnification can be used only to seat reimbursement froa the contracting party for any sudv Oovmnwent-ijvaeed liability. Moreover, acme indaanificetJon contracta covering transformer carceae diepoeel are narrowly worded In a Manner that may lead to indemnification being daniad. indeanifieatlon lieitatlons era eaoerfaeted by the difficulty of obtaining insurance for liability for gradual release of tcarle ctmical* from landfills. Due to the easalvm liabilities now being levied for lardfill di^oaal in the past, the insurance industry is often no longer willing to insure oagpanlt* who dispose of toxic chaelrila against lang-tsas liabilities. dumb-bc81 SBWia Transformer coolant is drained on-site end aent diractly to an incinerator tor di^oasl. Wen the drained carcass is received, rveelning liquid raeiduas or drainings froa the core and coil aaaedily are revved prior to processing. In the first step the transformer oouer and bottom valves are revved and a aall hole cut into the tank floor. Die intact transformer than is hoisted Into s primary cleaning tank and solvmit teahad. After completion, tha transformer is evacuated* reaming solvent fren the traumforaar and its internals. Naart, the dry transformer la raaovad from the primary cleaning tank, transferred to a taardown arms and oaplataly ill aaaead-ri art. Metallic oa^onanta are segregated fay type and placed into containers for further cleaning. Miwed metal tags with traMfonsr ID numbers era attached to aach container for positive Identification. Oaabustible solids (papafa/gasketa^prsaabaard, etc.) are collected for incineration. The now qpty can/tank and structural steel la r^rooeaeed through the primary cleaning cycle until deoontaalnated. Bntry and amlt procedures, 2-18 HONS 217202 Inn-->ctipI it; standards and dedicated equipment/tools are used within the teerdown area. Contamination during disassestoly, whic*i has plagued other processors, la largely awided by operating the primary cleaning etage in t earner which eeaentlally reeove* all li^iid residuee and provides a dry transformer during taardo*). in the third step, the metallic part* are prooeeaed throuipi several cleaning stage* where surfaces ars thoroughly cleaned. This method has nshled decontamination to exceptionally low levels > considerably below tlst established by the WA Region V for PO-fre* metal {less than 10 ug/100 cn ). After secondary cleaning, the evtainere are rescued to a holding area, a yellow tag affixed, and wipe samples taken of all surfaoM. then analytical results ars reoelved ths next day, s grean tag is affixed Indicating all records and certification* have bean received, satisfying OR requlments tor PS-free, and the setals are now reedy fee Bwltlng. Over ana hindered aakarel end mineral oil tranatonasrs have been procasaad under tvn. successive CUD permits to demonstrate and develop ths TOWB-e* Service. Results of deoontsmination are shown In imbls I. ws have found all manufacturing types, slams, and coca and coll configurations can be processed successfully, generally with standard procedures. Only three construction features hew required extra labor or effort. These have been: (1) welded tops, (2) ribbon-wound landnet ions, or (3) s failed winding. With aakarel transformers, greater then 7S% of the windings are either kraft paper or linen wrapped with no isprsgnstion used. Oil transformers of ths sise and voltaga class processed, on ths other hand, ars typically wrapped with either paper or linen and lnpre?tated with varnish, in all cases, ths impregnated windings have bean sufflcimitly brittle that complete stripping was easily accomplished. Ths mstslt recovery realised with TRANS-DO* Servioe makse full dsetructltm onpetitive with disposal by burial and son attractive than burial whan the elimination of long term liabilities is incorporated into the risk evaluation and daciaion process. WT Transformer Sixes Processed INK $-2000 Average KB Residual ug/loOoTt Windings l.l , Range PO ***IAm' ug/100c Transformer Can 01. -- .$ LaUnations 0.1 - 2.$ Windings 0.1 - 2.7 4S-1000 lass than 1.0 II 2-19 HONS 2172Q3 OPTIONS AVAILABLE FOE ASKAREL TRANSFORMERS T. Luby Sun Envlronaentel, Inc. 1700 Cutaway Boulevard SE Canton, Ohio 44707 ABSTRACT PCS t ranaf ornara containing aakaral fluid ara typically uaad foe"Indoor oubatatlon application# for critical pouar dlatrlbutlon within a facility. With tha currant EPA regulation#, nanagara ara faced with daadllnaa by which daclalon# auat ba nada to aolva tha PCB dllanna. Thla papar will dlacuaa tha Motivating factora facing tha Manager and tha currant aolutlona avallabla to naka tha propar daclalon for tha baat aathod to ba aaployad. Tha active aolutlona avallabla would Include tha ratroflll aathod to reeleeelfy the PCi tranaforaar to NON-PCB atatua or tha ellalnatlon of tha PCB by a raaoval and raplacaaent project, Thera are optional aathoda avallabla for either approach, but coat effectlvaneaa auat be weighed agalnat envlronaental concerna bafora a final daclalon can ba reached that will aatlafy EPA raguletlona. OPTIONS AVAILABLE FOR ASXAREL TRANSFORMERS Tha aolutlona available for the reclaeelfleetlon to NON-PCB atatua of aakaral tranaforaara have expanded to provide alternative# for the varloua typaa of aubatatlon lnatallatIona, The particular Inatallatlone, electrical charactarlatlca, loading condition# and corporate pollclae aa they apply to each tranaforaar will dictate which option will provide ba tha baat "rlek aanagaaant" daclalon for the PCB dllaaaa. A dletlaotloo auat ba aada that clearly dlfferantlataa contaalneted alnaral oil froa aakaral. Mineral oil, If containing PCB, could roach aoacentratlon lavala aa high aa 20,000 parta par allllon. Aakaral la typleally In tha range of 400,000 - 800,000 parta par allllon of PCB concentration. Tha PCB concentration la aakaral tranaforaara varied by aanufacturar. Certain brand naaee ouch a: Pyranol, Inartaan, Chlorextol and Aakaral Indicate tranaforaara that contain a fluid that la aaaantlally "pure" PCI. All of thaaa 2-20 HONS 217204 btend neaee became generlcelly known eakaral. The focua of thla paper will ba on thaae "pure" PCS tranaformera. There are thraa aajor optlona available for eekaral tranaformera: - Mana|aaent and Contalnaant - Ratroflll and Recleaelflcatlon - Replacement and Dlepoeel Initially, your company auat dataralna whether the PC# problaa will ba handled In a peaalva or active manner. The paaalva approach entelle ateylng within tha EPA tuldallnaa and aanailm tha PCI rlek through a Management and Contalnaant program. Thla couraa of action la tha laaat expenalve. In tha eaaa of coapanlaa with Halted financial reaourcea. It la uauelly the option of choice; and tha paaalva approach la alao choaan by coapanlaa whoae facllltlea can not accoaaodata tha extended outage that nay ba . required for tha retroflll method or tha replacement of tha PCR> tranaforaara. In caaaa auch aa thaae. Management and Cor.tainaenp:" prograaa are a viable temporary eolutlon to tha PCS problem. If the Management and Containment eolutlon la ehoeen, the company aey wleh to Implement a long-term program that will eventually eliminate the problem over a dealgnetad period of time. Tha Menagamant and Containment program la the broadaat area of the thraa optlona end ahould Include! - Labeling of tha tranaformara. - Inepectlon of tha tranaformer a. - Record keeping. - Maintenance. Tha four atepe llatad above ahould alwaya be Implemented even whan an alternative eolutlon la choaen aoma time In tha future. In caaaa where tha Management end Containment approach hae been choaan for tha long-term, aevaral riak-raductlon tachnlquee can ba Implemented In hlgh-rlek arena. Soma of thaae tachnlquee are) - Diking for Spill Containment. - Vaulting ot Endowing the Tranaforaara. - Currant-limiting Fuaa Protection Syatama. - Temperature Alarm or Trip Syatama. - Liquid-level Alerma or Trip Syatama. - CO2 or HjO fire Extlngulehlng Syetcma. 2-21 HONS 217205 - Air Isolation Valvee on Air Handling Syataaa or Exhauat f ana. - Floor Saalora to Stop Fenatratlon If a Spill Occura. - Hall and Calling Saalara to Stop Penetration if Flra Occura. - Periodic Oil Quality Taatlng Prograa. There are eavaral notlvatlng factore which encourage conpanlaa to bacoaa active In dealing with thalr PC# problem EPA Beaulatlona have aotlvatad nany coapanlaa Into action, the Food and Feed Induatry waa targeted by the EPA to ellnlneta PCBa by October. 1983.Soaa coaaarclal office bulldlnge have a target data of 1990. Other lnduetrlel facllltlaa era not affected by the EPA ragulatlone end could ehooee to continue to uaa thalr praaant electrical aqulpnant. The Inauranca Induatry hee alao sored groupa Into ectlojf by lncraaalng coata or by cancellation of cetaetrophl# or accidental coverage, Klak Aaaaaanant and Conpany Policy have played large rolca In the novanant to ranova PCBa. Corporate lnaga. rlght-toknow novananta by anployaaa and axpoeura to rlak by tha praaanca of PCBa have alao contributed to tha novanant. Leaking. Overloaded, and Poorly Maintained Tranafornari hive encouraged ayatan chengea. Incraaaad need' for capacity or ayatan upgradea have helped to reduce the PCB problena. Location of Tranafornara haa been a factor In nany caiai. High-profile tranafornara overhead or on gratlnga abovi anployaa work arena or walkweya nay ba good candldataa for raplacaaant actlvltlaa. Dnlta next to watarwaya or aaver yatana nay alao need attention. Tina will eventually nova nora and nora coapanlaa into action. Coat will notlvata coanarclal and lnduatrlal facllltlaa Into tha active role of allowing funda to neat certain deadlines. Tha active appraach to aolvlng a conpany'a PCB problen would ba to either ratroflll to raclaaalfy tha tranafornar to NON-PCB atatwa or replacanant with a new tranafornar and dlapoaal of tha PCB tranafornara. Tha naterlala lnalda tha tranafornari tha lenlneted core ataal. tha paper lnauletlon and tha wood epaeera have baan lnnaraad In PCBa for nany yaara, Tha PCBa have lnpregnated Into every crack and cravlcc within tha core and Into tha poroua paper and wood neteriela. Over period of tlna, tha PCB level la reduced by certain proeaduree to laach tha PCB out of tha tranafornar until it la raclaaalflad to NON- 2-22 HONS 217206 PCB atetue. The EPA raqulrea that the PCB level raaala below 50ppa tha and of a 90-dty reclaeeIf 1cetIon period. gatrofilllng for raclaaalflcttlon lnvolvae draining and dlapoalng of tha aakaral. Thla proceee laaadlataly raducaa tha PCB laval; and thara ara procaaaaa avtllabla that will. In tine. raduca tha laval of PCI to laaa than 50ppa for tha 90-day parlod and ultlaetely raelaaalfy tha tranaforaar. Tha moot populer--and currantly avallabla--weye to raelaaalfy aakaral traaaforaara ara tha aarlaa ratroflll acthod and tha axtarnal 'black box' aathod. 1 With tha aarlaa ratroflll option, tha procaaa takaa placa aa followat - Tha aakaral la dralnad and dlapoaad of. - Tha tranaforaar la uaually regeeketed. - Tha unit la fluahad. - Intarla fluid la uaad to oparata tha unit. - Ovar a parlod of tlaa, FCBa laach out Into tha fluid. - Tha unit la ahut down oe that lntarln fluid can ba raplacad. - Tha procaaa la rapaatad thraa to aavan tlmaa aa naadad, dapaudlng upon warranty and operating condltlono. - Tha unit la reclaaaiflad aa non-PCB. - Final fluid la placed In tha tranaforaar for operatioa-uaually allicona or ETEap. Thla procaaa typically takaa froa 12 to 21 aontha to coaplata. With tha black box aathod, thara ara two proceaeeei - Filtration Syntax - Slatlllatlon Syntax After draining and dlapoaal of tha aakaral fluid, ragaakatlng la parforaad aa required. Tha black box la than lnatallad at tha tranaforaar location. Tha tranaforaar la flllad with a apaclal dielectric fluid for a parlod of tlaa that will continually raaova PCBa Iran tha fluid by circulation through tha black box. Thla fluid will raaala In tha tranaforaar with tha ayataa operating until tha rata of change In tha concentration of PCBa haa nalntalnad a relatively conetent laval. At thla tlaa, tha procaaa la atopped for raclaaalflcatlon and teatad to daternlna If tha lavala will ranaln balow 50 ppa after 90 daya. If auccaaaful, the black box nay or aay not ba raaovad depending upon warranty taraa. A final raplacaaant fluid aay or aay not be lnatallad. Moat ayataaa uae allicona or ETEap; however, in certain caaaa, tranafornare can oparata with tha lntaraadlary dielectric fluid aa tha final raplacaaant fluid. Thla procaaa typically takaa 6 to IB aontha. 2-23 HONS 217207 Tha Initial outaga tlna nay range Iron 12 to 24 houra, and 6 to 12 houro lor aaeh required outage for tho aarlaa ratroflll nathod. Tha block box nathod nay require only a alngla Initial outaga for lnttallatlon. Many laauaa aurround tha ratrofllllng for raclaaalflcatlon cholca. Tha coopany haa to thoroughly lnvaatlgata nany factora, aono of which ar a I - Number of outagaa "" lntarruptlon of aarvlco. - Amount of fluid handling and treneportetion. - Tha characterlatlca of tha Interim fluid and final flulda. Thaoa charactarlatlea nuat ba datarnlnad both environmentally bacauao aona ora hacordoua chemlcala-, and electrically btcauaa NEC Coda nay have othar raqulramenta, , aucb ao diking or fualng, baaad on dloloctrlc atrangth and flammability. - Tima of conplation raclaaalflcatlon. - Duration of guarantao Cl-to 5-yaar tarna). - Potantlal darotlng of tronaformoro. Roplaconont and diapoaal lncludaa tha removal and diapoaol of a PCB tranaformar, and tha lr.atallatlon of a nav tranaformar. keplacement allowa tha company to aaaaaa and evaluate tha currant load altuotloo today and can thua plan for.tha futura. Ovar a poriod of yeero, a company may have added or ranpvad a groat daal of equipment that haa affactad tha load on tha tranaf ornara. Aa a raault, a company now would hovo aovarol pooolbllltloo to conoldari ~ Down alta tranafornaro (from 1300 to 1000). - Kamova thraa alngla-phaaa unlta and raploco with ona thraa phooa. - Toko out thraa alnllor unlta in tha aamo location and put back only ona unit. - Kaplaea thraa - 1000 kVA unlta with ona - 1500 kVA unit with now awltchgaar. - Ivaluata your load loaaao and buy high-afflclancy, low-loaa tronoformara Somatimaa loaaaa bacoma a vary Important iaomo la ehooalng a raplacamont. (Loaaaa ara tha anargy coot to operate a unit. Tha lowar tho loaaao, tha lowor tho oparotlng coata.) Thoro ara a vorloty of roplaconant tranaformar monufacturara that can offar dry-typa tronoformara or tronaformoro fillad with a laaeflaamabla fluid ouch aa KTEmp or alllcona. Tha downtlma raqulrad for aaeh tranaformar la typically 9 to 24 houra for a raplacamont project. 2*24 MOHS 2172O0 FCB tranafornar dlapoaal lnvolvaa Incineration of all PCI fluid and than dlapoaal of tha PCS tranafornar carcaaa. Tha aoat coaaon aathod for tha carcaaa dlapoaal la landfilling. Thla la accoapllahad by flrat dacoaalaalonlnt tha tranaforaar through an EPA approved fluahlng procedure, and than, burial of tha carcaaa at an EPA pprovad landfill. Aa technological advanecncnta procaad within tha anvlronnental control induatry, nora optlona for tha final dlapoaltlon of tha tranafornar carcaaaaa nay be evallabla. An option that could be available to tha raplaeanant narkat In tha near future la tha ecrapplng or the recovery of aalvaged natala by detoxification of an anpty carcaaa. However, thla ayatan la labor intanalva and tha coata will have to be weighed egalnat the potential llabilltlea of landfilling. Other partlnant factora whan conaldarlng tha ratroflll veraua raplaeanant option are tha verloua eondltlona affecting tha tranafornar* a operation and tha cuatonar'a naada. Thaaa factora night bat > " T ranaforaera in uao ara typically 10 - JO yaara oldl' Newer unite between 10 and 20 yeara old nay be good candidataa for ratroflll. Older unite (30 to 50) nay bo batter candidataa for raplaeanant. Tha tranafornara that ara in the aid range abould ba carefully evaluated to dotarnlna ratroflll or raplaeanant. Load. Tranafornara by application ara loaded vary differently. Sona have conatant load while othara hove a vary cyclic, variable load. In retrofllllng whara tha final fluid nay ba a laeaflaaaabla fluid like allicona or RTEnp, there nay ba derating of the tranafornara. Tranafornara with heavier loada typically have quicker leach bock rataa aaaoclatad with a footer ratroflll raclaaaIfication. Tha unite that are lightly loadad aany taka nore tine to aehlavo raclaaelflcatIon. Lightly loadad tranafornara nay alao be good candidataa for raplaeanant. Slaa-Voluna. Tranafornara by doaign vary In tha nunbar of gallona required to cool than. For ezanpla, a 1000 kVA tranafornar nay vary fron aa few aa 130 gallona to aa nany aa 050 gallona of PCI fluid. The ratroflll coata for tranafornara with higher volunaa of fluid nay ba aa nuch aa, or nora than raplaeanant coata. - Oucaaaa. Tranafornara that nay not bo aaally aceaaalbla or ara axtranaly difficult to ranova nay ba a better ratroflll candidate. Unlta that ara required to operate aevan deya par weak and 24 houra par day nay ba raplaeanant candidataa beceuao only one outage will ba required for the new lnatallatlon. No one aolutlon la tha "leaet axpanalva" all of tha tine. Sona PCI tranafornara nay ba coat effective to ratroflll and other PCI 2-25 HONS 217209 trenaformera will be wore coat affective to replace. Whan a company expend* tint, alfort and money to evaluate thaaa option* and than to prapara a aultchla plan to naat th* |o*la within a United meaoa, tha dacialon ahould anconpaaai th* coat* aaaoclatad with th* option* available, rlek aa*aaaa*nt for each lnatallatlon, corporate policy and current and futura EPA regulation*. In conclualon, a eonpany'a available option* Iron a rlak aanagaatnt parapactiv* would faa th* 'do nothing** policy, ratroflll for raclaealflcatlon to NON-PC# etatue, or total elimination of on-alt* PCBa by replacament. w* f**l that there 1* no ONE aolutlon,for all caaea. Plaeee contact the Sun Environmental Conpeny for tha aervlcaa to develop a prograa for evaluating th* clrcunatancaa pertaining to each tranaformar at all of your company'* facility location*. Our goal will be to help the reaponalbla manager make a coat affective and environmentally conacloua dacialon for tha company to comply with the current EPA regulation*. 2-26 HONS 217210 HONS 217211 SUCCESSFUL FIELD PROCEDURES IN THE RETROFILL OF EUROPEAN-DESIGNED TRANSFORMERS HARRY CLARKE CrOMvnor Transformer Sarvicea, Ltd. Weat Yorkihtr*. England ABSTRACT Successful ratrofill of tranaforaara and associated'equipment requlraa a sound technieaj approach, aafa and effective dielectric tluida, and conaidarabla amount of field planning and aarvicing resourcefulnaaa, Europe an-deeigned transformara, diffarant in configuration from thair US. counterparts but broadly axportad around tha world, eaphaaita tha importunes of field ratrofill flaxibility and ingenuity. The unique daaign of trantforaara m each country, auch aa conaarvator-typa traneforeera, add to t/ic need for very detailed field planning and execution, it ia miateke to t generalize on tiald ratrofilia procedure without taking into account auch difference* by country. Field modi fleetiona to the tranaformer and aqulpaant may be nacaaaary " and appropriate in conjunction with tha ratrofill itaalt. Thla paper will describe' and iiat tha Icaaona learned from tha author'd axparlancaa in ratrofi1 ling huarfrerfa of tranaforaara in a nuahar of European and intarnationai countriaa. INTRODUCTION In ay praaant poaltlon at Groavanor Treneforaere Serviced, Ltd,, 1 have, over the leat decade, planned, auparvlaed and participated In tha ratrofiii of over SCO transtoraara of varloua daalgna in countrlea aa dlvarae a# tha United Kingdom, Holland. Franca, ttaly, Ireland, Belgium, Singapore, Hong Kong, Bahrain and Saudi Arabia to . nano nut a few, Aa can be imagined, tha dlvaraity of tranaformer daaign, earvice requlramenta and phyaical aattlnga can be aatoniahlng and even frightening conaidar~ ing the political altuatlona around tha world, For example, we warn involved in tha ratroftli/aervlcing of tranaforaara in Singapore under tha watchful aye of heavily armed Curkha Cuarda. To be in auch a altuetlon, unable to communicate aaally with tha man at tha other and of tha guna can be dlecoocertlng, to aay tha laaat, la tha aaaa vain, working at tha alta of a major tranaforaar/FCB Incident cauaarf by a car bomb planted at a power aubatotlon can alao eat the oarvaa on edge. In thie cana. the bombing, motivated by political aantlmanta, wee intended to cauaa maximum vialbla damage. Probably unintended waa tha major problem encountered when a wall from the aubatmtton fall on aoma tranaforaara, ahattarlng tham and relearning algnlflcent quantltlaa of PC9 tluida, Thla PCB material flowed down aavaral lavala of a car park and lota tha water eump at tha bottom. Contamination woe maaalva and compounded by the fact that tha tire brigade uaad water to control the raaultant fire, thue apraadlng tha contamination further. Whether dloxlna or furana ware released In thla Incident la unknown but vary likely, Raleaaa of much informat ten In aoat European countrlea hea been leaa likely to occur than In tha United Stataa due to official raatreinta and the deaira not to panic tha public. Wa were involved in tha cleanup which waa conrfuctarf under tha utmoat and unusually tlfbt aacurity and aacracy. Some of tha paraennal at tha alto during cleanup ware even armadi Published with permission of Grosvenor Transformer Services, Ltd. 2-27 MOWS 217212 A in the Stataa. many have In the past attmmptrd to handle their pen altuatlona by burying the problem (Out of sight, out or einil, unit connl itdes/. such a fool hertiy approach only Invitee difficulties which surely will occur tooner or Inter, As e eoee in point, we were involved in the cleanup of n significant IT.B spill In s con tainer eh/p from a Middle Eastern country which hed sailed into a European port city. In e large cargo hold, two iontalnrra with transformers were located on top of m score of other contelnere, During the transport, the transformers Inot designed for such movement I ruptured, spilling their contents and contaminating the entire h,,h!. contents end all. A significant and costly decontamination uf the vessel and its con tents thus wee required. Fortunately, auch incidents no longer erti necessary btmuee transformer replscement snd IsndfiJJ ara not the only methods for eliminating PCF transformers. New retroflll technology, successfully commercialixnd In the Unit i d States, Is being demonstrated on Europesn designed trsneformers In nperntZonal plant settings In Frsnce end Jtsiy. with my participation. EUROPEAN SITUATION Kit in Europe and the real of the 'developed'' world are at Jcaat aa common aa in the United Stataa, In aome areaa. particularly franca end Aaat Gereeny, the concentretion of PCB transformers is significantly greater then in the States, it has been eatimeted that franc# alone has approximately the same number of PCB transformers us tlnry United Stataa, with Germany having perhaps half that number. Other major PCtt contend ing countries are Italy and Japan, Aa one can imagine, the concentration of PCS h transformers la rniatnd to tAa population density of the industrial world. This should cearn aa no aurpriao considering PCBa (Pyrana, Pyrocier, Chiophen. Kanaclor. etc.) were ceneldered to be the beet transformer dielectric fluid for use in those altuetlona where fire heserde were of paramount concern. PCB Hanlatorv Cl imete in Sutop- Until recently, sentiment supporting PCHa w universally bald in Surope, which continues to lag the United states in PCB regula tory mat tore, In fact, until recently, PCBa continued to be menufme lured end pieced In new tranaformers in franco, to the continued amassment of Americana. If the regu latory climate in the States is considered to be confusing, the situation in Europe and elsewhere la orders of magnitude worse due te widely differing regulatory cli mates in tAa various countries, Holland, for example, wee the first country to encourage PCM removeJ by granting subsidies to spur industry forward. Such subsidies (recognising the value at maintaining end existing transformer in piece vie retroflll rather then replacement) are fraatnr for retrofili then tAa other option. France, due mainly to major KB incident* In Raima in 1985 end lyen in 1986. la awing toward# rigorous control end regulation of PCB end KB containing equipment. Other countries ere now beginning to address the situation. Germany for example does not have e netlonel policy per ee. However, state legislation on transportation, a terete, destructloe end processing of KB wanton la savers and restricts movement of tAa aatariai. Italy fntJJi effected by the specter of Sevoaol has specific regula tions under deeeJepment, Finally, Japan has perhaps the worst possible situation taeglnabieiPCte seem too dangerous to move or hondio. Such material and contaoinatnd equipment ebeuld remain untouched end unmoved from currant iocatinna untii some future date and idamtlflcation of a netlonel policy for eddreeelng the total problem. Thle leads te the altuetion where contamination of the acoayataa la continued. However, Me* o policy (one would expect banning onviromantoiiy unacceptable land fill) la approved, tAa Japanese can be expected to move rapidly to correct tAa aituatlon (Apparently no one wants to risk another "Yuaho* incident). A major, though completely unpublicited, FOB Incident Involved a major excavation project in Europe, new abandoned. A site substation containing t PCB transformer* leaked ever 100 gallons of KB aatariai, which uitiaataiy reached the sea. The site wee not claanad up at the time due to the tremendous coat aaaociatad with dacontaat- 2*28 HONS 217213 t nation and remains contaminated. Events like thia. telme, Lyon end Sevsso should causa nore count riot to address tha actuation Ay stricter environmental litre modeled after the V.S. BPA regulations in addition. Ineurenee cerrlere In Europe faucti at A5EA. Alllene end La Lit tors1) are now recommending removal of PCBs, thue putting Increasing preeaura on the regulatory agendas to anact stricter controls- EUROPEAN DESIGNED TRANSFORMERS there are many significant design differences In European designed transformers (often found In such far afield places as Singapore. Bahrain, ate.) that to anuaarata tPaa aJJ would take mure apace then allowed hare. These tranaforaara, Ilka their V.S. counterparts, era sited for the power requirements for a particular application. That, It would be Impossible to discuss differences In average KVA par transformer, otPar than tn atata tpat the average RCB tranaforaar Is about 1,000 KVA. However, it seams trua tPat European designed transformers are more conaarvativaly designed then the V.S. tram formers, (that is. they have a higher gallon to KVA ratio than In the States), This would be particularly true for thosa transformers which wars initaiiad In tropical environments where the greater air ambients require Increased cooling capacity. Aside from these minor differences, unusual equipment with raapact to the ' V.S. market Is often encountered which must be taken Into consideration during the successful ratrofill servicing procedures. _ jr Cpnservstor tanks are rather like a reservoir fitted on the top of the transformer., and used for the expansion of oil In the transformer as It comae up to oparatinf timparaturaa. In addition, the conservator dacraaaaa the surface arse of oil in contact with the atmosphere, reducing tPa potential tor moisture contamination in these free breathing transformers. Such unite peas, in the author's opinion, the gras teat diffi culty towards the auccaaafui ratrofill operation. This Is trua basically because drainage of the conservator is not atraiffttformrd. A standpipe within the conserva tor and connecting it with the transformer tank extends about S cm up into the con servator. As a result, about ION of the conservator volume is undralnabla, yet can appear to Pa totally aapty of Its PCS contents. Compounding this la the fact that the conservator has a drain plug with no valve. In such a situation, raaovai of the undralnable PCSa in the conservator can be accomplished by removing tha conservator itself, an action which can causa PCS to spill. Alternatively, the drain plug may be utilised, Put at tPa risk of experiencing an uncontrolabla flow of PCS material. Groavsnor Transformer Services has developed procedures for resolving this situation an a routine basis. Fluid changes from PCB to silicone (tor example) pose apaoiutajy no problem with raapact to the successful ratrofill of convantionaiiy designed treneformara which can more than handle the minor dlfferancaa in expansion of the various acceptable fluids. Thta, In faaarai also is trua tor the conearvatar tank treneformara in Europe because of sufficient capacity within the conserve tors. For those inatancaa where the capacity at the conservator la Insufficient, the knowledgeable ratrofill aarvlca technician can easily overcome the problem by either changing or expanding the consarvatar, with both operations exhibiting their own particuiar eat of difficuitiaa. In bath cases, careful examination by the technician is required to identify the materials of construction of the conservator (mild ataai, atainiaaa ataai. ataai with braged ends, etc.), and to utiiiaa compatible aatariaia for the modifications last different metal expansion characteristics result in cracking of walda and occurrence of leaks. Our experience demonstratee tPat fluid expansion and conservator design peas no insurmountable problem barring the successful Implementation of ratrofilla. Bucholsa Raleys, fit tad on conservator unite, serve aa protection against fluid loss or as a fault detector triggered by rising gases caused by a fault. As in the case of the conservator itaaif, tPa duepoiaa relay can retain a certain amount of fluid within its suap aftor tPa tranaformer unit has been drained of its contents during 2-29 HONS 2172X4 the rtrofjll procedures. Tha floats of the fluid level gauge, designed for certain cot]onto. oy require changing for proper gauge functioning. Fully In torn 1 Filled Trans formers *ro hermetically *eeled unite which, in contraxt (a the coneervntnr design, are non-breathing units. Fluid expansion in taken up by the expanding fine of the cooling redletore, end cero mutt bo exercised when changing fluid* in thi* type of trenefnrmrr leu undue pressure rexul t. Careful choice or replacement fluid or inetellation of tooled conearvetor tank* or seeled pressure typo vessel* tro loan nf the options available tv overcome thi* ainnr difficulty. Gasketing Metarlalt oftan era compoaad of matarialt not compatible with both FCb and silicon* dielectric fluid. Am in the United State*, standard operating procedure* should cell tor regaaketIng with illlcona compatible matarialt prior to introduction cf tha allicon* dialectric fluid. In moot Furoptan designed tranaformera, thn nore and windinga of tha units srs attachad to tiro oeln covar. kagaakating requires the uaa of o lifting gantry, making regaaketing morn difficult, but cl early not Iwihjh tibia, Altarnotlvaiy, tha uao of specially dovelopad atalanta may ba Indicated. oss comm approach Ilka their American countarperta, all European designed PCS transformer* (whether located In Europe or In othor, aoro exotic location*) have one common problem, pim ply stated- THEY CONTAIN PCBs. Except for the long term risk to the environment . pommd by the PCHe, nothing about those particular trenetormere suggests that they have anything but a long Ufa of efficient operation ahead of them, Nhy then ahvoi<1 tha trantformar ownar want to mllmlnmtm such a valuebla aaaat whan technology to suc cessfully ratroflll and ramove the PCS from the transformer exists totfy7 The solu tion to the problem of remove] of PCHs from a transformer requires the couplet* removal of tha KBs from tho core lnsulmtlon materials (calluloalc in nature In both Europe end abroadh One common approach will suffice for oil thooo vorlouo traps former design*. That epproaob require* the rapid and total removal, vie diffusion, of tho PC8 from tho tronsformmr core. Older technology directly utilising silicone oil toiled miserably in this respect when the silicone actually blocked th* diffusion of the Kte from tho colluloaic material, Hew technology, recently pioneered In the United States, Jo now being applied to European designed trsnaforaara of the types listed above. furtAor, contrary to unfounded claims, siJleone in my experience worldwide, exhibit no detrimental effect on formerly KS containing trenetormere. CONCLUSIONS A, Europe feces the same dilemma regarding PCS transformers ot In America, but Is somewhat behind In rsgulat ions/control versus the Stetee. g. PCS* arm commoe in Europe and other industrialJxad nations. C. European designed trenetormere exhibit several differences from tho U.S. unit*. including high gal Iona/KVA ratio, conservators, hermetically sealed tanks, *tc 0. Such dittmremeee poem their own oot of service problems, hut do not in any way rule out the utility of ouccooo of ratroflll procedures. B. Field medltlcations need be routine end a detailed knowledge of many transformer dealgas la required, necameitetlng the use of specieUsed contractors. F. Successful ratroflll cam heat he accomplished with aped el dielectrics which max- imtgb removal of PCSo from the transformer internals. Q. Ultimata ratroflll with silicone la acceptable worldwide end deem not adversely effect the operation of previously PCS containing transformers H, In Europe, old things- even transformers- ere treasured, not die carded. 2-30 MONS 217215 IN-SERVICE RECLASSIFICATION OF ASKAREL FILLED TRANSFORMERS PROGRAM UPDATE Humy 0. McMahon and Thomas 0. Venabla Westlngnouse Electric Corporation ABSTRACT EPA regulations restricting continued use of PCB transformers has caused most owners to seek the most efficient and cost effective means for minimizing PCB risk. PCB risk reduction programs should Include risk surveys, remedial action and long term plans for replacing or reconditioning PCB transformers. PCB transformer owners do have some choices In this program, PCB contaminated transformers may be retrofllled or replaced. Pure PCB {askerell transformers have traditionally been replaced. The askerel Is Incinerated and the carcass Is burled In a secure chemical waste landfill- Until recently Industry could not offer a means to clean an askarel transformer so that It could be reclassified to non-PCB status. Westlngnouse offers a field-proven process by which pure askarel transformers mey be reconditioned with guaranteed reclassification to non-PCB status of less than 50 PPM. Commercially owned transformers that have been reclassified at PCB levels as lw as zero to 17 PPM following a few months of processing and ninety days of In service waiting period required by EPA regulations AO CFR 7(1 will be discussed. Westlnghouse Transform1" was Introduced In early L9B6 and has already resulted In more than 0 commercial transformer reclassifications. The process, extensive test program and actual case history results will be discussed. tmTransForm Is a registered trademark of the Quadrex HPS Corporation 2-31 MONS 217216 in-service reclassification of ASKAREL FILLED TRANSFORMS PROGRAM UPDATE Murray D. McMahon and Thomas C, Venable Westlnghouse Elactrlc Corporation TEXT-INTRODUCTION Tha 1079 enactmnt of EPA regulations restricting the continued use of PCB transformeri end furtner revision of tnese regulations through 1985 has caused mot* PCB equipment owners to seel' the most efficient and cost affective means of minimizing the PCB risk now confronting them. The degree of this risk depends upon the PCB concentration (PPM), which determines the risk category, and upon the equipment location, which may Increase risk of exposure to the environment or possible fire. Equipment age and condition, of course, are contributing factors. It Is beyond the scope of this paper to explore In depth the EPA regulations at they are defined In 40 CFR. The reader Is advised to refer to 40 CFR 751 and to his own legal and environmental council for Interpretation of the regulations. In general, the current regulations define three categories of PCB devices; > 500 PPM - PCB > 50 but < 500 PPM - PCB Contaminated < 50 PPM - Non-PC B PCB contaminated devices (> 50 PPM but < 500 PPM) have long been remedied by simple "retroflll" or replacement of contaminated fluid with new fluid. Mineral oil devices, contaminated to even greater than 500 PPM have been easily remedied In the same manner. Many owners of PCB devices have elected to perform a complete changeout of the device, replacing It with a device of like kind and thus eliminating the Immediate PCB risk, PCB fluids are Incinerated In approved PCB tmTransForm Is a registered trademark of the Quadrex UPS Corporation 2-32 MONS 217217 lntrators and carcasses are burled in EPA approved landfills. Retroflll and fnkey replacement services are available from several reputable service pliers. Ir ^Industry has sought an acceptable procedure by which pure askarel transformers |(buld be reconditioned In sons manner to permanently reduce the PCB concentration *to below 50 PPM while the transformer remains In service, as 1l permitted by the Regulations. Several attempts have been made to achieve this goal In the past. Certain methods attempted to filter or absorb PCB's from the transformer; others "attempted to reduce PCB concentration by multiple retroflll actions over long periods. Varying degrees of success (or lack of success) have been achieved. Residual PCB, leaching from the core and colls, untenable frequent power interruptions and lengthy processes have been frequent barriers to complete success and acceptability. In early 1966, Westlnghouse Electric Corporation Introduced TransFormtm, a PCB reconditioning process which guarantees reclassification of askarel filled transformers to non-PCB status (below 50 PPM) quickly and with only two short power Interruptions. This paper will functionally describe the proprietary process, the extensive test program and results, which are impressive. Although just introduced at the American Power Conference In April, 1986, the TransForm1* process was turning out reclassified transformers by the fall of 1986 and by raid-1987 more than 50 customer owned commercial transformers have been certified non-PCB. Many more are currently being serviced or are In the 90-day reclassification period. Actual case history results will be described of in-service askarel transformers, mpy of which were processed in six months or less and reclassified at levels of zero to 17 PPM. It now appears that transformer size, as well as other variables such as manufacturer and Internal configuration, may slightly effect processing time. Oata will also show that leaching was insignificant over one year after reclassification. PROCESS The Transform1* process was jointly developed by Westlnghouse and Quadrex HPS, Inc. starting In 1984. This process allows decontamination of operating transformers that were originally designed to be filled with askarel, a non-fleasable transformer dielectric of the 1930's to 1970's specifically suited for Indoor 2-33 HONS 217218 transformer applications. The process is not intended for mineral oil filled transformer designs, which can t>e remedied by the simpler retrofit! method. Not all askarel transformers are considered candidates for Transform*TM or any other reclassification procedure. We recommend that potential candidates be scrutinized carefully as the decision is made for turnkey replacement, recondition or 'do nothing*, Including an evaluation of: electrical Test Fluid Test Physical Condition Age Physical Location (ease of removal) Cost of Replacement Owner's Plans and Concerns _ Following this evaluation with our clients, and once the choice Is made to proceed with Transform, the project schedule begins with a scheduled transformer de energization for a period of less than 48 hours. Asfcarel fluid Is drained from the transformer Into tankers or barrels for disposal by Incineration In an CPA approved PC9 Incinerator In full compliance with all EPA regulations. Gasket materials are always replaced during this Initial outage. The transformer Is then filled with a proprietary dielectric fluid, TDR-3. A Transform*" processing unit Is connected to the transformer via smell teflon hoses with safety features such as stainless steel braided shield, quick disconnects, locked panels, and solenoid operated valves at each end to close In event of a problem. The process Is designed for orderly shutdown of the processor In event of malfunctions, without disrupting the transformer operation. The transformer Is then re-energized and processing occurs during normal, full-load operation. The TDR-3 dielectric fluid Is an excellent medium for PCB removal which readily extracts PCB from the transformer Internal components. The unit processes a continuous flow from the transformer, removing the PCB's from the fluid and returning cleaned TDR-3 to the transformer. The TransForm** unit Is Interlocked In such a manner that the liquid level in the transformer Is maintained at the proper level. All parameters of the Transform*" unit which can affect operation of the transformer are monitored and Interlocked to assure that the transformer remains 2-34 HONS 217219 fCVtnln *** normal operating range. TransForm" It designed to run automatically (S^ing the servicing period of approximately * to 5 month* or let*. Remote (fnterrogttlon vie telephone modem Is available. Servicing and Inspection visits fire mde at two to three week Intervals. The extracted wastes are removed from me ^ilte for Incineration. I r Vs the conclusion of the processing period Is recognized from test sample data, me rTr*nsForw unit Is disconnected from the transformer and the 90-day In-service ! parlod for reclassification to non-PCB status (below SO PPM PCB content) In accordance with EPA regulations <0 CFR 761 Is started. After reclassification, me transformer Is scheduled to be out of service for approximately B to 24 hours, during which the TOR-3 fluid 1* removed from the transformer and handled In accordance with EPA approved procedures. The transformer Is retrofllled with the dielectric fluid of the customer's choice. Candidates are mineral oil, silicone, R-temp, etc, TDR-3 remains the property of Westlnghouse and Is not Intended to be- a permanant replacement dielectric fluid. /- Using TransForm, transformer owners can achieve guaranteed non-PCB status without having to replace existing equipment. TransForm" Is particularly wall suited for units that are expensive, difficult and costly to remove or have long remaining useful life. TESTING PROGRAM During the initial testing program, a number of transformers were processed In accordance with the above procedures. The specific testing variables and results are discussed 1h detail In C. Claiborne's and C. 1. Yacher's paper, "A Process for In.Service Reclassifications of Askarel Filled Transformers", presented at the Annual Meeting of me American Power conference April 14*16, 19B6. (1) During this testing program, monitoring of the contamination level Indicated mat the PCB level In the transformer fluid Is reduced rapidly to below 50 PPM and neld there for the remainder of the processing period. Figure 1 shows typical curves for contamination as a function of time during Initial processing for units with original PCB levels ranging from 30D.00D to 700,000 PPM. Obviously, PCB concentration In the dielectric Is reduced drastically Just by removal and replacement with new fluid, but even with careful flushing procedures this 2-35 HONS 217220 reduction ray create false Image since leaching from the core colls end other Internals would cause rise back to thousands of PPM. The TransForm*1" process continuously extracts PC8's, nence, tne fast reduction to the lower level. The completion of the processing period Is determined by monitoring the rate of PCB removal from the transformer. Figure 1: PBC level during process start-up. As part of the test program, the leachback rate during and after redassflcatlon of two of the units continues to be monitored. Test data sheets 112 show the results of this monitoring. Both transformers were drained, retrofllied with silicone and returned to the customer. After the completion of exhaustive electrical tests, other units nave been untanked, disassembled and evaluated. No evidence of any effect upon the transformer material and minimal PCB residuals were found. FIELD EXPERIENCE The success revealed by the test program using customer owned transformers In the Westlnghoust Lansing, Illinois facility, lead Westlnghouse to confidently offer the TrangFom** process for generel field applications. We were confident that askarel transformers could Indeed be serviced and reclassified to non-PCB status (< 50 PPM) In the anticipated short period of time and that concerns of material degradation, leaching In the early or long-term stages, ate., nave been overcome. Test results were discussed previously and are shown in figure 1 and on test data sheets 1 and 2. The TransForm*91 process was now ready for field Introduction, and was officially announced at the American Power Conference, Chicago, in April 1986. 2-36 HONS 217221 jut nta ****** i T**c Cat* SS..C t t ^ lrktl * * ti, < t| luUMka , mi n it> rn,..i ^ _ ir*'*aafc l f Inwfiw ^k(tn **'<"( ftM *>* K) batMt fill***# ftt CMIW UMh * __ t ill* tail II Nil frtt. v*lU|* __f^aafl (it. MUl|* c*li**- fcll_ _ MMHMnrir lum* l.il.l *. <i.'lt Tr. >1 III it;i llilnmi 1 .. I... If. ta --... i ua TrMf*V NhIMUi <Um4 tW MMiUUMIm tot* to tout*m *t -HJu rm I....UI >. m !-_____ Lbfut rU#V'to K OMIW t*M*l ku *--** --to>* --- bit lUirt ii tot* PHu **Uece >*. Viltt|i Cell** liana MTU JuuoiJILiai. -U. OL1. Jlhiuo Customer orders were developed, besed on the successful pilot programs, ringing from major utilities committing their entire system to small Industrials with two or three transformers. One of our early coanltments, a utility company opted to have Its 2500 KVA transformer containing 1060 gallons of asktrel processed in our Chicago facility rather than on-site. This large transformer processing was Initiated In November, 1985, and completed August 7, 1986. The unit was certified non-PCB at a level of 17 PPM following the 90-day In-service period, it is significant that this large unit was processed under simulated load conditions, with special approval of the EPA. This procedure can be used to process askarel units that are not readily energized such as spares. One client has chosen to bring his transformers to a central facility for processing to minimize public attention and vault congestion. The client Is reporting on this procedure to E.P.R.I. Simultaneously, orders were received to process a multitude of types, sizes, ratings, manufacturers and ages of askarel transformers. Transformer ratings from 600 KVA to 7500 KVA with volumes from 150 to 2500 gallons of askarel are being Transformed. Ages range up to 30 years or more. Manufacturers of the askarel 2-37 HONS 217222 *L unit* Include Westingnouse, Gener*! Electric, ITE, Pennsyl venle, Heloney, Nlagra, Alii* Chalmers, end ottiert. A few of tnete certainly deserve mentioning nd me tabulated In Figure 2. One major mldwestern utility company cnoie Westfnghouse to recondition tne remaining 69 askarel unit* of it* Tran*ml**ton/01*tn button and Power Plant systems In a very tight time period. This has been discussed in greater detail in papers by our client. (2) Suffice to say here that the commitment Is being met and the units began receiving reclassification certificates In November, 1986 following five months or less of Transform1* processing. Reclassification levels of zero to six parts per million following the 90-day period are not uncommon as snown In Figure 2. ' , ASKAREL TAAKSFOfKQ RECLASSIFICATIONS TRANSFORMER KAMUF. KVA PRIM. VOLT SEC VOLT A 1500 12KV 480Y/277 8 CE 2500 12KV 4I0Y/277 C 2500 13,2KV 410 0 <s> 1750 13.2KV 480 E <s> 1500 13.2KV 480 F 9 1300 13.2KV 480 C XTE 1300 6900V 480/277 FLUID RECLASS GALLONS TIKE PPM f reclas; 410 120 days 7.8 400 100 daya 8,3 1060 1 BO. 17 230 5 BO - 0 221 5 BO. 6 221 3 mo. 5300 PO: 3 6 Figure 2: Typical Caae Hiaeory Raaulta Another Midwest utility achieved reclassification of Its 1500 KVA, 300 gallon transformer at 6 PPM following five months of TransForm11* processing end 90-day In service period. Many more transformers for Industrial, conmerclal and utility customers have completed their processing and are currently In the 90-day waiting periods. Many, many more are currently in process in major commerlcal buildings, hospitals, universities, dairies, chemical plants, paper mills, steel mills, utility power plants end distribution systems. 2-3B MOWS 217223 nr*nsformers having broad range of KVA's end liquid volumes heve been ind ere now ^Ing processed. Some ere very old end ire being reconditioned due to the owners Kiuctince to lindflll the units coupled with high replacement costs of some fipeclil units and the interest In repilr In event of ultimate failure. As long as fthe unit passes the electrical and fluid acceptance test, successful processing and ^reclassification Is achievable. It does appear from these experiences that larger transformers such as the 1000+ gallon variety may require slightly longer < processing time, but that desired results ere readily achievable. Fast reduction of PCB risk Is a reality. BENEFITS ' The askaral transformer owner cen now retain selected units within his system as . non-PCB transformers with minimum disruption to his power supply and production schedule. The Immediete economic savings Is an obvious benefit. The resulting non-PCB classified transformers which are no longer regulated and can be repe.fred . If they should fall are probably the most popular advantages. The reclassified transformers can legally be disposed of as non-PCB devises et the end of their useful life. It Is not uncommon for TransForm1* reconditioning of an average 2500 KVA transformer, where "in end out" costs will be slgnlflcent, to render e savings of 4OB over turnkey replacement. Obviously, site conditions greatly affect the difficulty to remove and replace transformers and each must be evaluated on Its own merits. CONCLUSIONS This paper does not intend to promote or recomaend Indiscriminate reconditioning, or retrofllllng, of atkarel transformers. Nor does It Intend to raeommend Indiscriminate changeout or replacement. It Is the Intent of the paper to raeommend that the owner's entire PCB system be carefully evaluated from the standpoint of risk; that the Identified deficiencies be Immediately remedied; and that carefully evaluated long-term PCB program be Implemented to retroflll, recondition or replace each PCB or PCB contaminated device as Is most appropriate from a service and aconomlc standpoint. Askarel transformers that are small, easily accessible and Inexpensive to purchase are usually better candidates for turnkey replacement. Similarly, askarel units that are "old" or that art In poor physical or al tetri cal condition should usually be replaced. The PCB program may 2-39 MOMS 217224 also give added opportunity for replacement of askarel transformers that no longer accomodate tne owner's electrical needs. In this case, a power system study It often recomended to determine the client's current power requirements before specifying a replacement program. It Is the primary intent of this paper to report that askarel transformer reconditioning through an approved servicing procedure, TransFormtm, Is field proven and available for fast reclassification with minimum power Interruptions ami that, for selectad PCS applications, such reclassification Is practical and economically feasible. ' For a<\y of these PC6 risk reduction procedures, a reputable, total service supplier is recommended to assure an unbiased evaluation of each option and, thereby, achieve maximum risk reduction per dollar spant, with less disruption to your business operation. REFERENCES 1. Claiborne, C. and Vacher, C.L.: "A Process for In-Service Reclassification of Askarel Fllltd Transformers", American Power Confernece, April 14-16, 1986.2 2. St. John, Robert M.: "KPl Gas Service Experience with Westlnghouse TransFortn PC6 Reprocessing", Missouri Valley Electric Association 58th Annual Conference. April 21-23, 1987. 2-40 HONS 21^225 system so** process rot retropiuinc MtD RECLASSIFICATION OP ASKAREL TRANSFORMERS Michael J. Hsssay and David R. Hopper RE1 Teehnolotles, Inc. Itl Vlrjlnls Rosd, Concord, HA 017ai The following 1* a report on experience salnad In tha retroflltlnt end rettssslflcstlon of spproxlmsttly *0 PCS transformers ualnt Spate* SO** technology. Experience clatrly demonstrates that PCS transformers can ba alaanad and raclaaalflad to a non PCS atatua with a single lntarruptlon of tranafonaar service of laaa than }t hour* and at coats which ora fully competitive with transformer replacement. CleanIn* la complete and permanent with aasantlally no Intrusion Into tranafonaar oporationa. SYSTEM 50 TECHNOLOGY System 50** tachnolosy consists of a proprietary coolant/dlelectrlc fluid and a proprietary fluids processor. In an Initial maintenance phase of System 50** aervlclns, a transformer la (a) de-enertlsed, <b) hulk askarel la drained from It, (c) tha transformer la reteeketed. (d) a System 50** fluids processor la attached to tha transformer, (a) System 50** fluid la introduced Into the transformer, and If) tha transformer Is re-enertlsed. As residual PCB's leech from tha transformer Into tha fluid, tha fluid Is cleaned In tha system 50** fluids processor and returned to the transformer. Such procasslnt continues until essentially all residuals have leached from the transformer and have accumulated In the System 50** fluids processor. Processlns Is then stopped and PCS consentratIons In tha transformer are monitored for 90 days. Once tha PCS concentration Is demonstrated to remain below 50 ppm over this period of time, the transformer la declared reclassified and all PCS labels are removed. Under a basic service warranty, transformer PCS levels are then monitored for one year and adjusted to less then 5 ppm at tha end of that tine. H 2-41 HONS 217226 System 30** coolent/dlalectrlc fluid is Factory Mutual Approved nonflavmable fluid. Ita coolant capacity la twice that of sskarel and lta dielectric propart lea are comparable. AccordIngly, Syto* 30** fluid la an excellent permanent replacement for aakarol In PCa transformers. Ita uao rodueea t rant former shutdowns to one and eliminates any noceaelty for the derating of transformers. Ita uao actually oxtenda the uoaful Ufa of transformers. System 50** fluid proceaaora are compact, rusted, reliable and effective. They are 2 feet squsre, leaa than 3 feet tall end welsh leas than 300 lbs (see Flture 1). They sit Immediately adjacent to tha transformer and operate virtually unattended for the entire durotlon of a transformer servlclns In environments rentIns fro* severe outdoor winter conditions to transformer vaults as hot os 130*F. RAMCC OF TRANSFORMERS CLF.ASID As Illustrated In Table 1, Syate* 50** cleaned transformers have rensad In sice fro* 50 KVA to 2500 KVA and contained fro* 30 to over 700 s*Uons of PCS fluid. They have encompassed the full rens* of PCS arochlors In Initial concentrations fro* 500,000 to over 000,000 pp*. Transformer locations have Included operations outdoors, In power generating stations. In public bulldlnss, and In industrial manufacturing facilities. Transformer loading patterns have spanned the complete spectrum fro* continuous, fully losded units to lightly losded units with extreme cyclic patterns of uso. Ambient conditions under these loads have Included extreme coal dust, subtero temperatures, rain and snow, end alavated temperatures of up to about 130*F. System 30** fluids end fluid processors havs performed well over the complete range of conditions toetad. PATTIMS OF TRANSFORMER CLRAN1N0 Rool PCS risks are mitigated almost Immediately with Syste* 30**. PCS concentrations In bulk transformer fluid fall rapidly ss soon os Systaa 50** processing begins. As shown In Figure 2, concentrations typically fall below 500 pp* within e couple of weeks end below 50 ppm within about six weeks. They remain at or below those lovsls for the duration of the cleaning. HONS 217227 2-4? ,1 cleaning time verle* with transformer operating condition*. k ehown In Jtir > *!* operating continuously under full lo*d clean within 3 to t ^nth*. Lightly loaded units end units under highly verlshlo losd or having low ibl*nt temperature* can require fron t to 12 mernthe to cloen (so* riquro ). jjuch unit* typically hva low but per* latent Peg leaching rates (or such of the Cleaning period, in thee* eases, cleaning tines cen bo shortened by raisin* the 3^*r*tur* of these trensfoners. f COMPLETENESS or SYSTEM SO CLEANING fe on gyoten 50 cleenlng psrnanontly ollalnateo the PCS leaahlng capacity of e trensfenaer. This 1* Illustrated In rlgur* S. which shew* PCS concentrations in ' o tysten SO** cleaned trensfornor during and after reclasslflcetlon. PCI concentrations ere substantially less than SO ppn at the completion of reclesslfIcatlon. When this residual PCS level Is then cleaned with the System 50** processor, the transformer show* essentially no further cepeclty to leech peg's. This Is verified by detailed dlsmantloamnt and Inspection of the contents of s System SO** cleaned end reclesslf led transformer (sec rlgur* 5). In analytical studies performed by * reputable Independent laboratory, total mooaurod roalduol PCB's In e recleeelfied tranaformar constitute an aqulvalant of only T ppm ef PCI'a If all raalduala ware dieeolved In that tranaformer'a coolant fluid. i 2-43 HONS 217226 TABLE 1 Partial llat of Syatm 50 Tranaforaar CUaninsa Unit Ho. 10151 10141 10171 10211 10141 10201 10051 10241 10251 10221 10231 10121 10041 10111 10131 10071 100*1 looai 10101 10021 10031 10041 10111 101*1 TRAJlirOIlMEE IHPO KVA Hatlm 2500 2500 500 750 500 2500 2000 1000 1000 500 750 2500 1500 2500 2500 750 750 750 750 2000 2000 750 750 750 PCB ArwMtt 1240 1240 1240 1242 1240 1242 1240 1254 1254 12*0 1240 1254 1242 1254 1254 1240 12*0 1240 1240 1242 12*2 1242 125* 1254 PCB'a Tranafona VOluiM m___ Hanuf. (Cal) 59,000 CE 720 455,000 CE 720 754,000 Cl 2*5 70,000 Cl 130 4*4,000 Cl 2*5 700,000 CE 440 740,000 CE 435 540,000 CE 154 540,000 CE 154 7*0,000 CE 300 440,000 CE 245 41*,000 CE 3*0 HA CE 225 74S.OOO CE 3*0 422,000 CE 390 HA W 3*1 13,000 W 341 HA w 341 13,000 w 341 11,000 CE 300 34,000 CE 300 47,000 CE 147 700,000 CE 215 00,000 CE 215 2-44 HONS 217229 FIGURE 1 SYSTEM50 FLUIDS PROCESSOR IS COMPACT 2-45 NONS 217230 FIGURE 2 SYSTEM 60 CLEANING REDUCES FLUID PCB CONCENTRATIONS RAPIDLY AND PERMANENTLY *ONS *17*31 FIGURE 3 LARGE IN-SERVICE TRANSFORMERS CAN BE CLEANED QUICKLY AND COMPLETELY KVA 1IOO AtmM*' 1I1NM Unit 1011 01 ASKAREl TRANSFORMER RECLASSIFICATION Z-47 HONS 217232 FIGURE 4 LOW LEVEL RESIDUAL PCB LEACHING CAN PERSIST FOR 6 TO 12 MONTHS ON TRANSFORMERS WITH LOW LOADS AND FOR LOW AMBIENT TEMPERATURES 2.48 HONS 217233 FIGURE 5 SYSTEM50 CLEANING IS COMPLETE AND PERMANENT 4 9m MEASURED RESIDUAL PCB IN SYSTEMSO RECLASSIFIED TRANSFORMER H KVA 01 TwwWwir CmliiwiM ............. CmU* VHMl IllrfMM Co St*W Winding*. Wood. Colhilo** Copoor Conductor Ml*o*llon*ou* Totol < 01 ppm 3.7 ppm 2.0 ppm 0.9 ppm < 0.1 ppm < 7.9 ppm 2-49 MOWS 217234 HONS 217235 Problems Associated With Reclassified PCB Transformer disposal Or. J.B. NcOermott Chemical engineer Gf Corp. BBS 1 River Rd. Schenectady, Nr 12345 R.K. Xump Mgr. But. Oev. - PCBt GC ISGS 1 River Re). , Schenectady, Nr 1?J4S Or. C.l. Cocclo Ngr. PCB But. Oper, GC ISIS 1 Rlvtr Rd. Schenectady, NY 12345 ABSTRACT Tht 'Flr't Hatard Rult* Ittutd In July 1985 provided new rettrlctlont on certalp typtt tnd applications of transformers with the basic deadline for modification, rtmovtl or rtdtttlflcttlon In October 1990. Retroflll tervlctt t offered by vtrlout companies may be able to effect reclatsificatlon by the CPA definition, thut allowing the owner to continue operetlng the unit. Tht questions which thould be answered are - How much PCB remains In the transformer after retrofllllng and what actions thould be taken by the owner of a retrofllled transformer? The cradla-to-grave responsibilities of the original owner could require him or her to remedy any contamination resulting from the residual PCB In the retrofllled unit. A study was performed to determine which solvents were suitable for use at retroflll fluids. Diffusion studies and mathematical modeling were then performed for the most likely retroflll solvents. The results of this investigation suggest that significant amounts of PCB remain In the internal structure of the transformer after reclassification to PCB-contamlnated or non-PCB regardless of the retroflll process used. INTRODUCTION By 1990, PCB transformers In commercial Installations will have to be modified with high and in soma cases low current fault protection equipment and certain PCB network transformers will require reclassification or replacement (1). The choice can sometimes be difficult for the owner of the transformer. If the owner chooses the transformer replacement option, he mutt remove the PCB transformer and replace It with a suitable environmentally acceptable non-PCB transformer. Oespite these efforts, he remains responsible Indefinitely for the contaminated carcass. Retroflll services seemingly alleviate the potential liability by removing and ultimately destroying the PCBs. Those who choose retroflll may believe that a reclassified unit Is equivalent to a unit that was non-PCB originally and can be disposed of in a like manner. The present CPA regulations allow units reclassified to non-PCB transformer status to be disposed of as non-PCB units. Two important questions remain - how much PCB remains in the retrofllled transformer and what liability can ba Incurred in the unregulated disposal of these PCBs? 2-50 HONS 217236 There Is nothing magical or mystical about th removal of PCBs front transformers. Jh* process involves draining tha PCB fluid from the transformer, replacing It *1th another dielectric fluid that Is also a solvent for -CBs, and waiting a tuffldently long tine for the PCBs to leach out of the Internal structures. As the PCBs diffuse into the bulk fluid, they can be removed either by periodically changing the fluid or by continuously removing a fraction of the fluid, separating out the PCBs and returning the fluid to the unit. This cleaning process, since it is strictly a diffusion*! process, can be characterized by transformer structural information and the nobility (dlffusivlty) of PCBs in the various transformer components. Typical transformer materials Include paper Insulation, wood, phenolic material, copper and aluminum windings and B to U mil thick sheets of steel used as the magnetic core. Herein Is presented Information regarding retroflll with the three most suitable solvents-tetrachloroethylene (TCE), trichlorobenzene 1(TCB) and silicone fluid. The information presented strongly suggests that a significant amount of PCBs remain in the transformer components after the retroflll process is complete, even though the transformer may meet the reclassification requirements as presently specified by EPA. EXPERIMENTAL RESULTS AND DISCUSSION FlUltt jftilffltl The amount of PCB fluid held In the internal structures of the transformer after It has been drained Is an Important piece of Information for the modeling of the retroflll process. A ID KVA oil-filled pole-top transformer was disassembled and each of Its components was solvent eitracted. The extract was collected and the solvent evaporated allowing determination of the amount of fluid trapped In each component. The amount of fluid extracted was a function of the degree of fragmentation. Samples that were extracted, then chopped to smaller pieces and re-extracted yielded considerable volumes of oil with the second extraction. The nominal size of the extracted fragments was D.S inch. The Internals of the transformer held 3.3% of the original volume of fluid that filled the transformer. See Table 1 for a more detailed breakdown of the fluid volumes. Independent of whether the transformer had been filled with IOC oil or PCB fluid, the volume of fluid trapped in each component would have been the same. While there are some structural differences between an oil-filled pole-top unit and a pyranol unit, the above Information Indicates the magnitude of the fluid trapped In the Internal structure of a transformer. Olffuslvltv Measurements The above work defines the amount of PCB In the transformer at the start of the retroflll. The other piece of Information necessary for the modeling Is the rate at which the PCBt leach out of the structures. This is characterized by the dlffuslvlty (D, cm*/s) of the PCB In the materials. Dlffuslvlty Is the mass transfer analog of thermal conducltlvty and Is a function of the solvent as well as the medium In which the diffusion Is occurring. The molecular dlffuslvlty of biphenyl In TCE and TCB was measured at 23*C using the method of hydrodynamic stability (2). The molecular dlffuslvlty describes the mass transport through a homogeneous phase (stagnant film of fluid), not a porous structure. A porous medium, by providing resistance to diffusion, decreases the 2-51 MONS 217237 effective dlffuslvlty. The molecular dlffuslvltles determined here cen be viewed as upper bounds to the rite of diffusion In the various transformer components. Biphenyl provided for an easier analysis of the data since It is a single compound, unlike the PCBs used In transformers that were complex mixtures of similar chemical species. The transport properties of PCB and biphenyl ere similar. The dlffuslvlty of a PCB (polychlorinated biphenyl) can be easily estimated from the biphenyl value by accounting for the differences in molal volume at their respective boiling points (3). The estimation of dlffusIvltles at temperatures other than the temperature of measurement is also straightforward (4). See Table 2 for the measured dlffuslvltles of biphenyl along with the estimates for hexachloroblphenyl (KCB) at 23*C and 60*C. Hexachloroblphenyl (6 chlorine atoms out of a possible ten on the molecule) Is the 'average* constituent of Arodor 1260 since Aroclor 1260 Is 60X chlorinated, lhe dlffuslvlty of PCB in silicone fluid Is substantially lower than in TCE or TCB as a result of Its higher viscosity. Because of the lower dlffuslvlty and partial miscibility with askarel, silicone fluid would be considerably less effective at . PCB removal than either TCE or TCB. As a result of the lower leach rate, silicone fluid could be used to Increase the likelihood of the reclassification If used as the dielectric fluid during the reclassification period. The silicone fluid would retard the leaching of the PCBs from the transformer Internals resulting In a lower PCB concentration In the bulk fluid but higher PCB residuum. MATHEMATICAL MODELING The system cholen for the modeling of the retroflll process Is a 500 KVA PCB transformer filled with 300 gallons of fluid that Is 50X by weight Aroclor 1260 and 5OX TCB (trl- and tetrachlorobemene, a typical askarel mixture). The modeling is specifically of the transformer colls because these represent the most difficult structures to render PCB-free. The core, the other major constituent of the transformer, has spaces between he laminations that are large compared to he dimensions of a PCB molecule and the diffusion path out of these laminations is not tortuous (straight-line). Thus, the mode of diffusion out of the laminations Is molecular, not hindered as Is the case In the coll Insulation, The level of PCB residual predicted here, modeling only the colls, is an under-estimate; because, there are likely to be considerable residual m the fiberboard and the maple in addition to what remains In the colls. A conservative estimate of the amount of PCB material contained In the three colls of the 500 KVA transformer before retroflll Is 4 kg based upon the fluid volume experiments described earlier, The actual amount could be as high as 16 kg. The dlffuslvlty parallel to the paper windings Is several orders of magnitude greater than perpendicular to the paper (5). Therefore the diffusion was modeled In one dimension parallel to the paper. THe length of the coll in the direction of greater dlffuslvlty was 30 cm. In Figure 1, the amount of PCB remaining In the colls after 6 months of diffusing Into a solvent with tero PCB concentration (the maximum driving force for diffusion) Is plotted against values of dlffuslvlty/dlffuslon-length* (D/L?). Curve A depicts the results for the conservative 4 kg fluid mass estimate while curve B depicts the results for the 16 kg estimate. D/L* is an Indication of the rate at which the concentration of PCBs in a medium decreases. The dependence upon the length-squared Is significant. A large transformer with larger internal parts could take very much longer to achieve the same degree of PCB removal than a smaller unit. 2-52 HONS 21723B Only S* 0 of PC6 It necessary to raise the concentration of the 300 gallons of transformer fluid to $0 ppm. This quantity can be calculated by multiplying the Ltota1 weight of transformer fluid by 5 * 10'5. To be sure that the transformer fluid never exceeds the 50 ppm level, the PCS residual must be reduced to less than this quantity, for the transformer modeled here to remain under SO ppm PCS (residual < 56 g) Indefinitely, the D/L? value must equal or exceed 2.6 x 10** **' The higher diffuslvlty of PCB In TCE makes this the solvent most likely to effect the desired cleanup. The highest value of 0/L* (using the molecular diffuslvlty upper limit) possible for TCE at 60*C Is 1.8 x 10-* s*1. Thus even TCE at 60*C with no Impedance to diffusion from the coll materials Is Insufficient to clean the colls well enough to guarantee under 50 ppm concentrations Indefinitely. Any reduction In the diffuslvlty resulting fro* the dlffuslonal resistance of the Insulation will substantially increase the residual level. from curves A and 0 in Figure 1. it can be seen that kilograms of PCB are likely to remain In the colls. With the possibility of additional material In the fiberboard and wood, the values in Figure 1 art under-estlma* .s of the total PCB remaining In the transformer after retroflll. The large PCB residuum does not , imply any difficulty with reclassification. The leaching rate, particularly If J silicone Is the final fluid. Is sufficiently low that the bulk fluid concentration would remain under SO ppm for 90 days. The significant criterion that the J transformer owner should use to evaluate the success of a retroflll process Is the reduction of the PCB residuum to below the level necessary to guarantee under 50 ppm Indefinitely, not the ability to meet the present reclassification requirements. CONCLUSIONS Retrofit! services utilizing a good solvent may effect the desired reclassification by meeting the 90 day requirements set by the EPA for the dielectric to contain less than 500 or 50 ppm PCB. This does not mean that the transformer Is truly PCB-free. Kilograms of PCB likely remain In the colls, flberboard and maple wood. By opting for retroflll Instead of retrofit, the owner risks the possibility of the reclassified transformer becoming a PCB-contaminated unit, or worse a PCB unit, as a result of the slow leaching of the remaining PCB. The owner, upon discovery of the increased level of PCBs in the replacement fluid. Is subject again to EPA requirements at determined by the PCB concentration. His options may then be limited to replacement only, depending on the type, location and application of the transformer, or he may ba able to again retroflll. Potentially more serious would be the discovery of the Increased PCB concentration aftar a Spill, leak or fire involving the transformer. As the EPA focuses more attention on transformer scrapping operations, the possibility increases for becoming Involved In site remediations due to the disposal In a scrapyard or landfill of an EPA classified non-PCB or PCB-contamlnated carcass containing significant amounts of PCB. The financial risk can be substantial as noted by several recent cleanups directed by EPA. The rectroflll and reclassification of a transformer might Initially be less costly than retrofit, but there are potentially higher future costs and significant risk that should be taken Into consideration before a decision is made between the two choices, MOWS 217239 2-53 Figure 1. Amount oF PC6 remaining In colls versus 0/L?: A- conservative estimate, 6- upper estimate. 2-54 mons 217240 Table 1 Breakdown of transformer fluid volume* Structure Cor# Coll* (2) Mberboard total Traniformar fluid Volume fluid Volume fin HI 1 initersl 270 6S0 177 1097 ml 1 Percent of Total volume 0.6 2.0 o.s Ox SfiiSiSl TCI TCB Table 2 01ffuilvlty (em^s) Btnhenul f23*Cl 1.4 x 10*5 6.6 x 10*5 HCB f?3Cl 1.0 x 10*5 4.6 x 10*5 HCB tm 1.6 x 10*5 9.1 x IQ*6 MOWS 2172V1 2*S5 REFERENCES 1. 40 CrR 761.30(4) 2. J, A, Quinn, C. H, Lin and J. L. Anderson, Measuring Diffusion Coefficients by Taylor's Method of Hyrdodynamle Stability." A1CHE Journal. Vol, 32, No. 12. December 1966, pp. 2028-2033. 3. 1. K, Sherwood. R. L. Plgford end C. R. Wlllte. Hass Transfer New York- McGraw-Hill. 1975, pp. 25, ' 4. R, H, Perry and C. H. Chilton. Chemical Engineer's Handbook, sth ed New York! McGraw-Hill. 1973, sect. 3, pp. 235. ' 5. L. A. Morgan and R, C. Osthoff. 'Problems Associated with the Retrofl1 ling of Askarel Transformers." IEEE PES winter meeting. NY. Paper A77, January 1977, pp. 120-129. .................... .................. 2-S6 MONS 217242 MOWS 217243 J. F. KcPartlsnd low* Electric Light end Power Company Environmental Coordination P. 0. Box 351 Cedar Rap Ida, Iowa 52406 TITLE AND ABSTRACT - Ratrofill in a Remote Location of Network Transformers Uain* the Weatinihouae Syatemi The PCB transformers that are the subject of thla paper preaent aome pedal conditiona. Thav are located In vaults beneath the aldewalka in down' town Cedar Raplda. Cedar Rapida ia a citv of about 110,000 peraona and a trade area for additional thouaanda. The downtown area, aa you can ima|lne, aa a well-established, tradi tional ahopplni end trade nel|hborhood. It ia hi|h-traffic for both automobilaa and pedeatriana. Network tranafonaera in the area preaent for our utility a typical low-probability, hi|h-riak condition! the chancea of a problem affectini utility cuatomera and the public are very low. Should a problem occur, however, the riak ia potantially very hi|h. Many of you have been, or are now, confronted with the aame aituation. What do you doT Do you leave things aa they are, chen|in| to non-PCB equipment aa it agio, falla, or becomaa economically inefficient in the natural courae of events? Or do you, aa many have done, replace the PCB apparatua aa quickly aa you can? That ia the aefeat way. Alao, tha moat expendve. All companlea cannot fol low tha replacement courae becauae of budgetary limitatlona. There ia an added coat factor in replacement, too. That la the coat of dlapoeal and deatruction. Ratrofill ia a middle courae that many are following. It ia the couraa Iowa Electric decided te follow for ita downtown Cedar Raplda network transformers. Thie deciaion waa carefully and thoughtfully made. It waa reached after careful evaluation of all the factora--public and cuatomar welfare, system efficiency, coat, and impact on overall operation. Ratrofill will coat somewhat leas than replacement. We do not know just what that coat savings will be aa yet. But coats of ratrofill now appear to be two-thirda 2*57 HONS 217244 to thraa-fourths those of replacing existing unit* with naw apparatuses. Thla savings of 33 to 25X of replacement Include* tha avoldad coat of disposal and de struction, Iowa Elactric poraonnal mad* tha ratrofill docialon after caraful evaluation. To data, that docialon aami to ba a good ona. So far, our experience ha* baan |ood and ua axpact to continue to have good experience. Wo are now working with tha ratrofill of four of tha tran*formers--and fully axpact that wa will continue with thla ratrofill procaaa for an additional 10 to 13 trenaformera, Whan Iowa Elaetrie dacidad to ratrofill, our tachnielane ware concerned about tha impact retrofill night have on cuatorara and tha public aa they watched ua work in hightraffic downtown. Wa rightfully fait that work in downtown vaulta night eauae unuaual cement and concern among customers and tha public. Heavy vehicular and pedeatrlen traffic * could raiaa More questions about tha ratrofill procedure than tha procedure itaaf would anawar. Aa you all know, tha preaence of FCBs in electrical equipment ia wall known to tha public, Tha public haa no trouble perceiving PCB dangara. At tha aaae tiaa, tha public in ganaral ha* little perception of FCB'a actual dangara to human health and welfare, Tha ganaral public haa not bean able to raaliatically evaluate the low level of PCB riak. Thua, Iowa Electric ualeaned a ratrofill proeaaa which allowed tha company and lte contractor to carry out tha transformer procaaa in a remote location. In thia aatup, tha tranaforMr ia removed froa ita place in tha network vault and truckad a alia and a half to a facility tha company own*. The tranaforaar i* re placed with a aparc ona froa tha company'a inventory. The tranaforaar taken to our raaote facility for tha tranaforaar procaaa haa, of couraa, baan carefully evalu ated for age, projected remaining uaeful lifa, and ganaral condition. Only good eendidataa for relatively long remaining ueaful lifa are aalactad for TranaForm. llnlta which do not naet criteria are removed froa aervlce and are raplacad either with tranaforaar* froa inventory or with new apparatuaaa. At the transform facility, thla procedure ia followed! PCI fluid la drained, gaaket material* era replaced, and tha transformer 1* filled with e proprietary dielectrle fluid called TMt-3. Then a processing machine is connected to the transformer and the transformer ia rs-enarglxad. Thla first stage ia expected, by Wastinghouaa, to not exceed Al hours. Experience indicates that under Boat circumstances not mors than twelve hours sra required. The processor than operates with tha transformer in service for duration of the traataiant-*usually four to nine month*. Whan testa and completed processing time 2-58 MOMS 217245 the end of this stage, a oocond stage begins. Tha processor ia dloconnactad R^oa tha transformer and tha TDK-3 la dralnad from tha tranaformar. Tha transnormar la than vecuum-fllled with tha dlalactrlc fluid of tha owner's cholca. It &ould ha mlnaral oil, alllcona oil, or other material. Tha cholca la beaad on Ftha owner'a cholca and coda raqulramenta applicable to tha permanent location of ^the tranaformar, ; Tha building In which tha Transform proceaa la carrlad out la In a coanarclal/ [residential area In Coder Rapids. Wa now have four transformers In TranaForm pro* Fcaaa. While tha facility la not manned contlnuoualy, It la monitored continually Lwlth aanaora which activate telephone equipment If and whan a glitch occura and ` the procaaaor automatic equipment ahuta down tha operation without affecting tha tranaformar. Thue, monitoring la carrlad out by Iowa Electric Oparatlona par* aonnel or by Waatlnghouaa tochnlclena. Iowa Electric peraonnol are only a few mlnutoa away. To data, tha automatic shut-down and telephone earning devlcoa have operated vary wall. / The Waatlnghouaa TranaForm proceaa la a aIngle-treatment reconditioning service. Wa are guaranteed raclaaalflcatlon of tha tranafonara to non-FCS status. As you know, non-FCB status la leas than 50 parts par million. At tha and of tha process ing period, tha tranaformar la disconnected and a 90-day ln-eervice period la be gun. Than, tha TDR-3 fluid la removed and replaced with tha final fluid. In our case, that fluid will probably be alllcona. (Results of our TranaForm experience through September 30, 1917, win be presented when the paper la read.) 2-59 HONS 217246 MOWS 217247 EXPERIENCES FROH RETROriLLING ASKAREL TRAMS FORMERS A TWO YEAR SERVICE DATA PROGRAM G. R. Atwood nd W. B. Martin UNISON transformer services, Inc. Subaldiary of Union Carbide Corporation e00-544~0030 ABSTRACT Since RECLASS 50* Servicing was first offered In July of 19BS, it has been accepted by more than 200 major clients. Over 3,000 askarel servicings have been coapleted with no, evidence of incompatibilities or other problems having bean/ observed. in general, the vaat aajority of askarel/' equipment has been found, upon examination, to be in' excellent condition, dry, lightly loeded and operating at oil teapareturea of leaa than 50WC. The results of a Servicing information Data Program are summarised. The data include most types of 15KV equipment (including rectifiers, voltage regulators, and grounding transformers), over 23 different manufacturers, and network and radial electrical configurations. A common question for existing transformers Is the condition of the equipment and how much useful life remains. The mean age of equipment under service is greater than 25 years. Age alone, however, has not been a reliable indicator. Transformer inspection, electrical testing, and coolant analysis can be helpful. Askaral coolant has been observed to be quite stable and inhibitory towards internal degradation. The vaat majority of coolant in transformers have tested low in water with correspondingly high dielectric insulating strength (Indicative of tight gaskets and bushings.) Transformers in the Data Program differ greatly In design and electrical characteristics but have been constructed from similar porous materials and thus are observed to be responding similarly with respect to PCB removal. The dominant parameters influencing PCB removal rates and methods for tracking progress are discussed. 2-60 MONS 217248 ENVIRONMENTAL ALTERNATIVE TO LANDFILLING PCB TRANSFORMERS Dana S. Myers S. 0. Myers, Inc. Transformer Consulttnts Division 180 South Avenue Tallmadge, Ohio A4278 ABSTRACT In order to eliminate the "lingering labilities* associated with the landfilling of PCB transformers, S. 0. Myers, Inc. has developed a process whleh will decontaminate the Internal metallic parts of the unit. The celluiosle materials, along with the askarel fluid, will be Incinerated. (For fluids contaminated up to 3300 ppm PCB, the PCBs will be chemically destroyed using the PCB-Gone Mobile Process.) The end product will be that the natural resources are recovered for reuse, the PCBs are destroyed, and no trace of the transformer will exist. Since the advent of Superfund, it Is no longer possible to place toxic or hazardous substances Into a landfill end assume that the problem has been solved. Despite the Constitutional prohibition of retroactive laws (ex post facto). Congress decided that they can pass laws In the present that may affect actions of the past. Therefore, disposal methods which are legal today may turn Into tomorrow's extraordinary costs. EPRI recognized this when It spoke about the "lingering liability" associated with the landfilling of PCB transformers. Since the owner of a PCB transformer bears responsibility for disposal of the PCB transformer at Its end of life, and landfilling may not constitute "end of life," landfilling could subject the generator to possible future liability should any number of things happen (e.g., leaching, leaks, Improper disposal, poor record keeping, changes In the laws, etc.). Development of the disposal process discussed In this paper (the details being highlighted In the accompanying slides) began as a research project to ratroflll askarel transformers.. Experiments with cleaning tightly packed laminations to below 10 ug/100 car revealed the difficulty of such a feat. Then, when wa found 144 pounds of askarel soaked hardwood together with over 60 pounds of paper In a 200 gallon askarel unit, It was decided that this was a very difficult. If net Impossible, proposition. The fact that we are not aware of any company claiming to ratroflll askarel units to non-PCB status, and the guaranteeing that they stay non-PCB for one or two years without any servicing after the 90-day wait period, points towards a high probability that It cannot be done. S. D. Myers, Inc. therefore developed our disposal process, now In the midst of commercial scale*up, that relieves the transformer owner of his PCB liability and eliminates the need for landfilling any transformer, PCB or not. The process 2-61 0*S 2172*9 Involve*, In the cat* of askirel unit*, first draining and flushing the unit to remove gross amounts of PCBs. After this, the transformer core and colls are untanked, all porous materials (paper, wood, gasket material) removed from the metal parts, the laminations separated and all the metal parts rinsed until the PCBs have been removed. This is done under EPA authorization, and health and safety Issues have been addressed. The case Is then separately rinsed both Inside and out to ensure that the PCBs have been adequately removed. The waste streams and materials are then handled as follows: All porous materials are sent out for incineration. All PCB-free metal parts are sent to smelters. The solvent used for rinsing Is distilled for reuse, and only the still bottoms collected for Inelneretlon. Thus, nothing exists that can. In any Imaginable way, bo traced back to either the generator or the disposer. PCBs have bean adequately removed, according to the EPA, when less than 10 ug/100 cm2 of_PCBs are detected on a wipe sample. Region Vll EPA considers 10 ug PCB/100 ear to bo the limit of detection for wipe samples. Region V EPA, under whose authority we have been working, considers less than 10 ug/100 car to b* the goal of such clean-up activity. U believe that good raason exists to justify that tha 10 ug/100 cm2 \t the environmentally safe level for clean-up that should apply for this operation. First, the Agrll 2, 1987, "TSCA PCB Spill Clean-up Policy Rule" uses less than 10 ug/100 cm2 its level for clean-up of "high contact solid surfaces." Second, the EPA allows PCB contaminated transformers to ba drained and the core, colls, and case (with the porous materials still attached) sent to a smelting operation, These transformer parts often contain more than 10 ug/100 cm2. This being the case. It would be Illogical for tha EPA to require stricter clean-up levels for disposal of PCB transformers than they do for disposal of PCB con taminated transformers. Third, If the 200 gallon unit previously mentioned had all Its metal parts cleaned to 9 ug/100 cm2, the total amount of PCBs remaining would be 0.B gm for a 99.9999X removal efficiency. Tha goal In developing this process was to eliminate tha "lingering liability" of PCB transformer owners In an economical fashion. While this goal has been realized, other benefits also accrue with this process; namely, valuable natural resources are recycled for use, the amount of waste generated is reduced, and tha generator can say, "1 have selected the method of treatment, storage or disposal currently available to me which minimizes the present and future threat to human health and the environment." 2-62 HONS 217250 PART 3: MISCELLANEOUS MC1NS 217251 na fat* of pci* ih ton. and lAiai 7 aka P, Itnii Jr,, UVut a. laaaar, Beta* Li Jaaaa C. Caraakaa as4 Iaaal4 Dataraaa Oaaaral Claatrl* laaaarak a4 MaLaiaiat C*atar, takiaaata4f NX P.0, lac I, lakaaaatalp, MX 12p01 Oatll raaaatlp, tkaca ailatal t*a aoatta41atatp paraaptlaaa ratirllas tka kakafiai at PCI a la tka (astral aarlrosatst. Oat ** tkat tka aaaaaralal PCIa Urea lor t) Tara ataaatiallp ialaatrattlklt, aa4 *aaL4 paralat lalaflaltalp at fill altaa salat* reaara4 vr aaaa Cara at raaa41al aallaa. Tka atkar *** tkat tka asalptlaal |ai akraaaiatraaa of PCIa raatratal fraa aarlraaaaatal aaapla* tatalp aatak#4 tkaaa at aitkar ls41*14s*l r aiaa4 Araalan, aa tkat aarlaaa arkitrarp aaaraatiaaa aara aaa4a4 la ar4ar ta rapart aarlraaaaaial PCI aaalpaa* la taraa aC "Araalar" asapaaltlaa*. Tka akr*B*t*|r*pkl* alaaatak vaa attrlkatal ta H***tk*rls|" at tka PCIa, Oarlaf *1* F**t Caw pasta, *a kara kaaa atalplai tka aaapaaltlaa at awlrat* aaatal PCIa tltk kl|k raaolatiaa aa pi Harp taa akraaatairapkp aa4 aaaa spaatraaatrp la ar4ar ta kattar akaraatarlia tka PO **a*tkarla|" pkaaaaaaaa aa4 14*atlfp Ita arlglaa. It la aa* apparaat tkat It la*la4aa at laaat (aar 4ltfaraat tppaa at PCI altaratlaa praaaaaaa) parti tlaalat lata a aakila pkaaa, acl4atl*a kla4*|t*4*tl*a, ro4aatl*a kle4a|r4atlaa (laakltrlaatlaa) aa4 pk*talpala kp aaall|kt U-4). Tkaaa faar praaaaaaa, tkalr aarlrawaatal ratal raaaata, tkalr ca*a|altlas faataraa, aa4 tkalr laflaaaaa am PO fata *111 k* 4aaarlka4 la tara. PAtXlTIONINO INTO A MOIILI PIAll Tkara ara at laaat fame pmralp pkpalaal aaakaalaaa kp wklak POa aa* ba reaaral (rta aaataalaatal aalla at aallaaata. Tkaaa ara (*> avaparatlaa lata tka atMSpkara* Ck> attraatlaa lata a ko4p af *atar kp traa, aalaaalar aalmtiaa, (a) attraatlaa lata tka *atar kp 41aaal*a4 argamla aallal4a (faallltatal aalatlaa), aa4 (4) tlaaklat af *aap*a4*4 4caplata ar partial** kp a **tat atraa*, Praia aa (4) ratal raa aa appraalakla amxraat valaaltp, aa4 kaaaa rapraaaata aa Irpattait PO traaapart aaakaalaa la rl*ara, kat tat la aeat Lilat, aataarlaa, at |raaa4*atar. It aaa ka 41atla|alaka4 fraa (k) aa4 (a) kp flltarlat a aaapla af tka *atar aa4 aaaIpalag tka flltrata aa4 a*paa4a4 partlaalataa aaparatalp far PO aaataat. Praaaaaaa (a) aa4 (k), aallka (a) aa4 (4), raaalt la akaafaa Uatsallp, *arp alallar akaaiaa) la PO aaapaaltlaa. Tkaaa aaaar kaaaaaa tka Ttrlaat la41*14mal PCI aoa|aaara 41ffar aaaallaraklp la valatllltp aa4 *at*ra*lskllitp, tlaaa tkaaa prapartlaa ara alaaalp ralatal ta aakllltp oa a |aa akraaatotrapkla aalaaa* If aitkar araparatlaa ar *atar-attraatlaa af aa aarlreaaaatal PO apaalaaa kaa *aarr*4, lta akraaatairaa *111 aka* a (astral vtakaalai af tka aarlp pasta tkat kaaaaaa aara aarkal tka aarllar tka rataitlaa tlaa, kat *ltk aa aarkal altaratlaaa -la tka ralatlva 3-1 MOHS 217252 iituiitin ( eei|bborlai pasha. The attest of iuk M^ntitt or eatraetlve lose la prebeblp >* ititatii bp tMtifiiii vith Areal or HiUtfli that kata baaa altered ta evaporate ta kiwi etteate af *ai|bt leae is tba taberatarr* Saab aatlsataa ladleate etteselre (20-10%) fci leasee (ica tba iat(aai lepere af aaila eed aaAlseate at Aroeior 1242 eplil eltee. aaA (asatisat area alislflaaat eveporatiea fres Arealer UiO. This leal seebeales, kmnat, i, ebrioaelp iaprebeble far PCBe that ara sora Aeeplp barieA ar aafiifaraaf, aa la leaAfllle. OXIDAWI 110DS9IADATI ON lalta, eedlseste. taf amafaea vetare eoatals eospter papalatlsee af aarobla laraariaml as a that ara aafakla at eriAetlvelp biede|tadls| ell af tba ae t tr et tr aaaarrlai ebtsleel eoaetitaeste of oriesle setter. aaA alas assp PCI asiasara. PCI-Ae|redls| baatarla kite baas detested Is star? tail as4 eedisast that aa baaa eeesiseA. Ta 4ata. aaar taa dates atralsa af FCI-4e|redia| baatarla bare baas laeleteA (l). Tbaaa varp videlp is PCt-deiradls| eetivitp; . ease aas attaab eslp fe* seao- asA diehlerebipheapli. athara ass attaab a laaa t all at tba lever aesiasara. sasp at tbe pesteehlerabiphesple, aaA area a fev beaeehlerebipbesple. Thar elaa varr Is aeaiasar ealaatlvltf patters: teas (tba sajeritp) talarata tba praaasaa at ahlarlsa a teas is bvtb para (4.4'-) paaltlasa bst are IsblbltaA vhas ahlarlsa ataaa oeeapr tva artba (2,2'- ar 2.A) paaltlasa. or paaltlasa 2.S-. vhila tba atbara aas talarata 2.2*- asbatltatlas aara aaallp thas 4.4*- (1.2). The 1 aval a at the lsilvlAsal atralsa Is aaila aaA aaAlaasta ara prabablr lev aaA prabablp aat Isaraaaad Is tba preaesee af PCI east aalsa ties, eisee sasa af the PCI-de|radls| earaba a aas aatsallp |rev as PCI. Is aavlraaaastal PCI aaaplaa tba aaasrrasaa af aalAstlva alarablal bieAeirsAetlas sap ba Alitls|slihaA fraa that af or spare tire or alstrlatfva laaa bp the appaarasaa af aeleetivitp Is the aasfasar revere! patters. IsateaA af aa lsAlaarlalsast laaa at all laitr ees|esera is prapartias ta thalr volatility, asa aiaillp aaaa Laaaal af tbaia lover aesiasara that aarrp aslr asa artba ahlarlsa Is prafirasaa ta tbaaa at tba apasotrieallp Al-artha (2.2'-) etbetitmtaA type,.asd tbaaa is prafarasaa ta tbaaa af the aaepasetriesllp Ai-artba (2.4-) asbatltataA tfpaa. la have aaaa tbaaa aart at alteritieae seat alaatlr Is aasplae at irassAvatar. astf tbaaa af rivarvatar that baA eaitaisaA sett af the Kl is trsa aalstlaa; is eerebie aaila asA laAisasta laaaaa of lever easiasere bp aarobla biaAairaAatios ara aftea orerekeAevei bp tbaaa arlaisi fros araparatias ar alstias. A bieehaslesl lp Alt tereat fan of atiAativa biede|re4e ties (that le. a fare saAlataA bp sosoacpiasaea rather tbss Aiarpiaaaaa asrpsae) fan aaasra is birAa. Simla, ersstseeaae, ssA ease blade at flab (I). Aa s raealt. is esvlreaseatai Ml epeelaeae derived fra eaab easraaa. rather thas fros eolle. aadisasta. voter, ar sallsaaa. tba sltaratiasa is PCI aeaiasar Aiatribstiom pradsaad bp either phpeieel partitiasisi or eavireaaestal baatarla eas ba evetciddea bp tbaaa of feat ad bp seaeetpieaaee (i.a.. P-450 aptaobresa) setabalies. Tbie tppa at satabalias resever aeaastlallp all PCI aosiesara aaaapt tbaaa that are di-para esbatltstad. asd partiaslarlp tbaaa aarrpisi ablarisai Is paaitiasa 2.4.5. asd 4*. UWCTIPI IIODISIIDATIM (DtaLOUMATIQN) Tba seat raaastlp diaaavarad fan of asviraasastal PCI biadairadatias aasaiate of radmetiva Aaablarisatias is a%satia eaAisastt (4,5). dvldasaaa for the 3-2 MOMS 217253 Iiuttltt Bf IMk praataaaa hiva iw kH Iiut lB MiiMIU M (Ilk fCM tkl vatera at Part !. HI; HttiMili, Ik; liiki|ii, 1L; Ikikinii. II; Kaaaama, NT; Albaap. NT; Nev ladtord. Ml; Caaaabia lap, FL; and Nev fork Clip. Tha preeeee kaa baaa dapkkaatad la tka leberaterp bp laembatlai pCIa vltk aaatarlliaad aadlaaata aadar eeaeroble aoadltloaa. hat la atepped bp atarlllaatiaa. ladlaatlaf that a blalefiaal a|aat la lavelved. Available evidaaee ladlcataa that at laaat I dlffaraat cevlroeaeatal a|aata. prceaaeblp all difftreat atralae of aaaoreble bacteria. at# rcipeaclble far ctrrplaa oat tka okaarraA dcehlorlaetlea praaaaaaa- la alaa believe that tkaaa bacteria aaa tka fCIi aa teniae! clcotrea aeccptere 1b tkelr actabelie praaaaaaa. Tkaa. tkaaa eaeerebee, aallka tka PCI-atldltiai aarobaa, aap ba akla to derlv* a eoapetitlve advaataie (ria tbalr PC*-de|redle| eetlvltlee. a ad therefore prodaaa attaadad aalaalaa af a ala|lo apaalaa la araaa akara tkap here aeacied ta aaad a PCI aplll alta. At aap nat, pattaraa af kitker aaaiaaar daplatlaa aad laaat aaaiaaar faraetlaa taad ta ka aktrplp'daf laad a ad fait a aaaalataat (raa eeapla ta aaapla altkla a ala|la aplll alta. bat deaeattrablp dlffaraat la dlffaraat altoa. Ckaraatarlatla raaaialtlaa faataral af aavlraaaeatal PC* tkat keve aadarioaa redaatlve daaklarlaatlaa laalada depcecied levela of ao<t kl|kar aaaiaaar a ( pirtlomlarlp of tkoao ooatalalai >,4-. J,d,J- or 1,1,4oklorapkoapl iroapa; tad ekarplp laaroaaad levela of aortala looar ooaioaora, oklok aap bo tkoao earrplai altkar 1-, 1-, 1,1- 1,4- or 1 .l-okloropkaap 1 iroapa, dopaadlai apaa tka partlealar daaklarlaatlaa epetea lavelved. Thta fat, *a kata aaaallp aaaa redaatlve daaklarlaatlaa la tka keevllp ooattalaotid aadlaaata froa tka laaodlato vlelaltp of aplll altoa, tad la tka lata keevllp aoataalaatad railoaa or aaad tka parlpkarp af aak altoa, bat aaaallp aat la tka ll|ktlp aaataalaatad aadlaaata frea reaeta araaa. Tka al|alflaaaaa af redaatlve daaklarlaatlaa la tkraa-fald. Plrat, bp radmalai tka da|taa af oklarlaatlaa af tka PCt eoleealea it aakea tkaa aara aalllp raaor ad froa tka alta bp altkar partltlaalai lata air ar vatat or bp oaldatlve bladairadatlaa. laaaad, bp raaaalat tka aaa|aaara aarrplai 1.4-, 1,1,4-, aad 1,4.3-ekletopkeapl iroapa redaatlve daaklarlaatlaa alaa raaaaaa tka pataatlal far aklar aaaa |a ala tatlaltp, a ad bp reaevlai atkar cklarlaa ataa frea para (4-) pealtleaa, aa aall tka pataatlal far PCt blaaaaaaalatlea la vata-blaadad aalaala. Tkaa, tka blalaitaal daaklarlaatlaa alaa aeeoapllakaa datatlaatlaa. Tklrd, bp ekarplp altarlai tka aaafaaar dletrlbatlea la tka Araalac, It aaa provide aaaaaal PCt aoapealtlaaa vheaa aevaaeete tkraaik eavlraaaeato aaataalaatad vltk PCta froa atkar aaaraaa aaa ka traced. PtOTOLTSl* IT IONUOIT tabaratarp aad aadallai atadlaa (4) kava akova tkat PCta la aalatlaa aap ba pkatadapradad bp aalat altravlalat, tka pradaata helai aaatlp tkaaa of redaotlva daaklarlaatlaa, alaa| vltk Ma af pkata-aaalatad aalvelpala, Tka pkotoakailaal daaklarlaatlaa, la akarp aaatraat ta tka alarablalotlaal, kaa a atraai pradaraaaa far raaavlai artka aklorlaaa. aad tkaa plalda PCt alataraa aaalatla| predealaavtlp at aaae-ertke aad aaa-artko aabatltatad aaaiaaara. Va kava aat pat aaaa aap aaak eeapeeltloae la vatar, flak, ar aadlaaat aaaplca (m la akara ar lalaad laaatlaaa, aar daaa tkaarp pradlat tkalr aalataaoa. laaavar, aadallai raaalta aanaat tkat tkap al|kt appaar la ff-akaia ipeeiaaaa, aaak aa ald-eeeta plaaktaa aallaatloaa. Pkatackaalaal daoklarlaatlas akaald laprava PCt amaatptlbllltp ta alatlaa aad aildatlva bledatradatlam. bat la tka aarlp atapaa vaald laaraaaa ratkar tkaa daaraaaa aklarasaaiaala tatl altp. Pattlai tkaaa proeaaaaa tapatkar. It vaald appaar tkat tka altlaata fata of PCIa ralaaaad oa laid vlll ba a partial bladatradatlaa bp aarabla aall bec- 3-3 HONS 21725* terle oa alte moaptil^ hp fredael iMiiftit vie aetaoroiopioel ud bpdre- rtMtiiii to lerta lekaa i miui tkiti deetraotlea till m( bp i eeablaatloa ( photeohwleel tad aerobic aloreblel fee tboae PC* tiltiiU late tittirifi ted tbeeae tekea f bp tb aedlaeata, eaeereble alcre- bl at diohlerlaetlea *111 parait t eeoeidarable eeeeleratloa tf the pteeeeaee ef detoaioetioa ad aoblliietlea, tad five prodeote that *111 be aori repldlp deetroped bp pbetolpala cad oaidetive bledefredetloa la the lattice vetere ef rivera, leheei tad eeieai. The ittaat te vblcb tben freoimi of treeeport ead tceaefecattlea bi*e eoearrad et cap eae ilte *111 ebvlomelp bi depeadeet pea leeel ea*lraaaiatil (eotere, pertlealerlp theee iffaitlat tbi levela ead aatlvltlae ef bath aerobie aad eaaerobla loroblel popaletioae, At preeeat. aeh teeter* ice aet veil mad a ti teed, a* that their aet effeet mpea PCI feta at up apaelfia ilta kae to ba da tarsia ad tkrompk a detailed ahresetoirepbi* eaelftla ef the reeldael PCI ooapoeltloa. tEFIIENCCI X. laderd, D.I., Cat a rata, I,, lopp. L.I. , Ireaaaa, N.J. , libarl, N.L., ead Jokaaea, C. tepid Aaeep for Sereaalap ead Chareetarlalaf Nlcroorpaai iajr for tka Abllltp to Degrade Polpaklerlaetad lipheaple, Appl. Eavlrea'I Mlaroblel, SI .741-7 41 (1I4>. '' 2. ledard, {.I,, lebarl, N,L. , Hep, t.J, , ead Iraaaaa, N.J. Evldeaoe for Novel Naekaalaaa ef Pelpokletlaa tad llpkaapl Netabellia la Aleallieaea Htmlti lllO, Appl. a*lroa, Nlerobiel. 5>tll0>-1112 (iff};, f. loadatrBa, 0., latalapar, 0., aad left, I. The Netabellia ef Cbloreblpkaapla. A te*!**. Ckeaeepkara J:2dT-2fl (lfTfl. 4, Iteva, J,P. Jr*. laderd, 0.1., Iraaaaa, N.J., Caraahea, J.C., feag, I., ead Vefaar, t.E. Pelpeklerlaatad llpkaapl Deeklorlaatlee la Aqaatle fadlaaata. lalaaea iJ4;T0f-Tll (lfIT) . 5. Ire* a, J.F. Jr., Vafaer, d.., Feaf, I., ledard, O.L., Ireaaaa, N.J. . Caraakaa, J.C., aad Nap, t.J. Eavlroaaeatel Daeblorleetioe ef PCIa. Earlrea. Tealaei. Cbm. : 0OO-O00 (Iff};. C. loaoe, N.J,, laser, I.. aad Irovalae, 1.0. Aa Aeaaeeaeat ef the lapeet ef leler Degrade tioa Of Polpaklerlaetad Upkeep la la tbe Aqaetie Eavireaseat, ChMoephare TtlSS-144 (lfTIl. MONS 21?255 3-4 HONS 217256 PCB-RELATEO ACTIVITIES AT EPRI. 1986-1967 Mary E. MeLearn Electric Power Research Institute Coal Combustion Systems Division 3417 Hlllvlew Avenue Palo Alto. CA 94304 . ABSTRACT Research activities concerning polychlorinated biphenyls (PCBs) are currently being conducted In three technical divisions of the Electric Power Research institute. In the Electrical Systems Division, activities are focused on the decontamination of utility fluids, decontamination and destruction of PC6contalnlng capacitors and transformers. PCB fires, and substitutes for PCB. Pro- , Jects In the Coal Combustion Systems Division address remedial action for PCB spills. Environment Division research Is concerned with risk assessment for PCB exposure, risk management for utility PCB equipment and PCB-contamlnated sites, and analytical methods development for polychlorinated dlbenzodloxlns (PCDDs) and dlbenzofurans (PCDFs) In PCB matrices. ELECTRICAL SYSTEMS DIVISION In the last year, most of EPRPs PCB-related research has been managed by the Electrical Systems Division. A 500,000 gallon per year plant for the decontamina tion of mineral oil has been constructed In the Georgia Power Company system at Atlanta-(Resaarch.ProJect 202B-13.14). Research permits were received In autumn 19B6 and shakedown runs and Instrument calibration began In October 19B6. PCB runs have been conducted, problems In the extraction section have been corrected, and problems In the solvent recovery section are being addressed. The facility Is scheduled to begin operation again In June 19B7. This Is expected to be the final EPRI research effort toward decontamination of mineral oil. Studies Investigating the pyrolysis and combustion of PCB as a contaminant (RP202B-4) have shown that PCDF formation In PCB-contamlnated fluid Is propor tional to the PCS concentration, with trl/tetrachlorobenzene replacing PCB as the contaminant, at concentrations as high as 5000 ppm, neither PCDF nor PCDD Is found following pyrolysis or combustion. Pyrolysis end combustion of pantechlorophanolcontamlneted Insulating oils art currently being examined. As part of this pro ject. the flit-cell bioassay technique Is being developed to measure PCDF/PCDDllke activity In pyrolysis or combustion products In a PCB matrix. This should serve as a simple screening technique for emergency uses. An Improved analytical method based on gas ehromotogriphy/mess spectrometry for measurement of Individual PCDF/PCDD species In utility fluids has bean developed (RP202B-5 through -10) end tested through a laboratory round-robin. Both the Electrical Systems Division and the Environment Division participated In this project. Agreement between the five laboratories participating In the round-robin testing was generally within a factor of two, which was considered satisfactory. In ganerel, results Indicate that the method represents a significant advance in analytical technique for measurement of PCDF/PCDD In utility fluids, and no addi tional research Is planned In PCDF/PCDD analysis. 3-5 MOMS 217257 A OC arc furnact for destruction of PCB-capadtors Is being constructed at a field site In Model City, New York (RP270L-1). Permits have been received from the New York State Department of Environmental Conservation and the U.S. Environmental Protection Agency and initial tests on non.PCB surrogate materials have been planned for the second quarter of 1907, Tests with PCB materials will follow in 1987. This will be the final EPRI research project In askarel destruction. EPRJ has been evaluating options for rapid and economical methods to retroflll or scrap askarel transformers to meet EPA requirements (RP2028-I9), seeking a method for cleaning drained transformers so that they would not require disposal In spe cial landfills. EPA permits have been received for the experimental work, and experiments are underway to detank and clean metal parts, followed by Incineration of PCB-seturated celluloslc materials. The econoailcs of such a process win re quire careful study. Under the same contract, a material balance and analysis is being done on the residue remaining in contaminated mineral oil transformers after careful draining. The objective or this work Is to gain background information for possible simplification of analytical requirements for reclassification of retrofllled transformers as non-contaminated. COAL COMBUSTION SYSTEMS DIVISION In EPRI's Coal Combustion System Division, PCB-related activities have addressed remedial action for PCS spills, Including PCB analysis and spill cleanup. In I960, phaseout of PCB-related activities was begun in the CCS Division. A portable PCB analyzer (PCBA-102 gas chromatograph) was developed under EPRI contract (RP1263-9); extensive laboratory and field testing has now demonstrated that accurate and precise measurements can be made by experienced operators using rigorous quality control procedures (RP1263-23). The field Instrument has been modified and ruggedlzed as a result of the field tests and Is now commercially available from the developer. Pilot scale tests have been conducted of a soil-washing system for PCB remediation (RP1262-15) and have demonstrated successful volume reduction of hazardous mater ials using a proprietary solvent. PCB-contamlnated soil (up to 4000 ppm PCB) was cleaned to below 2 ppm and the solvent could be recovered for reuse leaving a PCBsolvent residue for disposal. Field demonstration Indicated the need for addi tional development of the mechanical system for soil-washing. EPRI Is currently pursuing options for additional development of the soil-washing process by the commercial sector. Mobility of PCSs on soils Is currently being Investigated (RP1263-22); sorption uptake equilibria and release rate studies are being conducted for three PCB con geners on typical and low organic carbon soils. Examination of the effect of aqueous surfactants on PCB release, towerd development of an aqueous soil-washing process. Is planned. In-sltu vitrification of PCB-contamlnated soils has been demonstrated on the engineering scale (RP12B3-24). Opportunities for further development and demon stration are being discussed with EPRI member utilities. In addition, use of Insltu vitrification for Immoblllzetlon/dastructlon of mixed radioactive and hazar dous wastas and usa of vitrified barriers for waste containment are being consi dered as futura project areas. 3-6 HONS 217258 ,IR0MHMT DIVISION Environment Division et EPRI Is developing tntlytlctl tools end Infomttlon to <Tp utilities to tssess end menage risks from PCBs. A PCD Spill Exposure Ktttsent Model has been developed to Include exposure assessment for PCD* Konttmlnated mineral oil and askarel. Components of the PCD exposure assessment [methodology Include release mode, transport and fate moda, and exposure mode. [After release, a number of processes act to transport the PCDs In air, water, and [toll* The transport and fate component of the methodology contains several [models; a spill-site model called POSSM, PCD On-Site Spill Model, and several offrslte models, which are established air, surface, and groundwater models. Once a PCD spill occurs, a number of key hydrologic and transport processes come tInto play, depending on whether the spill Is cn soil or asphalt/concrete. From toll, PCD may volatilize and enter the atmosphere, leach through soil Into ground water, or migrate overland to surface water. If PCD spills on concrete, the com- pound may volatilize and/or migrate overland to surface water. POSSM can consider tha Influence of these processes on two types of spills: relatively pure chemical spills (e.g., capacitor spills) and spills of a mixture of two chemicals that art relatively Insoluble In water (e.g., PCD-contamlnated transformer oil spills). When applied to the second type of spill, POSSM simulates the Impact thtt each component In the mixture will have on the volatility and solubility In water of the other component, - The off-ilte models are a Gaussian plume dispersion model, an analytic surface water transport modal and an analytic groundwater transport model. These model! predict PCD fate as the compounds migrate through the air, surface water, or groundwater. Exposure can occur by three routes; Inhalation, Ingestion, and dermal contact. Population distribution and activity patterns determine contact. The exposure model, EXPOSE, Includes a general exposure analysis framework for estimating expo sure levels for each route. The framework Is currently used by EPA. In addition, software for uncertainty analysis has been produced. The software will establish the variance of the predicted values of concentration In air, water and soil over time. It will also aid In estimating the probability of exceeding a given stan dard and so can raplace worst cast scenarios. The computer models ASK end COIL have been developed to help utilities manage their economic risks from PCD equipment (RP2595). The models are designed to help utility staffs to develop and explain policies to manage dollar risks to the util ity and Its ratepayers from two sources: PCD equipment In power plants and con taminated mineral Oil transformers In the distribution system. Health risk man. agement of PCD or contaminated mineral oil equipment Is addressed In a separate model also developed In RP2595, the Transformer/Capacitor Risk Management Model (TRIM). All three models operate on IBM PC-compatible computers. ASX Is designed to analyze the alternatives for managing economic risks from PCB equipment in power plants. A PCD spill or fire In a power plant poses the risk of extensive cleanup costs, the cost of replacement power if the plant must be shut down, end possible legal liabilities. ASK helps the analyst to compare the costs Of posilble PCS Incidents of varying severity versus the costs of management alternatives to prevent or limit such Incidents. COIL Is designed to analyze alternatives for managing tha economic risks from PCBcontamlnated mineral oil equipment In utility distribution systems. A spill or fire in such equipment poses the risk of cleanup costs and legal liabilities. 3-7 HONS 217259 COIL Kelps the analyst compare the risk of Incidents against the costs of policies to manage those risks. An important aspect of this problem addressed by COIL Is deciding whether a program to go out and sample mineral oil equipment In opera tion, for PCS content. Is worth the effort. A series of case studies was conducted to field-test a$k and COIL and to demon strate how the models might be used. Write-ups of the cate studies describe the structure of the analyses, the major input assumptions and the results. COIL was applied at two utilities; one was large and urban, the other was small and rural. ASK was applied In analyses of different types of transformers In five different power plants: two coal, one lignite, cne gas, and one nuclear. The seven write ups of the case studies are availed1'* now. Later they will be available as part of the ASK and COIL documentation. i A computer model called SITES has recently been developed to help utilities to. manage their risks from PCB-contanimated sites. SITES addresses two problems In site remediation: determining the extent of site Investigation to perform and evaluating the effectiveness of remedial actions in reducing health and economic risks. SITES has been applied to two manufactured gas plant waste sites, and EPRI . Is currently seeking host utilities to apply SITES at PCB-contaalnatec locations. / Updates on PCB research activities are available several times per year as the Pci technical report from EPRI. ACKNOWLEDGEMENT The author wishes to thank Gil Addis, Jacques Guertln, Vic Nlemeyer, Abe Silvers, and Walt Weyzen for their guidance and support. HONS 217260 3-8 TRANSFORMER LIFE EXPECTANCY Dr. Steven C. Vick and Mr. Dcnnl* F. Tulloh Union Carblda corporation Terrytown. New York 10591 ASSTRACT This paper eooprahanalvely analytaa tranaforoer Ufa expectancy. Conclusion* ara pra- aanted in teraa of tranaforaer typa and dlalaetrlc fluid utilized. A ratlonala la provldad In aupport of vlgoroua purault of policial by tranafornar ownera which aain tain axlatlng tronaforaara In aarvica. INTRODUCTION Tranafornar Ufa expectancy ii a subject of critical conoarn to all tranafornar own- ara. Tha coneapt of aehadulad raplacanant bafora a tranafornar hia failed oftan la praetlcad In tha hopa of nlninlsinc forend outages and othar dlaruptlona of aarvica.. However, rallablllty aurvcya hava alao ahown that tht_aJorlty of tranaforeer fell-.-' yrta ara cauied by factora not rtlatad to nornal deterloralJM from see. Preeeture changeout nay raault In a poor allocation of raaourcaa and nay In fact cauaa nora ~~ tranafornar falluraa than would ba experienced if tha old jtranaforaer warn laft in aarvica. Accelerated raplacanant of trancforncra due to envlronnentel riaka caaocl- atad with PC# aa coolant la not only counterproductive with retard to failure rata analyale but la alao extrcnely coat Ineffective. Proper tranafornar raplacanant requires n underctandlnc of tranafornar failure ccuece aa wall an evaluation of tranafornar Ufa Including both advene and poalttvo factora auch aa preventative nalntananca and retroflll optlone. ' TRANSFORMER FAILURES Failure Ratal Trenafornere are reliable, trouble-free plecea of equlpaent, resulting in an unobtruelvoneee which nakee falluraa both unexpected and difficult to predict. In an effort to nore preclaely define and categorize tranafornar falluraa, aavaral aurveya by IBEt, Doble, tha U.S. govarnnent. and othara have bean undertaken2-3. For thla paper, a 'failure' la derined aa an unplanned or unanticipated event which reculta In any nf the following to occur: 1) partial or ooaplata chutdown. or belowetanderd operation; t) unacceptable perfornence of uaer'a equlpaent: 3) operation of the electrical protective relaying or energency operation of the electrical ayatan: 4) de-energlsatlon of any alactrlcal circuit or equlpaent. in auch aurveya, an effort wee eade to Identify the Initiating ooeponant failure aa well aa the contributing cauee of that failure, dlccuealon Halted hare to liquid filled ualta due to the greater aaount of available hletorlcel date. A coapcrleon of the IICC 1973-74 and 197t total failure rate aurveya reveale an increaaed failure Publlahed with Perailaeion of Union Carbide Corporation 3-9 MOWS 217261 rat* of SOt In just alx year*. Thli suggests that newer liquid flllad tranafortera ora not aa rollahlo aa their older counterparts. Confiraing thia ar the data for liquid flllad transformer* between 300 and 10000 kVA which chow that tha failure retee for unite eged 1-10, 11-25 and (renter than 25 yeara ware 0.0072, o.ooss and 0.00*0 respectively. New tranaforaera auffer froa hifh 'Infant aortality*. aiddla a(ad tranaforaara dlaplay greatest reliability and only a alight Indication or daereoaed reliability la aean with the oldeat ega group. Thle behavior, the 'Bathtub curve' 4 holda that the Ideal decision point for achcduled replccaaent in the point where the failure rata for an existing in-place tranaforaer equal* the failure rata of a new raplcceaant unit. HfpLceant prior to thia nolnt will actually reault in if higher ovrell fallacy rate for anv_g|ven avatea. . failure Node* txaalnatlon of failure aoda* allow* a tranaforaer owner to Judge the rlak that tay given tranaforaer la aubjact to and dctaralna if and whan a echaduled replccaaent ahould occur. It la clear froa the IEEft eurvey that the aajorlty (5tt) of failure* reault froa aoae type of Inaulatlon breakdown. Moot intaraatlng ie that in only I3_,3 percent of the fall urea wta noraal deter 1 oration free aga^clltd aa q cantrlbutlne eauaa. the reaalnder cauead by either unpravantabl* outaida caua* or by preventable abuao. alauaa or Inadequate aalntananca. Thaaa atatlatlca call Into quaetlon tha vary concept of echeduted raplacaaant end lndleate that the aoat sound qoi- iSl ta alnlelta tr*nfbreer felluree It a ceaerehenelve preventative ealntenance program to retain dependable tranaforaera Iq **rv)c*. A further juetlflection for thle preside le the widely held belief9 that elder transformer* were built with deeign exceeeoe which retultod In elnlaux etreeelng of cenductore and inaulatlon. fACTOgg AfFECTlWO TkAWSfQkMEf ACINfl Jn^yl^tlnn Life hoot troneforeor failure* can b* related to a ahort coming of the calluloole Inaulatlon eyetea, often described ae an altotrleal a yetee, a chtoleal eyetee or eeehenlcal eyetea. Ae aa electrical syotmm, the dleloetrle strength of the oil Impregnated paper la the critical perentor and It aeet affected by contemlnation of the oil by water. Ae a eochanleal ayatae tha celluloalo Inaulatlon oust ealntaln Ita tenello strength to with*tend the etreeeee which occur with overvoltage eurgee. Dictating both of these propertie* la Jta cheelcel integrity, l.e. It* abil ity to withstand detrleanttl chemical tranafornatlon*. which hna load to tho davelopeont of the currently accepted rational for theraal Inaulatlon aging e* an eppllca tion of the Arrhenius rate equation. The Arrhenius equation allows performance of accelerated functional life testing under controlled conditions, a* early isal and oontlnulng until 11T2 Induatry atendard* for avaluatlng both power and dlatrlbutlon tranaforaar Ilf* txpectanclt* at and abov* naaaplat* rating ware baas aolely on laboratory measurements. The 'end of life" point wee arbitrarily cheaan aa tha tie* to doorcase tho Insulation's ten sile strength to 50k of its original value. During the l*S0'e and ItftO'e a aerloe of teat* (published aa ANSI C5T.21 (it**)) were performed by the AIEB on email distribu tion transformer* (ISkVA) which showed that the published life open lnformntloft bated ialely dfl_lft*ulstlM>_>glM.wa conservative. The ti*#-tamperetur* raUtlonchlp for existing power traneforeer* baaed on Inaulatlon glng studies le alto unneceeearlly coneervetivo and ahould be oonflraod by etudlee on entire unite. Thia rataarch haa not boon performed to date, and plana7 art now being Implemented celling for dovelopeent of * ltberttery teat model which will more closely oloulat* entire unite. When thle research 1* performed one cen expect that the life expectancy curve* for power treneferaere will be likewise shifted upward. Transformer Vinters The change in the design philosophy ever tho lest 50 yoora had allowed tha manufacture of unit* which do not poaataa tha built In aafatv factor resulting from nora conaervatlv design practice. Design difference* in modern 3-10 MOWS 217262 tra*ferMr* of particular cencirn art lower Seale Insulation iapulaa Laval* (bil*). Vlfh*1* nuaktr r volt P,r turn* raducad iapadanc* and rtdueed oil content par kVA. It la difficult to foresee tha raault of auch changes Khan the unit la atraaeod beyond It* Intended uee, the aituatione where aoet felluree occur. One cate In point le tha apldeolc of through-fault feilurea which began to appear In the leTO'e* due in large aeeaure to the reduced BILa end their correspondingly reduced lapedance rating. The lncreeaed electromagnetic forcea created during abort circuit currant aurgea created excaeelve aoveaent and reaulted In winding lnaulation rupture. Currently spring loaded cleoping hee been adopted to correct thie deeign flew and through-rault felluree are beginning to decline. Theee date lend credence to the propeeltlon that the only true aeaeure of reliability le field experience, tha exact asm* field tn>. rlance which 1 present In unit which hai been flawlaaalv pointing for 30. <o ar Uft Yttfli- yrenaformer Oil Juet ae in eny chenlcel eyetea, 'tha environment (dielectric) in which a reaction (deterioration) le perforaed will deteralne the outcome of the reaction. Mineral oil hae been ueed in the overwbelalng majority of traneformere to date. In certain treneformere, Aekarel wee the oil of choice until the IBTg ban on the manu facture of PCS. Since that tine eillcona hae generally beta ueed far application requiring flame retardence. The ownere of tha mora than 190,000 Aekarel treneforeere extant today ere faced with the choice of reaoval of the PCI fluid or premature replaceatnt of the entire traneformer. The question that auet be enewered le -lejthe ociluloslc lnaulation In my Aekarel treneforaar deteriorating mora or leee than U* mineral oil counterpart? : 6egradation Pathway* The primary egentt of celluloolc degradation era oxygen end water, with heat accaleratlng the reactlone. Additionally, verloue ell degradatlea product* will aet et catalyete for thla deterioration. Varloua deta>10 indicate the eolublllty propartlee for mlnerel oil and Aakarel vie e vie oxygen and water ere not markedly different, end equivalent amounte of dagradmtlon raaotente will be avail able. Any dlfferencee In aging cbaraoterletioe of the celluloalo will be attribut able to the preeeaoe of eny cetelyete or dlfferencee In heat trenefer la the eelluloelo matrix. Conduction of the haat out of the oelluleee la dependant on tha ther mal conductivity of the fluid, with Aekarel having the advantage over mlnerel oil. Heat trenefer due to convection ie e complex function of Vleooeity, Denaity. Thereel Conductivity, Heat Capacity and Coefficient of Thereel Bxpanaion. On balance. Aekarel la aore effaotlve In convective heat trenafer. An additional feotor whloh greatly favora Aakarel le the total abaence of eludge formation. Mineral oil la proa* to aludge formation which le very deleterloua to convective heat trenefer froe the core. A* n reeult, many utllltle* nave Inatlgeted e policy of mlnerel oil "polishing" et leant once every five yeare to remove eludge buildup.11 The final factor In oelluloele degradation le the formation of eddlo realduee which act aa catalyete. The Important difference between the acidic realduea la that Aakarel forme HC1 while mineral oil foraa relatively w*ak. but aore dallterloua. carboxylic aelde. Strong eclda can be trapped by neutral acid acavengera while the lean reactive organic acid* cannot. For the** reaeona. the lnaulation will age wore gracefully In an Aaknrel unit than In lta mlnerel oil tranafornor counterpart, Tha earn* conoluelona ere reached with regard to eillcona oil trenaformer*. Silicon* oil exhibit* aupcrlor (with reapect to Aakerel and mineral oil) conductive heat trenefer. doen not form eludge and 1* chemically Incapable of degradation to acidic realduea. for theee reaeona. all loon* oil hee become the standard dielectric coolant for virtu ally ell new liquid filled. Indoor treneforeere. Because of various factor*. d*-tanklng and oore examination atudltt have been Halted aaantlally to mineral oil traneformere. On* such etudy1* Involved fifty oil filled treneformere which had been In continuous oparetlon at Bonneville Power Administra tion for epproxlaately 25-21 year*. Severei conclusion* were drawn from this study; 3-11 MONS 217263 1. Only noalnal lot* waa obaerved In *uch dlalactrlc propcrtiaa ** Jepulae awltchlng turf* *nd low-frnquancy voltage atrengih in trantforwera over * 25 v. ptriod. ,r 2. Only low to aoderate theraal degradation of tht eelluloeic Jnaulation wtt obaarvad. Further. Unit lott in cellulotlc tentilt atrength wtt obaarvad. 3. Mechanically, aubtttntit! uttful life regained in thett trenaforMra (trenafona- rt at thtlr itited, Jnatalled lift expactancla*). * 4. Thtat 25 yetr* reprttent NOT MORE THAN 20 PERCENT of tht expected llfttltet- with auch projection*. 125 ytar* tty bt poaalbla. 5. An additional twanty-fiv* or tort yaara of uaefwl aarvice lift (roughly twica tht lntttlltd lift expectancy) can ba expected fron auch.traneforaer*. Anothtr ttgdy by Poblle fitrvlc* Eltctrlc and Ota Cotptny13 conclgdtd "that tranaforaere of older conetructlon have an averare expected fellgre Ufa of tround *0 year*," eupportlng the conclue Ion that older traneforaere have a life expectancy of two or three tleee the Inetalled expectancy, la addition, PStao oonoluded that 'todey'a eaoe production eethode hava reeulted In eany ceeet of faulty workeanehlp and aerginal detlgna that are not uncovered by factory inepeetien or teetinc. reeuitlng in e higher failure rate during the flret three yeara of tervica. Thla It in contract to the crefteaenahlp of yeeterday with ite pride In a perfect product.' Theca two eoeprehentlv* etudlee conclude thet the average life expectanciee of older* tranofomere are far longer then the originally etated expectanciee. Given the tup*rlor propertlt* of Aekarel and tllleon* fluid, the life expectanciee 0f the older Aekarel unite when retrofitted and reelaeeifled to non-PCS atatue vie Reclaet-SO1* Trentforeer Retroflll Service, likewiee, are expected to be far greater then orlgldaily etated, thu* augmenting the rlek reduction value of retroflll and recleetlficetion to non-PCB etatua. flwmr ahp cwttwiw 1. Traneforaere, particularly Aekarel traneforaore, were elgnlfIcently overdeeigned piece* of electrical equlpaent with exceptionally long life expeetenelea. 2. Hletory ha* ahown that ouch traneforaere have true life expectanciee of fifty, elxty, aeventy, or even eighty year* or core. 3. Viable, coaaereially proven teohnology exlete to retroflll that traneforaer and recleeeify It ta non-PCB atatue per EPA regulation*. 4. The life expectancy of any traneforaer 1* dependent on the eara with which thet traneforaer ha* been aaintelned, UNISON Traneforaer Retroflll Service*. Inc. ha*, during the pact two yeare. initiated in axcett of two thoutend traneforaer eervlolngt. The** Aekarel traneforaere ere exceptionally well built place* of equlpaent. well worth eevlng. A tuaaery table of anticipated traneforaer life expectanole* of inetalled equipaent It the following: Vear Placed la Service Mlnieua Life Expectancy Max leu* Life . Aekarel (or Blllcono Oil) Prior to 1270 Slnoo 1BT0 SO 40 S 0 i Mineral Oil Prior to 1970 4S eo Since 1070 29 35 MOMS 217264 3-12 REFERENCES I, -Report on R*liability Survey of lnduetriel Plant*. Part l: Reliability of Elec* 'trical Equlpeent*. IEEE Coanittaa Report, praaantad et the ioi3 Induetriai and Coaerclel Power Syetea* Technical Conference. Atlanta, GA May 13-16. t, `Report of Treneforaer Reliability Survey - lnduetriel Plante end Coaeerclel lulldlnct* IEEE Coaalttee Report, preeented et the 1060 Induetriai end Coeeercie) power Syeteae Conference. Houeton TX Key U-18. j, Doble E;s(lneerlnc Conference Minute*, Technical Queetlone on Traneforaar failure*. 4, R.Sahu, *U*int Traneforaar failure Date to Set Spare Equlpaant Inventorlee*, 1060. . S.D Myer*. J.J. Kelly, and R.H. Perrleh, fifty Year* - A Oulde to Traneforaar [uintenence. Traneforaar Maintenance lnetitute. . AIEE Traneforaar Subcoaalttee, 'Interla Report on Guide* for Overloedinf Traneforaere and Voltaca Refulatore*. ATEE Traneactlone. Vol. 61, pp. 661-604. Sept. 1042. usi1. W.j. McNutt, 'A Propoeed functional Life Teat Model for Power Traneforaera', Tramactlone on Power Aoparatut and Syetoai'^oL-PAS-OA^oo.J?. Seot.^Oct. iott. t. Sea Reference S, pafe 135. 0. Solubility Data Sarlee. R. Sattjno editor. Parfeaon Preaa. Elaaford NY. vol. 7, Pf. 305. 1011. 10. T. Orbeck and B.R. McCllntlck. 'Service and Safaty Experience with Silicone liquid-filled Saall Power Tran*foraere*. Prooeedlnf* of the MONTECH `66 conference on PCS'* and Replaeenant fluid*, Sept. 1066. U. "Dacontaainat* PC5 Vault Traneforaar*'. Electrical Morld, pp. 73-74, Oct. 1065. 12. P L. Bellaeehi, 'Ufa Expectancy of KV power Traneforaar* in Service*. Minute* of Annual Conference of Dob)* Cl lent*. 35AIC66. Sec. 6-701, Traneforaar Seotlon. 1066.13 13. J.A. Keytar. "Dlacutelon of Ufa Expectancy of HV Power Traneforaar* In Ser vice'. Minute* of Annual Conference of Doble Cliente, 36AIC6I, sec. 6-701A. Trantforaer Section, 1066. HONS 217265 3-13 MOHS 217266 ASKAREL TRANSFORMER RETROFIlL - AN ANSWER TO COMMON MISCONCEPTIONS DENNIS F, TULLOH and STEVEN C. VICK Union Carbide Corporation Tarrytown, Now York 10591 ABSTRACT With th commercial Introduction of technology to successfully retroflll transfer, inert and reclassify then to non-PCB status, the transformer owner for the first time hat a real choice of options for dealing with hit or her PCB transformer problems. The choice should be made only after consideration of all the factors which eight have a bearing. Including risk reduction and management, near-tera and long-term liabilities, transformer life expectancy and safe operation. Although . technology to successfully reclassify transformers to non-PCB status was Introduced to the market In 1984 by UNISON Transformer Services, Inc., the safe use of sill . cone as e retroflll fluid has been demonstrated for many years. Even so,' a number of questions concerning the advisability of utilizing silicone In askarel transfor mers have been posed. This paper will enumerate and discuss these subjects In view of available scientific Information, INTRODUCTION With the development of the RECLA$S-50sm Transformer Retroflll Service by union Carbide Corporation and UNISON Transformer Services, Inc,, reclassification of askarel transformers to non-PCB status became a reality. This technology directly addressed the problem of leeching the PCB out of the Insulation, and utilized a proprietary Interim coolant, TP-1, to accomplish this task. During tha leaching with. TP-1 to remove PCBa, the transformer may be operated under normal conditions. Following the TP-1 cycles, during which virtually all the PC#s are removed from tne transformer core, any of several possible permanent dielectric coolants may be used, the most desirable of which, would b* silicone oil. Doubts about silicone's utility, though unfounded, when circulated throughout the electrical Industry can cause anxiety. It Is the Intent of this paper to resolve these uncertainties, by restating the questions and then factually resolving the Issues. POINTS Of CONCERN ARE SPECIAL FLUSHING A6ENTS NECESSARY TO CLEAN OUT AS MUCH ASKAREL AS POSSIBLE PRIM Tfl ltfTMfILL 0TTTgCTSFORMER7 special flushing agents, such as perch- loroethyiene or Freon", are nof required In order to achieve non-PCB status via retroflll. While superficial eskarel Is removed this brief flushing technique does nothing to solve the fundamental problem of retroflll - diffusion and removal of deeply Imbedded askarel. The surface cleaning advantages do not outweigh the risk of transformer damage by these strong solvents. UNISON'S RECLASS-50* Transformer Retroflll Service Is designed to enhance the natural diffusion mechanisms which leach out the deeply Imbedded askarel. UNISON'S TP-1 accomplishes an acceptable time frame and also without damaging the transformer. Published with permission of Union Carbide Corporation 3-14 HONS 217267 'Retroflll processes have been proposed which recommend thorough flushing with vtrong solvents, followed by retroflll with silicone oil, rither then tn inter'edltte leaehant such as TF-1, However, silicone oil preferentially leeches out Whatever diluents (askarel co-solvents) may be present, thus end reducing PCB 'teachability. Consequently, latching askarel with silicone oil takes years, even 'if strong solvent flushing agents are utilized. I. util RETROFILL COOLANTS BE COMPATIBLE WITH ANY TRANSFORMER? In this Instance, eompillbfHtV means the absence of deleterious chemical or physical Interactions, The coolant should not dissolve, degrade, or otherwise modify the Insulation, Its adhelives, sealants or the Insulating lecQuers used on many transformer windings, Cooltnts which are recommended by UNISON at this time are Its proprietary TF-1, itllcone oil, and mineral oil, TF-1 It a low viscosity coolant, totally miscible with askarel, and compatible with the materials used in askarel transformers. Its use will enhanca diffusion*! leaching of PCBt from askarel transformers, but will not affect the Integrity or electrical characteristics of the Insulation, TF-1, however, Is not always com patible with transformers designed for mineral oil. Other fluids and procedures need be utilized In these cates. Silicone oil Is noteworthy for Its Innocuous Interaction with other types of materials. It *111 not dissolve or degrade the Insulation or lacquers In either askarel or mineral oil transformers. With respect to Interaction with silicone, gasketing materials are a special case. Mott gaskets, whether silicone rubber or neoprene, will be swollen by askarel or mineral oil. Such swollen gaskets can deswell and possibly leak after retroflll with silicone oil. Accordingly, all gaskets need be replaced with Ylton or other gasketing materials at the appropriate time. Mineral oil Is considered to be compatible with askarel transformers, and can be a final coolant If the transformer Is located such that the flamiability of mineral oil Is not a hazard, IS THERE DANGER OF EXCESSIVE TRANSFORMER PRESSURE DUE TO THE HIGHER COEFFICIENT OF THERMAL EMH5ldM FOft SILICoNe? The erroneous fear that excessive transformer pressure can develop when a transformer Is retrofllled with silicon* Is bated on a common misconception as to a suggested "excessive" thermal coefficient of expansion of silicone oil. Exaggerated values as high as 0.00106cc/cc*C have been claimed. In actuality, the value for silicone oil Is 0,00092cc/cc*C, while those for askarel and mineral oil are about 0,0007 and 0,00086cc/cc*C, respectively. Thus, for a 65*C rise In temperature, silicone oil would expand,6,0% vs, 4.6X for askarel a mere 1/2 Inch difference for a 350 gallon case, not a large difference, but one which UNISON has considered, particularly where the transformer may have been designed with insufficient head space or Is hydrostatically designed to be gas free. IF HY ASKAREL TRANSFORMER IS RETROFILLED WITH SILICONE OIL. WILL IT NEED TO BE DERATEPT This ts a complex subject which deserves detailed discussion. TTrsTT however. It must be noted that for most transformer owners, this Is an academic question because most transformers are used well below their rated capacities and there Is no reason to consider derating. For those few transformers that run at capacity, derating Is not a major Issue. Oil temperature Is used by many as a gauge on transformer Insulation life. However, winding tempertures are more likely to correlate to the insulation and transformer life than the fluid temperature. The actual electrical windings are surrounded by celluloslc materials for electri cal Insulation and spacing. $uch materials are also thermal Insulators unless they are saturated with * fluid, such as askarel or silicon* fluid, which provides ther mal conduction. The thermal conductivity of silicone Is higher than that of askarel (0,036 vs. 0.023 sec C"C/cmj, respectively) and accordingly, silicon* is more efficient In this phase of heat transfer. Oat* generated by Oow Corning, 3-15 HONS 2 1 72 68 from two Identical pancake type transformer! (2500 KVA 13.8 KV HV Oelta 450 lv wvri filled with askare 1 and silicone show that temperature rises for the high voltage ' and low voltage windings are 3-4*C lower for the silicone filled transformer than for the askaral transformer. Thus, the temperature rise for the transformer win dings and the surrounding cellulosle materials Is lower for a silicone retrofitted transformer than for the corresponding askarel filled transformer, Regarding top oil temperatures, the effectiveness of heat transfer by convection is a complex function oft viscosity, density, thermal conductivity, heat capacity, coefficient of thermal expansion. The last three favor silicone. On balance, the thermal transport due to convection Is marginally slower for silicone, and bulk top oil temperatures can be expected to be slightly higher (only five degrees or less) for silicone than for askarel. Even for transformers run at electrical capacity, the top oil temperature rise for silicone filled transformers should be less than the rated degree rise, and derating Is of no concern. Taking Into account the top oil temperature rise and the winding temperature rise, It Is apparent that the temperature of the cellulosle winding Insulation In a sili cone retrofllled transformer Is essentially the same as the temperature In the corresponding askarel transformer. The transformer life Is, to a major extent, determined by the life of the cellulosle winding Insulation, and the essentially Identical temperature of a silicone versus askarel filled transformer corresponds to Identical transformer lifetimes. In sumary, as stated above, for most transformer owners, this Is all academic, because most transformers In fact are used well below their rated capacities. However, for those who do run at capacity. It Is comforting to know that a slightly higher top oil temperature does not necessarily signify the need to derate. Those wishing e greater, though unnecessary, margin of safety In top oil temperatures should consider derating the transformer by one to not more than five percent maxi mum. However, while we may expect a slightly higher top oil temperature rise with silicone fluid, we will encounter lower winding or hot spot temperature rises, and the transformer does not need to bo derated. IF W ASKAREL TRANSFORMER IS RETROFILLEO WITH SILICONE OIL. WILL ADDITIONAL precau tions it necHSftrra~MrTHE wiwwmrv no-loadrcr-'ENEwrzEr operation i W Silicone fluid'in ho way effects the standard operation of no-loea tap changers which sot and allow changes In the voltage ratio of a de-energized transformer without breaking the transformer seal. Tap changers are generally set. during the Initial conalsslonlng of the transformer, and once the transformer Is pieced In service, the tap changer requires no attention and rarely, Is changed from Its Initial position. A tap changer consists of stationary conductive elements and movable conductive elements which frequently are tin plated copper. Prior studies show that si 1 leone fluid Is e good lubricant for tin on tin. Thus, it Is unlikely that the drive shaft, which controls the movement of the movable elements, would break and lead to or cause e misalignment of the tap changer. In the unlikely event that the drive shift would break, the cause would undoubtedly be Improper movement or handling of the drive shaft rather that the presence of the silicone fluid. If the drive shaft should break, the absence of any high torque region during tap changer movement would be clear Indication that a problem exists within the changer. At this point, it would be a relatively easy task to replace the tap chinger. If the tap changer were to fall on energizing due to Improper positioning of the contacts, the failure would occur regerdless of the fluid contained within the 3-16 MOHS 217269 IRkformer. Failure would occur due to arcing across the contect el emeriti, nd Kid be severe enough to compromise the Integrity of the transformer Itself. It Writer thet THE TAP CHANGER MUST BE IN THE CORRECT POSITION TO INSURE PROPER Deration, such position being the center of the high toroue region. 7 is true thet redesign of tip ehengers occurred In perellel during the time ,r1od thet silicone ms replecing Atkerel es the trensformer fluid of choice. Isuch redesign occurred to counter e design deficiency of the then existing units 7ither then In response to e problem ceused by silicone. It was determined thet voltege retlo of rneny trensformers was being chenged more often then the ^designers T tht T*P ehengers hid entlcipeted. F el lure due to Improper positioning [of the drive was occurring, elbelt rerely. As e result, the tip chenger design was chenged to provide for both eesler movement of the mechenlsm e*3 easier, proper 'placement of the contacts. FV. MY TTRKAiNuSeFOcRMMvEnR IrSe eRcETTRanOrFnIUiEcOn uWtITruH cSIrLirICmOuNcE. uWnILiL aBAiStiICr ItMuPbU.iLi SeEe i cu^i (Bits) BTfflJlffk HtPUniON DUE' 10' CTFFEftEUCts 'IN POSlTm'WOWTV IMPULSE i TIT gMEMIfLlClM AHb ASltXRiLT Assuming a transformer has been properly maintained ond Is protecteo try suitable lightning arresters or other fault protection equip* Mnt, there ere no reasons Bit's should be reduced. With the advent In the early 1980's of silicone retroflll technology (whether reclassification had been achieved or not), and the corresponding availability of silicone retrofllled askarel transformers, data became available which show that transient voltage surge Induced faults are no more likely to occur with a silicone retrofllled eskarel transformer than with the askarel transformer Itself. An additional support for this conclusion Is the building of transformers with reduced BlL's, a trend that has become an usual original equipment manufacturer (OEM) practice. At the present time, the Industry accepted norm for most new transformers Is a BIL range of 45-60 KV, with previous designs for older transfor mers being 90-125 KV. Simply stated, this translates to assembling transformers with reduced Insulating materials, effectively lowering the manufacturing costs of the transformers. If the reduction In Insulation capability of pressboard Impregnated with silicone were to cause problems or faults through transient voltage surges, then the current OEM practice of building transformers with a reduction In Insulation materials and concomitant reduced BIL's would also present a problem. Since the latter obviously Is of no concern, the former (any suggested but clearly not evident reduction In Insulation character due to lower positive Impulse polarity creep strength of silicone) likewise presents no problem. This clearly supports the widely held belief that older transformers were overdesigned and, correspondingly, are superior to modern transformers in reliability and per formance under stress; making them assets well worth preserving. CONCLUSIONS In summery. Questions have been posed regarding the retroflll and reclassification option fer dealing with a transformer's PCB risk. Such questions or doubts, posed by a few individuals, can cause the transformer owner a great deal of anxiety even though such doubts are based only on supposition. When answered In the face of available, scientific evidence, however, such doubts vanish. This leaves the transformer owner free to concentrate on more Important factors such as risk reduc tion and elimination of long-term liabilities associated with PCBs, With the demonstration that RECLASS-50*11 Transformer Retroflll Service offars a viable retroflll technology which does not adversely affect the transformer, the trans former owner finally has en option for eliminating his or her PCBs and their asso ciated risks, forever. 3-17 HONS 217270 PART DESTRUCTION MONS 217271 SMALL-SCALE DESTRUCTION OF PEB FLUIDS BY ELECTRICAL DISCHARGE PLASMAS Richard Wm. Tock Professor of Chemical Engineering Texas Tech University Lubbock. TX 79409 Don Ethlngton. President ' Al-Chem Fuels, Inc. Olimltt, TX 79027 abstract A process which uses high-voltage, ac discharges as a reaction zone to decompose oils has been developed and patented. The system Is unique In that the discharge plasma Is confined to the Interface between the oil being decomposed and water. The temperature of the discharge region Is of sufficient magnitude to cause fast pyrolysis of the oil. The water helps prevent carbon buildups via a shift reaction which produces hydrogen and carbon monoxide. The water also allows soluble catalysts to be Introduced to the reaction zone, and reaction products to be removed. For example, the chlorine of chlorinated hydrocarbons Is converted to HCl, then neutralized to a metal salt which Is withdrawn from the water phase. The gaseous products of the decomposition are withdrawn as hydrocarbon vapors. Fluids contaminated with PCB's have been tested on a limited basis. Those and other preliminary tests on waste agrichemicals and other hazardous Industrial wastes indicate that the geses evolved are free of hazardous or toxic components, while precipitates are condensed carbon structures and Inorganic salts. Projected advantages are low capital costs and the ability to be scaled to small or large sizes without loss of efficiency. Processes to destroy PCB's continue to be of high Interest both nationally and internationally. A recent International meeting in Vienna addressed this topic as well as a multitude of other problems Involving the management of hazardous and toxic wastes (1). The concept of 'waste minimization* appears to be the goal for future control efforts. Meanwhile, efforts to develop acceptable technology for the treatment of existing hazardous wastes continues to go forward. With respect to PCB's, 00-Site clean ups have always been an attractive feature for developing technologies (2). This feature Is particularly agreeable with the electric power Industry which acknowledges the potential hazardous condition of widely scettered transformers containing PCB's. Such transformers are distributed throughout most populated geographical areas. They represent a multitude of smell volumes, 250 liters (60 gal.) which can contain anywhere from pure askerels to ppm concentrations of PCB's In the dielectric fluids (3). As such, they represent potentlel high risks for ceuslng environmental insult should accidental spills occur. Progress Is being made In the removal of these PCB containing fluids from active service. Incineration Is an accepted technology. It Is effective end cm be regulated by governmentel agencies. Howevir, most Inclneretlon processes are large 4-1 MOWS 2172 72 teal* and necessitate that the hazardous fluid ba transported to the disposal siu> a process which also can have a high liability risk associated with it if !n accidental spill occurs. The more preferable on-site technology for treating th PCB fluids has centered on both physical and chemical treatmant processes. Physical processes utilize distillation or extraction techniques with proprietary solvanti (2). Chemical treatments use alkali metals or molten salt baths to actually chano* the PCB molecular structure. These processes are successful In many Instances, but can be expensive, may require repeated applications due to diffusion controlled phenomena, and are still dependent on Incineration to treat by-products which are formed. For these reasons, on-site disposal of fluids containing PCB's remains a competitive area of technology. This paper will describe a new technology being developed which may perhaps find a niche in the removal processes for PCB's on site. \ PROGRAM OBJECTIVES The technology to be discussed In this paper was developed over the last four years as a process for generating fuel gases from waste or low cost liquid hydrocarbon^, A patent covering this technology has been applied for and will issue to Al-Chem Fuels, Inc. (Dlmmltt, TX) this year. Only within the last year has the application of this technology been directed towards the treatment of hazardous or toxic chemical wastes (4, 5, 6). Moreover, It has only been during the last six months, that serious attention has been given to the problems associated with PCB dlsf&sal; Therefore, many pertinent questions pertaining to the technology remain to be answered. In our Initial approach to PCB disposal several program objectives ware established. These Included the following: (!) to develop a capability of completely destroying PCB molecular structures without creating new hazardous wastes (l.e., dioxins)*, (2) to- attempt small-scale, on-site disposal {l.e., 200 llters/day (SO gal/day) with minimal utility requirements) and; (3) to strive for a cost competitive process. The technology being developed appears to be progressing towards achieving these objectives. The discussion which follows offers data and evidence as to how this Is being achieved. ELECTRICAL DISCHARGE PROCESS The discharge of electricity between two electrodes Is known to contain electrons at temperatures In excess of 1500K. This level of temperature is sufficient to dissociate most chemical bonds and create lower molecular weight species which are thermally more stable. Thermal cracking and pyrolysis processes on an Industrial scale are examples of such thermally Induced changes. The technology used In this process makes use of the elevated temperatures associated with repetitive electric arc discharges to destroy the PCB molecular structure. Not only Is the PCB structure destroyed, but also that of the mineral oil, silicone oil or any other solvent In which the PCB's are dissolved. Hence, the process Is not one of resource recovery and recycle, but one of total destruction. The physical structure requirements of the process which will be discussed hare art depicted In Figure 1. As shown, a metal electrode Is Immersed In an Insulating oil phase and brought Into tha proximity of the Interfece formed with a conducting water phase. The water phase acts as an electrode during operation. A high voltage potential Is created between the tip of the metal electrode and the conducting water phase. As this potential Is Incraased, a point Is raachod at which tha nonconducting oil phase breaks down and an oloctrlcal discharge Is created through tho gap between the electrode tip and the water interface. By using an alternating power source, multiple arcs can be struck over a period of time as the polarity of the electrodes cycles between the extremes of posltlvo and nogatlvo potontlals. Genorally, tha potentials Involved are in the kilovolt range while the current -2 HONS 217273 ifties are a function of tht potential drop squared and the Inverse of the cuba the distance between the electrode tip and the water interface. Hence, moving f electrode awey from the interface can cause cessation of the discharge process llarly, an Increase In the electrical conductivity of the Insulating oil phase reach a level at which discharges are eliminated and ohmic conduction and ;1ng are created. To be effective therefore, an arc discharge must occur. It Cjt be repetitive to the point that it is continuous. If this can be accomplished nd controlled, then the arc becomes the destructive mechanism for all molecular 'species drawn into the plasma tone. ji pi asms treatment processes are not new technology for waste treatment. Freeman 'discussed two plasma processes that have reached demonstration stages (7). One unit Is offered by Pyrolysis Systems, Inc. and the other by Applied Energetics, Inc. The pyrolysis Systems' technology Is based on a plasma'torch concept developed at the Pittsburgh based Meetinghouse Electric Corporation (6). It has been described as a oblle unit capable of treating up to six tons of waste per day with a one hundred percent conversion efficiency. Gases produced by the plasma torch must be scrubbed to remove hazardous constituents. These examples of the proven ability of electrical discharge plasmas to destroy identical structures are offered as supportive evidence for the technology developed by Al-Chem. The unit being developed by Al-Chem also utilizes the destructive potential of a hot, Ionizing electrical discharge. However, it differs In several significant ways: (I) It Is a much smaller plasma zone; (2) the discharge occurs at a water Interface; and (3) It has a built In gas scrubbing mechanism. A fourth feature Is that It Is capableof utilizing the fuel gases produced to offset the power requirements of operation. In order to put a scale of size on Figure 1, It should be noted that the plasma arc created by the discharge rarely exceeds an elliptical shape whose major axis Is 0.5 cm In length. The volume of plasm region Is therefore somewhat less than one tenth of one percent of the volume of liquid oil and water In the vicinity of the discharge. Therefore, It Is possible to maintain a steep thermal gradient between tha thousands of degrees centigrade within the arc and the less than one hundred degrees of the bulk fluid. The gases produced by the electrical arc are thereby quenched and scrubbed by the surrounding oil and water within seconds of their formation. The large volume of fluids relative to the discharge zone also helps prevent spurious discharges of electrical energy which car. arise as carbon deposits build In the oil phase. This carbon buildup is the direct result of the pyrolysis caused by the high temperatures within the ere and carbon-rich deposits represent a by-product of the cell's operation. The presence of the water Interface and the actual use of water as an electroda is necessary in order to prevent an excessive buildup of carbon deposits. Unlike the Insulating oil, the more conductive water Is actually drawn into the reaction zone by the forces of the high electrical potential. The chemical analyses of the gases produced suggest that because of this participation of the water in the reaction chemistry, solid carbon Is shifted to molecular hydrogen and carbon monoxlda. Therefore, depending upon the type of oil being destroyed, a quasi-steady state level of carbon rich precipitates are formed. The level of condensed carbon structures can be further reduced by the Introduction of water soluble catalysts. Finally, the water phase acts as a highly adsorbtlve medium for the removal of any acidic gases which are formed (1,e., HC1, SOx, NOx, ate.). It Is well known that these Inorganic mineral acids are many times more soluble In aqueous solutions than they are In organic fluids. Moreover, If the aqueous phase contains mineral basts of high pH, then soluble or insoluble salts can be formed. In this way tha offending anions of the hazardous waste can be removed expeditiously without tht need for auxiliary gas scrubbers. 4.3 HONS ZllZTt The schematic thown In Figure 2 Indicates how the gases produced could be scrubbed by caustic water If It were deemed necessary. Also shown In this figure is th* manner In which the fuel gases produced by the Al-Chem device can be used to po*,!! or at least co-fuel the unit. The efficiency of this type of system will be discussed later, but generally light hydrocarbons to serve as fuel must bo brought to the site if the twenty-five percent efficiency of the Internal combustion engine is to be overcome. However, the electrical energy needed to run tha Al-Chem unit can come directly from an electr*c*l power source If it Is available on site. EXPERIMENTAL APPROACH The experimental approach used In this study Is the tame as that used In similar prior studies which Involved fuel gat generation. This Is detailed In other publications (4, 5, 6) and only a summary of the procedure Is repeated here. The reaction container was a glass vessel (3.8 x 10'* m3 or 1 US gallon). The glass provided a visual display of the electrodes during operation end for photographic purposes. However, stainless steel containers and carbon steel units have bien assembled on a pilot scale. A 110-120 volt power source was used with the one gallon glass reaction vessel. Here again a 220-240 volt, three phase power source has been used with larger units. The 110 house voltage was connected to two electrodes within the cell throudn i. proprietary electronic circuit. This allows power consumption by the unit `to be monitored and provided some diagnostic assistance. Gases produced were collected In metal sample bombs or vented through a laboratory hood. In some cases samples of residual liquids and precipitated solids were collected for analysis. In most cases, the small-scale, two electrode device Is run on a semlcontlnuous mode for from six to ten hours. Both water and hydrocarbon fluids are added during operation to maintain a proper level of the Interface. Most of the data collected have been from runs with tap water and three hydrocarbons; n-heptane, diesel fuel, and toluene. A silicone oil used as a viscosity standard was also run. For this particular study, a transformer oil containing SS0 ppm of Aroclor 1242, and a blend of 100,000 ppm of a PCB In diesel ware tested. Concentration levels were determined with HPLC using EPA approved guidelines. Similarly, all analyses of gases which were produced were performed on a series of chromatographs with programmed elution. This particular GC system could Identify permanent gases and hydrocarbons below t$ to the nearest 0.01 percentage, although all report values were rounded to the nearest 0.1 percent (1000 ppm). The carbon sludges which formed were subjected to elemental carbon, hydrogen and oxygen analysis. EXPERIMENTAL RESULTS Although a large number of experimental runs with various different feed materials have been conducted, only three runs relate to the PC6 trials. The experimental results are shown in the following tables. Table 1, for example shows the variation In composition of the gases produced during a series of three, six hour runs in which the organic phase contain a low level of PCB's (S50 ppm); a rather high levil of PCI's (S/,000 ppm); and one without any PCB's (pure diesel). The diesel was selected because we nave amassed a considerable amount of run time during test procedures with diesel fuel, and because It appeared to mimic the performance of the mineral oil used in the transformer fluid which contained the 550 ppm PCB's. Also shown In Table 1 are the theoretical heating values expected for the gases produced each test run. The data given In Table 2 show the various types of Information obtained before and after six hours of run time. These data Include PCB concentrations In the Initial and final periods for all three of the phases. With the pure diesel oil, mora specific data concerning mass and energy balances were also obtained. In general, 4-4 HONS 217275 he. total Bl** biltncc wi$ closed to within three to five percent. ikltnce wet *uch more difficult to close, however. IftCUSSION OF RESULTS The elemental production Bised on the data shown In Table 1, It would appear that the mineral oil In the .'transformer fluid (Run A) behaves much like the pure diesel fuel {Run C) when Subjected to the arc discharge. Both fluids decomposed to produce essentially the same gas phase composition. The slight increases In carbon monoxide and acetylene my be due to differences between the mineral oil and the diesel fuel, or It may mil be due to the presence of the PCB's. A comparison between Run ft and Run C, in which the only difference Is the presence of PCB's,,would seem to Indicate that the contaminant has an effect. Based on other experiments not reported In this paper, It appears that halooens can act to enhance acetylene formation and. In some cases, carbon monoxide as well. This Is thought to be a Lewis Acid catalytic phenomenon In which the halogen combines with metallic ions, such as iron, from the electrodes to produce Lewis acids In the aqueous phase. In the other experiments, fluorine ts Introduced to the system through the water phase and found to double the fraction of- acetylene produced. One surprising result was the comparatively high level of carbon dioxide In Run A. It was assumed that the presence of calcium hydroxide and the higher pH would effectively remove any acid gases which formed Including carbon dioxide. This had been the case with other experimental runs In which sodium hydroxide was used to Increase the pH of the aqueous phase. In fact, It was possible to remove all carbon dioxide from the product gases by using sodium hydroxide. In Run A, however, the calcium hydroxide appeared to be ineffective. Rather, It appeared that the divalent calcium Ion was participating In the formation of a greater fraction of solid precipitates. Since the calcltrs Ion can form structured soaps or greases which are less soluble than the sodium Ion structures, this may well have been what occured. In any event. It Is evident that the inorganic Ions, anionic or cationic, Introduced through the aqueous fluid can indeed change the overall reaction chemistry and, therefore, deserves more attention in future studies. Finally, the theoretical heating value of the product gases produced are shown in Table 1. These data should be Interpreted only on a relative scale, since the calculated theoretical values can change significantly by the addition of small amounts of heavier hydrocarbons (C3+). In fact, the two to five percentages of gas compositions not shown In Table I, were Indeed hydrocarbons greater than C3 and most of which appeared as unsaturated hydrocarbons. An average heating value equivalent to pentane was used for this fraction In calculating the values shown In Table 1. In all three runs, the heating value was In the mid range of fuel values of known commercial fuel gases. Moreover, the heating value of the gases produced can be significantly Increased by spiking the organic phase with a light hydrocarbon {Cj. C7) and operating the unit at an elevated temperature. The higher temperature causes thm light hydrocarbon to distill out of the organic phase as a vapor component. As will be shown, this can be used advantageously for on-site destruction of waste fluids. Llnuld and Solid Residuals The data In Table 2 deal with the chemical changes In the liquids fed to the unit and with the organic sludges produced. During the three, six hour runs, the PCS concentration dropped, indicating that It was Indeed being destroyed In the plasma arc. The destructive nature Is more dramatic at the lower PCB concentrations where the six hour operation resulted In nearly a fifty percent decrease of the PCB level. It should be kept In mind that during that six hour period, less than five percent 4-5 HONS 217276 of the bulk organic phase was consumed. Hence, If both oil and PCB contaminant were being consumed at equal rates In proportion to their concentration, then a fift: percent drop In PCB concentration would not have been predicted. At the much high/ PCB concentrations which were used in Run B, this Is more nearly the case. That is six percent of the PCB's were destroyed during which approximately five percent of the oil was also destroyed. in both Run A and Run B, the PCB's were found to contaminate both the residual water phase and the sludge which formed. In the latter case. It appears as though the PCB's In tht sludge are associated with the organic fluids it retained, since the PCB concentration Is nearly the same In both. This Is In keeping with the hypothesis that this plasma process Is not a "vis breaking* phenomena. That Is, th* molecular structure of the oil phase Is not successively reduced to lower and lower molecular weights. Rather, whatever material Is drawn Into the plasma ere is rapidly pyrolyzed to gases and solids. The bulk fluid remains essentially unchanged. Since hazardous wastes In either the oil phase or the aqueous phase are more sensitive to the alternating electric field potentials that develop prior to discharge, they are more likely to be drawn Into the discharge region. It is Important therefore to develop techniques which enhance this effect, l.e., perhaps modify the frequency of the alternating current. An elemental analysis of the sludge produced during processing of the dlfkel fuel Indicates that rather condensed carbon structures are formed. It Is Interesting that oxygen from the water also participates In this chemistry. It Is expected that other divalent anions, l.e., sulfur, nitrogen, phosphorous, etc., will do the same. The sludge has not yet been analyzed for chlorine, but these monovalent halogens may also be part of these condensed structures. The approximately four percent of unknown, shown In Table 2, Is suspected of containing iron atoms from the electrodes. This is based on the magnetic properties exhibited by the sludges which were produced over longer experimental test runs. Finally, Table 2 offers the observation that the organic phase Is consumed at approximately twice the rate of the water phase on a mass basis. Horeover, the electrical energy Input to the system produces a nearly equal amount of chemical energy as fuel gases which can be drawn from the system. This latter point is Important to on-site waste treatment. Ideally, It Is desirable for four units of energy to be produced per unit of electrical energy consumed. This ratio was observed only when n-heptane was used In the organic phase under thermal conditions which caused some of It to be volatilized. In this Instance, some of the input electrical energy was used es a heat source for the latent heat of vaporization of the heptane as well as for the pyrolysis chemistry. This effect will be discussed later. UNIT OPERATING CHARACTERISTICS Figure 2 depicts schematically the field operation of the Al-Chem technology m which the fuel gases generated are combusted In an IC engine. The engine powers a generator which produces electricity and which in turn Is used to generate more gas. The actual hydrocarbon fuel for the Internal combustion engine comes from the waste oil being decomposed or from a utility source as required. If the tfflclencies of the various components are known, then an energy balance can bt structured to Indicate at what point the gases produced from the waste hydrocarbon are sufficient to power the system without assistance from an auxiliary gas source. Ont solution to this energy balance relationship Is shown In Figure 3, This figure depicts tne ratio of (1) chemical energy produced as fuel gas from the waste to (2) the electrical entrgy consumed, as a function of the thermal efficiency of the internal combustion engine. The region to the left of the curve indicates that an euxilUry fual gas source Is needed. The region to the right and above the curve Implies that the equipment Is being operated In such a manner that more fuel Is produced than 4.6 HONS 217277 KH*t which It required to sustain the operation. Since Internal combustion engines thennaV efficiencies of twenty-five percent or less, then the electrical Bi*charge device must producesomething In excess of four energy units of fuel gas ifir every unit of electrical energy consumed. A. ratio of four or more to one is oss1ble only when volatilelight hydrocarbons are used as a diluent In the waste 'organic phase. In another sense, this Is the fuel required for a double incineration of the hazardous waste; once In the plasma discharge and once In the ^cosfcustlon chamber of the engine. Although nearly all the experimental data were obtained on a single pair of ^electrodes, sufficient longer term runs with multiple electrodes have been 'undertaken so that estimates of cost Information could be made. These data are 'given In Table 3. At this point It is difficult to compare these costs with those 'reported In the literature (7, 9) although they appear to be competitive. As suggested, the operating costs can be reduced by making use of the fuel gases produced to offset the cost of electrical energy. However, what Is not shown directly In Table 3 Is the low capital investment required, The unit In Table 3 has been scaled as small size by the standards of most waste disposal systems, Because of this small scale, the unit Is expected to cost somewhat under fifty thousand dollars per unit. This mans that a producer of small quantities of hazardous wastes (200 llter/day) could afford to treat his own wastes on site. This would Jiot only eliminate expensive transportation charges, but also remove the potential risks. Involved with an accidental spill In transit to a central disposal site. *' ACKNOWLEDGMENTS The authors wish to thank Flna Oil and Chemical for assistance In chemical analyses. BIBLIOGRAPHY 1. David Hunter. 'An International Forum looks at Waste Disposal,* Chemical Week. Vol. 140, p. 23, April 1, 1957. 2. Pater Savage. 'Cleaning Up PCB's On Slta,* Chemical Week. Vol. 140, p. 13. April 1, 1987. 3. Sam Hixson. 'Granulated Carbon Does Quick PCB-Cleanup Job,* Electric World. Vol. 10B, p. 76, July, 1954. 4. Richard Urn. Tock. 'Electro-Thermal Chemical Reformer,* AlChE New Orleans Hatting, April, 1986. 5. R. Vfm.Tock, H. W. Parker, H. Shafl and Don Ethlngton. 'Hass and Enargy Balances Around Electrical Discharges at Oil-Water interfaces,* ASME/JSME Thermal Engineering Conference, Hawaii, March, 1987. 6. R. Wm. Tock and Don Ethlngton. 'Small-Scale Disposal of Agrichemicals,* 24th AIChE/ASME National Heat Transfer Conference, Pittsburgh, PA, August, 1987. 7. Harry Freeman. "Innovative Thermal Hazardous Organic Wasta Treatment Processes,* Noyes Publications, Hew Jersey, 198S, 8. Kathleen 8, Dempsey, Editor. 'Plasma System Destroys Waste,* Plant Sites and Parks. Harch/Aprll, 1986. 9. James R. Hollis, 'Plasma Temperature Incineration.' Environmental Progress. Vol. 2, No. 1, February, 1983. 4-7 HONS 217278 TABLE 1 CAS CHROMATOGRAPHIC (GC) ANALYSIS OF OFF CASES FROM THE TREATMENT OF PCB CONTAMINATED HYDROCARBON LIQUIOS Description of Liquid Feeds For Etch Run Is Shown Below Gtseous Components Hydrogen (Hj) Ctrbon Monoxide (CO) Acetylene (C2H2) Ctrbon Dioxide (CO2) Methtne (CH4) Ethylene (C2H4) Run A Vol. Percent S3.3 21.0 6.7 4.1 2.3 -Li 98.7 Run B Vol. Percent 61.4 21.1 ' 9.6 1.5 2.6 -Li 9B.3 Run C Vol,Percent 63.9 17.0 6.3 3.2 2.5 -Li 95.2 Netting Vtlue of Gts Kilojoules/molt (BTU/SCF) . 409 (1) 470 (564) 500 (600) Run A Trtnsformer oil conttining 500 ppm PCB's tnd wtter C{OH)2 tnd 11.9 pH. Six hours of run tlm. Run B Diesel spiked with 97,000 ppm PCB tnd ttpwtter, pH 7.B. Six hours of run tin*. Run C. Pure diesel tnd ttp wtter, pH 7.B. Six hours of run tine. Vau' 'hut fWMU) FlWH 1. tTU*CMT1HltCMMT .wDitlCl KAWC HOOII IF Milt 4-8 HONS 217279 TABLE Z DATA OBTAINED FROM THE THREE EXPERIMENTAL Runs with pcb's Parameter Being Monitored Initial PCB's In Oil Final PCB'S In Oil (6 hrs.) Initial PCB's in Water Final PCB'S In Water (5 hrs.) PCB's In Sludge Formed Description of Etch Run is Given In Table 1 Run A Run B 550 ppm 97,000 ppm 287 ppm 91,000 ppm -01 ppm 247 ppm -0B49 ppm .... Composition of Sludge Formed--Atonic Percent Ratio of Diesel;Water Consumption by Weight ------ Ratio of BTU Electricity In: BTU of Fuel Gas Out Gas Production Rate Liter/Hour (STP) ----- -----------FltrM ll| Run C -HA-HA- -0-MA- NA63.52% C 7.37% H 5.19% 0 3.92% UK 2-1 * 1:0.9 15.B4 1. !*! epMtin |u |l t. MinUr ), c**tnl Mi i. dtiwi >p* nitdH t.inw I. Htt nciMfif litnMid I. uur (.mm mu) f, llltt (trlM>w *111 I. itM mttruu mtMfi.it 4-9 MONS 217260 TABLE 3 HYPOTHETICAL COST ESTIMATES bill: Orginie witt It t trinsformor fluid contlining 1000 ppm PCB's Processing riti 1$0 lltir/diy (40 gil/diy) RmlcrjYaiMi: Numbor of *1tetrodes: 1300 Volume: 5 wfi (180 ft3) ttoeritlonil Utility Requirements: Hitir: 75 llter/diy (20 gmT/day) Elictrlclty: 110 or 220 AC, 80 Hz (i) Power lino, S0.07/ktlloNtt hr negligible cost t2.55/gl (b) Nitunl git tnglno ond giniritor S8.00/10 BTU (c) Co-fueled with product gises tt u $2.58/gt1. Si.M/gil. I i ---I ji___________ i.. .. tl It M H tWilitty f lMtrmt WmttM lt|tN rum ). at n*i hki rnwco u hw Motet 4-10 ` HONS 217201 HONS 2172B2 TESTING Of TSCA INCINERATOR FOR DESTRUCTION or PCS* IN URANIUM CONTAMINATE) HASTES" R. N. Anderson Martin Marietta Energy Systems, Inc, oek Ridge Csssous Diffusion Flint Osk Ridge, TN nil abstract a Toxio substances Control not (TSCA) incinsrstor for environmentally ssfs destruotlon of FCSs snd hstsrdous organic materials contaminated with lew level redloeotive weetee from seven DO! feollltlse hee been constructed et the Osk Ridge Geeeous Diffusion Flint, ind hie undergone performance testing with FCS surrogitss. The system Incorporates state-of-the-art off-gee treitaent, i highly Instrumented kiln, end eeieondery combustion chember, end sn Insrt etmoephere solids hendling feed system*' Releeee of orgenio during en upset event, whloh triggers opening of the secondary ooebuetlon ohember relief vent, will be prevented by melnteining exoess oxygen in the kiln end e high tenpereture in the seoondery oombuetion ohember with en opereting burner. Mixtures of ohlorlnsted bsnsenee used In performenoe testing to eimulste destruotlon of FO, worst oese studies to satisfy regulatory ooncerns, end impiioatione of performenoe test results will be disoueeed. RCRA/TSCA MIXED WASTX INCINERATOR DESCRIPTION In the pest, no inolneretor facility wee eveilable with llosnelng to handle both toxio, heeerdoue, end low-level uranium oontamineted wests. With the addition of this faci lity, ell beoklogged stored westee elong with ourrently generated wests from seven DOB facilities under the direction of the Oik Ridge Operation will be diepoaed in s cafe manner. About 75 to 10 percent of these wastes will be from ths Oak Ridge complex. The DOB-OAO incinerator was custom designed to meet the needs of this facility end wee nenufeotured by International waste energy Systems, Ino. of It. Louis, Missouri. The design incorporates e highly instrumented rotary kiln, mixing ohember, end secondary combustion nhanhtr (SCC) combined with e state-of-the-art off-gee treatment system to insura that tha Inolnarator masts or exceeds ell regulations. Off-gee from the BCC is pulled through a quench chamber, variable throat venturi scrubber, packed bed, eroes-flow eorubber, end two 1uniting wet scrubbers in eerlee by en Induced draft fen to remove particulates end sold geese before discharge to e etaok. Incineration Process Nonvolatile waste materials remain inside the kiln for 1 to 1-1/2 hours et temperatures 4.a HONS 217283 of 1500 CO 1BOO*F. Solid* passing through the kiln fall into water basin, where ( dreg link eonvayor continuously remove* th* solid* to collection hopper. Combustion gas** (roe th* kiln sntsr s nix chamber *nd from thsnes trsval through s secondary combustion chamber *t 1900 to 2200*F. Th* SCC provides gas retention tin* of four second*, twice that required by Federal regulations. Technology Advances This project he* three specific ereee in which the state of technology was advanced. Dr wed Solid* Hendllnq. This is the first inelneretlon facility to provide mutomatic handling of 10, 35, end S3 gallon druse In an Inert atmosphere. FCS surrogate. PCS'* ere not pereitted to be destroyed in en incineration feclllty until the feclllty enter* its licensing testa. To enhenoe th* probability of passing the lioenelng test, the Energy System* Quality S Technical Service* Division daveloped a elxture of chlorinated bentene compound* to simulate the etomlo composition end dif ficulty of destroying FCS elxture* et Oak ftidge. Th*** chlorinated beneane mixture* were used in performance testa. ; Assurance of oreenlce Destruction In Incinerator Dpeet Condition*. The oak nidge 1 nolo*ration facility implements a new EFA requirement in that during emergency shut down, la which the Induced draft fan and gae scrubbing eye tea l* shut down and the QC thermal relief vent le opened, the Oak Ridge design provides at least 25% excess air for ooebuetion of residual unburned eolide while maintaining operation of the auxiliary ICC burner to aeeure high enough temperatures for destruction of organic* when the relief vent is open. Effluent Management Liquid scrubber blowdown end wet eeh will be collected end analysed prior to release, if exoeoeive levels of organics are present the ecrubber blowdown will be paeeed through a oarbon column to ranove organiee, and wet aah will bo recycled to the rotery kiln. INCINERATOR TESTING Construction of tho Incinerator ayetea was completed in October T988. a functional teat was carried out during November i9B6 to determine eyetom Inedoquaciee, and performamoa teating wee carried out during July 1987 to determine if th* incinerator meets performance standards setmbllohed by procurement specif1cation*. Teat Results All EFA requirement* under RCRA were met by the functional tost with perchloroethylan* ee FOffC end by th* performance teste. Average DRla > 99.99991% for trlehlcrcmoncfluoromathane and carbon tetrachloride at RCRA temperature* and for liquid polychlorinated beneenee e* aurrogeta* for FCS et TSCA temperature* were obtained in performanoe taste, and raeulta indicated that th* inolnsrator 1* able to mast all procurement specificetione. in the functional taat aulfur dioxide, from combustion of aulfur fed to tho kiln, waa oxidized to sulfate and sorbed in the scrubber for a removal efficiency of 99.9S%. keaulta from a apodal taat between RCRA and tsca phases of functional taata indicated that the TRV stack draft should be sufficient tc meat the new EFA requirement for 23% excoea kiln air whila maintaining an SCC tem- M2 HONS 217284 > iai2*r and sufficiently negative pressure to prevent s eustelned positive t the kiln face plate for store then IS seconds during e TRV opening event, eontel test Involving feed of coal at e rate of 9.2 x io* BTU/hr, prior to e S emergency TRV opening will be conducted during trial burns to verify rnt of the required excess sir, kiln vacuus, end sinleun SCC tespereture. , problems nssding correction which were revealed by the functionel test i (1> strength end operation of sechenlcel eye teat i (2) air lnleekegei (it quench flowi (4) instrumentation* end (SI dleerepenclee between Orset end ^ok Ins trues nt readings for CO2 end Oj. Although probleas with quench flows end leerepencles between orset end stack CO3 end Oj values persisted, during performance etts the eost eerlour problems werei (1) an unexpected chealcal reaction of ooensnte In a carbon tetrachlorlde-msthanoUlsopropyl alcohol-polydlmathylailoxan* *fe*d solution with severe corrosion of the steel six tank* (2) lose of eight type K ^thermocouples In the secondary combustion chamber due to overheating end corrosion, 'end ()> failure of demletor components with scrubber plugging during test 1 bscause [the oopponents wars febrleeted froe Moryl plastic rather then the specified FRY materiel. 'Other problems encountered were fugitive emissions which caused field blank samples . to eontaln more FOHC then etaok eemplee. end detection limits for chlorobensenes which were not low enough to determine whether or not the required DRX of 99.9999% wee achieved in teat T which Involved a email faod of chlorobansanaa with aollda. *r* % principle Organic Hasardoua Conatltuanta (POHCa) The flrat four performance taata at RCfth tamparaturaa uaod triehloromenofluoromathana or carbon tetrachloride for FOHC1 a ainea a SOiSO mixture of theae chamieala will be uaod In Trial turns. Trlchloromonofluoromsthana was used because It la the moat dif ficult to Incinerate Appendix vui constituent according to da's inclnorablllty ranking bacauaa of ita low haet of combuatlon. Carbon tetrachloride, which wae added aa a second YOHC at the raquaet of s?A, Region IV, la the fourth moat difficult to deetruct on the SPA Hat. Taata 5, 6, and 7 ware intended to demonatrate the pro bable destruction efficiency of PCS'a by destruction of polychlorinated ben sens mix ture# ee aurrogataa for PCI's. To be eeceptable the combuatlon mixes for use in the performance teats had to be homogeneous, have the required average heat of com bustion, have the required chlorine content, and yield the required ash content. These requirements ware mat by mixtures of the FOHC' a with vsrylng amounts of dimethyl aslonats, asthsnol, ethylene glycol. Isopropyl alcohol and polydlmothylslloxsna. fci Surrogate. Polychlorinated banrsne mixture* were selected for testing which had the same chlorine oontent, aims average heat of combuatlon, and approximately the ease distribution of temperature* required for 99% thermal degradation In two aeoonde in a dry gas stream as ths average of PCI waatee at K-2S for runs 5 and 6, and Aroelor 1 2*0 for test 7. RCRA Trial Rurns Teat 1 will uaa maximum faad rates for all waste feeds, snd minimum hstts of com bustion of 7,000 RTO/lb. for the kiln snd 10,000 ITO/lb. for ths SCC with kiln tsspsrsturs from 1400 to 1*00*F snd tn SCC outlst temperature of 1S12 * 50*Y. Methanol will be mixed with the CCljP-CCla mixture to obtain ths 7,000 BTO/lh. heat of coebuatlon for kiln feed, and ethanol will b* mixed with the CCI1P-CCI4 mixture to obtain a mean Hq of 10,000 BTU/lb. for the SCC feed. Ths sscond RCJLA trial burn will Involve waats feed to the ICC while the kiln la chut down to domonotrate the capabi lity to operate ths ICC slons. 4-13 MONS 217285 TICA Trial turn* TSCA teat 1 will be conducted by feeding organic liquid* with a heat of eoaibuation * 7,000 W/lb., aquaoua waete, aludgae, aoll* and ahraddad capacitor* containing rca> at naxlaua rata* to tha rotary kiln, whlla alao feeding at a eaxiaua rata PC* organi* liquid with a heat of coabuatlon of 10,000 ETU/lb. to tha tCC. Thla teat wl,? daaonatrata tha lnelneratora ability to burn all fora* of PC* v*t*i, and win *i, aatabllah aaxlaun allowable feed rata* and tharaal dutlaa. TSCA teat 3 will b* eon* duotad feeding only non-liquid pc* aatarlala to tha Incinerator. The objective* 0f thla taat will b* to aatabllah alnlaua taaparatura* acceptable for proper daatruction afflclanoy whan PC* liquid* are not being fad to th* Incinerator. Anticipated *ii,, and ICC taaparatura* are expected to be 1700-1900*P and 21SO-22SO*P respectively, ror TICA teat 2 tha axpactad kiln and ICC taaparatura* are 1400-1600*P and i750-i45or raapactivaiy. lhakadown Teating Shake down tasting of th* Incinerator 1* planned to begin during th* latter part of October or flrat of Moveaber, and will pracad* Trial Sum*. However, before any waatca containing uranlua or other radlonuclalda* can b* burned a parait auat be . obtained frea NESKAP. : COHCLUIIOM Although com problaa* reaaln, pra-trial bum taat raaulte indicate that th* DOE-OAO HCAA/TSCA incinerator ahould aaat all regulatory raqulraaonta during trial burn*, and 1* axpactad to ba paralttad to daatroy all hacardoua waataa Including dloxlna which have a heat of coabuatlon graatar than that of trlchloraonofluoroaathan*. ACKMOHLnOEHHTS Th* author la grateful for contribution* of aany In Engineering, operation* and Analytical Chaalatry for Martin Marietta Energy tyataa*-, Inc. H* la aapaolally gra taful to w. w. Mara** for hit a upper t, h. m. crotta, PhD. conaultlng chaalat for co operation and aaalatanoa In aalactlng and taatlng aixturaa for hoaoganeity, and to t. O. Roger* for loan of alldaa. AEraUMCES 1. Ouldanoa Manual for Raaerdou* waate incinerator Peralta, g* IPX, office of solid Meat*, waahlagtOA, 0. C., March HE 1. 2. coda of yadaral Regulation*. Title 40, Part 261, Appendix vill, (raviaad July 1, mi). 2. cod* of federal Regulation*. Title 40, Part 264, 342 (a) (2), 19*6. 4. R. H. Andaraon. Recoaaandad lurrocata PC* watt* Peed and rual CoepotItlone to Meat Raaulraaanta given In *pao. K/D 9SS2 for Taat *uma In th* Martin Marietta Energy Ivatcaa, inc. incinerator. Martin Marietta' Energy tyatcaa, Inc., R/Pt-176, Daeaabar 19*4. Th* Oak Rldg* caaaou* Diffualon Plant la operated by Martin Marietta Energy Syatana inc., for tha 0.1. Department of Energy under Contract No. DE-AC09-C40A21400. 4-14 HONS 217286 arc pyrolysis project A Progrea* Report true* Meyer Are Technologl.ee Company 3003 Rutterfleld toed Oek Brook, llllnole 60SZ1 J. Kenneth Ulttla Cherlee Tltue Electro-Pyrolyala, Inc. 996 Old Engle School Reed Wayne, Penneylvenle 19087 ABSTRACT A high temperatura DC ere furnece for the deetruction of cepeeitore contelnlng polychlorineted biphenyl* (PCS) he* heen permitted for teat et the SCA Model City elte of Chemical Ueate Manegement. Thle prototype reeearch and development furnace la baing developed with major funding by EPRt. The technology la baead upon tha utllltetlon of a direct currant arc impinging on e molten natal bath. Tha ayatem le daaignad ao that initial dacompoaitlon take* place in the molten bath and tha raeultant gaeaoue product* are paaeed In tha vicinity of the high teepereturn arc. Tha eyatam reduce* PCS* to NCI, CO. H,, and particulate carbon. Solid* added to tha ayatem malt to produce tha molten^metal bath In tha furttaca. Conatructlon and parmlttlng of the facility vaa completed In September of 1987. Tearing of tha eyatam hae begun and vill continue through November of thle year. BACKGROUND At tha 198) EPRX PCS Seminar, a paper deacrlblng the concept for thle project vaa praaantad. At that time, completion of the project vaa projected to ba completed within three yaara. At tba conference, it vaa anticipated that tha furnace wee to ba alted in California at a utility cite. In tha intervening year*, the project prefraeead but not in California. Difficultiaa In permitting a "green field" elte were found to be lnaurnountable for thle new end alternative technology. After Are Technologic* Company vaa formed by Chemical Uaet* Management and Electro* Pyrolyeie, Inc., axlating haeardeue vaata altaa vara evaluated for the location of tha furnace. In addition to tha alte, tha procaae required adequate electric pover and water. Tha Modal City elte in ueetern New York mat all of theaa requirement*. PERMITTING Dual permitting wee required under Federal TSCA regulation* a* adminiatered by the United State* Environmental Protection Agency (EPA) and New York State regulation* 4-IS MOHS 217287 which arc adainlatared by tha Department of Environmental Contarvatlon (NYSDEC). Tha New York State Regulation Part 373 Application euppliaa detailed orgenuetion,i and operational Information auch aa a waate analyala plan, a contingency plan, a financial aaeuranca plan, a cloture plan, and a danonatratlon plan. The Part 201 Permit Application contelna aaeuranca* that tha facility can and will operate in full compliance with all applicable air entlealona regulatlone. The Fart 361 Application wte a Raquaat for a Certificate of Environmental Safety and Public Kaeaealty and the Supplemental Draft Environmental Impact Statement. Thla application wta aubmltted to both NYSDEC and a apaclal airing board appointed by tha governor which waa charged with reviewing tha project. Both tha altlng board and NYSDEC required public hearlnga. The Federal permit application waa aubmltted in April 1965 and tha permit to conduct the taat waa received In January 1967. The New York State application* war* aubmltted In May through June 1985 with additional Information being auppliad during the next year. A complatanaaa determination waa rendered prior to tha public hearing* which ware held In June 1966. With no major public oppoaltlon, the hearing* proceeded amoothly. Tha Draft Permit and the Permit to Conatruct waa laauad In November of 1986. Conacructlon waa atartad and continued through *. September 1967. During thla period, additional document* war* aubmltted to the / State a* required a* apaclal condition* in the Draft Permit. The final permit tol atart up wa* laauad on Auguat 17, 1967. FACILITY DESCRIPTION Tha facility 1* an integrated ayatam capable of taking the amallaat to tha largaat utility capacitor and dactroylng them under pyrolytic condition* in tha eaelad ere furnace. The facility con*lata of a eapacltor handling area, DC arc furnace, gee handling ayatam. natal tapping facility, and control houa*. DC power 1* auppliad by a three phaaa AC full wav* eolld etata dloda rectifier having AC and DC reactor* on tha input and output of tha power aupply. Tha capacitor handling era* eonalata of a building in which capacitor* will b* unerated and catalogad. The capacitor* will be loaded on a aamlautoaatlc conveyor ayatam and tlevatorn vhleh will load them and feed them into the furnace. Tha eapaeitora are fad into the furnace through a aealed three-door automatic loading ayatam. The firat atap In the charging aaquane* la to open the flrat door and load the eapacltor into the flrat chamber. The firat door doaaa, but before the caeond door open*, tha flrat chamber la purged with nitrogen. Tha aacond door open*, allowing the capacitor to drop Into the aacond ehambar. In the aacond chamber, the capacitor la punctured by aavaral ataal prong*. Tha third door than opana. and the ^apaclcor la puahad into tha furnace chamber. One* in tha furnace chamber, which ic controlled at 1600c., the ataal eaaa and caraaic buahinga a*It Into tha molten bath. At tha tarn* time, tha PCBa and eapacltar cora pyrolyaa, decompeaing into carbon monoxide, hydrogen, and hydrogen chloride gaa. The email volume of gaooa produced during pyrolytic pea* through tha 6000C. plaema ton*. Exiting upward through the 30 ineh diameter hollow oloetrodo, the gaaao flow through o aaalad duct, conotruetod of otool, lined with refractory notarial. Into tha gaa handling ayatam. In tha gaa handling ayatam, the gaaaa will b* quenched by evaporative cooling. Two pray nottla* aupply recycled acrubber liquid and on* nottl* euppliaa cool fraah water. In a portion of tha quench chamber, additional cooling taka* place by maana of a noncontact Jacket of cooling wator. 4.16 MOWS 2X7288 IR( the dry aaparator racalvaa gases aaturatad with water vapor froa tha quench C&abar. Hera, axeaaa watar droplet* era removed by gravity, draining to a sump bottom of the aaparator and Into tha ecrubbar recycle tank. IE cyclone aaparator racalvaa tha geaaa next. It removes tha nadlum altad carbon Cgrtlclaa. Tha hoppar, or cone eheped receiving vaaaal on tha bottom, atoraa tha ^oiiactad partlculataa, A eaelad aollda collection system haa bean lnatellad on `the bottoa of tha lower hoppar for aollda removal. hCaaaa travel frow tha cyclone aaparator Into tha second phase of tha gaa handling ayataa, where they enter tha venturi ecrubbar. Some of the hydrogen chlorlda gaa 'will be removed In thla chamber, along with tha smaller altad particles. Tha operating liquid for the venturi ecrubbar la also recycled scrubber liquid. following tha venturi scrubber, tha gaaas peas into two packed tower aactlona. Hare, tha hydrogen chlorlda In tha pyrolysis gaa will ba ramoved with a minimum efficiency of 99.9X. Scrubber liquid will flow in the opposite direction of tha gaa flow, draining Into tha underlying scrubber tank. from thla point, the gaa flowa Into the afterburner section of tha gaa handling yatam. The afterburner will burn tha remaining hydrogen and carbon monoxlda, . converting them to carbon dioxide and watar vapor, gaaaa we humane exhale. Tha/ afterburner is a 60 foot stack with an Inside diameter of 30 Inches. Tha combustible gaaaa flowing Into the afterburner will normally burn without ' additional fuel. Whan required, propane gaa will be uaad to maintain the minimum required combustion temperature. Caa exiting tha top of tha stack will be coion carbon dioxide and watar vapor. Approximately every 8 hours, tha furnace will be tapped using standard furnace operating procedures. Tha molten metal will ba tapped Into mold care altad to hold tha approximate 1 foot of moltan metal and slag which accumulates on the furnace hearth. A 10.000 CFM blower and beghouae control the emissions during tapping. Tha ayataa la controlled from a control houaa which Includes the motor control canter, continuous stack gaa monitoring equipment, and furnace and feed chamber controls. Two multichannel data acquisition systems record more than 35 points of data continuously. An annunciator panel Indicates and alarms over 79 functions for the fail-safe operation of the ayatam. Power for tha furnace la supplied from a 115 KV line on Niagara Hohavk'a ayataa. Tha power la rectified by < diode rectifier utilising both AC and DC raaetora to provide continuous smooth power to tha arc. The design philosophy uaad In tha ayatam provides for redundancy of ell functional eyetame. The control ayatam operates on 24V DC with battery backup. In case of power lose, all eyatame return to a fell-eefe condition. A 168 KW emergency generator la designed to pick up tha power load of all equipment except tha DC arc itself. In addition to redundant water cooling pumps, an emergency watar ayatam using city watar has bean provided. Due to tha nature of tha facility, tha concarn for the city water ayatam dictates our use of both double backflow preventers and a water break. 4-17 HONS 217289 Other Auxiliary equlpaont required on alt* conolot* of two 20,000 gallon blow* otorag* tonka, liquid nltro*n otoro(o, ond propane otorofo. All haterdou* 0WT> notorial* or* otorod In orooo doolgnod to contoln the velum* of th* utorioi pi 11 OX of the relnw*t*r fro* o 100-yoor otorm, p u* Wo oro obout to otarc two phooo otort-up ond toot progron to doaonotroto tho olo nlnoo Dootructlon ftaaovol Efficiency (DUE) copoblllty for th* furnoc* oyotoa to dootroy PCB*. Th* flrot phoo* progron con*lot* of oovon toot* to chock out olj. oopocto of eh* oyotoa' operation prior to feeding PCBo to tho furnoco. Toot I Toot II Toot III Toot IV Toot V Toot VI Toot VII Furnoco lining euro Mixed **C*1 Motol ond coronlc* Motol, coronlc*, polyethylene Motol, coroalco, file ond peper Motol, coronlc*, FVC ond popor Non-PCB filled copocltoro , ' Phooo II conoloto of feeding PCB filled copocltoro *c food rot** of 3000, 4500, *nd 3500 pounde/hour. toch toot will bo run In trlpllcoto, An oxtonolvo toot plan will chock oil byproducte Including otock onleolono, Ingots, blowdown liquid, ond collected portlculoto* for PCB*, dioxin*, furono, volotil* end *al-volatile organic*, PP + 10 (Priority Pollutant*), notolo, cyanide*, chloride*. Tho plod currently provide* for * long-ton* hoelth rlok ooooooaont to b* provided to both Now York Stoto Dopertnont of Environaentel Conaorvotlon and Now York State Dapertnant of Hoolth, Rooult* oro co b* oubnittad by December, rocolpt of public coanont* by February 1900, ond coaaorclel operation In April - Juno 1900, <-I MO*s ULTRASONIC process for the destruction OF PCS* IN OIL AND SOIL M*rcu SittanfUld M*rcu* Sittanfiald end Asaociate* Hesardou* Watte Manegaaant, Inc. 1015 Chaatnut Street Philadelphia, PA 19107 ABSTRACT lb* ua* of ultrasonic rodlotion to promote chemicel reactions hot boon ttudiod for many years. Tho literature i roploto with roforoncot to many difforont choaicol rooctiono including dochlorinotion of both oliphotic ond oroaotic hydrocarbon*, cloovog* of oroaotic molecules, promotion of cotolytic rooctiono, etc. ' i tt Ultrasonic rodiotion proaotoo choaicol rooctiono by Mono of high onorgy generated in tho cavitation cone crootod in liquido. It hoe boon oboorvod that eccouiticelly gonorocod cavitation cou*o* the rapid formation, growth and iaploeivo collepte of vapor filled vocuoloo. Thie sequence goneratoo ohort lived, localised "hoc-opoto" whoro peak taaporotureo of 5000 to 10,000K and high prooouro* of 300 to 1000 otaoepheree hovo boon reported. The time cyclo for tho formation, growth *nd iaplooivo collapsa of tho go* voeuolo* i* reported to bo of the order of ntecond*. Cleavage of choaicol bonde in moleeuloe con occur by increasing tho vibration frequency of tho bonde by high teaperaturee or tho phyolcol action of high frequency vibration*, It ha* bean tuggootod oloo thot covitotion onorgy con croot* organic rodical* through ion gonerotion at the ourfaco of tho vocuoloo. The formation of organic radical* promote* chain reaction*. It 1* wall known thot PCS* or* conoidarod to b* chomicolly v*ry inort. Howovor, they will rooct with cortoin chemical* under vary high comparator* condition*. For example, PCS* rooct with aodiua hydroxide at ol*v*t*d toaporocuro*. PCB* con alto bo dootroyad by coobuotion with tho formation of hydrogon chloride. Deapit* it* ralotivo inartno**, a number of proco**** hav* boon proposed for tho destruction of PO*. Thao* includ* incinorotlon, oxtroction with oolvont*, photo* lytic irradiation, gomt radiation, reaction with a aodiua organic toaplax under *nhydroua condition*, ate. Of thaao.th* on** chat have bean ctudiad aoat and davalopad for coaeearcial ua* ora incineration and reaction with a todiun organic comp lax. In the cat* of inclnaration, whan the equipment i* proparly designed and oparacad, the procaa* ha* a da*truction efficiency of 99.999S of th* PCB* fad. However, there are aoM inherent problem*. First, dioxin* con bo formod in th* combustion proco**. Soeond, portable incinerators or* difficult to design and operate at peak afficianciai Third, it 1* not possible to decontaminate liquid* by burning only th* PCS*. Fourth, if tho contaminated material i* non-combustible, than fuel costa can become quite high. Th* process** using tho aodium organic complex reactant war* daaignad to recover contaminated liquid*. However, the preparation of tho reactant require* handling metallic sodium, a vary roactiv* and hasardout aubstanc*. A* result, th* process 4.19 - HONS 217291 muat b* conducted under anhydrou* condition*. R**ccion time* for that* proca***. h*v* been reported to require aevaral hour* to complete. The ultraaonic procet* developed by Hacerdou* h'aat* Management, Inc. for deeontea. inating veriou* liquid end lolid *ub*trete* containing PCS* represent* * novel approach to the PCS problem. The proce** la b***d on the fact that under extreme condition* of temperature*, eueh * *re obtained in the cavitation ton* generated by ultraaonic action, PCBt will react with other chemieel* retulting in breaking carbon to carbon end eerbon to ehlorine bond*. Th* HUM proce** for detoxification of aubatanca* by utilitation of ultr**onic energy i* deecribed in U.S. Patent No 4,477,357. It eonaiat* of irradiating PCI containing materiel in the preaenee of an alkaline materiel with ultreeonic energy of aufficiant inteneity to deatroy the PCB*. The alkaline aubetence* era added to remove any chlorine or chloride ion* and permit the reaction to go to completion. ' A aerie* of experiment* ere daacribed demon*treting the feaaibility of the proce**. On* aerie* aubjected * tran*former oil containing 93 ppm of Aroclor 1343 to dif- ; ferent reaction parameter*. Aa * reeult, the PCB concentration* in th* oil were reduced to a* low ** 33 prprm. . Another aerie* of experiment* were mad* on a heavy aludge obtained from a wa*t* diapoaal ait*. Thi* aludga contained about 3.6X Aroclor 1343 and about 3.3X Aretlor 1360. After aubjaeting th* aludge to the HUM ultraaonie procaaa, . analyae* thowed that about 99X of the Aroclor 1242 and 63X of Arcolor 1360 ware deatreyed. Reaction time* of about 3 minute* were u**d. To date, th* experimental work ha* been don* uaing a commercial 330 watt ultreonic generator operating at 20 Kilohartf. Plan* have been prepared for additional work to optimle- operating condition*, evaluate flow pattern* through th* generator and taac continuoua flow ultreeonic unit*. An economic analyai* of th* proce** indiceta* that overall coat* to decontaminate liquid* are of the order of SI.30 to $2.00 per gallon, baaad on current information It ia eatin*ted that a portable ultreeonic decontamination unit can be built for between S200,00f and $430,000 capable of procaaaing a* much ** 30 gpm of contaminated fluid*. HONS 217292 4-20 THE USE OF LIQUID REAGENT FOR IN-SITU TREATMENT OF PCB'S IN CONCRETE AND OK SURFACES JOHN P. WOODTARO, P.E. ENZO M. ZORATTO, P.E. INTERNATIONAL TECHNOLOGY CORPORATION KNOXVILLE. TENNESSEE ABSTRACT This paper describes a new development In PCB concrete end other surftce decontamination through the use of e liquid treetment reagent. The reagent, developed In Europe specifically for treatment of chlorinated hydrocarbons, Is applied In a heated liquid form and allowed to either penetrate porous surfaces or coat non-porous surfaces. The technique provides a significant advantage In many Instances; for concrete It allows destruction of PCB In place without concrete removal, while on metal or other non-porous surfaces It can be used to reduce or eliminate the need for PCB disposal of decontamination residues. The technique has also been used successfully for treatment of dioxin and dlbenzofurans, and provides an Initial response tool in PCB transformer fire Incidents Involving significant levels of these compounds. INTRODUCTION PCB spill and fire cleanup projects require expertise In a variety of decontamination technologies, given the similar variety of surfaces and materials that require decontamination. While Improvements In technology have resulted In cost savings and efficiencies through.the use of recyclable cleaning solvents and tow volume cleaning techniques, decontamination of concrete continues to be one of the most difficult problems facing utilities and decontamination contractors. Traditional methods of washing or otherwise removing portions of concrete Is well documented. These methods alone can account for the most significant portion of a decontamination project cost. International Technology Corporation (IT) licensed a patented reagent process In 19B6, designed to be used In a solid or liquid form to dechlorlnate PCB. After reviewing and confirming some of the Initial field results from the European use of the reagent, IT applied for a TSCA research permit In January, 1B87 and received permission from USEPA to proceed with field scale demonstration of the technology in May. IT has completed Its first field trial of the reagent, and has plans for several additional tests In the next six months. Field research will focus on a variety of surfaces, levels of contamination, aroclor types, penetration effectiveness, and dlbenzofuran destruction. 4-:i HONS 217293 CHEMISTRY The IT reagent Is bated on phase transfer catalysis chemistry, in which one of the chemicals to be reacted Is transferred from a phase In which It is relatively unreactive to one In which it can be reacted. In the IT reagent, the reactive chemicals In the formulation are an alkali metal alkoxlde or peroxide and a polyglycol of varying molecular weight. The high molecular weight glycols are solid at room temperature, but liquids at the reaction temperature range of 60 to 90*C. The liquid reagent Is prepared by suspending the alkoxlde In the liquid polyglycol (low Molecular weight) at elevated temperature. The mixture is then heated and applied to the surface to be treated. The material remains in Intimate contact with the contaminants for days or weeks until the reaction proceeds to completion. Experimental use of ultraviolet light has also been, conducted to enhance the free radical formation association with the reaction. TEST RESULTS The liquid reagent has been applied to coenerclal surface decontamination In Europe on sever 1 projects Involving PCB, dlbenzofurans, and dioxins (Ref. 1). These field scale demonstrations have shown the liquid reagent to be an effective destruction agent In as little as one week. Because of differences In spill cleanup standards and approaches, however, these projects do not provide sufficient Information for ready technology transfer In this country. In July, 1987, IT conducted the first U.S. test of the reagent technology at a transformer fire site In Shreveport, Louisiana. Results of the Shreveport test will be available Just prior to the presentation of this paper. PERMITS Because spilling PCS liquid constitutes Illegal disposal as Interpreted by USER*, destruction of PCB In place constitutes an alternative to conventional disposal and must therefore be permitted. IT received a TSCA Research and Development permit from USEPA In May, 1987, allowing for the demonstration of the technology at several active PCB decontamination project sites. The first such demonstration was conducted In Shreveport on an emergency basis, where the state and EPA region waived notification requirements In order to proceed expeditiously with the test during normal decontamination. Attempts to permit the technology for coenerclal application will hinge on the results of tne first several field demonstrations, all scheduled this year. While the reagent Is known to be effective for surface or shallow contamination, the optimum reagent recipe and application parameters are not sufficiently known to guarantee commercial success. Any degree of technical success In the Inltiel field demonstrations could result In an application to HONS 217294 4-22 TeM for * commercial permit, although such t permit would likely be limited to tthe only specific type of successful application associated with the rdemonstration. The USEPA permitting process clearly did not anticipate the 'advent of this type of technology, therefore requiring fairly stringent USEPA testing requirements, thorough permit review, and narrowly defined permit conditions. PLANS FOR DEVELOPMENT The liquid reagent technology has several obvious applications In Industrial PCS decontamination, including the following: . 1. Treatment of contaminated non-porous surfaces, such as metal cabinets and machinery, 2. Treatment of porous surfaces such as concrete and wood. 3. Initial response treatment of furan/dloxln contamination following PCB fire Incidents. The technology has been proven effective In situations like 1 and 3. Successful field confirmation of the European results will result In commercialization of a viable emergency response technology for PCB spills and fires, as well as a means of decontaminating industrial equipment contacted with PCB during years of use. Successful use In decontaminating concrete and wood, and the biggest problem, would perhaps provide the most dramatic Improvement In technology due to the primitive nature and high cost of technologies currently available. ACKNOWLEDGMENTS The authors would like to acknowledge the active participation and support In IT Technology Development by Or. Jurgen Exner, Vice President, and Mr. Robert Fox, Director. The authors would also like to acknowledge the assistance of EPA management and staff, particularly Mr. Edward Anna,, for thalr patience and cooperation In the development and review of tha permit applications associated with this novel technology. REFERENCES 1. Noblla, G., W. Tumlattl, and P. Tundo, May 1986, Mn-S1tu Oacontamination and Chemical Degradation of PCOFs and PCDOs Coming from Thermal Oxidation of PCBs," presented at tha American Chemical Society Division of Environmental Chemistry Symposium, New York. 4-23 HONS 217295 plasma arc obstruction op HAZARDOUS HASTES N. F. Joseph Wtstlnghoust PUsm* System Cahada Int. Ctntdt T. G. Dirton Pyrolysis Systems Inc., Ctnedt S. C. Vorndrin ind W. H. Retd Wtstlnghoust Environment*! Technology Division Midi son, Pennsylvtnl* ABSTRACT The Wtstlnghoust PIisim Systems PYROPLASMA wtste destruction unit dtstroys liquid orgtnlc materials by breaking the molecular structure of chemical wastes and changing hazardous wastes Into nonhazardous, potentially useful substantes. The highly efficient mobile destruction process Is based upon the concept of pyrolyzlng waste molecules using a thermal plasma field. DESCRIPTION OF TECHNOLOGY The Pyroplasma process Is based on the concept of pyrolyzlng waste molecules using a thermal plasma field. The heart of the destruction tystem It a plasma torch which was designed by Westlnghouse Electric Corporation and Pyrolysis Systems Inc. Similar torches have been used commercially for years In practical applications ranging from blast furnaces and boiler Ignition to the testing of atmospheric reentry heat shields by NASA and development of Mach 6 aircraft engines. The Pyroplasma unit Is entirely contained In a 48-foot tractor trailer and requires only power, water, and sanitary sewer discharge lines. The power requirements are 4160 volts, 3-phase. Oomestlc water supply and access to a sewage treatment plant (STP) are the only addition external requirements other than a waste source. Only a matter of a few days are required for complete system mobilization to the point of actual operation. There are currently two commercial site units available*, a 1-gallon per minute (6PH) unit operating at 350 kw and a 3 6PM (1 ton/hour) unit operating at 7S0 kW. Mobile units may be designed with throughout capacities as high as 6 6PM and still be contained In a single trailer. While current emphasis has been on the design of mobile units for reasons of lower environmental risk and greater public acceptance, the construction of fixed facilities is possible in the event that higher throughput capacities are required. 4-24 HONS 217296 Lib ns fr'ilalnary'f1l4 testing of the Pyroplesma mobile unit wet completed In eerly *1B8B a* part of the contract between Pyrolysis Systems and New York state, all tests were observed by both federal and state authorities from the Unite States, it well as federal, provincial and local Canadian authorities. Chemical analyses of both gas and water effluent streams were performed externally by lenon Environmental (Burlington, Ontario) and stack testing was conducted by gga Corporation of the li-S. and 1HET Incorporated of Canada. Htchanlcal operation of the mobile plasma pyrolysis stream was first verified by processing a nonchlorlnated blend of Htk/HeOH (1:1 volume). Following this, thrae, one-hour carbon tetrachloride runs were conducted to demonstrate 1) the destruction efficiency of the plasma process with a difficult to destroy chlorlnited compound. 11) the stability of the system upon exposure to high concentrations of chlorine, and 111) the effectiveness of the scrubber for ncl removal. The carbon tetrachloride was blended with Hk/Me0H/H20 and fed at a rate of one kilogram of CCI4 per minute. Destruction efficiencies were greater than gB.BBBBS* for all three runs based on measured residuals In all effluent streams. Stack emissions for CCI4 were analytically nondetectable. After completion of the CCI4 runs, seven tests were performed using a blend of Askarel (Aroclors ITS* and 1260 In trichlorbenzene) in MEK/MeOH to determine the PCI dastruction capabilities of the process. Three one-hour, one two-hour and three five-hour tests gave destruction removal efficiencies consistently greeter than ll.tmn. technology advantages The Westlnghouse Plasma Systems mobile Pyroplasma unit provides unique advantages over other conventional technologies. The most Important of these Is the very low emissions resulting from the high destruction efficiencies combined with the low PIC formation. The technology Itself is pyrolytic in nature and does not require tha large volumes of air needed for combustion. The lower gas volumes and thus lower quenching and scrubbing water volumes land themselves to a small, compact process which Is easily made mobile. 4-25 WINS 217297 CATALYTIC HYDROGENATION OF POLYCHLORINATED HYOROCARBONS K. J. Youtsey and D. R. Hedden UOP Inc. 25 East Algonquin Road Dot Plaints. Illinois '60017 ABSTRACT Tht UOP Decontamination process employs catalytic hydrogenation technology which converts the chlorinated compounds.producing hydrogen chloride and a petrol ei#i derivative. Typically, the petroleum derivative is a reusable product of such value that It offsets the costs to treat the waste material. Depending on the source of the waste oil, its economic value can be recovered by using It as a source of energy (fuel oil); recycling It as a refined Intermediate (lube base stock); or, upgrading It as a specialty product (chlorinated benzene to cyclohexane). As well as an economic means of converting contaminated waste oils Into reusable products, e properly designed catalytic hydrogenation process unit eliminates the possibility of releasing products of Incomplete conversion Into the environment. Process units are designed and constructed to allow certification of products before they are released from the treatment facility. PROCESS ADVANTAGES Catalytic hydrogenation as practiced In the UOP Decontamination process Is a safe and efficient means of treating PCB-contamlnated oils when designed and operated Sursuant to the standards of the petroleum refining and petrochemical Industries, aslc hydroprocessing technology Is found In most modern day refineries and petrochemical plants, and Is used to reduce the contaminant levels In virgin oils of such heteroatoms is sulfur, nitrogen, oxygen and metal complexes. Most Importantly, the UOP Decontamination process offers a method of treatment for a wide range of hazardous materials converting chemical waste streams Into hydrocarbon products that have value as petrochemical charge stocks, solvents, lubricants and fuels. Based on pilot plant runs employing PCB-contamlnated waste oils, UOP has demonstrated that undesirable side reactions Involving the hydrocarbon matrix of the waste oil can be minimized. The formation of partially oxidized materials such as chlorinated dioxins and furans which can be formed by oxidative processes such as Incineration Is chemically Impossible with the hydrogen reducing environment of the process (1,2]. Further, when compared with other chemical reduction processes, such as those based on sodium technology, the final product from catalytic hydrogenation Is a more valuable oil since It Is not contaminated with tha sludge-like material formed from polymerization raactlons during reduction by metallic sodium. 4-26 HONS 217298 jfoCESS DESCRIPTION ft-unit process design Is based on the waste oil composition,' the and product specification, the regulator/ requirements, and the desired operational flexibility that any constraints on utilizing the technology ara economic, not technical. In nature, x Along with catalytic hydrogenation, the UOP Decontaminationprocess utilizes unit operations such as phase separation, extraction, adsorption,evaporation and distillation for pre-treatment of the waste oil to remove solids, metal contaminants, or catalyst poisons and post-treatment of the products to meet requisite effluent specifications. In the UOP hydroprocessing scheme, after pre-treatment, the waste oil Is heated and combined with a hydrogen-rich gas stream before entering the reactor catalyst bed, refer to Figure 1. The UOP catalysts utilized by the process react hydrogen with the waste oil halogen contaminants at temperatures and pressures exemplary of those found In the petroleum refining industry: e Operating Pressures, psie 200 - 1000 e Operating Temperatures, F ISO - 700 The reactor effluent is cooled and neutralized with an aqueous solution containing a basic compound. UOP has engineered a unique system to ensure intimate contacting of the reactor effluent and aqueous solution In order to cool, neutralize and purify the reaction products. The technique along with proper selection of metallurgy minimizes the corrosivity of the product streams caused by the presence of HC1. Within the same unique system, the neutralized reactor effluent Is next separated Into three phases. A hydrogen gas stream Is recycled to the reactor section to provide a large excess of hydrogen In the catalyst reaction zone. Hydrogen gas Is added during the operation to balance Its consumption. An aqueous fraction leaves the plant as a solution of non-hazardous salts and the decontaminated organic fraction Is recovered as final product. The overall objective of waste minimization Is applied to each specific design case. PILOT PLANT TEST RESULTS PC8 Waste Streams Pilot plant test results support the application of the UOP Decontamination process to a broad class of hazardous waste types, such as transformer oils, still bottoms, waste solvents, cutting oils and used lubricating oils. PCBs have been chosen as the principal focus to Illustrate the capabilities of this treatment technology. The following waste streams were continuously processed to demonstrate the feasibility of the technology In this service: e Diala AX transformer oil contaminated with MOO ppm PCBs as Aroclor 1016. e Waste lubrication oil obtained from a contaminated oil recycling site. The material was contaminated with 270 ppm of Aroclor 1260 and 750 ppm of lead. 4-27 HONS 217299 In both cists, tht waste oils were processed without dilution In pilot plant designed to evaluate catalytic activity, stability and selectivity, demonstration data were obtained using a recycle gas flow configuration to eliminate scate-uo assumptions. p AoilrUctl Both the product liquid and gas streams were subjected to a variety of detailed analyses to quantify pollutant conversion, hydrogen consumption and hydrocarbon product quality. Reduction In metals, ash, sulfur and other undesirable compounds was measured using a combination of ASTM, HOP and USEPA derived last methods Monitoring the waste oil's PCB concentration was by a gas chromatogaphy/electron capture detection method (GC/ECO)[3]. The objective of catalytic hydrogenation Is to remove the chlorine atoms from the PCB molecule. Thus, the typical Aroclor pattern used to detect the PCB level In the waste oil feed Is eliminated from the final product. When measuring the final product PCB content, the GC/ECO detector's response to other constituents tends to Interfere with low levels of PCBs. Therefore, measurement of the product oil's PCB concentration was with either a HP S9B7 GC/HS system or a HP 5890 GC equipped with a HP 5970 HSO detector. The final product PCB concentration was further confirmed by* an outside laboratory, Battelie Laboratories. P Results Summary High conversion levels of contaminants were achelved for the waste oils processed In the pilot plant. In addition to reducing product PCB concentrations to nondetectable levels, other contaminants, such as lead and sulfur were also converted, further Improving the quality of the final product. Table I Is provided as a comparative summary of the waste oils and the corresponding final product. Tnnifocatr (HI. The PCB-contaminated transformer oil was processed for approximately 30 days under an accelerated stablllty/actlvlty test program. A final product PCB content of less than 2 pm* was the operating basis throughout the pilot pUnt run. As the analytical results show In Table I, the level of PCBs In the final product oil was reduced to the limits of detection (-0.5 ppm) thus demonstrating a complete conversion level for PCBs greater than 99.9*. Over the same period, the concentrqtlon of sulfur heteroatoms In the transformer oil was reduced reflecting a sulfur removal of 97.$X. Htitt LubrlttUm Oil. The waste lubricating oil treatability was examined over an 8-day test period. Catalytic hydrogenation of the waste oil produced a final material which was measured to contain less than 2 ppm of PCBs at each level of chlorination (per Battelle). The oil's lead content was reduced from 750 ppm to less than 10 ppm. Desulfurization of the oil was 73%. Hydroprocessing the waste oil retained tha excellent viscosity characteristics of the starting material as evidenced by comparing the Viscosity Index of the raw oil with the final product. Thus, as illustrated In Table 1. once the undesirable contaminants were removed, tha oil became an axcellent candidate for reuse as a lube base stock. . HONS 217300 4-2B ; CftcESS ECONOMICS the discussion here his focused upon converting PCB-contemlnatad wist* oils Into reusable oils, wide ringe of wiste streams can be treated In a similar fashion. OOP's current pilot plant experience includes trichloroethylenecontaminated still bottoms from a solvent recycling operation, highly chlorinated Waste oils (circa 60 wt-% chlorine), and both chlorinated and non-chlorinated waste solvents. a pro forma economics for the UOP Decontamination process have been prepared assuming tnnual on stream factors of 70*, although 90% or greater Is readily echelvable. The payback calculations summarized in Table 2 are based on a plant size of 10,000 gpd ind conservative assumptions with respect to capital costs and operating costs. The positive contributions utilized In determining the simple paybacks arise from avoidance of external disposal costs and from final product credits; both of which were based on current competitive values In the United States. In all of the waste oil cases reviewed, the payback on the Installation of a new UOP Decontamination process was favorable; less than 2 years in all Cases. In certain applications, such as treating Askarels or highly chlorinated waste oils, the paybacks are less than 1 year. As might be expected, the rapid paybacks are directly attributable to the ever Increasing costs to dispose of waste ollCoff site. r. COMMERCIAL STATUS State-of-the-art processing technologies coupled with over two dozen proprietary hydrogenation catalysts provide a firm basis for offering the UOP Decontamination process to the waste management industry. The highly qualified engineering staff at UOP make possible the custom design and supply of treatment plants to satisfy a wide variety of environmental and Industrial needs. Joining the knowledge to design, engineer and construct treatment facilities with UOP plant start-up, operator training and troubleshooting activities provides waste oil generators a fully supported single source option to finding solutions to today's waste treatment problems. REFERENCES 011e, X., Vermeulen, E. E-, and Hutzlnger, 0., "Chlorodibenzo-p-dloxins and Chlorodlbenzofurens Are Trace Components of Fly Ash and Flue Gas of Some Municipal Incinerators in the Netherlands", Cheriosohere. , 7, 4SS (1977).. Weeraslnghe, N. C. A., Meehan, J. L., Cross, M. L., and Herless, R. L.. "The Analysis of Tetrachlorodlbenzo-p-dloxlns and Tetrachlorodlbenzofurans In ChMlcal Waste and In the Emission from Its Combustion." Chlorinated Dioxins and D1benzofurans_lJLthe Total Environment. II. ed. Lawrence H. Xelth, et al., Butterworth Publishers, Boston, 1985, p. *25. United States Environmental Protection Agency, "The Determination of Polychlorinated Biphenyls In Transformer Fluid and Waste Oils", Method EPA600/4-81-045. 4-29 HONS 217301 FIGURE 1 UOP DECONTAMINATION HYDROGENATION SECTION NIUTAAUZma COMPOUNDS HONS 2i?32 4-30 Table 1 Pilot Plant Waste Oil and final Product Analysts PCB Concentration, ppm Aroclor Type Specific Gravity Distillation Range, C 18P SOX Over F8P Residue, volX Sulfur, wt-ppm Nitrogen, wt-ppm Metals, wt-ppm Lead Zinc Vanadium Nickel Viscosity Index Tran*former Oil Waste All Product 1400 1016 0.886 NO 0.878 zzz ZZO 327 3Z9 szz 493 700 17 1 --- -- - - Waste Lube fiU Mult. Oil Ecad^l 270 1260 0.887 <2 0.67S 163 416 48S ZO 4900 600 1ZZ 40S 545 S // 1300 2S0 750 5.5 Z85 1.7 Z. 9 <0.1 3.8 2.6 1Z8 126 Table Z Payback Feonmales of IMP PecontamlnatlOEL..Unit Mult bat Uasta lube Contaminated with PCBs Askere1 Chlorinated Still Bottoms Sp*nt Halogenated Solvent PiyhickJ-Ynl 1-8 <1< 1-8 <1-0 4-31 HONS 2l7303 MOMS 217304 PART 5: HEALTH EFFECTS AND RISK ASSESSMENT HONS 217305 PC* TRANSFORMER. FIRES: THE RISK IN NUCLEAR POWER PUNTS Kirk Blackmon . President - Bleckmon-Moorlng Steieatlc Technologies, Inc. On* Summit Av*nu* Suit* 202 Fort North, T*x*a 16102 On* of th* mor* valuable *Mt* *ny utility company po***a* 1* it* nuclear power plant. For that r***on, if on* of th**e plant* la out of commission for *ny period of tlm* du* to PCB fir* It can b* very costly. Th* average down tlm* eo*t for a nuclear powar plant la between 2 to 4 million dollar* * week, per unit end many plant* have multiple unit*. It la eatiaated that one-half of the preaent nuclear power plant* operate with PCB filled treneformer equipment. A atudy performed In 1986 for Nuclear Mutual Limited and Nuclear Electric Inaurenc* Limited addraaaed th* rlek potential for PCB flrea at nuclear generating fecllltle*. Tha atudy w*a performed by th* Netlonel Economic Reeearch Aaaoclatlor, Inc.. In conjunction with Protection Conaultanta and Clayton Environmental Contultertt. Tha report Identified condltlono where PCB filled tranaformera were located In clot* proximity to major oil hatarda beneath turbine generator*, Beceue* of th* large quantities of lubricating oil required In thee* facilities, a fir* In a power plent la not uncommon. A classic example of thl* was a fir* that occurred under th* turblna at tha 30 megawatt Pickway Generating Plant In Columbue, Ohio on June 23, 1951, Fir* damag* wae extentlv* and Included coll*!'** of th* plant roof. Of course, there was no fir* protection *y*tam at th* plant. Another Incident occurred approximately 15 year* ago when * flra at th* Brown* Ferry Nuclear Power Plant caught th* attention of the utility indue try. Apparently an employe* checking for leak* In **al* between the containment building and th* auxiliary building accidentally set fir* co eon* lneulatlng material. Th* fir* epTead under th* control room and severely damaged cable run* to th* point where the plant wa* shut down for an extended period of time, Thl* Incident 1* whet prompted th* NRC to require certain flra protection In all nuclear power plant*. Probability eetlmatea relating to the frequency of thl* type incident can never be accuratet however. It 1* possible to establish fairly accurate estimate* of potential clean-up coeta and down tlm*. In an attempt to obtain better estimate* of clean-up cost* In * nuclear power plant undar raasenable loa* scenario*, a study wa* conmleeloned, Thl* etudy wa* a joint venture batmen Blackmon-Moorlng Steeatatlc Technologies, Inc,, (BMS-TECH) and M6M Protactloo Consultant* U), This joint etudy was conducted *t a typical prseeurlied water reactor plant consisting of two 1000 megawatt unit*. Three specific scenarios were selected and analysed for thl* typlcel power plent, Thsea scenario* ware: 1) an electrical failure of a transformer in an isolated switch gear room; 2) a treneformer exposed to a 55 gallon transient combustion oil fir* In th* auxiliary building; and 3) * PCB treneformer Involved In a major turbine Luba flra in th* turblna building. . In th* flret acenerlo, it wa* assumed that th* switch gear room could b* completely Isolated and that contaminant* from th* fir* would be contained within that room. 6-1 MOMS 2l7306 Damage waa estimated to bt at approximately $500,000. Although thia laolatad witch gear room w ued only in ca* of emergency, th NRC clearly stipulated that thay would not allow tht plant to oparata unlttt tha equipment waa in workin condition. Bacauaa of this, It waa anticipated that tht plant would bt ahut down* during tha antlra 10 waakt required for tha dtcontaalnatlon and cl*n-up. How,v,r bacauaa thla waa a two unit nuclaer plant It wtt aaaunad that only ona of tha unite would ba affactad. In tha aacond acanarlo a 55 gallon drua of oil waa baing tranaportad through an rat of tha auxiliary building whan it accidentally aplllad and tha oil Ignited next to a tranaforaar containing PCB'a. Bacauaa of tha open conatructlon of the auxiliary building (batwaan floore and within each floor), toot fallout could ba axpactad to apraad throughout thla etructura. 'The coat for tha claan-up and decontamination effort wee aatlmatad at approximately 79 million dollar*. It waa otlaiatad tha entire plant would ba ahut down. Including both raectore for period of approximately 8 month* In tha final acanarlo a PCB tranaforaar waa engulfed in flamaa cauaad by an accidental turbine lube oil ralaeae. Thla time the tranaforaar wee located In a. open area of tha turbine building beneath tha turbine operating floor. Again bacauaa of tha vaat opanlnaaa of tha turbine building, and the poaltlva air flop from thla arte Into tha auxiliary building, It waa daaaad highly probable that the turbine building at wall tha auxiliary building would ba contaminated. Claan-up and decontamination coat* for tha third ecanarlo war* aatlmatad at approximately 98 million dollar*. Both reactor* war* axpactad to ba ahut down for tha approximate 9 nontha tha claan-up operation would require. In all of tha acanarlo* no additional damage waa aaaunad to have occurred to equipment axpoaed to the fire or the combuetlon by-product*. Alao, no aatlmata of damage to tha tranaforaar waa Included. Tha only regulatory delay* anticipated in tha clean-up eatlmatea were approximately 2 week* to negotiate with tha health official* concerning tha acceptable level of decontamination nacaaaary. Significant regulatory daleye cauaad by tha NEC, EPA, 0SHA, ate., could extend tha outage significantly bayond the eatlmatea Included In thla report. Another factor that muat ba included at a coat but waa not In thla study would ba the purchase of replacement electricity during tha time the plant waa ehut down. A* etatad earlier the average down time coat for e unit le eetlmatad to ba between 2 and 4 million dollar* e week. In general, a clean-up at a nuclear power plant would be more difficult than a claan-up In an ordinary office building contaminated at a raault of a PCB flra. Soma of the raaeona era a* follow*: 1. Both cleaning and handling of tha raaldua fro* PCB'a, related toxic compound*, and waste water would ba complicated by the preaanca of radioactive material. Cleaning would require additional worker protection which would axcand tha cleanup time. 2. Watt* handling and disposal could be more complicated and costly because both toxic chealcele and radioactive matarlale could ba Involved. 3. Negative air praaaura, typically found In tha containment building, daalgnad to keep radioactive materiel from spreading to the auxiliary and turbine building* would provide a vehicle to apraad any tranaforaar fir* contaminant* from tha turbine building to tha auxiliary building. 4. An additional regulatory authority, the NBC, would heve to ba added to the group of decision maker* whan It came to formulating claan-up criteria and operating procedure*. 5. Health end safety program* would not only heve to taka into consideration tha occupational physician' and Industrial hygalnlat'anormal concern*, but also would Involve input from health phyelclata to deal with possible problem* of 5-2 HONS 217307 radioactivity. . fc. Plant aacurlty which la typically exceptionally atrlntant in a nuclear g* generating facility, could alow the claan-up effort. [in performing decontamination at a nuclear power plant many of the procaduraa will ;^a vary olmilar to thoaa uaad In othar PCS fir**, while othare will ha quite [different * Soma tht dlffarancaa art aa follow*: Air filtration Syatame uaad to evacuate air from contaminated araaa muet not l. only bo able to remove the chemical contaminanta but will aleo have to raawva [ radioactive contaclnanta. It la probable that the air filtration ayatam will r advareely affect the plant*a operating radioactive air contamination controla. 1. All waata water genareted from the claan-up activity would flrat have to paaa ' through a radioactive wteta wetar treatment facility and then through a PCS waate water eye tarn. However, the capeclty of moat planta emitting rad-weata treatment ayatema appeare aufflclent to handle the volume of liquid waata that would be generated by auch a clean-up operation. ' Thera ware aleo eeveral other factor* that appear to affect coat and down time; 1. It 1* imperative that corroelon control proceduree be Implemented immediately after axtlngulahlng the fire. The corroalvt fallout gonoratod from a PCE fire ' pcould cauem axtonalvo damage to unpointed metal surface*. If thoaa aurfaca* war* loft untroated the coat and down tlma would dramatically Incraaaa btcauat v equipment could ba damaged beyond repair and therefore need to bo raplocod. .2 It worn dlocovorad, during tha coura* of thla atudy that If certain araaa of tho plant ware laolatad from oach other demege could bo mlnlmlted. Some ltoma to bo conoldorod era e* followsi A. The design of HVAC ayatam* through nogatlvo praaoura, smoko triggered axhauat systems, otc. B. Th* sealing of all oponlnga botwaan araaa. C. The encasement of PCB transformer* In vault* with separate ventilation ayatam*. 3. The degree of cloanlnooa that a plant normally maintain* with raapact to radiation contamination con alneffect cleen-up costs and down time. If on area 1* contaminated with PCB end PCB by-producta at wall aa radioactive contamination, tho cloan-up lo further complicated, The worker normally la able to work for S houro in a PCB/PCDD/FCDF environment wearing proper protoctlvo goer but If th* eras le additionally contaminated with radioactive material It la pooalblo that tho work day could bo reduced to two hour* or lea*, 4. Thla typa of looa generate* complex waata*, making dlapoaal more difficult, 5. Contingency plana covering the*# types of ovonto should be Implemented prior to the oeeurrance of an accident. How well an organisation 1* prepared fot auch a catastrophic event can dramatically effect coat and down time. Tho laauo of frequency of transformer failure* in a nuclear power plant va* also ddraaaad In thl* atudy. It can be axpactad that th* rata of thaaa Incident* may b* lower than In m cotmtrclal building due to bettor maintenance, surveillance. Inner locks and operator action, otc. For thee* reason* It 1* estimated that the annual rata of 6 x 10-5 per tran*former per year ehould he aaeumed. (2) These feature* ehould raduca th* likelihood of electrical or *chantcal failure*. However, a major portion of th* PCB riek le derived from trnneformore balng exposed to external flraa. Bacauea of tho fact that thaea transformers are normally locatad In opan areas of tha plant* and/or exposed to potentially saver* flraa auch aa turbine lubricating fir**. It la axpactad that contamination would ba wlda spread 5-3 HONS 217306 In the plant. Baaed on tho reaulta of the BHS TECH/HIM Protection Conaultanta otudy, tht Insurance ctrrltrt for thle lnduttry have implemented an adjustment In thalr rata ttructurtt for nucltar planta that hava PCB equipment, it ahould alao ba notad that moat nuclear power planta art aalf Inaurad for the flrat 6 month* of down tima. Given the raaaarch that haa bean completed, and considering currant technique* in decontamination and political aa wall aa environmental eoapllcationa that axlat In the United State*. the rlak of a PCB fire In a nuclear power plant la not only aignifleant but haa cataatrophle ramification*. Thia conclusion la baaad more on tha aavarlty of auch a avant rathar than lta frequency.1 2 1, KIM Protection Consultants art afflllatad with Harsh and HcLsnnan, Coapanlaa 2. PCB Transformer* - Tha Rlak In Huclaar Powar Planta. praparad by Jamaa H. Connelly, P.1., - HIM Protection Consultant*! November H, 19BB 5-4 HONS 217309 HONS 217310 RISK ANALYSIS OF PCS SPILL CLEANUP OPTIONS Donald S. Wilton Kurt D. Runke David Cohan Katharlno Kahlt Daetiton Foeut Incorporated 4(14 El Camino Raal LotAltot, CA (4022 ABSTRACT What raaidual eoneantration aftar a PCB aplU elaanup It low enough to antura public aafctyl How quickly ahould tha tplll ba claanad upt Tha faitatt cleanup to tha lowaat lavala will lead to the loweat ritk, but at extraordinary, and possibly unnecettary, cotta. The objective of thlt ritk analytic wai to develop a batter understanding of alternative tplll cleanup options by Integrating Information on potential incidenta, environmental fate, human expoture and deposition, and human health affectt. The atudy analyaed potential human health risks from PCB capedtoP tpllla for each of teveral tplll cleanup option. Tha elaanup options differ in the apeed of the cleanup procets and the final level of residual oonoentratton achieved in tha elaanup. The elaanup options were analysed using the EPRI Contaminated Sites Risk Management System, SITES. SITES provided e comprehensive framework for comparing cleanup options in terms of the health and environmental effects and total costs. This paper will diaeuss the SITES methodology, and the data, assumptions, results, and conclusions of the analysis. THE SITES MODEL The EPRI SITES model It a decision support tool to help utility personnel manage contaminated, or potentially contaminated, sites. SITES can help rank potentially contaminated sitat, decide on the best site Investigation strategy, and, as is tha case In this analysis, ohoote the appropriate oleanup or remedial action strategy. Its flexible structure allows analysis of risks due to a range of substances including PCBS, manufactured gas plant wastes, coal-combustion by-products, and petroleum products. The SITES model is an interactive, menu-based program which facilitates and guides the user through all steps of the analyses. SITES provides a framework for comparing alternative cleanup strategies in terms of both hsalth and environmental effects and total oosts. The model tracks the contamination levels over time and computes exposure and effects for several different ohemleals, locations, madia, site investigation and remedial aotions options. It can also evaluate other costs such as tines, legal liabilities, or future oleanup costs. A key feature of SITES Is that it can explicitly represent uncertainty In several important factors. Figure 1 shows a shorthand representation of the decision tree structure of the SITES modeL In the full decision tree, each successive node Is connected to every endpoint of the previous node. The left-most square node represents the decision to select one of the cleanup strategies, or no cleanup at all. The circle nodes represent uncertainties in cleanup effectiveness, actual contamination level, exposure, and health impacts. Using this decision tree struoture, SITES can examine the sensitivity of the total risk associated with e site to the extent and nature of the contamination, the possibility of human exposure and environmental damage, the costs of testing and cleanup, and the site and likelihood of ftnee and financial (labilities. This permits the user to focus on the most Important unoertaln factors tor each site. SITES allows the user to specify any single path through the decision tree to examine the detailed doses and effects based on that specific set of assumptions, or perform a tree 5-5 HONS 217311 rollback to Mamin* the expected impact* and cost* of all the scenarios. The SITES model report* the do** that *tch receptor receive* by chemical and exposure pathway, the health Impact* resulting from the** expoture*. and the total coat* aaaoclated with each cleanup strategy. THE PCB SPILL ANALYSIS The analyst* wat originally conducted In 1984 for the Utility Solid Waate Activities Group *nd formed the baalt for their comment* on EPA't propoaed tplll cleanup policies*. The analytic ha* tine* been updated to reflect current underttandlnf of trantport and fate modeling, expoture totnarlo*, and toxicological information. Table 1 (how* the four alternative cleanup ttretegle* following the tplll of a pole-mounted PCB capacitor examined In the analytia. For all cleanup atrategiea, It wat assumed that the aplll alte wat reatored to It* original condition on the 30ih day after cleanup. , The major data u**d in the SITES model repreaent (I) trantport and fate (II) expoture parameter*, and (ill) health Impact*. Concentration profile* and the Impact* of the cleanup itrateglet were modeled uiing EPRI's PCB On-Sit* Spill Model (POSSM)7. Figure 2 chow* *n example concentration profile over time aaaumlng a U day, SO ppm cleanup. The expoaure parameters were bued on reasonable and accepted behavioral assumption* for adult* and. children In urban and suburban setting*. For example, It was ssiumed that suburban adults coultf< have fairly frequent toll contact at the sit* after cleanup (but before reclamation), with 174 cmvday of dermal contact on 100 days/year, with 1% absorption through the ckln. I The health Impact data for PCBs was originally estimated from an EPA Office of Toxic Substances report, and was subsequently reviewed and updated by the Washington Occupational Health Associates4. RESULTS AND CONCLUSIONS The SITES model was used to first estimate the total doses of PCBs for the exposed individuals. Figure S shows the dose result*i the population group of Urban Children receive the highest dotes. The dominant exposure pathway Is generally Inhalation of volatilised PCBs. The lifetime Individuals risk of living near a PCB capacitor Is estimated by multiplying the dotes by a dose-response function, and multiplying this result by the probability of a tplll Incident occurring. Figure 4 shows the calculated lifetime Individual risks. The conclusions drawn from this analysis of the health Impact* resulting from PCB capscitor spills, given the data and assumptions used, are* Lifetime risks faced by all potentially exposed Individuals are small -- last than 10I when no cleanup is performed and lets than 10*1D for all cleanup options considered. 1. Hie Utility Solid Waste Activities Group. Proposed Soil! Cleanup Poller and Supporting Studies. October u, 1014. 2. The Utility Solid Waste Activities Group. Proposed Solti Cleanup Policy and Supporting Studies. October IS, 1914. 3. U. S. Environmental Protection Agency. Carclnosenlc Risk Assessments of Polychlorinated Biphenyls (PCBs). November 14, 1913. 4. Washington Occupational Health Associates, Inc. Review of Health Effect* Document* Relevant to the EPA Proposed Rule on the Use of ?CBs In Electrical Transformers. December S, lil4. ` S-6 MOMS 217312  Increasing the (peed of cleanup produce* t (reeter reduction in potential health effect* than doe* reducing the residual concentration, Remitting eooe** to spill site greatly reduce* overall exposure. Inhalation is generally the dominant exposure pathway. Figure 1. The SITES Model Decision Tree Dtp* Altai HpM Iwctau* Figure 3. Soil Concentrations Assuming 14 dsy, SO ppm Cisenup UltaiAMi Ht Oiwp I Dip pfm M Dnpe X ppm l iWf ftaj Affegi IpHl lacWriM w Oeyi ** Figure J, Total Dose of PCBt for Exposed Indlviduel* 5-7 HONS 217313 Individual UsUroa Risk Urban Children Urban Adult* Suburban Children Suburban Attain I Dtiy .VI pfrai IHyt Ailcr Spill Incident Flfur* 4. Llfatlmt Individual Risk l< Day. VI |tpm Tabla 1 PCB SPILL CLEANUP STRATEGIES SiS&CC TlrnttoCtoanup Rtsldual PCB Laval* SoU (ppm) AiWmlt/Conflrat# tuf/100 onr) I1 1 11 t 14 1 10 s1 SI 101 t 4 14 SO 101 5-8 HOMS 217314 POSSH: A TOOL FOR RISK ASSESSMENT OF PCS SPILLS SITES Jim Llngle Wisconsin Electric Power Co. P. 0. Box 2046 Milwaukee. Wisconsin 53201 INTRODUCTION POSSM, the PCB On-Site Spill Model, was developed for the Electric Power Research Institute by 8rown and 8outwe11 In order to assist electric utility , personnel In understanding and evaluating the risks associated with spills of.* oil from electrical equipment (1). Spills of PC8 or Askarel-type fluids such*' as from PC8 capacitors, as well as low concentration PCB contaminated mlnerar oil from distribution transformers can be evaluated using POSSM. The model utilizes spill Information such ss the volume of fluid lost, area of the spill, soil type, cleanup actions taken, soil concentrations, meteorological condi tions, and other data In order to calculate the fate of the PCBs over time. POSSM was used to conduct a human health risk assessment of two transformer oil spills and two PCB capacitor spills which occurred over the last three years In the Wisconsin Electric system. Site-specific data were used as POSSM Input In order to determine the fate of the PC8s In the soil, air, and rainfall runoff. Initial PCB loadings to the soil and vegetation were calculated based on the volume and concentration of PC8s spilled. PCB soli concentrations measured after site cleanup were used as Input data to the model for the time period following cleanup. Airborne concentrations of PCBs downwind of the spill site were calculated using the PTD1S gausslan dispersion model based on dally volatilization rates from the soil, vegetation, and solid surfaces at the site. Exposure pathways considered included Inhalation for the substation spills; and inhalation, dermal absorption of soli, and Ingestion of soil for the residential transformer oil spill cases. Exposure factors and chemical transfer rates are generally consistent with those used In the EPA PCB Spill Cleanup Policy. SPILL SCENARIOS Two 28 kVA distribution transformer oil spills which occurred In residential areas were used as Input to POSSM. Specific details are provided on Table l. A statistically based hexagonal sampling grid was usad to charactarlza the soil concentrations following claanup of both spills (21. Results of the soil sampling are shown on Figure 1. Both residential spill areas were grass covered. The Pewaukee soil consisted of a loamy soil whereas the Cudahy site contained a slit-loam soil. Both PCB capacitor spills occurred in substations. Although several residences are nearby, the substations are considered as restrlctad access areas since each substation Is enclosed by a secure fence and a second fence surrounds each 5-9 MOMS 217315 capacitor bank. A six Inch layer of crushed stone overlaid a silt-loam soli base at each substation, inhalation intake by nearby residents was based on a breathing rate of 20 cubic meter/day for an exposure period of 365 days a year for four years. A IS percent wtnd direction frequency factor was used to account for the time the wind blows toward the house, ho adjustment was made for Indoor vs. outdoor concentration differences. PCBs were assumed to be absorbed at a 50 percent rate in the lungs. Lifetime health risks were based on a 70-year lifespan for a 70 kg adult. A PCB carcinogenic potency of 4.34 mg/kg/day was used based on an EPA health effects report for PCBs (3). Dermal contact by children ws assumed based on a 1000. cm2 skin area and a dally soil deposition of 1 mg/cnr/day. Soil concentrations were averaged for 12 cm of the soil profile. The exposure period was estimated at 120 days/year for six years. A site access frequency of 10 percent was assumed based on the probability that a child would be In the spill area. (The Cudahy spill area represented 5 percent of the accessible land for the residential property.) Ingestion wes based on an average soil concentration In the 12 cm soil profile over a four-year period. Exposure frequency was estimated at 120 days/year for six years with a site access frequency of 10 percent as explained above. Soil Ingestion wes estimated at 0.6 grams/day with an absorption rate of 30 percent. RESULTS AND OISCUSSION The fate of the PCBs was determined by running POSSM for a four-year period for the residential spills and for a one-year period for the substation sites. Nearly all of the PCS was removed by cleanup activities, although a small amount was volatilized and an even smaller amount remained In the soli site. Specific data are shown on Table 2. Since none of the PCB migrated more than 6 cm In the soil, groundwater was not affected. Health risks calculated Indicate that of the four spill scenarios considered, none pose e significant health risk (see Table 3). The Waterford substation spill produced the highest numerical risk with a lifetime risk of 1 x 10 for Inhalation. The Waukesha substation produced a health risk from Inhalation of 3 x 10 . These data suggest that PCB spills In substations do not pose an unreasonable risk to human health, even when residences are nearby and the soil concentrations are relatively high (the Waterford substation soil contained an average of 20 ppm and a maximum of 150 ppm prior to the second cleanup). Perhaps the residential cleanup standard (10 ppm) now required by EPA for substations located within 32B feet of a residential area Is overly restrictive. The transformer oil spills also posed no significant health risk to nearby residents, even though exposure by dermal contact and Ingestion were assumed. Overall hetlih risks were less than B x 10"* for both transformer oil spills. One major uncertainty often overlooked in conducting risk assessments of trans former oil spills in residential areas is the probability that a child will come Into contact with soil in the spill area. In both spills examined, the area of the spill was small compered to the total yard area, and the spill areas were re-sodded following spill cleanup. POSSM has provided a useful method to evaluate the environmental behavior of PCB spills end to calculate human health risks associated with those spills. 5-10 HOMS 217316 REFERENCES ; t M. Brown and S. H. Boutwell. Chemical Spill Exposure Assessment Hethodo` logy (RP-2634-1), Electric Power Research institute, Haio"Aito, California, B. A. Boomer. M. 0. Erickson, S. E. Swanson. G. L. Kelson, Verification of PCB Spill Cleanup by Sampling and Analysis, EPA-S60/5-85026. August inbi. , us. EPA. Health Effects Assessment for Polychlorinated Biphenyls (PCBs), EPA/S4Q/1-86/004. Nils ho. PBB6-I3415Z, Septem&ifTW: 5-11 HONS 217317 FIGURE 1 SOIL SAMPLING DATA </ (Sn n^S -wumu i[.U % p r* r* ? 1 1 a ib: *t* rr _ /> ! ---- -- " Waterford SplU-ltt cleanup Waterford Spill-2nd cleanup 5-12 HONS 217318 TABLE 1 TRANSFORMER AND CAPACITOR SPILL DATA Location Area Waterford Substation Equipment PCB Capacitor Fluid Volume 1 gallon PCB concentration 100% Acoclor typa 1242 Mass of PCB Date of spill Area affected 5216 grams Mar., 1966 260 sq- ft. Ava. soil PCB level 1st cleanup 19.7 ppm 2nd cleanup 1.2 ppm Nearest Residence 92 feet Waukesha Substation PCB Capacitor 1 quart loot 1242 1304 grams May, 1966 30 sq. ft. Cudahy Residential kVA Transformer 6.5 gallons 100 ppm 1264 2.2 grams Sep., 19B5 312 sq. ft. 11.2 ppm 2.0 ppm 200 feet 1.1B ppm 50 feet Peuaukee Residential kVA Transformer 1$ gallons 1B0 ppm 1260 9.0 grams July, 1987 400 sq. ft. 0.25 ppm 122 feet Cleanup Volatlllzed Runoff Remaining Waterford 9B.BX 1.1% 0.0% 0.03% TABLE 2 FATE OF PCBs Waukesha 95.9% 4.0% 0.0% 0.03% Cudahy 65.0% J73% 0.2% 31.5% ' Pewaukee 95. OX .005% 0.0% 4.9X Pathway Inhalation Ingestion Dermal Absorption TABLE 3 HUMAN HEALTH RISKS FROM PCB SPILLS Waterford Waukesha Cudahy 1 x 10`6 3 x 10*9 2 x 10' 6 x 10.'-9 2 x 10 9 Pewaukee S x 10 -1 3 x IQ*9 7 x 10 -10 5-13 HOMS 217319 HOMS 217320 V EMPLOYEE BLOOD SCREENING FOR PCB EXPOSURE AT NORTHWESTERN RURAL ELECTRIC COOPERATIVE, INC. MICHAEL D. TIRFAK NORTHWESTERN RURAL ELECTRIC COOPERATIVE, INC. R. D. fl, RT. 86 CAMBRIDGE SPRINGS, PA 16403 ABSTRACT In early 19B3, eeveral aaployaaa at Northweatern Rural Elactrle Cooperative axpreeeed concarna about thalr expoauree to PCB contaalnated alnaral olla and tha potantlal futura haalth affaeta that nay exlet. Conaaquantly, th* Mnageaent at tha Cooparatlva aatabllahad, with eonaldarabla halp fron a loeal hoapital, a taatlni protocol that could ba uaad to aatlafy our aaployaaa' concarna aa to tha axtant of body contaalnatlon. A rapraaantativa aaapla of aavan aaployaaa vaa aalactad and taatad along with two hoapital aaployaaa for eoaparlaon. Thla papar outllnaa tha davalopaant of tha taetlng protocol, tha eneuing taetlng and tha aaaoclatad raaulta analyala. BACKGROUND Tha procaaa began In aarly 1913, whan at a regular aonthly aafaty aaatlng, aavaraj of tha Co~op'a llnaaan expraeaed a alncara concern about axpoaure to PCB contaaln atad alnaral olla. At llnaaan, thay have had direct contact with tranaforaar and racloaar alnaral olla during thalr cereere through varloua aalntananca progreae. Theee alnaral olla had known PCB contaalnatlon of up to ZOO parta par allllon CPPH). Tha quaatlona rained ware generally aa followei * How aueh body contaalnatlon haa baan tha raault of tha axpoauraa over tina to PCB'a? What ahort-tara and long>tara haalth affaeta doaa thla contaalnatlon repraeant? It bacaaa apparent that theae concarna needed two different, yat Interrelated aolutlona. Tha first being a procedure to deternlna accurately and reliably tha laval of body contaalnatlon of FCB'e. Tha aacond relating to Juat what thaaa raaulta aaant for tha proeant aa wall aa tha futura of our aaployaaa, 5-14 HOMS 217321 Kj^OCOL development Htaraturs available at tha tims indicatad that a blood saru test for PCB'a wn (callable, but drawing blood raqulrai assistance from the medical community. Efiaaquantly t a contact wee mad* with th* Meadvllle City Hoapital and a matting Pj-' aat'Up with tha Executive Director and ttvartl of hla key ataff people, including tha Director of tha Patholo|y and Laboratory Medicine Dtpartment, flrat netting pointed-out that few In our local aadlcal community knew about rpC) txpoturtt or tha propar tatting protocol naadad for our anployeae. (Fortunately, tha director of Pathology and Laboratory Madlcina took an intaraat in rthl* project and proceeded to do an extenelve literature aearch Including contacting 'the Center for Dlaaaaa Control (CPC) In Atlanta. CA. Tha CPC waa aoat helpful and auggaatad tha following protocol: Through Job hletory, identify tha moat highly axpoaad individual* for the acraanlng teat tempi*. Ucilixa control tamplat of non-*xpoa*d individual* whan poaalbla. Uaa atandtrd aaaplaa provided by th* CDC to check th* accuracy of th* laboratory equipment. Tha CDC also provided the naaaa of aavaral laboratoria* that would be auitabla for tha taating daalrad. EDUCATION While tha taating protocol waa under davalopaant by th* hoapital ataff, a contact waa aadt at th* National Inatltuta for Occupational Safety and Health CN10SH), Cincinnati. OH, that proved to b* vary helpful. Tha Chief of Medical Section. Hacard Evaluation, and Technical Aaalatanca Branch, Plvlelon of Surveillance, Kacard Evaluation and Field Studlaa, agreed to conduct educational aeainara for both our Cooperative'* employee* and th* phyaiclana of City Hoapital. Thl* taainar waa held in January. 196*. Wa learned fro* atudlaa completed by NIOSH^^ that vary little corralaclon exlatad batwaan PCB axpotura and worker health. Extra** txpoauraa have reaultad in chloracna and aigna of llvat enlargement, but routine utility work rarely expose* aaplayaaa to thaa* lavala, Th* atudlaa alto indicated that th* blood aarua PCB laval for utility worker* appears to ba very similar to the general public laval which la that approximately 90S of all individual* have 20 parts par billion (PPB) or Isas (BO to B5X art lass than 10 PPB). 5-15 HONS 217322 Theee educational seminars helped to answer che question of shore-term and longten heelth effects of our employees as well as rales the awareness and knowledge level of PCt diagnosis for the local medical community. TESTIDG AND RESULTS The final protocol for our screening procedure was as follows; ' ' Five of our employees wars selected who had the greatest exposure potential to PCB contaminated mineral oils based on their years service and Job function* Two employees were selected who had little or no known exposure to PCB'e. Two hospital laboratory employees were selected to provide further blind duplicate samples* < Penlsslon was obtained from each of the employees' physicians for ths blood work. Blood samples were to be taken, prepared, end sent by the City Hospital Lab to the Rel-Tach Science Services Lab. Madison, Wisconsin. ss per their Instructions. Three standard samples, provided by the CDC. were sent along with the above mentioned samples as e way of measuring the precision of the tasting. These samples represented PCB levels of 1.6, 9.9, end 22.2 PPB. In addition to the PCB testing at Rel-Tech, che City Hospital lab ran tests on the blood samples for liver eniymee (SCOT/SPCT) alkaline phosphatase end cholesterol levels to determine if any correlations axietsd with PCB levels as had bsen indicated in the literature on previous studlea. The blood samples were taken in early April, 1984, coded to eliminate names for privacy and sent to Ral-Tech for analysis. Table 1 outlines the results of the teeting. Employes sample #3, who had the highest PCB level of 25.2 PPB, had a slightly elevated liver ansyme level (SGOT) of 2B (normal range 7-23 unite par liter). Employee sample #5, who had a PCB level of B.2 PPB, also had an SGOT level at the upper limit of the normal range. Both employees ware advised to see their family doctors for e follow-up exam to inveatliats potential liver damage. Follow-up blood teste a few weeks later indicated the llvsr ansyms levels to be beck within ths normal range for both employees. After examinations, they ware each given a clean bill of heelth. It appears that a variety of fectore can Influence theee ansyme levels temporarily. A correlation with the PCB level did not appear to be indicated in our taste. 5-16 MONS 217323 terra enalyeis it Ael-Teeh was approximately JlOO par simple. The standard RiMpl** fr0<1 ch CDC wtrt provided it no co*t li were thi chemical profiles it fcity Hospital. Thi only renumeratlon naceseary for both organizations wii chi fsharing of thi dsti sc chi completion of the testing. Er ;swrm . Thi tiit riiulti indlcitid to u chit thi employee itrun PCB levels to bi obout expected. Even thi high reeding of 25.2 could bi conildirid ibout 2D PFB whin thi testing iccurtey wmi taken Into iccount. Our employees wiri nori thin iitlsflid chtt thiir body PCB contamination vat not significantly different from thi general populitlon, ind thtt minimal danger xiitid for ilthtr ihort-tirn or long-tint htilth iffict*. Both ntjor questions wire tniworid it thl point. With ill risks conildirid. thi btit courti of ictlon for thli particular problon wi to uot the concirnt of thi inployiit hiid on. ACKNOWLEDGEMENTS Miidvllli City Hoopltil (currently thi Miidvllli Midlcol Contir). Miidvllli, PA 1633S Anthony J. DiFoll, Executive Director. Dr. Jerry Mirty, Director Pithology and Liboretory Medicine Department. Center for Dliiiii Control, Department of Hiilth and Hunan Sarvlcii, Toxicology Section, Atlanta, CA NIOSH, Cincinnati, OH 45226 Dr. Alexander B. Snith, Chief of Madical Section, Hiinrd Eveluatlon nd Technical A*alatinea Branch, DivioIon of Surveillance, Hatard Evaluation nd Plaid Studlaa. UFEMMCES 1. Alaxandir B, Saleh, M. D., M. $., end David P. Brown, M.S. Polychlorinated Biphenyls in the Workplace. U. S. Dipirtnant of Health and Hunan Servlcas, fuolic Health Service, Canters for Disease Control, National Institute for Occupational Safety end Health, 4676 Coluabla Parkway, Cincinnati, OH 45226, April, 1983. 5-17 MOMS 217324 TABLE 1 BLOOD SERUM PCB LEVEL TEST RESULTS SAMPLE NO. EMPLOYEES - GREATER EXPOSURE #1 #2 #3 #4 #5 EMPLOYEES - LITTLE EXPOSURE #6 #7 HOSPITAL EMPLOYEES #8 #9 STAMDARP SAMPLES* #10 - 1.6 PPB laval #11 - 9.7 PPB laval #12 - 22.2 PPB laval RESULTS (PPB) 18.5 8.2 25.2 9.7 8.2 6.5 7.3 7.7 6. B 3.4(lst run); 2.0 (2nd run) 11.7(lac run); 15.5 (2nd run) 27.5(1st run): 30.2 (2nd run) *Tha standard aaapla runa lndlesta tha raaulta to ba aa nuch aa 10 to 20Z hl|har than axpactad. A rarun traa raquaatad to provlda a furthar accuracy chaek. 5-18 HONS 217325 MOHS 217326 PCB MANAGEMENT IN a MULTI-PLANT CANADIAN CORPORATION H, Torosslan Oomtar Inc. P.O, Box 300 Sennevllle, Quebec CANADA H9X 317 ABSTRACT Oomtar Inc.. a Canadian Corporation, oparatas 75 plants In Canada and 25 In the U.S.. It la a diversified company, producing pulp and papar products, packaging, construction matarlals and chemicals. Tha Corporata Environmental Sarvlcas Dapartmant established a program of PCB managamant to ansura compliance with Federal. Provincial and State regulations, and to develop and Implement a plan to reduce Oomtar's exposure to PCB related Incidents. The objectives of this program are being achieved by the execution of the following phases: Inventory of all electrical equipment containing or contaminated with PCB - Technical audits and risk evaluation Analysis of options for action to reduce risks - Action plan and Implementation INTRODUCTION Inefficient management of PCBs could be dlsasterous to any corporation, PCBs have become the focus of more regulatory attention than any other compound In history, Recant clean-up and decontamination costs after a fire Involving PCBs have reached millions of dollars. The cost of production loss and ensuing legal claims could be astronomical. Domtar Initiated Its PCB management program In 1985 In order to reduce Its exposure to PCB related Incidents and to minimize health, environmental and financial risks. INVENTORY An Inventory of all electrical equipment containing PCB fluids In Canadian and U.S. mills and plants was carried out, followed by Inventory of over 200 offices, warehouses and distribution centres, All electrical equipment containing or contaminated with PCBs, In service or In storaqe. were Included. A questionnaire was sent to every location In a format which facilitated reporting to government authorities, Due to the volume of Information collected and the necessity to keep the Information updated, It became evident that a computer was needed to process and 5-19 MOHS 217327 manage this Information, A data baa* management system using DBASE-II! program wat Implemented on an IBM-PC. Data manipulation and updating became an aaty task. Invantory listing of any type of electrical aaulpmant sued as capacitors, PCB transformers or mlnaral oil fIliad transformers par Company Group. Division, Provinca, Stats, Country la avallabl*. ' The Invantory format was dlvldad Into six aactlona, It Includad PCB transformara, capacitors, contamlnatad mlnaral oil transformara and mlscallanaoua artlclas In sarvlca, PCB aaulpmant In storaga for futura disposal at wall as a Hat of all PCS aaulpmant thlppad out for atoraga, A complata daacrlptlon of avary PCS aaulpmant It provldad. Including Its govarnmant labal number, atrial numbtr, kVA, location, voluma of fluid, and In tha cast of mlnaral oil transformara, tha contamination laval. For PCB aqulpmant thlppad out for atoraga, tha shipping data, carrltr, daatlnatlon and manlfaat nuiabar la alto Includad, Following tha eomplatlon of tha Invantory, all PCB flllad capacitors, transformers at wall at mlnaral oil transformara contamlnatad with ovar 50 ppm PCBs In Domtar'a Canadian plants wart labal lad using stlckars obtalnad from Environment Canada, REGULATORY BACKGROUND: THE CANADIAN ENVIRONMENTAL CONTAMINANTS ACT "Chlorophenyl Ragulatlon No. 1" which btcamt afftctlva on Sapttmbar 28, 1977, bans tht utt of PCB aqulpmant in any product, mtchlntry or equipment manufacturad or Imported Into Canada. "Chlorobl phenyl Regulations No. 2 (Product)" prescrlbts a maximum ptrmltslblt concentration of 5D ppm of PCB in electrical equipment which art Imported, manufactured or offered for tala In Canada. Exceptions exist where the electrical equipment containing PCB In concentrations greater than 50 PPM Is offered for sale as a necessary and Integral part of a building, plant or structure which Itself Is offered for sale. To qualify for this exception the electrical equipment must be functional and operating. A further exception Is PCB filled equipment sold for destruction or for storaga awaiting destruction. "Chloroblphenyl Regulations No. 3 (Release)" prescribes 50 ppm by weight as tha maximum concentration of PCB which may be released Into the environment other than an application to a road surface, In which case the maximum permissible concentration is 5 ppm by weight. The maximum quantity of PCB which may be released Into the environment from any PCB filled electrical equipment Is limited to 1 gram per day. Offences under the Environmental Contaminants Act ere punishable by a fine up to $100,000 per day or Imprisonment for two years. Chlorobl phenyl Regulations No. 2 and No. 3 became effective on May 15. 19B5. The major differences between Canadian and U.S. regulations are: - Any electrical equipment In Canada containing over 50 ppm PCB Is considered as a PCB equipment and is subject to chloroblphenyl regulations 2 and 3. - The ll.S. regulations make provisions for PCB contaminated transformers, l.e. ones containing 50-500 ppm PCBs. A PCB transformer Is one that contains 500 ppm or greater. - Transportation of PCBs between the two countries Is not allowed. - The EPA has stricter regulations regarding registration of PCB equipment with fire departments, removing of combustible materials. Inspections, location 5-20 HONS 217328 restrictions, maintenance etc, Oestruetion of PCB* It available In the U.S. but not in Canada. Mobil a decontamination units for mineral oil filled transformers have recently been approved by most Canadian provinces. technical audits and risk evaluation A PCB auditing program it a necessary measure to ensure compliance with PCB regulations. It should also be the basis on which risk assessment is carried out and corrective measures taken. Domtar's PCB audits are carried out during the general environmental audits, which are conducted by Domtar's Environmental Technology Group. The auditors (Including an Electrical Engineer) are trained in PCB regulations, spill and fire prevention measures, leak inspections, etc. The purpose of these audits is to examine the physical condition of the PCB equipment and its installation and to evaluate risks of spills and fires. A checklist based on the guidelines published by Environment Canada is used by the auditors, which Includes the category of the electrical equipment, its complete identification, the equipment condition and its layout, the pretence of labels and records, evidence of spills, spill containment, fire risks, such as the presence of flammable material near transformers, the availability of protective equipment against spills and fires etc. : After the visit, a list of recommendations for prevention and containment are made. The audit report it then conveyed to the management of that specific location with recommendations for an action plan. OPTIONS FOR ACTION Since all PCB storage sites in Canada are filled to capacity, and there are still no approved PCB destruction processes in operation, our choices remain very limited. The options available for a company concerned with its PCB Inventory in Canada are the following: 1. Do nothing, 2. Take all PCB equipsient out of service and store on-site. 3. Retrofill all PCB equipment with non-PCB fluids and decontaminate. Store liquid on site. 4. Keep all PCB equipment in service and take proper safety precautions. 5. Replace structurally poor and high risk transformers at once and take preventive measures for securing others, ANALYSIS OF OPTIONS Potion i; to inothing. Advantages No capital outlay, 2. Take all PCB equipment out of service and store on site. Exposure is low if adequately stored, Disadvantaaea -High risk of spills and fires. -Useful life of equipment is shortened. -Major capital outlay for new equipment. -Capital required for building storage sites. -Creates a PCB waste site. 5-21 HONS 217329 3*. Retroflll PCB transform*!** with non PCB fluids. Concentration of dioxins and furant will be lass during PCB fir**. -Does not eliminate PCBs, PCB levels will almost certainly be over 50 ppm, -May generate PCB waste 3 times the original volume. 3b. Decontaminate PCB contaminated qulpmant to below 50 ppm. If successful, a PCB contaminated mineral oil transformer will be reclassified as a non-PCB equipment. -Transformer could be downrated. -Applies only to mineral all transformers contaminated with up to 500 ppm PCBs. -PCB concentration will Increase within 6 months. -2 or 3 treatments may be required. -Generates small amounts of wastes which have to be landfilled. -Costs up to 520 per gallon. 4. K**p *11 PCB equipment In servlc* and talc* proper saf*ty precautions. -Exposure reduced. Maintain control over PCBs until such time when destruction facilities are approved. -Some mills or plants may ignore safety precautions. -Capital expenditure required. S. Replace all high risk PCB equipment with environmentally acceptable equipment. Minimum exposure, Economically and environmentally sound. -Additional servicing or replacement will continue to be necessary to minimize liability. -Will have to be monitored on a regular basis. -Will create PCB storage sites. If a PCB transformer 1* In good condition and could be kept In service for an additional 10 or 20 years, efforts er* mad* to secure that transformer end extract the maximum possible service as long as all precautionary measure* are taken In order to minimize spill and fir* risks. Option 5, which Is a combination of options 2, 3b and 4, allows for the gradual phasing out of the PCB articles and In th* present Canadian context. It Is an environmentally and economically sound option. It Is understood that Implementing this option It not th* final solution to th* PCB problem and that replacing them Is th* ultimate aim. However, under th* present regulatory environment and th* non-existence of PCB destruction facll-Ulot In Canada, the above recommended rout* must be pursued. 5-22 HONS 217330 CORROSION AND ITS COSTLY EFFECTS AFTER THE PCB FIRE Kirk Bleckaon - Preeldent Larry Wood - Chief Engineer Maurice Puna - Chief Chemiet Bleekaon-Mooring Steeaatic Technologic*, Inc, One Sumit Avenue Suite 202 Fort Worth, Texae 76102 When you welk. into the mechanical room of the Binghamton State Office Building one obvioue elte le the naeeive amount* of corroeion epperent on ell unpeinted motel eurfecee. All electrical twitch gear, backup electrical genaretore, fire alarm eyeteme, elevator evitcb gear, end maeeive amounta of electro-mechanical equipment . will have to be replaced. The corroeive effeete of the PCB fire have taken their " toll on thia equipaant, Although we have obearvad theee corroeive effeete at alaoar all PCB fire incidence little hee bean done to control it. It ie known that the eoot generated froa the PCB fire io laced with corroeive gaaea euch aa hydrogen chloride (BC1) end chlorine (Cl). Whan theee geeae combine with aoieture (Humidity) they form highly corroeive hydrochloric acid depoeite- Another example of thia occurred at the Air force Wind Tunnel Tearing Facility at Arnold Engineering and Developing Canter in Tulehoaa, Tanneaeee. Beeauoe the corroeion problem wee not addreeeed in the early etagee ell electrical equipment, ewitch gaare, controller equipment, and eome manufacturing equipment will have to be replaced. The cost of replacing this equipment and other equipment damaged by the corroeive effeete of PCB fire incidenta it ataggaring. Until now, thia haa racaivad little attention. The corroeion may ba primarily cauaed by the acid condition left by the fire incidents however, there era alao aeveral other factora that can accelerate the corroeive action. Theae include) 1. The praaanca of aoiature 2. The abaanca of protective coating on the metal aurfacaa 3. The praaanca of air Thera are certain ltaae with which you ehould normally ba concerned whan evaluating the damage dona by a PCB fire. They are aa followa: 1, Clectrouica 2, Hectro-mechenleel equipment 3, Ittduetrlal machinery 4, Metal Structural ltaae Aa a factor in the PCB fire arena, the corroeion problem ie relatively new. However, tha field of corroeion control after dleeetere ia not new. For yeare the by product* of fire* and floode have left a corroeive etaoephere in faeilitiee, Extenelve reeeerch in thle aree haa indicated that moat loaeae cauaed by euch corroeion can be averted with proper treatment. 5-23 HONS 217331 Tha natural tendency onca a PCB flra occura la to taat the building thoroughly to datarmlna tha axtant of contamination. Unfortunately thla takes time. Emergency corroalon control procaduraa ahould ba performed within tha flrat 24*36 houra attar tha lncldant. Thla work can ba dona vary quickly avan In maximum protactlva gaar. Tha actual raatoratlon work on tha equipment can ba dona latar. Tha kay In moat caaaa la tha apaad at which tha propar treatment la lnltlatad. Thaaa ara basically two atapa to corroalon control. Tha flrat la emergency treatment. which lncludaa tha atapa takan to ratard corroalon and alow lta daatructlva forca. Tha second atap la tha actual raatoratlon or removal of all contaalnanta from tha aurfacaa. In tha Initial emergency traatnant aavaral atapa ahould ba takan: 1. Control of humidity - In aoaa caaaa thla aaana alaply ranovlng tha flranana' watar and contdnarltlng It. In othar aituatlona thla could naan tha placanant of dahunldlfying aqulpnant or tha uaa of air condltlonara. 2. Isolating valuabla aqulpnant fron tha hoatlla anvlronnant - If tha aqulpnant cannot ba phyalcally laolatad fron tha contanlnatlon or tha high humidity, It night ba poaalbla to nova tha aqulpnant to another araa of tha building, 3. All untraatad natal aurfacaa ahould ba aprayad with lnhlbltora aa praacrlbad by a corroalon control chanlat to raduca oxygan on tha axpoaad aurfacaa and dlaplaca any nolatura. Electronic Data Processing (EDP) Equlpnant la particularly auacaptlble to tha affacta of corroalon for aavaral raaaona: I) Thay oparata on vary low voltage ao conaaquantly any particulate natter aetiling on aurfacaa can hava tha potantlal to produce a atray algnal raaultlng In aqulpnant Malfunction. 2) Vary tight tolarancaa and nultipla connactora make thaaa ltaaa partially auacaptlble. If tha corrosion has progressed to tha point where you can aaa It, normally It la too lata to save tha aqulpnant. Tha emergency traatnant of aqulpnant alowa tha prograaa of tha corroalon and buys the customer time for decision making. Normally during thla time tha building can ba analytad for tha axtant of PCt/PCDD/PCDF contanlnatlon and a claan-up and a decontamination plan can ba formulated. Aa a part of tha dacontanlnatlon plan raatoratlon of tha EDP aqulpnant should also ba Included. Tha natal aurfacaa ahould ba tasted to datarmlna tha nature of tha contamination and its cnrroalva properties. Using information obtained fron thaaa tests, tha corroalon control chanlat will formulate a solution for each surface and component. Soma methods that have bean auccaaefully used ara as follows: 1. Ultrasonic - This Innovation la particularly good for cleaning printed circuit boards, keyboards, and snail parts. Special cars must ba takan to inaura that sonic sensitive Items ara not placed In tha ultrasonic baths. 2. Rand cleaning with a wash and rinse ayatan - This process normally la used with a freon baaed claaner. 3. Wash and bake operation - Components are normally dipped in a washing solution and than baked dry. Most manufacturers uaa a form of this cleaning nathod In . the final stages of printed circuit board construction. Onca the unit has boas thoroughly dacontaalnatad, it must ba racartifiad and placed undsr a propar maintenance contract, if applicable. In many caaaa tha original naimtasanosprovidar for tha equipment may not wish to continue tha maintenance contract, fortunately, there ara many othar reputable third party maintenance companies that ara usually quits anxious to aatabliah an acceptable program for tha aqulpnant. Many times tha moat important aasat requiring preservation by tha coapany la Its corporate madia (company data baas). It la vary poaalbla to hava a 110.000 computer with a $130,000 worth of accounts receivable in its memory. This will normally ba containsd on taps or disk. Savers damage to diak raad/vrita haada is posaibls. Xf an attempt is made to use tha madia whan it ia not daan, a "head 5*24 HONS 217332 >ak caused by particle on ths surface of tha aadla will not only daaaga tha but aloe raault In a loaa of data. In dacontaalnating tha aadla It la jfasertant to keep all claanara away froa tha drlva haad and tha disk aurfacaa. |r eiaaninf of dlak packa. tapaa. and floppy dlaka raqulraa apaclal techniques and ifliauld ba dona only by experienced paraonnal. In tha avant aadla la dsaagad by a Kaad craah thla doaa not nacaaaarlly aaan that It la irratrlavabla. Howavar, it raqulra tha uaa of apaclflcally configured dlak drlvaa with aachanlcally ^ovabl* haada. Again, a aarvlca provldad by a profaaalonal. HtnduStrial aqulpaant la notaally traatad In a eoaplataly dlffarant faahlon froa tha 'EDP aqulpaant. In thla caaa, avan If thla aqulpaant la ruatad It can oftan ba 'brought back to a aarvlcaabla condition. Again, it la Important that tha ^aSticgancy traataant ba parforaad laaadlataly. Although you aay ba abla to raatora `tha aqulpaant If It goaa untraatad, tha coat and tha coaplsxlty of tha raatoratlon la auch aora difficult If tha corroalon la not ratardad in tha baginning. Soaa typaa of lnduatrial aqulpaant ara aa follow*: 1. Typawritara 2, Manufacturing aachinary ). Motor* i. Nuaarically controlled aanufacturlng aqulpaant j. Coaputar operated aanufacturlng aqulpaant 6. Raw aatal atock itana Tha aaargancy traataant uaually conaiata of tha uaa of inhibiting oila to reetrict oxygon on tha aurfaca of tha aatala and diaplaca any aolatura praaant. Controlling tha huaidlty la alao an laportant factor. Tha raatoratlon procaaa noraally begins with tha stripping of rust froa tha aurfacaa of tha aatal. In thla procaaa tha corrosion control chaalat will proscribe either an acid or alkaline ruat raaovar, depending on the contanlnant. Many of these ehsnicels ars heat activated, ao often they era applied with tha uaa of steaa cleaners. Frotactiva goer aust ba uaad to protect tha enployeea' akin froa ths caustic offsets of these chenicale. Next, the surface of the aatal is neutralised, soaatiaaa it is than pacified and then finally tha proper protective coating is applied. Sobs axaaplas of coatings ere lubricating oils, phosphate coatlnga or possibly a prlaer coat of paint. Although aany of tha landaark PCS firs incidents resulted in staggering loesae due to the corroaivs effects of PCS byproducts on tha aqulpaant, today we know this need not happen. These axcaaalva financial losses which have resulted froa PCS fires can ba substantially reduced in ths future through the laaedlata uaa of initial aaargancy tachniquaa followed by a aatbodieel restoration prograa. 5-25 MOWS 217333 MOWS 217334 PCB-CONTAMINATED TRANSFORMER OIL SPILL EXPOSURE ASSESSMENT S. k. Brown nd W. J. shields CH2H HILL P.O. Box 91500 Bellevue, Washington 98009-2030 INTRODUCTION A atudy waa conducted to estimate potential human axpoaura lava la aaaoclatad with PCB-contaminatsd transformer oil spills following vialbla traca cleanup (1). ^ia axpoaura assessment dlffarad In two waya from thoaa pravloualy conductad by the EPA (2,2> in aupport of chair racant Toxle Substances Control Act (TSCA) PCS apill cleanup policy rula (), Tirat, PCS coneantrationa and aaaoclatad axpoaura levels ware estimated for condltlona repreaentativa of vialbla traca claanup at trans former oil alt.ee. Second, the praaonea of Mineral oil and ita affect on the envi ronmental behavior of PCB were conaiderad. The EPA exposure aaasssaisnts assumed conditions typical of disposal sites, rather than spill sites, and did not con sider potential FCB-nineral oil interactions. APPROACH PCB concentrations associated with tranaformar oil spills ware estimated with the PCS On-Site Spill Model, POSSH, C5,6) and an EPA air dispersion model, PTDIS (7). POBSM is a chemical transport and fate nodal that simulates changes in chemical concentrations on a apill site and losses of chemical from the spill sits via vcl' atilisation, runoff-soil erosion, and laaching to groundwater. PTDIS calculates chemical eonemntrationa in air downwind from a point sourca of rsloaae. POUM was used to evaluate PCB losses from a 40-liter (10.6-gallon) spill of min eral Oil containing 270-ppm PCB in the form of Aroclor 1242. Visible tracaa of the spill were assumed to cover an arsa of 0.0016 ha (170 square feet). These spill conditions represent the average spill volume, PCB concentration, and claanup area for 60 spills from distribution system tranaforswra. Vialbla trace claanup waa assumed to occur one day after the spill resulting in between 65 and 95 percent removal of the PCB-contaminated oil. These two values 5-26 M0NS 217335 (bracket ths rings of spill cleanup efficiencies Observed by ths utility industry, .^plll alta restoration through tha placement of a claan soii-aod covar ovar tha Cleanup araa was aaaumad to occur 30 day* following cleanup. Covar thicknesses of ^5 centimeters (cm) (2 inches), 10-cm (4 lnchaa), and 25-cm (10 inches) ware avaluatad. HCPOSSH (8), or Monts Carlo POSSM, was also used to datanaina tha potantlal range of variability of estimated exposure levels. MCPOSSK was applied to the 30-dsy tins period between spill cleanup and site restoration, hcfossm runs wars con ducted for two cleanup levelst 65 and 93 percent removal. Input parameter frequency dlatrlbutlona were developed to repreeent the variability of spill con ditions baaed on utility data for 60 transformer apllla. a broad range of soil types, and the range of PC* properties typical of Aroelor 1242, soil concentrations estimated with POSSM were converted into soil ingestion and dermal contact exposure levels using exposure factors consistent with those used by CPA (2). PCS volatilisation losses were converted Into downwind air concentra tions using PTDZS, The resultant air concentrations were converted into inhala tion Intake rates using exposure factors consistent with those used by CPA (2), RESULTS PCS volatilisation was found to be the stoat significant lose mechanism In all sim ulations. Losses via runoff-soil erosion and leaching were negligible compared to the volatilisation losses. The results indicate that dermal contact is the moat significant route of expo sure, particularly for the 65 percent cleanup level with a 5- or 10-cn cover thickness. This result is due to the assumption that the receptor comes into con tact with soil to a depth of 25 cmr for the 5- and 10-cm-thiek cover options, the 25-cm depth includes residual PC* remaining following cleanup, estimated soil in gestion rates are a factor of approximately 3 lower than the dermal contact rates, and estimated inhalation intake rates are between s factor of 4 to 15 lower than the dermal contact rates. estimated intake rates for the 65 and 95 pareant cleanup, with a 10-cm covar, show that inhalation intaka could decrease by a factor of 6 if the mors common 95 per cent cleanup level were achieved. Soil ingestion end dermal contact intake could daoreaee by a factor of 9. 5-27 HONS 217336 The MCPOSSM remit indicate that Inhalation Intake rataa can ba highly verleb; MCPOSSK raaulta for the 30-day prereatoratlon period ahow that average Intake rataa could range over four to five ordera-of-negnltuda. tha large range of Virl ability la due to the largo range of potential variability In aplll condition#, aoll proper tiea, and PCB propertiaa. frequency dlatrlbutlone of lnheletlon lnteke rataa for tha 30-day prereatoratlon period ahow that a high percentage of tha tie* (i.e., 90-percent) exposure lavela era at tha low end of the range of eatimetad valuoa. ACmOWLEDGtUCNTS Thla exposure aaaeaanent waa aupportod by the Utility Solid Waste Activities Group, Bdlaon Ilectric Inatltuto, Washington, O.C. FOSSH and MCPOSSM warn devel oped by EPRI under RP 2d34-1. REFERENCES 1. PCl-Content nated Transformer Oil Spill Expoaure Aaaeaament. Washington, O.C.i Utility Solid Wasta ACtivltiee croup, Edison Ilectric Inetltute, June 19B7. 2. S. T. Hwang, J. W. raleo, and C. H. Hauaum. Development of Advisory Lavela for Polychlorinated Blahenvla IPCIa) Cleanup. Waehlngton. O.C.i Epa, Office of Health and Ehvlronawntal Aaaeeanant, 19B6. 3. PO Spill Cleanup, Ravlaed Draft Report, waehlngton, D.C.i IPA, Office of Toxic Subatancea. April IB, 1986. 4. "Polychlorinated Biphenyle Spill Cleanup Policyr rinal Rule." federal Regiatar, vol. 32, no. 63, April 2, 1967. 5. S. H. Brown and A. Silver, "cheailcal Spill Expoaure Aaaeaanent," Risk Analyala, vol. 6, no. 3, 1996. 6. S. N, Brown and S. H. Boutwall. Chenical Spill Expoaure Aaeeaawent Hathodology. Palo Alto, California, Electric Power Raaaarch Inetltute, Rp 2634-1, 7. 0. B. Turner and A. D. Buaaa. Uaer'a Guide to tha interactive Varalona of PTHAX, PTOIS, and PTHP. Reaearch Triangle Park, Worth Carolina, EPA, 1973. B, W. J, Shield*, I. W. Straekar, J. 0. Dean, and S. H. Brown. Cheailcal Spill Oncertalntr Analvale. Palo Alto, Californiat Electric Power Reaearch Inatl- tttte, RP 2634-1, 19B7. S-2B MONS 217337 HONS 217338 THE PC# SPILL CLEANUP POLICY OF 19*7; SUMMARY AND IMPLICATIONS Joseph E. Shafchek, CHMM Wisconsin Povsr and Light Company ABSTRACT Tha purpose of this papar is to summarise and discuss tha national PCs spill cleanup policy. Tha policy requires that all new PCB spills ba claanad up according to strict performance standards! All profasaionals responsible for PCB management should ba familiar with this policy, sines it ones again changes tha game rules for handling PCBs. This summary addresses and clarifies tha PCB policy's requirements for spill reporting, cleanup, post-cleanup sampling, and racord-kaaplng, along with.soma of tha policy's problems and Implications. INTRODUCTION On April 1, 1967, tha U.S.EPA issued a final rule establishing a National PCB Spill Cleanup Policy (1). Tha policy became affective Hay 4, 19S7, and significantly increases tha requirements for reporting and cleanup of all naw PCB spills. Spills are defined as intentional or unintentional laaks, spills, and other uncontrolled discharges of any quantity of PCBs running off or about to run off tha external surface of tha equipment or PCB source, as wall as tha resulting contamination. Tha scope of tha policy covers moat naw spills of PCB fluids containing 50 ppm and above. Howavar, spills directly into watar, savers, vagatabla gardens, and animal gracing land ara not covered by the policy but will ba conaidarad by tha IPA regions on a slta-by-sita basis. Cleanup requirements for thaaa types of spills ara likely to ba stricter than tha policy requirements. OVtRVUW OP RBQUIRZMINTS Tha Poliey addressee five basic aspects of PCB spill rasponsa. Generally, for moat new spills of materials containing mora than 500 ppm PCB, tha following is requiredi 1. Reporting; To IPA within 24 hours of spill discovery 2. Cleanup; Completion within 46 hours of spill discovery 5. Performance Standards; Variable according to spill location and mass of PCBs spilled 4. Poat-Claanup Sampling: Statistically valid methodology and analytical techniques for verification 5. Record-Keeping: Certification and document ratantion for fiva years HONS 217339 6-1 Spill Report int Th* overall objective of the Polio/ i* rapid PCB apill ra*pon*. Tha Policy require* that all new apilli of aora than 10 pound* of pura PCS by weight be reported to tha EPA regional office and National Re*pon*a Center (NRC) (1-S00-A2A-S802) within 24 hour* aftar the *pill h* been discovered. Typically, thi* would cover any coapleta ralaata of fluid froa aingla PCI ctpacitor or trantforaar. Thi* r*quiraa*nt aay ha waived only in tha caaa of advaraa circuaatancaa, auch aa tornado, hurricane, or civil aaargancy. Howavar, ra*pon*ibl* partiaa Who delay reporting end cleanup due to an adverse cireuaatanea au*t kaap record* docuaentlng tha cireuaatanea* precluding rapid raaponta. Most pill* of low concentration PCB (50-500 ppa) au*t be claanad up, but EPA notification 1* not required. Spill* of aatarial* containing la** than 50 ppa PCB are not covarad by thi* Policy. It i* worth noting that the published policy doaa indicate that "spills exceeding 10 pound* of PCB aatarial (generally on* gallon of dialaetric fluid)" au*t ba reported to tha EPA regional office. Conaequantly, the Utility Solid Wa*ta Activity Croup (USWAG) raquattad that tha EPA clarify thi* reporting raqulraaant inca it would have unduly required tha reporting of nearly all aineral oil traneforaar apill* ragardla** of tha aa*a of PCB* *plll*d. In a subsequent aaaorandua to USWAC, tha EPA Office of Toxic Substance* clarified that the pacified reporting roquiraaent only pertain* to *pill* of 10 pound* of pura PCS* or aora by weight and that th* regional office* had bean notified of thi* policy revision (2). Cleanup Standard* Tha Policy iapo*e* variable cleanup raqulraaant* ba**d on th* aa** of PCB* spilled and tha location of tha *pill. I. Per apilla of PCBcont*ainatad aatarial (50-500 ppa) containing la** than on* pound of pur* PCB by wtlght, th* following cleanup raqulraaant* au*t be coaplatad within AS hour* of apill diacovary. * Solid Surface*; Double wath/rin** with tolvant Soil: lime vl*lbl* trace* plu* a buffer of on* lateral foot ' Docuaentation: Provlda cleanup cartification II. The following ia required for all epill* involving PCB aatarial* ov*r 500 ppa end PCBcontaainatad aatarial* axcaading ona pound of PCB by weight; 1, laaadiat* teaponaa; Th* following requireaanta au*t ba **ti*fiad within 2d hour* of apill diacovary: Notification: Contact EPA and NEC if over 10 pound* of BCB * Barrier Protection: Kaatrlet acca** to *pill are* plu* a thr** foot bufftr son* * Ellainat* Spillage: Stop flow with ebaorbent or plug Initiate Cleanup: Ranova all visible trace* of *pi 11 6-2 HONS 217340 2, Cleanup Stsndsrdsi Spill cleanup mutt Mt stringent performance standard*. A summary of tha spill cleanup performance standards is presented in Table 1. Within AS hour* of spill discovery! eleenup should be completed and achieve the specific standard* for the listed locations. Post-cleanup sampling muit verify that the standard* for eleenup have been successfully achiavsd. p^at-Clannup Samplint Tha policy require* a statistically valid, reproducible, sampling methodology to verify the achievement of tha cleanup performance standard* for all high-level PCS spills or low level spills involving one pound or more PCS* by weight. Tha sampling scheme may consist of either random or grid samples. However, tha sampling era* must be the larger of either the arse cleaned plus an additional one foot boundary, or an arsa 20 percent largar than the original spill boundary.- The number of aamplee collected can be a* little aa three or ** many as 40; however, a sufficient number must be taken to ensure that areas of contamination of d radius of two feet or more within the sampling area will ba detected... Additionally, the sampling schema must ansure 95 percent confidence against fslsqf positive* and include e calculation for expected variability due to analytical error. Although any sampling methodology which achiavaa tha above requirements may be usad, tha EPA recommend* tha uta of tha sampling scheme and verification teehnlquaa developed by ths Midwest Research Institute for the EPA Office of Toxic Substances (3) (4). Record-Keeping Tha Policy requires that *11 spill cleanups be fully documented end that ths responsible party certify tha required site decontamination. All spill records, documentation, end pertinent data mutt be retained for at least five years and be made available to the SPA upon request. The record* end documentation must consist of the following information! * Identification of tpill source (equipment) * Estimated or actual data and time of spill * Actual data and tima of claanup completion * Description of spill location and nature * Era-cleanup templing date * Description of solid surface cleaning * Approximate depth end amount of toil removed * Eost-eleenup verification sampling data end methodology * Signed certification statement * Estimated cost of. spill cleanup (optional) IHPLICATIOH* AHD PROBLEMS Tha policy will prove costly to electric utilities. Tha EPA estimates that 620,000 pounds of PCI* are leaked or spilled from electrical equipment every year, 6-3 HONS 217341 Ba*d on available data, 381 of theae PCBa are spilled in electrical substations and 682 ere spilled in residential/eommercitl, rural, or industrial areaa. Given the large quantities of apilled PCBa and the very stringent cleanup atandarda required by the Policy, the coat of PCB cleanup ia certain to increaaa signifieantly. The cleanup of one PCB capacitor apill in e reaidential area it expected to coat on tha order of $10,000. Baaad on EPA'a coat estimates, u.s. induatry can expect to pay over $100 million per year to clean up PCB apilla. N0c only ia thia Policy very coatly, but it craataa some very aerioua compliance problems for electric utilitiea. Old and Hew Spilla Moat electrical aubttationt end other location! where PCB equipment ia in uaa have been subject to hiatorical PCB apilla. Therefore, a reeidual PCB concentration nay be expected at theae location!. Once a new apill occura in auch a location, tha praecribad decontamination atandarda muat be achieved at that aite. If the contamination from the new apill can't be distinguished from tha hiatorical contamination, the entire aite may have to be excavated and cleaned to the preacribed etendard. Thia aeanario may eaaily increaaa EPA'a original com ea time tee. To aolva thia dilama, it may be necaeaary for utilitiea to construct containment ttructurea in til aubatationa and araaa where PCBa are currently/in uaa in order to iaolate all new apilla from peat apill environment!. 48-Hour Requirement Heating the requirement of apill cleanup completion end reetoration within 4 houra ia elao expected to ceuae compliance problem!. In order to meet thia requirement, the aite muet be cleaned, verification aamplaa obtained, analytical reaulte reported, end the aita reatored within two deya. Needless to aay, getting a turn-around time of one to two daye for PCB enalyaea ia atypical. There will eleo be a need for all PCB generator! to have a reliable eource of clean fill material reedy for transport to any apill location for aite reetoration at a moment*! notice. If a contractor ie uaad for site cleanup and/or sampling, thia requirement will substantially increaaa tha cotta. REFERENCES (1) tt.S.EPA, "Polychlorinated Biphenyls Spill Cleanup Policy," (40 CFR 761). Federal Register Vol. 52, Mo. 63 (10688-10710), April 2, 1987. (2) Memorandum to Toni Allen, USWAC Counsel, from Martin Helper, EPA Director of Exposure Evaluation Division, May 1, 1987. (3) U.S.EPA "Verification of PCB Cleanup by Sampling end Analysis," EPA-J60-5-83-026, August 1983. (4) U.S.EPA "Field Manuel for Grid Sampling of PCB Spill Sites to Verify Cleanup," EPA-560-3-86-017, May 1986. 6-4 HONS 217342 Table 1. ro Sfltl CLEAJT WtWtWig QMiWW HONS 2173*3 Attenut1on of Polychlorinated Biphenyls In Soils D. C. Glrvln, D. S. Sklarew and A. J. Scott Environmental Sciences Department Battel1e, Pacific Northwest Laboratories The ability to predict the long-term mobility of polychlorinated biphenyls (PCBs) In the soil-water environment Is of particular Interest to the electric utility industry and regulatory agencies because of the history of use of PCBs as a coolant-insulation fluid and their resistance to degradation. This paper describes the Influence that adsorption/desorption has upon PCS mobility In soils and our current experimental work to 1) establish correlative relationships that can be used to estimate equilibrium sorption parameters from easily measured soil characteristics and well-established physical properties of PCBs; and 2) measure the release rates under non-equilibrium conditions of PCS congeners from utility soils containing Aroclor mixtures. The approach being used in this program to describe the role of sorption/desorption on PCB mobility In soils Is also applies ble to other hydrophobic organic compounds, such as the polynuclear aromatic hydrocarbons (PAKs), which are present In the soils at Town Gas sites. INFLUENCE OF SORPTION ON PCB MOBILITY I TRANSPORT In soil-water systems at low environmental concentrations, the sorption of a PCB congener Ml" can be described by a linear sorption isotherm, where the amount sorbed (S') is related to the equilibrium solution concentration (C1) by a con stant (k') termed the equilibrium partition constant for that congener (JJ and given byp or K' 7 (i) To Illustrate the attenuation or retardation effect that sorption hat on the transport of PCBs or other organic compounds (e^g-, PAH$) away from their Initial point of contact with the soil, consider the following simple example. Water is flowing at a steady hydrologic flow with an average velocity, v, through a soil of uniform porosity (n) that contains PCBs. Assume further that, the sorption reac tions are fast re 1 stive to v, so that sorption/desorption can be described by equation (1), the water content of the soil Is constant, and that dispersion effects unrelated to sorption are negligible. The rate of advancement (v1) of the PCB front through the soil will be retarded relative to the rate of advancement of the water by an amount v' v / Rf. The retardation factor Rf is defined as. 6-6 HONS 2173*4  v/v whtrt n tnd p are the toll porosity and density respectively (ZK (2) Consider the retardation of the Aroelor 1260 congener 2,4,5,2',4',5' In low organic carbon soil cnaraeteriied by 0.05% (by weight) orgenlc carbon (0C).,51 expandable clay miner*Is (CM), * porosity n 0.5, tnd density p 2.4 g/cm , Although * reasonably accurate "carbon-reference" model exists for calculating K and describing the sorption of organic compounds by soils containing greater than 0,2% X {1.1,3) no such model has been established to describe sorption on soils containing Test than 0.2% OC. Thus to estimate the retardation in this low X soil we could only make the questionable assumption that X still dominates sorp tion and Kd can be estimated using the carbon-reference approach. Based on a review of literature data (l.), Ks for the 2,2' ,4,4* ,5,5' congener for such low X soils range from 36 to 1400. For sake of Illustration K. can be actuated to be 300, yielding a retardation factor of Rf-1440. with a water velocity of 50 cm/d, we would expect PCBt to require approximately 306 years to move 50 meters. This assumption neglects sorption by expandable clays; however, there Is no "clayreference" model from which we can estimate a K. for the clay fraction of the soil. Bated on our current lack of Information1^ estimating e k. value for this J low OC, 61 clay toll. It It not unreasonable to postulate that the K used above .v could be In error by as much as a factor of 10, In this case, the 50-meter tran-4' sit time could b* at low at 3B years or at high as 3850 years. Thus, we currently have no basis with which to estimate the rate of PCS movement In low X tolls. Clearly additional Information Is needed on PCB sorption In low X tolls to define the role played by expandable clay minerals In sorption processes. ESTIMATION OF EQUILIBRIUM PARTITION COEFFICIENTS FROM PHYSICAL CONSTANTS Our current experimental program Includes Investigation of PCB sorptlon/detorptlon under equilibrium conditions for both typical (>0.21) and low (<0.U) OC soils. The objective Is to derive a predictive equation or equations, bated on a small but adequate set of experimental sorption data, which can be used to estimate equilibrium pertltlon constants (id) for a large nuafcer of Individual congeners for which sorption experiments have not been performed. Experiments are In pro gress to measure K0t for 2,4'; 2,2*,4,4'; and 2,2*4,4*,5,5' on 10 tolls differing In their X and CH'content (0.051 < X < 41; 51 < CM < 63%). For typical X tolls, regression equations of the form, log Kp a log lw b - log foc (3) have been extensively used In the literature, where Now It the octenol-water par tition coefficient and fnc Is weight fraction of organic carbon In the soil. A significant body of 1^ olta exists In the literature (-.6) and foc Is an easily measured quantity, Tn* a and b correlation coefficients determined for various classes of Hydrophobic organic compounds differ significantly (1,2*9). The coef ficients for one clett of compounds do not work for enother clast {3}. These coefficients heve not previously been derived for series of PCB congeners. Once the e end b coefficients and their limits of accuracy are established with data from experiments currently In progress, values for congeners for which no 6-7 HONS 217345 experimental data exist can be estimated from experimental {_) or calculated (5) Kgg values and the measured foc of the soil. Development of this Information ~ represents a significant advance because it Is far easier to measure the foc for i soil and measure or calculate the K 's for a series of congeners than to measure Kps for a series of congeners on thiTsoll. MEASUREMENT OF PCS DESORPTION RATES FROM UTILITY SOILS The partition coefficients described above treat the sorption process and retarda tion under equilibrium conditions, that Is when the flow of water through the soil Is sufficiently slow that local equilibrium conditions exist. When the flow Increases to the point where local equilibrium is not attained, the sorption proc ess Is described In terms of the rates of sorption and desorption. In general both the K s and the sorptlon/desorptlon rates are required for a complete description of the retardation of organic compounds In field situations. The utility Industry Is Interested In soils that have been In contact with Aroclor mixtures for an extended period of time. Thus the practical question Is. what Is the rate of desorption once these contaminated soils are contacted by the waters percolating through them. To address this question we are utilizing gas stripping columns with Tenax resin traps {10) to simultaneously determine the rates of release of 16 to 2S congeners from a utility soil suspended in water. The Tens* traps are changed at regular Intervals and the trapped PCBs are measured by gas chromatography. In this way the release rates from the soil can be determined for Individual congeners. This follows because the rate of PCS exchange between the water and the gat, which It flowing up the column. It virtually Instantaneous In comparison to the release rate from the toll which It diffusion limited. Thus the rate of change of PCSs In the Tenax resin trap Is equal to the rate of release from the toll. Gas stripping experiments heve been conducted with a 1.51 OC utility site soil containing 1.5 ppm total Aroclor 1260 to determine whether this method for measur ing release rates Is applicable to Aroclor mixtures In soils. The results showed that the release of 16 congeners could be observed during the four-month term of the experiments and that a greater number of congeners could be observed if soils containing higher total PCS concentrations were used. The cumulative fractions released, when plotted against the square root of time, are approximately linear for those congeners present in sufficiently high concentrations. This linearity is consistent with the hypothesis that the release rates from soil particles are limited by diffusion from the Interior of the soil particle (_10). This follows because the boundary conditions existing In these experlments~Te,g., zero aqueous PCS concentration) approximate those for which diffusion controlled release rates depend on the square root of time til). During the four-month stripping experiment, 381, 281 and nil of the total quantity of congeners 2,2',4,5,5'; 2,2',3,5,5 ,6; 2,2',4,4',5,5* were removed from the one-gram sample of utility soil used. This represents the upper limit of the release which could occur from this soil under field conditions. Sased on the success of these preliminary experiments, additional stripping experiments are planned for 1986 using several utility soils. These experiments will be conducted for longer times to quantltattvely determine the release rates and how these release rates change with time. The release rates, determined In this way, represent the upper limit or maximum release rates that could occur In a soil-water system. This Information directly quantifies the significance of a given spill site as a PCS source term for sub sequent migration In soil-water or aquifer-groundwater systems. 6-8 HONS 2173^6 SUMMARY `w# hv given'a simple example of how sorption/desorption Influences the mobl 11t> 0f pcBs In soils and described our experimental work to develop methods and data for quantitatively estimating sorptlon/oesorptlon parameters, wnlch can be used to describe PCS movement in soils using transport or risk assessment models. Sped* flcally we have described correlation relationships that can be used to estimate 1 quilibrium partition coefficients and experimental gas stripping techniques to measure maximum possible release rates. Finally, we pointed out that while PCBs are Important compounds to the utility Industry, the methods and approach described here for PCBs are applicable for the study of the attenuation of other hydrophobic compounds (e.g., PAHs) that may be of current or future Importance to the utility Industry. ACKNOWLEDGMENT The authors wish to acknowledge EPRI for support of this work under Rp 1263*22. We are grateful to Or. M, McLearn, EPRI Project Manager, for her technical guid ance, management, and support. REFERENCES 1, Glrvln, 0. C, and 0. S, Sklarew. Attenuation of Polychlorinated Biphenyls In Soils: literature Review. EPRI Report cs-*396, January 1986. Sklarew, D, S. and 0. C. Glrvln. "Ittenuatlon of Polychlorinated Biphenyls In Soils." Review of Environmental Contamination and Toxicology. Vol. 98, 1987, ppTT^I------------------- ---------------------------- 2. Cherry, <1. A,, R. W. Gill ham end J. F. Barker. "Contaminants In Ground water: Chemical Processes." In Groundwater Contamination. Studies In Geoph^sUs Series. Washington, O.C.: National Academy Press, ^$84, 3. Karlckhoff, S. W. "Organic Pollutant Sorption In Aquatic Systems." J. Hydraulic Eno.. Vol. 10, No. 6, 1984, pp. 707-735. "" 4. Rappaport. R. A. and S. J. Elsenrelch. "Chromatographic Determination of Octanol-Matar Partition Coefficients (K *s) for $8 Polychlorinated Biphenyl Congeners." Environ. Scl. Techno!.. Vou IB, 1984, p. 163-166. 5. Leo, A. J., "Calculation of Partition Coefficients Useful In the Evaluation oOTf tVhFelf RMeIIlaVtIivTeI Hnaiiziaiwrdsi ouif Viai riiovuu>s CVMhVeMmiSicpmalisa In the Environment." In 1C. J. C. Symposium- on Structure Accttiivity Correallaattilons In Studies of Toxicity and Bioconcentra't'ion with Aeuatic Organisms ad. 6. o, Veltn, Windsor, Ontario: International Joint Comisslon, Konasewlch, 0., Secretariat, 1975. 6. Shlu, W. V. and D. Mackay. "A Critical Review of Aqueous Solubilities, Vapor Pressures, Henry's Law Constants and Octanol-Water Partition Coefficients of the Polychlorinated Biphenyls." J. Phvs Cham. Ref. Oata. Vol. 15. No. 2, 19B6, pp. 911-929. 7, Hassett, J, J., J. C. Means, W, L, Banwart and S. G. Wood, Sorption Proper ties of Sediments and Energy Related Pollutants. Athens, Georgia! Environ. Processes Branch, Environ. Research Lab, 19ud, EPA-600/3-80-041, 6-9 HONS 217347 0. Schwarzenbeck, R. P. and J. Vestall, "Transport of Nonpolar Organic Com* pounds from Surface Water to Groundwater. Laboratory Sorption Studies." Environ. Scl. Techno!.. Vol. 15. 1981, pp. 1360-1357. 9. Kerlckhoff, S. u. "Sami-Empirical Estimation of Sorption of Hydrophobic Pollutants on Natural sediments and Solis." Chemosohere. vol, 10, 1981, pp 833-846. 10. Kerlckhoff, S. U, and K. R. Morris. "Sorption Dynamics of Hydrophobic Polly tants in Sediment Suspensions." Environ. Scl. Technol. 11, Crank, J. "The Mathematics of Diffusion." Oxford University Press, 1975, pp. 414. 6-10 WINS 217348 MOWS 217349 IVMUASTQK Of EBOCMOMZMOICM Of HUS S--ncXB BHJMP TO PCS* y JMt BOUT MO RMBSJBf MS BOOOSBC, no. US *.B. 1--tb, suit* SOS aaattia, a tom Md a. xmmdocrcn --dar tba authority of tbo *--io Mxtuot central Act (ffao tbo V.t. Biwli'w--nlal Protaoti-- bgauy b-- xvoodtly wUMlihA a unifor* policy for flaonntaalnation of polrotolortjiatna bipbantyl (Kl) apiH or--a (1). H--art--1 --cent--lnatlcc itiodudi, Akfe dart-- adaq--to oloamy bt tar-- of mloal Kh, and paxtoTvam-- h--art atand--da barn ba-- aotabliahad. Ohdar a parfiw--n-- haul ata--d, olaawy la aooocdan-- with a --aoifiad pro--duro la o--Uand adag--to daaap without p--bel--wp a----lag and a&alyvia. --athar naatioal or porfur--noa b--ad standard# ara apartfiad la dapandant IV-- tba quantity and o--mti-- of tba KB --ill. * optimal aqrtg--nl and awta--ala to a--sofully a--isos aitbar tba t--nrlnal or parfoaaaao^raaafl ataadarda for nlaatiy of try nail--Inal ad aolld aurfaoaa tm aofe ba-- aotabilahad. fba aaad for appropriate aaaaur-- fox plowing -- raaiduaa of poly--lori-tad Upt-yls <KBa> -- a raciaty of --lid aucfao-- ocatlaoaa to ba a high(-priority iaaua oonfrcntiag atillti-- and otbar KB apMp--t o--axs. Bam--(ring tba oonttnuad aaad for a--nod aiaa--p afttcianoy and tba findln-- of otbar taaiar--ara -- tba a--float, tba authors daol--ad a 'itmrt'HT imnaatigati-- to pcovl-- additional oa--arlaoaw of pc--Lrtog aolaauta and oloanaaxo <s>. --a lalwaatoty taata vara daaiqnad to aval-- olaanlag --tarlala on--aoly uaad for nlaaray of both par--a and a--rpo-- aurfao-- by tba apo--oriag utility, aattla City Li--t (Tabla 1), Ban-- tooting antallad tba appll--ti-- of aplbad KB mil--lnalol at--ral oil JW ug/g) onto ola-- aurfao-- to total atfpcod--ly 1,000 ug/ioo or. --a taat aurfao-- -- aayooad to tba scaa for n-- dam at to-- fparvrm* prior to olaaop. la-- poraua aurfa-- --a elaanad by pdpotlag tbo olaaning agint ($ al/100 car) onto tbo taat aurfaoa (irx--ndad by o--iking), a----Mag vitb a --tal tea--, and than ah--log tba vasb vat-- with a poljpttyylano ab----t pad. Tbr-- au-- ---- itacati--a wo 6-U HONS 217350 pTfor--rt prior to >--tiling for noidaal rao. Bach neo-porom surfaoa w alancd fey pipotiag tbo alooning oolutla onto a gouoo pod and wiping tea toot Nrfaoo. nm mob itorationa woro aloe potfonod oo tbo nco-pomus ourfaon prior to sapling tor rnidual POo. After tbroo waah iteration residual vcso won ovaluatod by oollooting a vipo sacplo (n oaob toot ourfooo. Tbo vipo stapling woo porfoaod using a gauoo pad aataratod with bran, to rurtbar evaluate tea lata of tea Peso ^pllad to tea porouo ourfaoao, a iui telanoo of tbo originally applied 2Qo woo attainted. tbo following oaplao won onolyaod for PCBo to porfoa tbo aooo bolonoot 1) Maoorboat pado ooUoetod after oaoh wash, 2) final rinooto fra tbo wtol bnioh and ataal tat used to woab water, and j) tbs 100 a* pikad ourfooo (ran roil by chipping). Qiipo won oolloetod la tbo following lnrn iwiloi VO-inch (ourfooo), met (dapth 2), and final l/d-incb (tepth 2). All PCS analyses a tbo wipo and chip Hgi won porfonod by gas cnraatogxaphy with olootra nptun detection. Cloaning agnto, spike oonontntion, and rooulto fra tbo wipo toots an listed in Table 2. On control aplo was propand for aaab typo of ourfon by placing aplkod IH) noil nine!oil ainoral oil a tbo toot ourfoa and ooUooting o wipo aapla after ana days without washing. trbonogoodonfroantnot.iaotntoof1M.0b2sui^niotoboewa?iVn monmsliogoniofiocUaonotteddifafoftneor noainanktbe waohim oloaing ability woo fond nag tbo thno nlsuing agate uaod fa oonante washing, baaad a o on way analysis of worisan of tbo post wash wipo toots, tbo oatrol wipo nault is oj<prif(aitly higbar tbn oil oonante post wish wipo toots but rgnnti o neevary of only 2.2% of tbo originally applied tbo low nooary of PCbo with tbo central wipo oa^lo Indieateo tbo no oithor abooobod strongly nough to tbo oonroto ourfon te promt rraal by tbo wipo toot, qprood te anw outside tbo toot ana. or pantrated bgn late tha oonroto. adp onpln ooUooted fra tbo oonorote 19 te o daptb of 1/2 inch after n aloaaav roooworod only 20% of tbo originally oppliod Mb. 6.12 NONS 217351 The oouomtretian of PCSa in the vipa taste oollaotad aftar asphalt sashing ranged frm 1.20 to >o.i ug/ioo ear. Pangea and variability van Hub greater for tba an^halt aurfaoao than for tba oonerete surfaces. As ms found vitb oooents washing, no significant diffannoa in PCS elaanup ability ms foiaid mong tba tbraa olaaning aganta uaad for asphalt mahing. Tba control vipa tast, vhieb ms oollaotad aftsr no elaanlag of tba asphalt, rvoovarad a. 17 ug/100 car of PCSo frm tbs aurfaaa. This is lomr than four out of tba niaa vipa tosts oollaotad aftar cleaning, and la not significantly higher than tha poet-mah vipa tasta. last rasults indioata that tba poor raoovary of FC8a vitb tbs asphalt oontrol vipa tast ms dua to strong absorption of tbs KSa to tbs a^taalt aurfaoa, nds ms further indiaatad fay tba naaa haianoa analyaisi raoovary of tba originally applied PCSs in tba mab mtar and chip angles oollaotad aftar olaaning ms <7% to *7%. Tha largest proportion of tba PCBe mm oollaotad in tba chip engilaa oollaotad fron tba surfaoa of tha asphalt (figure 2), rapraamting 30% to 40% of tba originally applied KBs. This high raoovary of KBs after msblng indicates tbs strong affinity of tba KBs for tbs asphalt surfsos. Matot wfl ffiiwlirttfl l lbs oonoontration of tha pcbs in tha vipa sa^laa oollaotad aftar malting tbs natal surfaces vith aaob olaaning agmt ranged fron 1.93 to 4.02 u^lOO cn3. Btatistioal comparisons, using a enemy analysis of varianoa, sbomd no significant diffannoa neng tha olaaning agent abilities to clean painted or unpointed steal; nor oould any significance bo attributed to vbstbar tba steal ms or wpaiated. Unlllta tba vipa tasta oollaotad fron oonerata and asphalt, tha varianoa in vipa tast data oollaotad (ns tha painted and wpelntad steal ms lov. Therefore, any large differentiae naong tha abilities of cleaning agents to slam nan-porous surfaces vould have bean note readily Poor raoovary of KBs fron tba sstal surfaoa ees obtained for tba oontrol vipa aulas oollaotad aftar no vashlng. only 2S% of tbs originally applied KBs mm raoovarad fron tba mpalntad steal, and only W% mm moovamd fron tba steal. Tha mnllriwg surxotndlng tba pointed natal ms fnmd to contain 434 ug pa vhien inomasad tba raoovary of pas fron 32% to 77%. mis indinates tbnt a sigaifioant portion of tba PCBs ^iread outside tba tact area titiniT tba actual pa oontamt vithia tba tact area. based on tba laboratory benob tests, designed to evaluate spills of lov nraimntritirai (lass thaa SOO ug/g) pa oontaaisatad-ainaral oil, tbs following oonolusioos am sadai a rm mail ml ml ail ainaral oil pmfarentislly apmada laterally across moraefcad surfaoas of oonamts. Over a seven-day period vitb lass than 2 g/100 an3 of ninsml oil originally applied to a oonomta surfaoa, KBs mm found to have ^read outside tba 100 or tact arcs outlined fay oaulJtlng. Mom KBs mm moovamd fron tba csulkinq bordering tbs test area, than fron chip sanies oollaotad fron vithia tba tast area at a daptb interval of 1/4 inch to 1/2 incU. 6-13 HONS 217352  Wlpo tooting after tba elaaap of aonomte aurfaoaa indicated that all cleaning aganta tereed ware enable of cleaning tba ocnaraU teat airtanaa to tba lawal of elaaap required for all oatagerlae tndar the fHt P3 apill elaaap policy, luwwr, aaaa balance detaminatioua during tba baneb taating on ooooxata indioatad that a -<<-- f g% to oat of tba PCBo la tba taat ana raaaiaid la tba eenereta after cleaning. Iban la a naad for additional raaaarcn regarding tba potential fata of tba retaining PCBa, and tba applicability of wwfailttlca to oleaaad oooorata. a BJ i tail ml naiad alaanl oil ahanrbad atnugl.y to albeit, tba apraad of pcse aciroaa tba asphalt aurfua. fbe severity of tba P9a recovered aftar olaanlng, whan obtaining a aaaa *i---- of tba originally acpliod PCBa, wan la tba chip an^ilaa oolleoted tn tba aapbalt surface. o Tba atrong abaorptlan of PCBa to aapbalt Inhibited raaeval of PCBa by tba elaaap pnoabma evaluated, and Iwhibltad taoovery of aurlieial PCBa during tba wipe taat pnoadure. Laas than 10% of tba PCBa wan imnral fna tba aapbalt aurfaoaa during tba oleaap prooaduna. Pipe taatlng wta highly variable, and a wipe taat eolleetad baton elaaap u lower than aavaral wipe taata oollaotad aftar deaap. o Mo aignifioant diffaneoa between tba aMHHaa of Panatom, TBP or Mna to dean 9 pri-oonmlTiatad palatad or wpalated otaal could bo detected. Baaed on wipe aa^laa ooUootad aftar wntdag, all tba meaning aganfee taotad ware able to dean tp tba natal aurfaoaa to aocwptabla level* under tba m pa apill policy. tbla otady waa agported by tba Baaaaicb and r*velo|aent progna for tbo City of Oaattla, paattla City light tftiiliwilal Affalxa Division) wdar tbo dinotion of Krla Banoan. Additional finding apport wan raoaivad fna tba tear!can MUo Power haaodatlon,a COD ywyna. (1) O.B. torlrry--itat Protaction Agamy. 1M7. Pdychloriaatad bipbmyl* apill "1--TMT pelioy. O.a. OB, mahlngten, o.o. Meal Baglatar, wd. ax, M>. S3. Ip. 100*0-10710. (X) Ponrtmii 1007. pa deaap naoarob. Pinal taport. pnpand for Oaattla City Ufpb. BooCban, Zno., OaatUo, u so fp. HONS 217353 6-14 PCB CHIPS FROM CONCRETE CHIPS FROM ASPHALT U fcO/fl PCB 6-15 HONS 217354 MLB 1 HKTTOXU EVXLOffl tscBR ama test oowmcn Dataraant/telvant Triaodiua itosphata MhU Paintsd Oalvaniaad b b b b b b * That oonditioaa wn raplioatad tbraa tinaa to dataalna trltfitn rraanainr variability, tar aaob traataant, wash prooaduraa vara than final KS ocntant mi tetualMA for tba aolid snrfaoa by a vipa taat. tar ena of aaob taat ooodltieo tba following jilaa vara oollaotad and analyiad to svaluats tba fata of tba agpliad vchai - bbaotbapt pads oollaotad aftar aaob waah. - Final rinaaata tna tba natal brush and ataal box uaad to "--**" waab wtar. - Chips tram, tba taat sanpla aurfaoa and two lowar depths. b Taat aondltiQas vara raplioatsd tbraa tinaa to dstatalna witbia-traataant variability, tar aaob traafaat, tba ataal mi vaatoad tbraa tlnas* Umo a vlps aapla oollaotad and analynd to avaluata raaidual Rha. 6-16 HONS 2I.7355 TMX 2 OOKIIQ VZMTS, WOT aWCWnUBICNO, MC WIPE TEST RESOWS Cl--ning Average weight of K9 Spiked (un/loo Txiaodii-- itoophata OcntrolD 7. too. loot. 1022. j painted Steal Ttiwodlm Phosphate OontrolD Trieodlm Phosphate OontrolD 070. 077. 071. too. 024. 000. 113. 070. Q^piintid (tad Trieodii* Phosphate Ocntrol 0C7. 070. on. OM. ----- Wiot Toat Result__ (ux/100 tan standard Deviation 2.22 1.C1 3.U 1.30 2.43 0.30 22.4 (one staple) u.a 3.32 12.3 2.17 i ! 10.3 1.54 10.3 1.47 0.31 2.02 0.70 2.23 1.23 322. (one stapls) 2.23 1.03 2.30 0.45 2.73 0.17 243. (one eaple) * Test ar-- spited with ninarnl oil containing P3 Aroelar 1200 at 4ii vq/q. b Burfaoe spiked the seas as otter toot sopl--, bat no washing perfoxaed before wipe toot. 6-17 HONS 217356 MQNS 217357