Document ypXLdELz97oEGg52G8Rn1xd96

2S iino|;uiis3E le c tric C o r p o r a t i o n Mr. Stephen R. Wassersug Director, Enforcement Division Environmental Protection Agency Curtis Building 6th and Walnut Streets. Philadelphia, Pennsylvania 19106 r-tli: V - '!**r September 16, V.J vj. c C'i 1 r*!v.. 1975 j rd Re: Request For Information - Polychlorinated Biphenyl Compounds or Mixtures___________ Dear Mr. Wassersug: In response to the request of the Assistant Administrator for Enforcement, U.S. Environmental Protection Agency, Westinghouse Electric Corporation submits the requested information for Westinghouse facilities which are known to handle poly chlorinated biphenyl compounds or mixtures (Attachment' A ) . Due to the lack of sufficient time and because records are not customarily maintained for all of this information there are some facilities for which a complete response cannot be made. With reference to the above-referenced letter and the questions attached thereto, Westinghouse has the following additional comments: 1. The presence of polychlorinated biphenyl compounds in the environment has been recognized for some period of years and has been a concern to the electrical industry. The industry recognized, that because of the documented need for the continued use of polychlorinated biphenyl compounds in capacitors and transformers to provide the public with safe, reliable,' and efficient electrical equipment, unusual protective measures would have to be taken. Westinghouse did not delay in introducing a new capacitor dielectric (Aroclor 1016 from which the higher-chlorinated persistent homologs have been substantially removed), sealing drains in manufacturing areas where PCB's were used, utilizing incinerati' facilities for scrap material and PCB EXHIBIT 904451 ms Page Two September 16, 1975 contained wastes specially designed for the destruction of P C B 's or special land fills, and instructing operating personnel and users regarding the need for care and waste disposal (Attachments,B and C ) . Most of these methods were implemented prior to the enactment of the Federal Water Pollution Control Act Amendments of 1972. 2 Any environmental standard or regulation must be developed upon a sound legal and technical basis. , The history of the usage of polychlorinated biphenyl compounds reflects that while they were initially used in other applications, the only domestic supplier of polychlorinated biphenyl compounds voluntarily limited their sales to the electrical industry in 1971. Therefore, laboratory and environmental studies should reflect the types of polychlorinated biphenyl compounds used by the electrical industry for setting any effluent standards relating to capacitor and transformer facilities. Furthermore, the results of these studies should be made available to the scientific community and the Science Board for evaluation before they are used as a basis for any regulation. Very truly yours, a REWrmlm Enclosures Rog'er E. Wills, Jr. Attorney 904452 r jr-'> .-// poi,va!?,oninAT]:D biphenyl -'pen) compounds or 'mxturlt. 1.. For each PCB compound or m ixture produced or imported C by your company, for each company facility, during each year of 1271, 1272, 1573, 1974, and the first two quarters of 1975: a. The total amount of each PCB compound or mixture produced or imported. C b. The name and address of each of your c o m p a n y 's facilities which handle PCB compounds or mixtures (including production facilities and wholesale and retail outlets), and the amount of each PCB c compound or mixture distributed through each facility. c. The name and address of each customer of each PCB compound or mixture, and the amount of each FCB compound or mixture obtained by each customer from each facility. The entire question .is not applicable for all facilities 2. F o r each PCB compound or m i x t u r e incorporated by y our company into its products, for each company facility, c. during each year of 1971, 1572, 1973, 1974, anc the first two quarters of 1975: a. A description of each product. 1. Sharon - Transformers c 2. South Boston - Tra n s f o r m e r s 3. Bloomington - C a p a c i t o r s 4. Cleveland - Capa c i t o r s 5. Repa i r facilities - Transformers b. For each proavict the total amount incorporated of each PCB compound or mixture, (pounds) (cst.) v 904453 ^I For each product the name and address of each source from which your company obtained each PCS compoundor mixture, and the* r- of each PCIi compound or mix ture obtained from ouch source. For all products and all faciltiics the source is Monsanto Chexa: 800 North Line St. Louis, Mis 904454 production faciliti.:: and ^wholesale and rc', ai l outlets') , and the* amount of (.neh j^reduet d i s tributed through each facility. 1. Westinghousc Electric Corporation' Power System': Transformer Division 469 Sharpsvillo Avenue Sharon, Pa. 16146 2. Westinghouse Electric C orporation Small Power Transformer Division Box 9 20, Highway 58W South Boston, Virginia 24592 3. Westinghouse Electric C orporation Distribution Apparatus Division Curry Pihe Bloomington, Ind. 47401 4. Westinghouse Electric Corporation Outdoor Lighting Division 1216 V.'est 58th Street Cleveland, Ohio 44102 5. Repair Facilities - See Atta c h e d Chart e. The name and address of each c ustomer of each produc and the amount of c-ach product obtained bv each customer from each facility. For consumer products list only the total production of each product at each facility and the total number of customers. Do not provide the name and address of each customer of consumer products. For each PCB compound' or mixture used by your company in its operations other than for incorporation into its products, for each company facility, during each year of 1971, 1972, 1973, 1974, and the first two quarters of 975: 7\ description of each use 904455 b For each uo-e the to al amount of e.-oh PCE co*pound or mixture. For each PCB compound or mixture reclaimed by your company, for each company facility, during each year of 1571, 1973, 1973, 1974, and the first two q uarters c-f 1975:. a. The total amount of each PCE com p o u n d or m i x t u r e reclaimed.' b. The name and address of each source from w h i c h your company obtained PCE compounds or mixtures, ancl the amount of each PCB compound or mixture obtained from each source. The entire question is not. a p p l icable for all facilities. 1 -A - 904456 For each I'CE compound or mixture d i s p o n e d of by your company .(vi ih or without the involvement of other par tie for each company .facilit.*, during each year of 1973 , 1972, 1973, 1974, and th first two" quarters of 1979: ti. 7v description of each method of disposal. b. For each method of disposal the total amount of each rCB compound or mixture. c. For each method of disposal, the location of every disposal site, the name and address of each party involved in the disposal of each PC3 com pound or mixture, and the amount of each PCH compound or mixture disposed of by each party. DEFINITIONS AND SYMBOLS U S E D FOR TilIS- SECTION 1. Incration of liquid wast e s by Monsanto, Sauget, 111., G22G1, using approved thermal oxidation, scrubbing and neutralization. 2. Incration of liquid w a s t e s by Chem-Trol P o llution Services, 1550 Ealmer Road, Model City, New York 14107, "using thermal oxidation, scrubbing and neutralization in accordance with New York State and Federal Pollution Control C o d e s . " (See Note to No. 3). 3. "Drummed solids and capacitors shall be disposed o f (by Chem-Trol] in an approved scientific landfill in accordance with New York State and Federal Pollution Control Codes. All leachate shall be trapped, tested and treated as necessary prior to release." NOTE: Contract with Chem-trol provides further that "No other method of disposal shall be used. There shall be no re-sale of any waste or the prod of any waste received by Chem-Trol under the terms of this Contract." 4. Neal's L a n d Fill Off Road 603 Owen County, Indiana 5. Special Designated S e c t i o n of Monroe County Landfill Monroe County, Ind. 47401 904457 6. Valor; Vcidc:; Lana 1111 8. 11. Koch hand Till 26301 S. Crenshaw JJl.vd. Harvard. 6 Cast 78 St. Rolling lliJls, California Cleveland, Ohio (Special Area for Diepoaui of PCD Contaminated Was tea) 7. Richmond Sanitary Dump 9. Rockr.ice. Reclamation, In Richmond, California 5661 Canal. Road (Special Area for Disposal of Cleveland, Ohio PCJ1 Contaminated Wastes) FACILITY s h a r o :: YEAR TYPE (2) Liquid (3) Soi id SOUTH BOSTON (2) Li quid (3) Solid 1 '".COMIKOTON Liquid Solid CLEVELAND Li quid Solid REPAIR FACILITIES 6. The composition of each PCB compound or mixture produced, imported, sold, reclaimed, used, and/or disposed of by your company since January 1, 1971 C^ -6904458 f > V t 1 4 f L5 * 4 7. T h e result of tiny and /: : -samplin'; ami- analysis performed by your company, its ago. Ls or contractors, since January 1, 1971, concerning the -foi'owing*. a. Concentrations of Kjj; compound.-; or mixtures in -the .j effluent of any discharges by the company (into waters ; of the United States, or Publicly Owned Treatment V'orhs) or in the emissions of the company into .the air. b. T h e flow .and/or. composition of ;any discharges or ernissi c i by the company (into .'waters of the U n ited States or \ Publicly Owned Treatment -Works, or into trva*.ai.r) which I contain PCB compounds or mixtures. \ c. Concentrations of PCB compounds or mixtures in receivingj waters (both upstream and downstream) of any discharges t by the company, which contain PCB compounds or mixtures i iand concentrations of PCB compounds or mixtures in the air in the area of the company. PCB ANALYSES Sample Date 2/13 2/21 4/16 5/1? 6/18 7/17 7/30 8/13 8/30 10/15- 11/15 2/13 2/21 4/16 5/17 6/18 7/17 8/13 8/30 10/15 11/15 Sample Location 18 74 Westinghouse Sharon -- R-Building Westinghouse Sharon A-Building 904459 1254) (3 260) (12.C0 ) (1260) (1260) (1260) (1260) (1260) 9.7 (124 2) II 9.0 (1260) || 10.6 (1260) (I 3.3 (1260) |l 4.8 (1242) |i .7 (1260) .4 (1242) ; 2.5 (1254) ' 1.7 (1260) ; .4 (1260) .3 (1260) j .5 (1260) j .4 (1260) i 1.04 (1260) j 1.1 (1242) j .7 (1260) ; .2 (1242) 1 .3 (1260) ' . 1 (1242) .2 (1 26 0) . 1 (3 24 2) I r Sample Date 2/13 2/21 4/16 5/17 6/18 7/17 7/26 7/30 7/31 8/13 8/30 10/15 11/15 Date 2/20 2/27 3/06 3/13 \ V '4/23 5/29 6/26 7/31 8/30 10/02 10/31 11/26 12/30 Date' 2/26 2/27 3/01 3/06 6/05 8/12 10/08 11/10 12/12 Sample D M :o V?o3t.;mjhouse Sharon Power House . South Eoston Bloomington -0- Kcnnl l:r. 40.0 (1252) 26.6 (3 260 ) 2.2 (12C0) 1.7 (1200) 5.0 (1200) 219.0 (1200) 1.7 (1260) 1.7 (1260) 1.3 (.1200) 1.4 (1200) .8 (1242) 9.0 (1260) .1 (1242) 1.6 (1260) 5.3 (1242) .6 (1260) .6 .(1242), (PPB) 33 180 '4 8 34 5-*? 790 133 135 106 42 54.0 235 377 183 (PPM) "22.2 (se do 1.7 .90 3 3.2 1.8 2.3 1 .8 .26 .43 904460 ] 75 1/0 2/24 4/24 5/30 7/11 VJcsti -igliouse Sharon R - Building (ppbLc-- V . 19.1 /l26u) 2.8]/( 12G0 ) ) 2.1 VL260y (Sampler Inop 1 1/8 2/24 4/24 5/30 7/11 1/8 2/24 4/24 5/30 7/11 6/05 Westinghouse Sharon A-Building V7estinghouse Sharon Power House South Eoston 3. S /(1 2 G0 ) 0.23(1260) 5.5 U 1260) 0.33 12 G0 ) 0.72fil20) 1.6 1260) 10.97 1260) 1.9 1260) 0.9 8 (1260) 1.75. ( 1 2 6 0 28.6 1/09 1/09 2/3 3/1 4/30 5/30 Bloomington (PPM) 4.6 3.17 .526 .964 .268 1.93 In addition, a sampling program was undertaken in February 1971 at Bloomington which indicated 3-40 ppb in the discharge with a rate of flow of 240-280 gallons/minute. The daily r a t e of flow from Sharon is: Power House, 252.000 gallons; A-Building, 378,720 gallons; and R-Builaing, 504.000 gallons. The South Boston facility discharges in a batch process w i t h a daily rat e of 13,50.0 gallons. -9904461 r r C c ( v .< V c & 'V .1 The flow from Blooming t/..< to the sanitary sewer for the dates sampled are as foil.ws: Date Gal/Pav . 2/26/74 2/27/74 3/01/74 3/06/74 6/05/74 8/12/74 10/08/74 11/10/74 12/12/74 1/09/75 1/09/75 2/3/74 3/1/75 4/30/75 5/30/75 Sewer clogged-Sc-wn g c baci: 225,615 232.460 232.460 178,000 252,502 186,544 183,874 160,734 109.481 189.481 162,069 134,924 118,637 106,177 Receiving waters have been sampled at the following locations with the indicated results: Sharon Shcnanco River at Bank above Clark Street Bridge Shenango River at . Bank by Clark Street Substation (below dis charge) 6/6/74 6/6/74 0.1 ppb C .1 ppb Bloomington Clear Creek 1/9/74 0.25 ppb (above Sewage Treatment \ Plant) Clear Creek 1/9/75 . 5 ppb .(below Sewage T r e a t m e n t Plant) 8. The m e thods by which PCB compounds or mixtures are t r a n s ported to, by, and/or from your company, including: a. A description of each method of transportation, and the form in which PCB compounds or mixtures are transported by each method. Where different methods of transportation are used at different facilities specify which transportation method is used at each facility. - 10- 904462 Sl -'OK Wcstin'ihouso Electric Co poration (purchased material) Via bulk tank --.rs (rail) . via truck in Sii gallon drums. F r o m W o s t i n y h o u s c Electric Corporation (.scrap Incrtcen) . S c r a p Incrtcen Via tank truck. (Sec question 5.) Sc r a p Incrtcen Via truck in 55 gallon drums. (See question 5.) F r o m W e s t i n g h o u s e Electric Corporation (material shipped IN_ Transformers). Shipjjed Via common motor carrier or rail transport. From Westinghouse Electric Corporation new material PDS 54201KA in 55 gallon drums for field filling of transformers. Shipped Via common motor carrier. Each shipment of new material from Westinghouse Electric Corporation has the following instructions and information given to the carrier. INERTEEN Method of Shipment: Packaging : Ship via all modes. Pack in leakproof container (see n o t e ) . I I j Mar):ing : Labeling : No marking required (except on water shipment container must be marked): "Liquid Plastics No Label Required". No label required. ! j jj Billing : ' Bill as "Liquid Plastic NOI" and add the following statement: "This product contains polychlorinated diphenyls (PCB's) which some studies have shown may be a persistant environmental contaminant. Prevent any entry into the environment through spills. During shipment avoid spills and leakage into inland waterways and the sea. Keep away from food, animal feedstuffs, and pharmaceuticals. In case of emergency concerning this shipment:, call collect 610-271-5835, or Chemtrec 000-4 24-S 300.' Note: Any leakage will result in shipment being refused or stopped in transit. Leakage may cause liability for environmental damage. - 11- 904463 I>!<W s o u t Jj o s t o :-: Received vio h IIJ: ton): cari; from Honx.-nto. liquid anWB*tlid wastes, are shipped from South -Boston' by Privately-owned tank trucks arid vans' of Cheni-Trol, Inc. Shipment of transformers containing PCB's are by common carrier BLOOMINGTON received via bulk tan); cars from received via 55 gallon drums from common carriers. Liquid and solid wastes are shipped from Bloomington by privately-owned tank trucks and vans of Chem-Troi, Inc. Shipment of capacitors containing PCB's are by common carrier. REPTilH FACILITIES (see attached chart) b. The names and addresses of all known transporters of PCB compounds or mixtures. L & N Railroad 908 Broadway Louisville, Kentucky Transport Motor Express 3190 East 79 Street Cleveland, Ohio 44104 Monsanto Chemical Co. 800 N. L ind berg Blvd. St. Louis, M o . . 63166 (Plant:S a u g e t , 111.) Anderson 1511 Lakeside Ave. Cleveland, Ohio 44114 M o s s Truc k i n g Co. Charlotte, North Carolina Chem-Trol, Inc. Model City, New York 14107 C & H Transport Dallas, Texas A & 11 Truck Line I n c o rporated 1111 East Louisiana Evansville, I N 47717 -12- 904464 9. All occasions (including spills) of which you arc aware on which I'CH compound:; o- mixture:; have or may hav<? been i n t r oduced into the c nv<.wnment. In particular, de::.cribe .such occasions insofar as they involved RCB c o m pounds or mixtores in -their liquid state, as incorporated into closed systems, or as incorporated into open .systems. For each occasion, indicate nano and address of party in volved; dates, time, and location of the discharge or spill and the amounts involved. 1. March 1972 - Rail tank car (Ho. ACFX4016) was dripping PCE upon receipt. The amount is unknown. 2. Carrier claim reports have indicated some leaking capacitors, however, only in one case is there information that PCB's were introduced into the environment. On 5/20/74 at 2: 00 A.14., an A&H Truck Lines Trailer truck loaded with 4 capacitor racks and other equipment, overturned on U.S. Route 50 about 17 miles southwest of Bedford, Indiana. In this accident, capacitors broke resulting in sens loss of PCD. Leaking units w e r e placed in sealed drums and sent to Chcmtrol. Soaked dirt was shoveled up (by Westingnouse personnel), ard p u t in sealed drums and sent to Chemtrol. 3. On 3/23/72 a Moss Trucking Co. truck veered off Route 158 approximately ten miles west of Roanoke Rapids, north Carolina. Five transformers w e r e dumped from, the truck trailer and approximately 1, 000 gallons of Inerteen was spilled. The sa'fety . inspector for Moss Trucking Co. indicated that there were no creeks or w a t e r areas around the' area and that there was no danger of polluting streams. 10. A d e s criptio n of any adverse health or environmental effects which you know or believe to have resulted from the introduction of PCB compounds or mixtures into the environment. Indicate any specific occasions including dates, times, location, amounts, and parties involved for which such effects are known. We do not have any direct knowledge of any adverse health or environmental effects resulting from these compounds being introduced into the environment. -13- 904465 r 11. Any and all other inform tio:: which you possess concerning: a. The production, im: tati'-n, rc:3 i;io n , use,, distribution, and Oi.;oo::;il of Pen; compounds or mixtures. b. The discharge of PCb compounds or mixtures into the r environment. Westinghouse Electric Corporation provided direct testimony on these matters during the EPA Toxic Pollutant Hearings in 1974. In addition, v;e are av.*arc that scientists c for Monsanto Chemical Co. have published recent articles or. the degradation of these compounds and that the Electronic Industries 7\ssociation has furnished Mr. Russell Train, additional information on these matters. ( C- i. 1 .. * c v, `. f -14 V c . 904466 ^ '* 1 b. .r inerteen (pounds) 73 L- M 1 % 2d. 5b Westinghou^o I.S.D. Amount disposed Location lbs. 71 k r1 Augusta A.S.?. 9 Uov/r.an Street Doston, WA 04330 Baltimore A.S.P. 4015 Foster Avenue Baltimore, MD 21224 Bridgeport A.S.P. 540 Grant Street P.O. DOX 5225 Bridgeport, CT 06610 3oJtqn A.S.P. 60 Charles Street t'oedhan iloights ,MA 021S4 ; Buffalo A.S.P. 1132 Seneca Street Buffalo, Nf 14210 .Chicane A. S. P. 3900 '.-.'est 41st St reo Chicago, IL 60632 C 1cve 1nd /.S .P . VGGG V.'e s t 1 6 0 t h S t . C lc .v o l.i.u ), 0!; 4 4 13 5 C i:i.:ir rv .i\ . t . .'i . P . 10V.- L-*':. j w Averi*n o C III'* J .*!. ' -1 , Oi; 4 5 2 3 7 i,f. ; m i *. A. * OP 1905. A l l - :i l.w.'ni T e r i . . *-Jr /V...-I3 w 904468 Westinghouse V.'ost ir.%;o j c c : C.i:u-.vuy ; V.'cs tc-rn J >>. ,> i 'i T. ? 1. J . t; 2b. r.-r.cr inerteen sed (pounds r i 172 I?3 & 0^ Westinghouse .1.S.0. Location E Z U r r r r -- - Charlotte A.S.P. 920 Eastv/ay Drivo Do:< 12037 Charlotte, UC 20205 Denver A.S.P. 200 Rio Grande Blvd. Denver, CO 80223 Eneryvilic A.S.?. 5099 Pelaeau 5t. E.rTeryvilie, CA 94600 I[Port liorth A. S. P. | 2!75 E . Long A v e . 1rt . V'o r th , t :< 7 0 .0 G |lloes ton A. S. P. '5730 Clinton Drivo / !!our*,ton, T/. 7 7020 r.artuar, City A.S.P. 4 14 0 Pronr. Street Citv, PO c-::2o I,o'j An'jeUt. A.S.P. 10020 S. Santa IV ,\v< Oii.n/'.an, C.\ 'J '/ - 7 S i ::i?y *! ? J i o : *:r .'*'>!/i l o . A*. JCvO: ; 904470 Rams Express J  I NOTE (CHART) The attached chart lists those Westihghouse Industry Services Divisions facilities which handle Polychlorinated Biphenyl Compounds. Records are maintained for each project; however, these are not further coded to designate which project involved Polychlorinated Biphenyls. However, based upon the information available, disposal is to approved facilities when required. 904467