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Monsanto MONSANTO WOUSTVHAL CMMfOALS 00. tOO H. Lrndboffh l0u(tvir4 St. Logit, Mrourt 6316? *h00: 014) e*4-1000 ^. May 21, 1984 TSCA Public Information Office (TS-793) Office of Toxic Substances U.S. ENVIRONMENTAL PROTECTION AGENCY Room E-108 401 "M" Street, Southwest Ueahlngton, D.C. 20460 Deer Sir: Re, No. OPTS-6203S Comments In Raaponae To Advance Notice Of Proposed Rulemaking On Use Of PCSa In Electrical Transformers (49 FR 11070) Monsanto Company, a broad-baaad manufacturer of chemicals, welcomes the opportunity to comint on this proposed rule. General Comments The EPA should proceed csutlously In proposing as yst another rule on the use of PCBs In transformers. It should not allow unfounded crisis mentality to provoke decisions without a complete assessment of avelleble analytical and health Information coupled with a determination of the economic Impact. This PCB transformer rulemaking la truly a case where benefits vs. risks should be very carefully evaluated. The firs resistant properties of PCBs clearly offers certain safety benefits for electrical equipment use that have stood thm teat of time - over 50 years. However, scientist* era Just now able to actually quantify the comparative fire risks of transformer units containing alternative dielectric fluids. In addition, tha effects of various othar potential health and environmental proper ties of possible PCB replacement dielectric fluids has not been adequately Investigated and defined. The Agency should act carefully In revisions to Its PCB transformer rule otherwise a mors serious problem may arise. Industrial usage of PCB electrical equipment has been shown to be safe and affective. Data submitted in this rulemaking by tha Chemical Manu facturer* Association (CHA) details chemical Industry PCB transformer usage. Including*Monsanto Company. Lessons learned from Industry should apply to other commercial building and utility Industry usage of PCB transformers. tfftll Of Mvnaomo Comomv MONS 216084 u.s. environmental PROTECTION AGENCY -2- JKC 5/21/84 At a CMA tubtr, Monaanto contributed data and technical expertise to the coBHDta aubmlttad In thla rulemaking by CMA for the Induatry. Therefore, Monaanto Company tupporta and adopta other commenta aubmlttad on thla subject by the Chemical Manufacturers Aaaociatlon. In addition, EPA should carefully evaluate the costa to Induatry and the national economy of a total elimination program. Thla should -include coats of nev equipment, removal and Installation coats, radeaigir and construction coats, and storage and disposal coats for uaed PCSa and related Items. Any risk assessment decision should take Into account whether a massive PCB ellmlnatlon/control program for electrical transformers at a significant coat will have a major Impact In reducing potential risks from.toxic com bustion products In building flrea. Tha Agency should provide substantial evidence that a new PCB transformer rule la necessary and la Justified on a coat/benefit aa veil as health and safety/benefit baala. Specific commenta relating to queatlona posed In the ANPR are addressed below. Quantitative Comparative Fire Risk Aaaeaament Of PCB-Aakarel Va. Mineral Oil__ Little If any Information la currently available which quantitatively asaaaaea and compares the fire risks of polychlorinated biphenyls (PCBs) with other common dielectric fluids, although such fluids have bean used on a wide baala for over 50 yeera. Monsanto Company has had In progress for over e year a study assessing and comparing fire risks of PCBs and of mineral oil, the moat commonly uaed commercial dielectric fluid In transformers. Ths quantitative risk assess ment, though not complete st thla time, does provide a valuable Insight Into the comparative risks and benefits of PCBs ea flame resistant dielectric fluids. The study ahowa that the average frequency of e fire starting and spreading beyond the trenaformer room la 300 times greater for a mineral oll-fllled transformer than for an askarel-fllled (PCB plus trlchlorobensene) trenaformer. In addition, the anelyaea Indicates that there la a signifi cant decrease In the risk of fatalities when a mineral oil transformer la replaced by an eakarel (PCS plus trlchlorobensene) transformer. A copy of the Technical Summary of thla Comparative Transformer Fire Risk Study la attached ae Appendix I. A copy of the full study report will be made avail able to the Agency when completed and published In several months. Such fire risk Information le essential In EPA's considerations of the "significant risk" assessment of PCB use In electrical equipment. Before asking e rash decision which may placa human eafety and property damage In even greater Jeopardy, the Agency should consider and evaluate fire risk of the various alternatives proposed for PCB fluids. Including purs PCB fluids and "gakerel blends" which nay contain PCBs end trlchlorobensenas. By the use of quantitative risk assessment techniques, which have been developed for the nuclear Industry, consultants, such aa the renowned group which perfoTraed the transformer fluid atudy for Monaanto, ara now able to apply these techniques to other potential risk situations, speci fically the transformer fluid issue. moms 216085 u.s. environmental PROTECTION AGENCY -3- JHC 5/21/84 f.tmtti Of Fire Frequency Accurate estimates of fire frequency of PCB transformers are not available alnca aueh racorda ara not routinely reported and recorded; and If flrea are reported and recorded, the appropriate category and detail nay not be accurately represented. Thla repreaenta a major difficulty In performing a quantitative aaaeaaaent of fire rlaka aa dlacuaaed previously.- In addition. If auch Information la currently available, care auat be taken to aaaeaa lta validity, hence one of the reasons for the coata and delays of fire risk aaaeaaaent studies. . For example, EPA cites (49 FR 11077) data from the Director General of the Finnish Institute of Occupational Health (PIOH) In support of the validity of EPA'a estimates of PCB transformer fire frequency. Yet In our study of the quantltetlve fire risk assessment of transformers, communications with the Director General of PIOH1 indicate that the EPA aatlmate baaed upon the Finnish data la probably Incorrect. The Director Genaral stated that tha Finnish data provided to U.S. EPA vac baaed not upon transformers but upon their report1 of capacitor flrea and leakages! (These data were reported by the Director General at an International confarenca on PCBa at Reaearch Triangle Park, North Carolina, September 12-14, 1983. Press reports of the preeentatlon erroneously referred to the Finnish (28) Inci dents that Implied that they were transformer Incidents. Thus extrapola tions reporting there nay be 1,120 auch Incidents In tha U.S. each year were In error. ) Toxic Combustion Products Of Transformer Flrea In addition to considering the fire rlak/beneflta of PC3 va. other dielectric fluids, tha Agency should thoroughly lnvaatlgate tha formation of toxic com bustion products from all fuel sources. In two of the fire incidents dis cussed by EPA In the ANPR, re Binghamton, New York and San Francisco, California, the Information dlacueaea at length tetrachlorodlbenzofuran (TCDP) and dioxin (TCDD) and Imply that the major source of these problem toxic combustion prod ucts in the building flrea la the PCB. Little If any al^lfleant Information la available on other combustible mate rials which ware consumed In either fire, Including trash or foreign matarlala stored In the electrical vaults, wiring and cables, along with associated electrical components that burned or pyrolyzed, paint and construction mate rials of the vaults and buildings par as and any other possible materials which served aa fuels for the building vault flrea. 'Personal Communication from Dr. J. Rantanan to Dr. M. Kazarians, January 1, 1984. 2J. Rantanen at al, "Recant P(2 Accidents In Finland", CCERP Confarenca on Potential Health Effects of PCBa and Related Persistent Halogenated Hydro carbons, Research Triangle Park, North Carolina, September 12-14, 1983. 'Chemical Regulation Reporter. September 23, 1983, Pg. 845. MONS 216086 u.s. environmental PROTECTION AGENCY 5/21/84 Raporta fro both of thaac fire lncldanta have baas fragmented and are incomplete. However, for exaaple, early raporta In tha uadi* and from on-the-acene obaarvera Indicated that In both caaea foreign aaterial other than dialactrlc fluid coiibuated. Binghamton - Large quantity (caaea?) of rubber "V" belta uaed to drive ootora were atored in tranaforaer vault. (One report indicated the caae(a) were on top of the tranaforaer .J Hiring and cablea burned. San Franclaco - The fire in tha vault "smouldered'' for eeveral houra, perhapa aa long aa eight, due to burning wiring and. cablea before the fire vaa put out. Coabuatlon of materials auch aa rubber gooda, wiring and cablea could account for large quantltlea of eoot in both of theee Incidenta. Before the Agency proceeda with any revlaion to the PCB tranaforaer rule, it ahould conduct atudlea to detenine ell aourcea of the varloua combuatlon producta of the flrea to lnaure that a new PCB tranaforaer rule la appropriate and neceaeary. For axampla, in tha ANPR the Agency expreaaea concern over praaence of TCDO in the reaiduea of tha tranaforaer flrea, yet TCDD la generated from trichlorobenzene, a major component of many askerel tranaforaera, and the Agency ramalna ailent on the manner in which it lntenda to proceed to eliminate or control both the trichlorobanzene fluid source and the combustion/pyrolysis producta thereof, including TCDD and poaaibly TCDF. Reapectfully aubnitted, / dg Attachment bcc; J. 1. Condray R. A. Feneterhmlm J. C. Kaaaif P. S. Perk/P. H. Smith John R. Craddock Product and Environmental Safety Director MOWS 216087 APPENDIX I Technical Summary of _ . - COMPARATIVE TRANSFORMER PIRE RISK STUDY by Pickard, Low*, and Garrick, Inc. Nawport Baach, California Technical Summary Prepared by Raymond A. Preeman and Raymond P. Boykin Engineering Technology Corporate Engineering Department St. Louis, Missouri May 11, 1984 MONS 216088 A risk initnt comparing th* us* of mineral oil and Askarel di*l*ctrlc fluids in two typical offic* bull-ding transformer applications has b**n completed (4)-. Tha study was don* by the consulting firm of Pickard. Low*'and Garrick, Inc. of Newport Beach, California. Th* study shows that th* average frequency of a fir* starting and spreading beyond the office building transformer room is GOO.times greater for a mineral oil-filled transformer than for an Askarel-filled transformer. The analyses of both office building transformer applications indicate that there is a significant decrease in the risk of fatalities when a mineral oil transformer is replaced by an Askarel transformer. A typical Askarel consisting of 50% Aroclor* 1254 (PCBs) and 501 1,2,4 trichlorobensen* was used in the study. Th* use of trichlorobensen* as a blending fluid reduces the fire resistance of the resulting Askarel mixture when compared to essentially 1001 PCB fluid. The study was done to evaluate th* impact on fire risk of the decision to replace mineral oil by PCBs as the cooling and insulating fluid for electrical equipment. Risk is taken to mean th* likelihood of a hasard resulting in th* actual delivery of loss, injury or some form of damage (2). By contrast, a hasard is defined as th* source of danger (2). In this study, fire risk was defined to include th* frequencies of fatalities, injuries and fires spreading beyond the room of origin. In the study, mineral oil transformers are compared to Askarel transformers. The term Askarel generally refers to a generic name for a broed class of fire resistant synthetic chlorinated hydrocarbons used as dielectric fluids. Por th* purpose of the study, the term Askarel refers to a mixture containing 50% PCBs (Aroclor* 1254) and 50% 1,2,4 trichlorobensen*. Two separate cases are considered in the evaluation of fir* risk for the two types of transformer fluid. The first -1- MONS 216089 (Case 1) involves the installation of the transformer in a one-hour fire-rated roots in a general use basement area of an office building. The other (Case 2) involvae a transformer room with a three-hour fire rating in a nonpublic use baeement of an office building. These two cases describe typical transformer installations used for Aekarel and mineral oil transformers respectively Iti - building applications, and meet current National'Electrical Code standards (3). The fire frequency, injury and fatality data used in this study were obtained by analysis of several fire incident data bases which are detailed in the final report (1). - _ Results The results of this study show a significant decrease in fire risk When a mineral oil transformer is replaced by an Askarel transformer. The likelihood of fire spreading beyond the room of origin is 300 times greater for a mineral oil transformer than for an Askarel transformer in Case 1 and 1000 times greater in Case 2. Table 1 presents the mean fire frequencies for each case. Table 1 Transformer Ffre~Frequencies (events per transformer year) Transformer Fire Fire Spreads Beyond Transformer Room Case 1 Askarel minerel oil Case 2 Askarel mineral oil 2.0 x 10-4 2.5 x 10-4 2.0 x 10-4 2.5 x 10-4 4.6 x 10-7 1.5 x 10-4 7.3 x 10-B 7,3 x 10-5 M0NS 216090 2 To provide a better understanding of the number* presented in Table 1, consider the case 1 Asksrel transformer fire frequency. The frequency of an Askarel transformer fire le 2*0 x 10-4. This means one fire every 5000 year* or every 5000 transformer yeara. If the current number of Askarel transformer* i* 140,000, this equates to 28 Askarel transformer firee per year. - ' An important factor of the Askarel transformer fire is the presence of trichlorobensene. If an Askarel transformer did not contain trichlorobensene, the frequency of -fire would be significantly smaller. This is because the trichlorobensene has a flash point of 99 C and PCB (Aroclor* 1254) does not have a flash point (Cleveland open cup flash point test (4)). Using the fire frequencies from Table 1, the fatality frequencies were calculated and are listed in Table 2. These calculations assume that about 1 in 1000 (1.2 x 10*3) of all fires confined to a transformer room would involve one or more fatalities. For fires spreading beyond the transformer room, about 1 in 100 (8.B x 10-3) were assumed to result in one or more fatalities. The frequency of a fire being confined to the transformer room was computed by subtracting the frequency of a fire spreading beyond the transformer room from the total frequency of transformer fires. Several statistical points of comparison are presented in Table 2 to show the uncertainty In the calculations. For all points of comparison, Askarel-filled transformers have a lower frequency of fatalities than mineral oil-filled transformers. Table 2 Transformer Fire Fatality Frequencies tNatality events per transformer year) statistleal Point of Comparison Case 1 Askarel mineral oil Cass 2 Askarel mineral oil Mean 2.4 x 10-7 1.4 x 10-6 Percentile 5th 8.6 x 10-10 1.7 x 10-7 95th 5.9 x 10-7 4.3 x 10-6 2.4 x 10-7 8.5 x 10-7 2.0 x 10-9 5.9 X 10-7 1.3 x 10-7 2.7 x 10-6 MOMS 216091 3 In both of th* cases, room fir** ar* th* dominant contributors to th* risk of Askarel transformers. Fir*s that spread beyond th* room ar* the dominant contributors to th* risk from mineral oil transformer*. This suggests that th* risk from mineral oil transformers could b* much greater than from Askarel transformer*, sine* a firs that spread* beyond the transformer room is of more concern than a fir* that is contained within th* room. Historical data (5) suggest that there is a greater likelihood of multiple fatalities when a fir* spreads from its room of origin. References 1. M. Kasarians, B.J. Garrick, T.L. Chu, and V.M. Bier. "Comparative Transformer Fir* Risk Study," Technical Report Number PLO-0356, Pickard, Low* and derrick, Inc., Newport Beach, California, 1984. 2. S. Kaplan and B.J. Garrick, "On The Quantitative Definition of Risk," Risk analysis, Vol 1, No 1, March 1981, pp 11-27. 3. "National Electrical Code - 1984," National Fir* Protection Association. 4. "Flash and Fir* Points by Cleveland Open Cup, Test," American Society for Testing and Materials, ASTM Standard D 92. 5. "California Fire Incident Reporting System," Annual Report, California State Fire Marshall, 1982. 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