1-
EPA
United Slates
Environmental Protection
Agency
Office of Toxic Substances
Washington DC 20460
Apnl 19/9
Toxic Substances
Support Document/Voluntary
Environmental Impact
Statement
and
PCB Manufacturing,
Processing, Distribution in
Commerce, and Use Ban
Regulation: Economic
Impact Analysis
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ENVIRONMENTAL PROTECTION AGENCY
SUPPORT DOCUMENT/
VOLUNTARY ENVIRONMENTAL IMPACT STATEMENT
for
Polychlorinated Biphenyis (PCBs)
Manufacturing, Processing, Distribution in Commerce, and
Use Ban Regulation (Section 6(e) of TSCA)
Prepared by
Office of Toxic Substances
Approved by
Deputy
the O,
^*H*>L^
ii'n~~P."~DeKany~ (J
stant Administrator for
ce of Chemical Control
60504
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VOLUNTARY ENVIRONMENTAL IMPACT STATEMENT
SUMMARY SHEET
(Check One)
( ) Draft.
(X) Final Environmental Statement.
Environmental Protection Agency
Office of Toxic Substances
1. Name of Action. (Check One)
(X) Administrative Action.
( ) Legislative Action.
2. Description of Action.
This rule implements §6(e) of the Toxic Substances
Control Act (TSCA) which prohibits the manufacturing,
processing, distribution in commerce, and use (unless
the use is totally enclosed) of PCBs and requires
regulations controlling marking and disposal of PCBs.
It applies to any chemical substance or combination of
substances that contain 50 ppm, or greater, PCS. The
rule authorizes several limited exceptions to these
general prohibitions in instances where activities do
not present an unreasonable risk of injury to health and
the environment. These exceptions are related to
limited servicing and use activities involving the
following: electrical transformers, railroad
transformers, hydraulic systems, mining machinery, heat
transfer systems, pigments, electromagnets, natural gas
pipeline compressors, small quantities for research and
development, microscopy, and carbonless copy paper. The
use of PCBs has been extensive throughout the United
States and, therefore, the rule has a nationwide impact.
3. Summary of Environmental Impact and Adverse
Environmental Effects.
PCBs are a significant environmental pollutant occurring
throughout the biosphere. They pose a significant risk
to the health of man and numerous other living things.
A number of adverse effects on living organisms have
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been demonstrated, including, but not limited to
bioaccumulation, biomagnification, carcinogenicity,
mutagenicity, teratogenicity, and fetotoxicity. PCBs
are extremely persistent in the environment, circulating
among the air, water, and land; and any additional
release of PCBs in the environment will eventually
result in widespread distribution of PCBs and,
therefore, increase exposure and risks.
4. Alternatives Considered.
In developing these proposed rules, EPA considered
whether there were other regulatory or nonregulatory op-
tions available as alternative approaches to implement-
ing the §6(e) prohibitions against PCB activities and
otherwise satisfy the purposes of §6(e) of TSCA. Below
is a discussion of the three major options that the
Agency considered.
a. No Action.
This alternative was rejected because Congress
mandated in TSCA that the manufacturing, processing, dis-
tribution in commerce, and use of PCBs be prohibited ac-
cording to a certain schedule. EPA's discretion with
respect to these prohibitions is to establish and clar-
ify certain definitions and to provide exceptions to the
prohibitions if there is no unreasonable risk to health
and the environment.
b. Action Through Other Statutes or Regulatory Bodies.
This alternative was rejected. It was determined that
using other statutes administered by EPA (i.e., Clean
Air Act, Clean Water Act, Safe Drinking Water Act, or
Resource Conservation and Recovery Act) was
inappropriate because they could not provide the
comprehensive coverage necessary to implement §6(e).
This is also true of statutes administered by other
regulatory agencies or state governments. Furthermore,
there is a strong case that EPA is required by TSCA to
use §6(e) of TSCA to implement and grant exceptions, if
appropriate, to the explicit prohibitions mandated by
§6(e). Section6(e)(4) specifically exempts EPA from the
requirements of §6(c)(l), including that of considering
the use of other EPA-administered authorities as
alternatives to rulemaking under §6 of TSCA. This
indicates that Congress intended that EPA use TSCA to
implement these prohibitions on PCBs.
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The use of other authorities to resolve the PCB problem
addressed by §6(e)(2) and (3) would be impractical,
complex, time consuming, and in some cases impossible.
No other Federal statute grants the kind of authority
necessary to directly control the range of PCB
activities covered by §6(e). Sections of several
statutes might have to be invoked in separate actions
for each aspect of each PCB activity. A number of
indirect controls would be necessary to effectively
prohibit PCB activities as required by TSCA except in
those cases where risks were found to be reasonable.
The other relevant statutes, moreover, are often not
designed to provide this comprehensive coverage, even
when used in concert. For example, many sources of PCB
air emissions are not included within the definition of
sources subject to regulation under the Clean Air Act
(CAA). The concepts of area-wide standards and controls
in the Clean Water Act (CWA) and the CAA do not seem
appropriate for implementing these prohibitions of PCBs
and specific PCB Articles or activities of concern.
There are final regulations under §307(a) of the CWA
which complement this regulation and which set effluent
standards prohibiting any discharge of PCBs, but only
from PCB manufacturers, electrical capacitor
manufacturers, and electrical transformer
manufacturers. If the CWA, the Safe Drinking Water Act,
or the Resource Conservation and Recovery Act were used
in lieu of TSCA, many spills could be controlled, but
other aspects of the PCB problem could not.
Some other Federal statutes not administered by EPA
could also be utilized to control some types of exposure
to PCBs. The National Institute for Occupational Safety
and Health has set a workplace exposure criterion of 5
ppm for employee exposure and recommended that the
Occupational Safety and Health Administration prepare
regulations accordingly. But again, this only addresses
a part of the problem. A few States have regulations on
PCBs, but they are not sufficient to cover all
activities addressed by TSCA nor, obviously, do they
provide control of PCBs on a national scale.
c. Action Under Section 6(e) of TSCA.
Numerous alternatives were considered within the author-
ity of §fi(e) of TSCA. These alternatives were fully
discussed in the Support Document/Voluntary Draft
Environmental Impact Statement, the Preamble to proposed
regulation, and the Preamble to this regulation.
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Major Definitions.
"PCB" is defined to mean any chemical substance
that is limited to the biphenyl molecule that has been
chlorinated to varying degrees or any combination of
substances which contains such substances.
"Significant Exposure" is defined as any exposure of
human beings or the environment to PCBs, as measured or
detected by any scientifically acceptable analytical
method.
Totally Enclosed Activities.
Congress mandated in §6(e)(2) of TSCA that all
non-totally enclosed activities are banned as of
January 1, 1978. Non-totally enclosed was defined by
Congress to mean any mannei- that resulted in significant
exposure as specified by EPA. Below are identified
those activities that the Agency considers to be totally
enclosed.
PCB Transformers (non-railroad) - Use, except
servicing, of intact, non-leaking PCB
transformers is considered totally enclosed.
PCB-Contaminated Transformers - Use,
except servicing, of intact,
non-leaking PCB-contaminated
transformers is considered totally
enclosed.
Electromagnets - Use, except servicing,
of intact, non-leaking electromagnets
is considered totally enclosed.
PCB Capacitors - Distribution and use
of intact, non-leaking, PCB
Capacitors are considered totally
enclosed.
PCB Equipment - Processing, distribution in
commerce, and use of PCB Equipment are considered
totally enclosed.
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7. Authorizations.
The Agency has found that the following activities do
not present an unreasonble risk to health and the
environment. In making these decisions the Agency
considered (1) the health and environmental effects of
PCBs, (2) the exposure to PCBs from these activities,
(3) the availability of substitutes in these uses, and
(4) the economic impact from restricting these uses.
Unless otherwise noted, all authorizations expire on
July 1, 1984; however, exemptions must be obtained if
processing and distribution in commerce are to continue
after July 1, 1979.
PCS Transformers (non-railroad) -
Processing, distribution in
commerce, and use are authorized.
Servicing (except rebuilding) is
authorized.
PCB-Contaminated Transformers - Processing,
distribution in commerce, and use are
authorized. Servicing (including
rebuilding) is authorized.
Railroad Transformers - Processing,
distribution in commerce, and use
are authorized. Servicing
(including rebuilding) is
authorized.
Mining Equipment - Processing, distribution
in commerce, and use (including servicing)
are authorized until 1/1/82. After 1/1/80,
rebuilding of continuous miner type motors
is prohibited.
Heat Transfer Systems - Use is authorized.
Hydraulic Systems - Processing, distribution
in commerce, and use are authorized.
Pigments - Processing and distribution
in commerce are authorized. Use is
authorized until 1/1/82.
Electromagnets - Processing, distribution
in commerce, and use are authorized.
Servicing (except rebuilding) is
authorized.
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Natural Gas Pipeline Compressors - Use
is authorized until 5/1/80.
Small Quantities for Research and
Development - Processing,
distribution in commerce, and use
are authorized.
Microscopy - Processing, distribution
in commerce, and use are authorized.
Carbonless Copy Paper - Use is
authorized indefinitely.
8. Federal Agencies That Participated on EPA's PCB Work
Group:
Department of Commerce
Department of Defense
Department of Transportation
Department of Interior
Federal Railroad Administration
General Services Administration
National Institute for Occupational Safety and Health
Tennessee Valley Authority
On or about Apn'i 3.0 ,1*114 the Support Document/ Voluntary
Environmental impact Statement was officially filed with
the Director, Office of Federal Activities, EPA. It is
available to the public. Copies can be obtained by
writing the Industry Assistance Office, Office of Toxic
Substances (TS-793), Environmental Protection Agency,
401 M Street, S.W., Washington, D.C. 20460, or by
calling (800) 424-9064, in Washington, D.C., call
554-1404. The official record of rulemaking, including
both the draft and final Support Document/Voluntary
Environmental Impact Statement, is located in room 709,
East Tower, Environmental Protection Agency, 401 M
Street, S.W., Washington, D.C. 20460, (202) 755-6956.
It will be available for viewing and copying from 9 a.m.
to 4 p.m., Monday through Friday excluding holidays.
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TABLE OF CONTENTS
Introduction p.
2
I.
II. Significance of Release of PCBs into
the Environment p. 8
III. PCB Substitutes p. 39
IV. Significant Exposure/Totally Enclosed
Manner p. 48
V. PCB Definition: 50 ppm , p. b3
VI. Dilution * .p. 62
VII. Transformers p. 65
VIII. Railroads .p. 8U
IX. Mining p. 83
X. Hydraulic Systems p. 84
XI. Heat Transfer Systems p, 87
XII. PCB Articles and PCB Equipment p. 89
XIII. Pigments , p. 92
XIV. Process Contamination p. 95
XV. Electromagnets p. 98
XVI. Microscopy p. 99
XVII. Waste Oil , p. 102
XVIII. Natural Gas Compressors p. 103
XIX. Revised Versar Report p. 105
Appendix I. List of Major Comments .....p. 109
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I. INTRODUCTION
PCBs have been used in the United States since 1929 in
such applications as transformer cooling liquids, capacitor
dielectric fluids, heat transfer and hydraulic liquids, dye
carriers in carbonless copy paper, plasticizers in paints,
adhesives, and caulking compounds, fillers in investment
casting wax, and dust control agents in road construction.
Monsanto was the major U.S. manufacturer of PCBs. Since
1972, Monsanto limited sales of PCBs to manufacturers of
transformers and capacitors. Monsanto ceased manufacturing
PCBs in mid-1977, and shipped the last remaining inventory
by October 31, 1977.
Small quantities of PCBs may be produced currently, as
unintentional byproducts of other chemical processes.
Similarly, chlorination of water which contains appreciable
concentrations of biphenyl can result in the unintentional
formation of PCBs. No natural sources of PCBs have been
identified.
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Prior to the enactment of the Toxic Substances Control
Act (TSCA), the authority of the EPA with respect to PCBs
was limited to the regulation of contaminated water from
point sources. EPA promulgated a rule under Section 307(a)
of the Clean Water Act on February 2, 1977 (42 FR
6532-6556), which banned the discharge of PCBs into
navigable waters by electrical transformer and capacitor
manufacturers.
The enactment of TSCA in October 1976, placed additional
restrictions on the use of PCBs and required that certain
actions be taken by EPA. Section 6(e)(l) of TSCA required
that EPA promulgate a disposal and marking rule for PCBs.
This rule, promulgated by EPA on February 17, 1978 (43 FR
7150-7164), regulates the disposal of PCBs and requires that
special warning labels be applied to large capacitors,
transformers, and other PCB Items. The Disposal and Marking
Rule covered liquid PCBs and all other material and
equipment components containing or having contained PCBs in
concentrations of greater than 500 ppm (0.050 percent).
Clarifying amendments to this rule were published on August
2, 1978 (43 FR 33918).
On June 7, 1978 EPA published the proposed rules (43 FR
24802) implementing §§6(e)(2) and 6(e)(3) of TSCA. These
rules proposed to prohibit or authorize certain PCB
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activities that are not conducted in a totally enclosed
manner. This rule also specified those activities that the
Agency considered to be performed in a totally enclosed
manner.
Concurrently with the proposed rule, the Agency also
published a Support Document/Voluntary Draft Environmental
Impact Statement (Draft Support Document). In that
document, the Agency discussed the different alternatives it
considered in regulating the various PCS activities.
The Agency held 10 days of public hearings in
Washington, D.C. from August 21 to September 1 to solicit
comments on the proposed rule. Over 50 oral presentations
were made. On September 22, 1978 (43 FR 43048), EPA
published a notice of the opportunity for cross-examination
and extended the reply comment period to October 10, 1978.
Two hearing participants conducted cross-examination on
September 26, 1978. EPA received over 200 comments on the
proposed rule.
Section 6(e)(3)(B) of TSCA also provides that persons
may petition the Administrator for exemptions from the
prohibition of the manufacture, processing, and distribution
in commerce of PCBs or PCB Items. Interim rules
establishing procedures for submitting petitions for
exemptions from the prohibitions were published on
November 1, 1978 (43 FR 50905). More than 70 petitions for
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exemptions have been received. On January 2, 1979 EPA
announced (44 FR 108) that it would not enforce the PCS
manufacturing and importation ban of §6(e)(3)(A) against
persons who submitted petitions, until EPA had acted on
their request for exemptions.
Concurrently with publication of the final
manufacturing, processing, distribution in commerce, and use
bans, the Agency has published its proposed disposition on
the requests for exemptions from this Rule. Public hearing
and publication of the final disposition will be
forthcoming.
This Support Document/Voluntary Environmental Impact
Statement (Final Support Document) has been prepared to
address the major comments made during the rulemaking
proceedings. Each of the major comments has been listed and
assigned a number in parentheses in Appendix I to this
document. For the convenience of readers, representative
comments are referenced by number when they are addressed by
the Agency in this document. EPA wishes to emphasize,
however, that the comments listed may not represent all of
the comments considered by EPA and which address the
particular issue discussed. In some cases, discussion of
issues raised by commentors will also be found in the
Preamble to the final rule.
As noted, this document responds to comments received on
the proposed rule. It contrasts with the Draft Support
Document which discussed the options the Agency considered
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to control the various applications of PCBs. Two sections
(Section I, Background and Section II, Alternatives to this
Rule) in the Draft Support Document that are relevant to
this phase of rulemaking have been revised and included in
this Support Document in the Introduction and the Summary
Sheet. Section III (Significance of Release of PCBs Into the
Environment), and Section V (Substitutes) of the Draft
Support Document are included as Sections II and III of this
Final Support Document. Minor revisions have been made in
v
these sections prior to their inclusion. The three
remaining sections, Section IV (Definition of PCB Mixture),
Section VI (Reasonable use Determinations), and Section VII
(Waste Oil), although containing much of the same rationale
used in the final rulemaking, have not been included in this
document. However, those three sections describe (1) the
regulatory options considered by EPA prior to proposal of
this rule and (2) reflect the information that was then
available to the Agency.
This Support Document/Voluntary Environmental Impact
Statement contains the same information as would be prepared
to meet the requirements of Section 6(c)(l) of TSCA. While
not legally required to prepare an Environmental Impact
Statement (EIS) by Section 102(2)(c) of the National
Environmental Policy Act (NEPA) of 1969, EPA has voluntarily
prepared this Support Document/Voluntary Environmental
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Impact Statement in conformance with the spirit of its 1974
statement on voluntary EIS's (39 PR 37419, October 21,
1974} . The voluntary preparation of this document in no way
legally subjects the Agency to NEPA requirements.
Persons who are interested in the approximate costs to
the various industries to comply with the requirements of
the rule, are referred to the economic study entitled PCB
Manufacturing, Processing, Distribution in Commerce, and Use
Ban Regulation; Economic Impact Analysis (the Versar
Report) found at the end of this document.
EPA wishes to emphasize that equality of PCB regulatory
costs for the different affected industries described in the
economic study is not the goal of this regulation. EPA is
seeking to regulate as many PCBs as possible. The Agency
recognizes, however, its inability to regulate some
activities, such as disposal of many types of PCB Equipment,
due to the broad ownership o£ such equipment at a vast
number of sites. Although equality of regulatory costs for
different affected industries has not been a goal, EPA has,
where appropriate, taken costs into account by lengthening
the compliance schedule or allowing disposal alternatives.
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II. SIGNIFICANCE OF THE RELEASE OF PCBs INTO
THE ENVIRONMENT
Introduction
Section 6(e)(2)(A) of TSCA prohibits the manufacture,
processing, distribution in commerce, and use of PCBs after
January 1, 1978, in other than a totally enclosed manner.
"Totally Enclosed Manner" is defined by TSCA to mean, a
manner which will ensure no significant exposure of human
beings or the environment to PCBs, as determined by EPA by
rule [Section 6(e)(2)(C)]. The final rule, in turn,
provides that human or environmental exposure to any
detectable quantities of PCBs shall be deemed significant.
This provision is based on the finding that any release of
PCBs into the environment will eventually result in
widespread exposure of wildlife, including some of man's
major food sources, and humans and that any such exposure
may have adverse effects.
The following sections summarize the variety of adverse
effects which PCBs have been found to have in humans,
laboratory animals, and other organisms, and the extent to
which PCBs released into the environment become distributed
throughout the biosphere. The adverse effects have been
described in greater detail in various documents, including
EPA Report No. 440/9-77-021, Criteria Document for PCBs,
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July 1976; Criteria for a Recommended Standard;
Occupational Exposure to Polychlorinated Biphenyls (PCBs),
National Institute for Occupational Safety and Health,
September 1977; and "Environmental Health Criteria:
Polychlorinated Biphenyls and Polychlorinated Terphenyls,"
World Health Organization, 1976. PCB-induced effects were
also reviewed in detail in expert testimony at a public
hearing before EPA and were acknowledged and described in a
decision by the Administrator to promulgate toxic pollutant
water effluent standards for PCBs (42 FR 6532-6556, February
2, 1977). These standards were affirmed in Environmental
Defense Fund vs. Environmental Protection Agency, 12 E.R.C.
1353 (D.C. Cir. 1978).
Significance of Exposure to PCBs
A. Absorption and Storage
PCBs are absorbed through the lungs, the
gastrointestinal tract, and the skin.-'- After absorption,
PCBs are circulated throughout the body in the blood and are
stored in adipose tissue and in a variety of organs and
tissues, including the liver, kidneys, lungs, adrenal
glands, brain, heart, and skin.2
B. Specific Adverse Health Effects of PCBs as Observed in
Toxicology Tests and Epidemiological Studies
The view that human health risks resulting from exposure
to chemicals may be determined experimentally by testing
laboratory animals is one that is widely accepted in the
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scientitic community and has been adopted by EPA. Because
experimentation on human beings raises ethical questions and
because epidemiological studies often provide incomplete
information, toxicology studies on laboratory animals are
otten necessary. However, because the extrapolation from
animals to man is subject to some uncertainty, corroboration
of laboratory test data with sound epidemiological
information is desirable. The available toxicological and
epidemiological data relating to the effects of PCBs are
discussed below.
1. Oncogenicity
PCBs appear to have caused malignant and benign tumors
in rats and mice in several experinvents.3 in one
carefully conducted experiment, rats fed 100 ppm of Aroclor
1260 in the diet for 21 months developed a high incidence of
carcinomas (26/184) and neoplastic nodules (144/184) in the
liver. Only one of 173 control animals developed a
carcinoma, and none developed neoplastic nodules. In
another experiment, rats were fed Aroclors 1242, 1254, and
1260 tor 24 months. Rats exposed to any of the three
mixtures at 100 ppm in the diet developed liver tumors
(hepatomas and cholangiohepatomas), whereas none was
observed in the controls (3/20 for Aroclor 1242, 6/27 for
Aroclor 1254, 7/27 for Aroclor 1260, and 0/20 for the
controls). A high frequency of nodular hyperplasia in the
liver, considered by some authorities to be precancerous,
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was observed in the rats fed 100 ppm of the three mixtures.
A significant increase in frequency in comparison to
controls was observed down to the 10 ppm dosage level.4
The results of the epidemiological data, although
somewhat ambiguous, provide additional evidence that PCBs
pose a carcinogenic risk to man. In 1968, at least 1,291
persons were afflicted with a disease known as Yusho as a
consequence of eating rice oil contaminated with PCBs and
relatively smaller amounts of polychlorinated dibenofurans
(PCDFs). Although precise data are not yet available, a
preliminary tabulation of the deaths among Yusho victims
through 1975 showed an excess in the rate of cancer,
particulary of the stomach and liver.5 in another
preliminary study, 92 workers considered likely to have been
exposed to Aroclor 1254 at a New Jersey petrochemical
facility between 1949 and 1957 indicated a significant
excess of malignant melanoma and pancreatic cancer.^a In
the third study, an examination of the death certificates of
50 employees formerly engaged in the manufacture of PCBs
revealed seven cases of lung cancer, compared with an
expected 2.5 cases. However, these results were not
corrected for age or smoking habits and are only
preliminary.6
2. Teratogenic, Fetotoxic, and Reproductive Effects
Beagle dogs fed Aroclor 1254 at the rate of 1.0
mg/kg/day had offspring with a significantly higher
incidence of patent fontanelles than did controls but
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exhibited no decrease in the number of offspring. In the
same experiment, dogs fed 5.0 mg/kg/day had a fetal
resorption rate of 45.5 percent (a fourfold increase over
controls). Patent fontanelles were present in 50 percent of
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the offspring.
Sows fed Aroclor 1254 at a dose of 1.0 mg/kg/day for 21
days before breeding and throughout gestation experienced a
statistically significant rate of fetal resorption. Higher
dosages further reduced fertility and caused a variety of
defects in the offspring, including cleft palate,
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syndactyly, and patent fontanelles.
Female rhesus monkey fed PCBs at 5 ppm and 2.5 ppm in
the diet for 6 months before mating with untreated males
demonstrated severe reproductive dysfunctions. Only one of
the eight animals fed the higher dose gave birth, with five
animals experiencing abortions and two not conceiving at
all. Of the eight monkeys fed the lower dosage, five gave
9
birth to extremely small infants, and three aborted.
In another experiment, three of six infant rhesus
monkeys born to mothers fed 2.5 ppm of PCB died within 6
months of birth. The surviving three infants exhibited
10
behavioral and learning defects.
Studies with mink have also demonstrated the adverse
effects of PCBs on reproduction. Ranch mink fed coho salmon
contaminated with 12 to 20 ppm of PCBs suffered
reproductive failure and kit mortality. Female mink fed
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dosages as low as 5 ppm of Aroclor 1254 and 2 ppm of Aroclor
1016 experienced substantial reductions in the number of
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live kits born.
3. Enzyme Induction by PCBs
It has been demonstrated in several experiments that
PCBs induce various microsomal enzymes of the liver,
including mixed-function oxidases. Such induction has
occurred after administration of Aroclors 1016, 1242, 1248,
1254, and 1260 to rats at dosages as low as 1 mg/kg/day for
21-28 days in the diet. Some of the enzymes induced by PCB
mixtures and chlorobiphenyl isomers in rats and other
animals are nitroreductases, dimethylases, diethylases,
glucose-6-phosphatases, aryl hydrocarbon hydroxylases,
cytochromes P-450 and P-448, NADPH cytochrome reductases,
and delta-aminolevulinic acid synthetases.12jn one study
it was shown that humans exposed to PCBs showed elevated
levels in the blood of the enzyme, gamma glutamyl
transpeptidase, a sensitive indicator of liver
dysfunction.^3
The consequences of this enzyme induction may be quite
significant. Some of the enzymes induced by PCBs, such as
cytochrome P-450 and cytochrome P-450 dependent
N-demethylase, are involved in the metabolism of therapeutic
drugs. Induction of these enzymes would therefore be
expected to alter the function of such drugs and interfere
with the treatment of diseases in humans. This possibility
has been clearly demonstrated in one experiment in which
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workers occupationally exposed to Aroclor 1016 for the 2
years immediately before the experiment and to Aroclors
1242, 1254, and 1260 in earlier years were administered
antipyrine, a prototype drug substrate. The half-life of
the antipyrine in the plasma of the exposed workers was
approximately two-thirds of that observed in control
14
subjects.
Another expected consequence of the induction of certain
liver enzymes is an alteration of the incidence of human
cancer. Although the mixed-fu^otion oxidases detoxify
foreign chemicals in the body, they may also metabolize some
15
of these substances into more toxic or carcinogenic forms.
However, it is difficult to predict whether induction of
these enzymes would have a net effect of increasing or
decreasing the incidence of cancer.
Induction of liver enzymes by PCBs could also result in
a modification of the overall metabolism of the body by
altering the metabolism of the steroid hormones.^^In
addition, stimulation of the production of the enzyme
delta-amino-vulinic acid synthetase by PCBs has been
demonstrated to cause porphyria and accumulation of
porphyrins in the liver in rats, mice, and rabbits.17
4. Effects on the Immunological System
Several experiments have demonstrated that PCB mixtures
produce immunosuppressive effects in laboratory animals. In
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one study, guinea pigs were fed Aroclor 1260 at 10 ppm in
the diet for 8 weeks and received injections of tetanus
toxoid to stimulate antitoxin production by the lymphoid
system. In comparison to controls, PCB-treated animals
exhibited reduced numbers of gamma-globulin-containing cells
in the lymph nodes as well as reduced serum gamma-globulin
18
levels. Infant rhesus monkeys dosed with 35 mg/kg of
Aroclor 1248 for 4 weeks exhibited atrophy of the thymus.
The same effect was observed in rhesus monkeys fed daily
19
doses as low as 3 ppm of Aroclor 1242. In addition,
decreased weight and atrophy of the thymus and lymphoid
system were observed in guinea pigs and rats
20
administered oral doses of PCBs.
5. Mutagenicity
Whydam and co-workers demonstrated that 4-chlorobiphenyl
is a potent mutagen in the Ames test for bacterial
21
mutagenesis. These workers also found that the mutagenic
activity of PCBs decreased with increasing chlorination and
that the most highly chlorinated mixtures had almost no
activity.
In several studies, various doses of Aroclor 1242 and
Aroclor 1254 were administered to rats and the chromosomes
of the bone marrow and testicular cells of these animals
were then examined for abnormalities. No significant
increases in chromosomal aberrations were observed in
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comparison with controls. In another study, administration
of these chemicals to rats did not appear to induce dominant
22
lethal mutations.
6. Effects on the Liver and Stomach
The induction of hepatic microsomal enzymes and the
causing of malignant tumors of the liver by PCBs have
already been discussed. Other adverse effects on the liver
have also been observed and are described here.
In one study, weaning rats fed Aroclor 1254 at 1 ppm in
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the diet exhibited significantly increased liver weights.
In another experiment, rats fed Aroclors 1248, 1254, and
1260 at 1000 ppm in the diet for 6 weeks were found to have
hypertrophied livers weighing four times as much as those
controls. Abnormal ultra-structural changes within the
liver cells of the PCB-treated animals included
proliferation of smooth endoplasmic reticulum, develop-
ment of large concentric arrays of membranes, atypical
24
mitrochondria, and increases in lipid droplets. One
study performed by the National Cancer Institute observed
25
proliferative changes in the liver cells of rats. In guinea
pigs, liver damage has been observed at dosages of Clophen
A60 (a PCB mixture) as low as 250 ppm in the diet.
Increased liver weight has been observed at doses down to 50
26
ppm.
16
-------
Low oral doses of PCBs have resulted in stomach lesions
in several species. Dogs fed dietary levels of 1 ppm of
Aroclors 1254 and 1260 and 10 ppm of Aroclor 1242 for 2
years suffered from stomach ulcers and nodules. Rhesus
monkeys fed 2.5 ppm of Aroclor 1248 and 3 ppm of Aroclor
1242 in the diet developed stomach lesions which were severe
in some cases. Sows also suffered from stomach lesions
27
after being fed Aroclor 1242.
7. Effects on Skin and Other Epidermal Tissues
Exposure to PCBs has resulted in various adverse effects
on the skin and other epidermal tissues in humans.
Chloracne, a specific type of acne caused by certain
chlorinated hydrocarbon compounds, has developed among
workers occupationally exposed to air containing PCBs at
28
levels as low as 0.1 mg/m. Skin lesions similar to
chloracne have been one of the major clinical signs observed
. in victims of Yusho disease. In addition, Yusho victims
have experienced eye discharges caused by hypersecretion of
the meibomian glands, swelling of the upper eyelids and
hyperpigmentation of the skin, nails, and mucous membranes.
It has been estimated that Yusho disease has resulted from
ingestion of PCBs in contaminated rice oil at a rate as low
as 67 ug of PCB/kg of body weight per day for 3 months,
although it should be noted that the Yusho incident involved
exposure to high concentrations of chlorinated dibenzofurans
and other chemicals which make it difficult to develop
precise conclusions.27
17
-------
8. Other Effects
Workers exposed to PCBs have been shown to have elevated
levels of fat (triglycerides) in the blood.30 rpne best
current thinking in medicine is that such elevations
constitute a serious risk for the development of heart
diseases and strokes. Workers exposed to PCBs have
experienced numerous other symptoms and adverse effects,
including digestive disturbances, jaundice, impotence, dry
or sore throat, and headache.31 in addition, Yusho
victims have suffered from abdominal pain, menstrual
irregularity, fatigue, cough, and disorders of the
peripheral nervous system.32
C. Effects on Wildlife
It is reasonble to expect that many of the adverse
effects observed in laboratory animals could also occur in
wild mammals exposed to PCBs. Since, as discussed below,
PCBs have a tendency to collect in waterways and
bioaccumulate in fish, fish-eating mammals such as otters,
mink, and bears are particularly at risk. It has already
been noted that mink fed PCB-contaminated fish suffered
reproductive failure. Other effects observed in exposed
mink include reduced weight gain, increased mortality, and
enlargement of the liver, kidneys, and heart.33
18
-------
Many wild birds are probably also highly susceptile to
PCBs. Several fish-eating birds, including two bald eagles,
have been found dead with lethal quantities of PCBs in the
34
tissues. Ring doves and American kistrels fed 10 ppm of
PCBs suffered from severe reproductive failure. In
addition, birds exposed to PCBs have also exhibited induc-
tion of hepatic microsomal enzymes, porphyria, changes in
thyroid activity, abnormal behavior, and increased suscep-
35
tibility to viral disease.
The various PCB mixtures are highly toxic to several
aquatic invertebrates and fish at extremely low concentra-
tions. Aroclors 1248 and 1254 impair reproductivity of
water fleas at concentrations as low as 0.48-1.0 ppb.
Aroclor 1254 is toxic to several types of shrimp at levels
of approximately 1 ppb. Substantially increased mortality
of the fry of sheepshead minnows resulted from exposure to
water containing 0.16 ppb of Aroclor 1254. It is thought
that PCB levels of only a few parts per trillion in lake
Michigan may be responsible for the reproductive failure of
several species of fish in that body of water. There is
also strong evidence that PCBs at concentrations below 1 ppb
36
may adversely affect aquatic insects and crustaceans.
Concentrations of Aroclors 1242, 1016, and 1254 as low
as 0.1 ppb have been demonstrated to depress photosynthesis
in phytoplankton and to reduce the rate of cell growth and
19
-------
division of these organisms. These effects are very
significant since the productivity of the entire marine
ecosystem may depend on the productivity of the
37
phytoplankton within it.
D. Toxicity of PCDFs
Polychlorinated dibenzofurans (PCDFs) are found in small
but variable quantities as impurities in most PCB mixtures.
In addition, PCDFs can be formed by photodegradation of PCBs
in the environment. At present, it appears impossible to
differentiate the toxic effects of PCBs from those of PCDFs.
Consequently, it is necessary to regulate the commercial PCB
mixtures with recognition that part of their toxicity
38
may be attributable to unavoidable contaminants.
E. Toxicity of PCB Metabolic Products
A number of studies have shown that PCBs are biodegraded
into even more toxic metabolites. For example, it has been
demonstrated that tetrachlorobiphenyl, which is a
substantial component of several major commercial PCB
mixtures, is transformed into toxic intermediate byproducts,
including arene oxides and dihydrodiols. These substances
have been found to cause cancer, mutations, and other toxic
39
effects.
F. Relative Toxicity of the PCB Mixture
PCBs are usually sold commercially as mixtures of
biphenyl molecules with varying degrees of chlorination.
Aroclors 1016 and 1242 have relatively low chlorine content,
whereas the chlorine content of Aroclor 1254 is relatively
20
-------
high. It has been argued (174) that the less highly
chlorinated mixtures and components may be less toxic and
hazardous than the more highly chlorinated mixtures, and
therefore the regulation of the former should be less
stringent. This argument was considered in great detail at
public hearings before EPA on Toxic Pollutant Effluent
Standards for PCBs and was rejected by the
Administrator.^O There were several bases for not
establishing separate standards for the different PCS
mixtures. It was determined that all PCB mixtures then in
use, including the less chlorinated ones (e.g., Aroclor
1016), are capable of inducing severe toxic effects at low
levels in mammals and aquatic organisms. In addition, the
compositions of the different PCB mixtures change and may
become more similar after release into the environment, so
that it would make no sense to regulate the mixtures, under
different standards. Furthermore, important components of
all the mixtures, including the less chlorinated ones, are
highly persistent. Finally, while the less chlorinated
components of the PCB mixtures are not stored in tissues as
efficiently as the more highly chlorinated molecules, even
the less chlorinated commercial mixtures have substantial
amounts of components that are subject to significant uptake
and storage.^1
21
-------
G. Inability to Establish a "Safe" Level of Exposure for
PCBs
The available data indicate the PCB may cause several
adverse effects in humans, mammals, birds, and aquatic
organisms at extremely low concentations. Therefore, for
all practical purposes, exposure of humans and other animals
to any level of PCBs should be deemed significant. This is
especially true in light of the demonstrated carcinogenicity
of PCBs. EPA has adopted the view that "safe" or
"threshold" levels for carcinogens cannot be established
42
given the present state of scientific knowledge. This
policy has been upheld by the Federal courts in several
43
decisions.
Environmental Exposure to PCBs
A. General
The purpose of this section is to discuss how PCBs
released anywhere into the environment may eventually become
widely distributed, with the result that many organisms,
including man, may become exposed. This section also
summarizes some of the data indicating that PCBs are already
widely distributed throughout the physical environment and
the biosphere and that this environmental burden is not
likely to become reduced in the near future because of the
persistence of these chemicals.
22
-------
B. Overview of PCS Transport in the Environment
Before presenting a detailed analysis of the manner in
which humans and the general biota might be exposed to
"free" PCBs (i.e., PCBs which have been released into the
environment), it is first necessary to determine the
processes by which free PCBs are distributed throughout the
three compartments of the environment—air, land, and water.
A number of processes affect the nature of this
distribution. Once a PCB substance has entered a physical
compartment, it may be dispersed throughout that
compartment. In addition, each compartment may have sinks
wherein free PCBs may be rendered physically unavailable to
the biota or may be degraded by chemical or metabolic
processes. Finally, a more or less continuous interchange
of PCBs between the three compartments might be expected.
The general nature of these processes is illustrated
44
schematically in Figure 1, and a summary of the possible
sources, sinks, and exchange processes is given in Table 1.
It should be pointed out that the processes described in
Figure 1 and enumerated in Table 1 are theoretical
possibilities that apply to any environmental pollutant.
Which of these processes play an important role in the
environmental transport of PCBs is determined by the
specific chemical and physical properties of the PCBs as
well as the characteristics of each of the compartments. In
23
-------
Figure 1
Schematic Representation of Transport Processes in the Environment
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view of this, the physical and chemical properties of PCBs
are discussed next, in order to lay the proper framework for
a more detailed discussion of the transport of PCBs.
C. Environmentally Relevant Properties of PCBs
PCBs are a group of compounds, some 209 in number, that
are prepared by the partial chlorination of biphenyl to
yield a complex mixture of chlorobiphenyls in the form of
high boiling point liquids of moderate viscosity. The
environmentally significant physical properties of several
of the commercial mixtures (Aroclors) are presented in Table
2. The properties of PCBs that have made them so
commercially attractive include low water solubility, low
affinity for water (high lipid solubility), a high degree of
chemical stability, and very low vapor pressure at ambient
temperatures. A more detailed discussion of the relevance
of these properties to the environmental hazard posed by
PCBs is presented in the following sections.
1. Chemistry of Chlorobiphenyls
Chlorobiphenyls have been demonstrated to undergo a
number of chemical reactions. Both oxidation and hydrolysis
of these chemicals can be carried out, but only under
conditions that are considerably more rigorous than would be
45
found in an environmental situation. Another class of
reactions to which PCBs are susceptible is that of
cyclization. Of particular interest is the cyclization of
24
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2,2'dichlorobiphenyl, which yields the compound dichloro-
46
dibenzofuran. The oral LD5Q of the dibenzofuran for rats
is approximately 250 mg/kg, whereas the LD5Q for the
47
chlorobiphenyl is in excess of 4000 mg/kg.
As discussed below, it is thought that transport as a
molecular species or as sorbed material on airborne
particles is the major route of widespread transport of
48
PCBs. Since such processes would cause PCBs to be
exposed to ultraviolet radiation from the sun, considerable
attention has been directed to the photochemical stability
of PCBs. A number of effects have been reported, including
partial dechlorination and even, in some cases, the
formation of very viscous semisolids apparently arising
49
from some complex polymerization processes. The
environmental significance of these observations is
difficult to assess since the solvents usually used in these
studies were hydrocarbons rather than water.
The hydroxylation of the PCB molecule is the first step
50
by which organisms metabolize this chemical. Once the
target chlorobiphenyl has been hydroxylated, there appears
to be a wide variety of species-specific addition processes
that can make use of the hydroxylated molecule. In this
context, the failure to detect chlorodibenzofurans suggests
that metabolic processes are not available to cyclize the
PCBs. The further observation that the residual body burden
25
-------
of PCBs usually consists of only the more highly chlorinated
PCBs suggests that the higher the level of chlorination,
51
the more resistant it is to metabolic processes.
Several of the PCBs with relatively low chlorine content
are readily metabolized by direct hydroxylation by both
52
animals and microorganisms. Consequently, di- and
53
trichlorobiphenyls are not very persistent. On the other
hand, the highly chlorine-substituted PCB molecules are
apparently not metabolized at all. In addition, these
species of PCB are not easily excreted because of their very
low aqueous solubility and high lipid solubility. As a
result, these species tend to accumulate in exposed
54
animals.
2. Physical Properties of PCBs
As indicated in Table 2, PCBs and their technical
mixtures are characterized by low water solubility, low
vapor pressure at ambient temperatures, and very high
55
octanol/water partition coefficients. The significance of
the combination of low water solubility and high octanol/
water partition coefficient is that when organic matter is
exposed to an aqueous solution of PCBs, there is a strong
tendency for the PCBs in the aqueous solution to be
56
preferentially taken up by the organic matter.
Consequently, when animals are exposed to aqueous solutions
of PCBs, the lipids of these animals will preferentially
26
-------
take up and store the PCBs. Since there is usually little
metabolic activity in lipid bodies, the stored PCBs are, in
some measure, protected from metabolic degradation.
Therefore, larger and larger body burdens may be built up
after continued exposure. It is this mechanism that
accounts for the very large bioaccumulation factors that
57
have been reported.
In general, the volatility of a solute from a solution
is governed by the vapor pressure of the (pure) solute at a
given temperature and the mole fraction of the solute in the
58
solution. However, in those cases where there is either
heat of mixing or change in volume when mixing the solvent
and the solute (nonideal solutions), the volatility of the
solute is not simply proportional to the molar concentra-
59
tion of the solute in the solution. In those cases, it
turns out that the lower the ultimate solubility, the
greater the effective molar concentration. Thus, the
volatility of the solute is significantly higher than would
be expected for the given vapor pressure and the actual
molar concentration. This phenomenon, which is known as
codistillation, is responsible for the very short
volatilization half-life of PCBs in water as illustrated by
60
Table 2. Codistillation from water is thought to be a
major route of entry of PCBs into the atmospheric
27
-------
61
reservoir and is believed to be responsible for the
worldwide distribution of these substances.
D. Transport of PCBs in the Environment
This section discusses the mechanisms by which PCBs are
transported from each compartment of the environment to the
others.
1. Atmospheric Compartment
A number of investigators have determined that PCBs are
62
very widespread in the atmosphere both as molecular
species and as adsorbed species on particulates and
63
aerosols. The mean air concentration of PCBs at several
locations in Sweden was found to range from the detection
limit of 0.8 to 3.9 ng/m3. The highest detected level was
12.5 ng/m3. In the United States, levels were found to
64
range from 1 to 50 ng/m3. Over the Atlantic Ocean the
airborne concentration was determined to range from
5 ng/m3 near the northeast coast to 0.05 ng/m3 at a
65
distance of 2000 miles from the coast. Numerous sources
of airborne PCBs have been identified, including the
incomplete incineration of PCB-containing materials (e.g.,
66
sewage sludge), volatilization of PCBs from paints and
67
plasticizers, codistillation from surface waters that are
68
PCB-contaminated, and direct volatilization from PCB end
69
uses and spills.
28
-------
Various writers have pointed out that the atmospheric
reservoir of PCBs is the principal route by which the world-
70
wide distribution of PCBs has occurred. Thus the
atmospheric reservoir serves as a mechanism for the
dissemination of PCBs to the other compartments of the
environment.
2. Terrestrial Compartment
The most significant sources of free PCBs in the
terrestrial compartment of the environment include discarded
71
consumer end use products that contain PCBs, atmospheric
72
fallout, and spills associated with the use or the
73
transport of PCBs.
For that portion of the free PCBs that is confined to
terrestrial sites, the primary mechanisms for dispersal are
volatilization and solubilization by ground or surface
waters. Since the vapor pressures of the typical PCB
preparations (Aroclors) lie in the range of 10~2 to
74
10~4 mm Hg at ambient temperatures, the loss rate by
direct volatilization should be very small even in the
absence of significant soil binding. It is possible,
however, that under certain conditions heat produced by
oxidation of organic materials in a landfill could raise
temperatures significantly and thereby substantially
increase the volatization of PCBs located in the fill.
29
-------
PCBs are soluble in water so that direct solubilization
by percolating waters is a possible mechanism for the
admission of these substances into the ground waters. As an
example, the limiting solubility of Aroclor 1254 in water
75
is about b4 ppbf and the average rainfall on the
76
continental United States is about 34.5 inches per year. It
therefore follows that, with the normal long percolation
time, the losses into the local ground waters could be as
high as 0.04 g/m2/year in a region where PCBs have been
landfilled.
In addition to solubilization, PCBs may be removed from
land and enter the aquatic compartment by surface water
runoff. This latter effect is of great concern in areas
where contaminated oils have been used on highways or where
land spills of PCBs are possible. There is no direct
77
evidence that PCBs are degraded by soil microflora.
3. Aquatic Compartment
Figure 2 illustrates the nature of the processes that
are involved in the transport of PCBs to and from a body of
water. It illustrates that the principal PCB inputs to a
body of water are contaminated inflowing streams and the
PCBs that precipitate from the atmospheric reservoir. An
example of- the significance of the inflowing streams is
78
given in a recent report which indicates that detectable
PCB levels were found in some 40 percent of a total of 900
30
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industrial effluent streams that were tested in Michigan.
79
An earlier estimate indicated that as much as 1 ton of
PCBs was entering the Clyde River in Scotland per year as a
component of crude sewage sludge from the Glasgow district.
In addition, as noted above, PCBs on land may enter the
aquatic reservoir as a result of solubilization and surface
water runoff.
It has been demonstrated that the PCBs have a high
80
affinity for soils in soil-water systems but that these
hydrosoils may serve as a reservoir for resolution when the
PCB concentration in the sediments become sufficiently
81
high. In addition, when contaminated sediments are
disturbed (as, for example, in river scour), some of the
PCBs may be resuspended. The processes associated with
desorption from a sorbent may also tend to fractionate the
components of the commercial PCB mixtures in favor of the
more soluble components. In general, it is believed that
the material that is adsorbed onto the sediments is
eventually removed by migration to the ocean depths. Thus,
the sediments constitute a sink and, most probably, the
principal sink for the removal of PCBs from the environment,
Measurements of the PCB concentrations in the sediments
in the Hudson River above the General Electric outfall
32
-------
indicated levels ranging from 0.0 to 16.8 ppm. At Thomson
Island, about 1 mile downstream, typical sediment levels
ranged up to 3700 ppm,83 with the PCB levels in the
i
overwaters ranging from 0.06 to 3.0 ppm. Fish collected
within 1 mile of the General Electric outfall contained PCB
levels ranging from 78 ppm in minnows to 350 ppm in rock
bass.84 Striped bass sampled near West Point (well over
100 miles downstream of the GE outfall) had PCB residuls of
between 1.16 and 7.54 ppm.85 The magnitude of the PCB
losses through the process of volatilization
(codistillation) is not fully established, but there is
general agreement, as noted above, that this process is of
significance in the detailed mass balance for an aqueous
system. Volatilization from the air/water interface is a
principal source of the atmospheric reservoir of PCBs.86
E. Exposure to PCBs
1. Current Environmental Load of PCBs
It has been estimated that between 300 and 400 million
pounds of PCBs entered the general environment up to and
including 1975. Of this total, it is estimated that some 25
to 30 percent is free material and thus constitutes the
reservoir from which exposure of the biota might occur.87
The remainder of the environmental load, mostly in the form
33
-------
of industrial waste and discarded end use products, is
believed to be in landfill sites and thus constitutes a
potential source of new free PCBs. It is further estimated
that, at any given time, approximately one-third of the
non-terrestrial free PCBs are in the atmospheric reservoir,
while the remaining two-thirds are in the aquatic
88
reservoir.
2. Exposure of Organisms to the Terrestrial Reservoir
of PCBs
As pointed out above, the largest portion of the terres-
trial reservoir of PCBs remains in the discarded PCB-
89
containing products that are contained in landfills. The
average soil concentration of PCBs taken in non-landfill
90
areas has been found to be below detection level. A recent
91
report indicates that only 0.1 percent of the soil samples
analyzed showed detectable PCB levels. Sixty-three percent
92
of the contaminated sample were from urban areas. It is not
clear whether any substantial exposure of the biota to the
terrestrial reservoir of PCBs occurs.
3. Exposure of Organisms to the Atmospheric Reservoir
of PCBs
Inhalation and dermal contact by humans and other
animals are two possible modes of exposure to the
atmospheric reservoir of PCBs. Although measurements taken
at widely separated points have shown that there is a
detectable level of PCBs in most air samples, the observed
34
-------
levels are close to the limits of detection except
93
in the vicinity of PCB sources. If the estimated atmos-
pheric load noted above were uniformly distributed through-
out the atmosphere, the concentration of PCBs in the air
would be approximately 5 ng/m-^.
4. Exposure of Organisms to the Aquatic Reservoir of
PCBs
The rather complex relationship between the aqueous
phase, the biotaf and the sediments is illustrated in Figure
2 by the interconnecting lines in the figure. The biota-
incorporate PCBs either by direct sorption from the
contaminated waters or through the food chain relationship
between the benthic organisms living within the contaminated
sediments and the free-swimming organisms. There can be
little doubt that the direct pickup of PCBs from the
surrounding waters is a major route by which these compounds
enter the biota. A large number of marine and freshwater
species have been demonstrated to take up PCBs selectively
from surrounding water and concentrate these compounds at
levels many times higher than those in the water. The
phenomenon is known as bioconcentration. A typical
94
example is the reported bioconcentration of PCBs
by the fathead minnow by a factor of 230,000.
Currently, there is considerable disagreement as to the
role played by the process of bioaccumulation in the
35
-------
contamination of aquatic organisms. However, this process
is apparently the major source of PCB contamination of
terrestrial animals that feed upon aquatic organisms. This
relationship is illustrated by the right-hand side of Figure
2. It should be noted that terrestrial animals may have
significantly higher concentrations of PCBs in their tissues
than the aquatic forms they feed on. For example, while cod
and pike have been found with PCB levels on the order of 10
ing/kg of extractable fat, fish-eating birds such as herring
gulls and cormorants have been found with levels of 600-700
rog/kg and 400 mg/kg of extractable fat, respectively.
However, the impact of this route of exposure is not
limited to aquatic species. Man as well as fish-eating
terrestrial animals and birds also may be adversely
affected. Fish constitute a substantial part of man's diet.
Therefore, the concentration of PCBs in fish gives man the
choice of either giving up an important food source or
subjecting himself to the adverse effects of PCBs. In
addition, man may be exposed to lower levels of PCBs by
drinking contaminated water.
F. Present Distribution of PCBs in the Environment
This document has shown that the additional release of
PCBs into any of the environmental compartments may be
36
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expected to result in widespread distribution into all these
compartments and will eventually expose large populations of
wildlife and man to PCBs. This conclusion is further
supported by the fact that PCBs are already widespread in
the physical environment and in the biosphere.
Since the earliest identification of PCBs in fish
samples,95 literally thousands of environmental and
ecological samples from all over the world have been
analyzed and reported to contain PCB. For example, PCBs
have been identified in Antarctic ice samples from depths as
great as 5.5-6 meters.9^ sea and air samples taken in the
Sargasso Sea showed PCB levels on the order of 1 ng/m3 in
the air samples and up to 10 ng/1 in the sea samples.
Approximately 75% of human adipose tissue samples taken from
31 persons in the United States in 1973, showed PCB levels
ranging from 1 to greater than 3 ppm.9** Polar bears,
sampled as indicators of the top trophic level in arctic and
subarctic food chains, have been shown to have PCB levels of
up to 8 ppm (wet weight in fat)." Seals taken from a
variety of Canadian waters show levels of from a few ppm to
a high of 52 ppm.100 In addition, PCBs have been
detected, frequently at high levels, in a large number of
fish and bird species inhabiting widely separated geographic
areas.101 These samples, which are by no means all-
inclusive, indicate that PCBs are a global problem.
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G. Conclusions
PCBs have been demonstrated to cause a number of severe
adverse effects on many living organisms at very low
concentrations. As a practical matter, it is not possible
to determine a "safe" level of exposure to these chemicals.
Because PCBs are already widely distributed throughout the
biosphere, they currently pose a significant risk to the
health of man as well as that of numerous other living
things. As a consequence, any further increase in levels of
PCBs in the biosphere is deemed undesirable by EPA. It has
also been demonstrated that PCBs released anywhere into the
environment will eventually enter the biosphere. Therefore,
as a corollary, EPA has determined that any such release of
PCBs must be considered "significant."
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III. PCB SUBSTITUTES*
The following is a discussion of substitutes
available or in the process of development for PCB
dielectric fluid used in capacitors and transformers.
This discussion of substitutes is intended as a brief
summary. Inclusion or omission of any substance in
this discussion should not be co-ctrued as an
indication of EPA approval or disapproval of its use.
A. Capacitors
1. Phthalate Ester1
Dioctyl Phthalate (DOP) has been used in capacitors
manufactured in Japan since 1974. It is presently
being used in most of the capacitors manufactured in
the United States.
*Theinformation on substitutes for PCB Capacitors and
Transformers was primarily based on data contained in
the Versar study, PCBs in the United States;
Industrial Use and Environmental Distribution. Some of
the facts in that study were updated based on a review
by Versar of this discussion of substitutes prior to
issuance of the Draft Support Document. Information on
Uniroyal PAO-20E was provided by the Uniroyal Chemical
Company prior to preparation of the Draft Support
Document.
39
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Advantages of DOP are: (1) the cost is
approximately one-half that of PCBs; (2) DOP is
available as a substitute since it is currently used as
a plasticizer for polyvinyl chloride; and (3) its
dielectric constant is 5.3, similar to that of PCB.
Disadvantages of DOP are: (1) the maximum service
temperature of capacitors containing DOP is 85°C, as
opposed to 95°C for PCB; and (2) the corona inception
voltage is lower than that of PCB but can be raised by
the addition of trichlorobenzene to the mixture.
Diisononyl phthalate is a potential substitute for
PCB. It is manufactured by Exxon under the tradenane
Enjoy 2065 and is not available in large quantities.
Diisononyl phthalate is similar to DOP, although it is
more stable chemically.
The flash points for DOP and diisononyl phthalate
are relatively high (220° for DOP), yet both of these
phthalate esters are more flammable than PCBs. It
should be noted that a particular class of phthalate
esters, the alkyl phthalates, were recommended for
testing by the TSCA Interagency Testing Committee2.
2. Alkylated Chlorodiphenyl Oxide3
Butylated monochlorodiphenyl oxide is marketed by
Dov; Chemical Company under the tradename XFS-4169L.
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Based on four years of testing, McGraw-Edison, a
capacitor manufacturer, has found this material (which
they tradenamed EDISOL) to be a "viable substitute" for
PCBs in high voltage power capacitors. Although the
dielectric constant of EDISOL is somewhat lower than
that of PCB (4.5 versus 5.85), the size of EDISOL
capacitors marketed by McGraw-Edison is the same as PCB
capacitors at equal KVAR ratings.
Advantages of butylated nonochlorodiphenyl oxides
are: (1) a lower loss-tangent; (2) a higher corona
inception voltage than PCB by 20 to 30 percent; (3) a
higher flash point (174°C). Advantages of this
substitute vis-a-vis toxicity are that it (1) is more
biodegradable than trichlorobiphenyl; (2) has been
shown to be nonmutagenic in an Ames test; (3) has a
lower bioconcentration factor than PCB; (4) has a lower
adipose concentration than PCB; and (5) does not show
chloracnegenicity.
Disadvantages of butylated nonochlorodiphenyl
oxide are: (1) the higher material costs; and (2) a
lower fire point (199°C) than that of PCB.
B. Transformers
1. Fluorocarbons
Certain fluorocarbon compounds have properties
similar to PCBs. Fluorocarbons are highly volatile in
41
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comparison to PCB, and they are about six times as
expensive. Perfluoroethane is extensively.used as a
dielectric gas in totally enclosed gas filled
transformers, which can be used to replace PCB
Transformers in certain hazardous locations.
2. Silicones
Low viscosity silicone fluids, on the order of 50
centistokes, are possible substitutes for PCBs in
transformers. They are produced by General Electric,
Dow Corning, Union Carbide, and SWS Silicones.
Polydimethyl siloxane, a potential substitute, has the
molecular structure:
.__._£-_ i_
«.' v »l s. ),»•
CMN CM
,
Silicone fluids have the special advantage of a
relatively temperature-independent viscosity. The
silicone fluids have somewhat poorer heat transfer
characteristics than askarel but can be substituted
directly for askarel in existing transformers,
resulting in only a small decrease in the transformer
rating.
42
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Electrical Properties;
Dielectric Constant 2.72
Dielectric Strength 200 volt/nil
Resistivity 7.1 x 101 ohm-cm
Dissipation Factor 1.8 x 10~5 at 100 Hz, 23°C
Polydimethyl siloxane has a higher flash point
than conventional, non-PCB transforner coolants: 280°C
for mineral oil (PCBs have no true flash point.) The
heat of combustion of 50 centistoke polydinethyl
siloxane is lower than that of mineral oil—7.67
kcal/gm versus 11.0 kcal/gm—and since the silicones
burn more slowly, they are considered poor fuel.
On the Underwriters Laboratories' fire hazard
classification (in which water is rated as 0 and ether
I
as 100) polydimethyl siloxane is classified as 4 to 5,
which is slightly higher than the 2 to 3 rating given
to PCBs, but is considerably less than the mineral oil
rating of 10 to 20.
These compounds do not biodegrade, as measured by
sewage sludge breakdown to CO2. However, there is
evidence that they partly depolymerize to low molecular
weight compounds upon contact with soil and water.
Since ultraviolet light decomposes methyl silicones,
sunlight exposure may be the mechanism for
environmental degradation.
43
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No tendency for bioaccumulation or
bioconcentration has occurred in experiments. In
mammals, the compound is not absorbed through the
gastrointestinal tract or the skin.
The PCB substitute developed by Dow Corning for
transformers is called DC561. This is a mixture of
polydimethyl siloxanes of various chain lengths which
have a viscosity of 50CS. The literature on
environmental and health characteristics of silicones
makes reference to at least six fluids, most of which
are probably similar to the DC561, but some of which
could be other mixtures with certain additives. By
necessity, the usefulness of published toxicological
data depends on the validity of the assumption that all
of these compounds have identical persistence,
bioaccumulation, and toxicity properties.
A review of toxicological studies of silicones
reported the following results:
Dietary Toxicity:
LD50 (rats) >28 gm/kg
Extended Feeding Tests:
Guinea pigs—47 gm/kg/day for extended
period—no toxic effect.
Mallard ducklings and bobwhite quail—5000 ppm
for 5 days—no effect.
44
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Rats—20 gm/kg/day for 28 days—no effect.
Rats—190 mg/kg/day for 90 days—no effect.
Beagle dogs—300 mg/kg/day for 120 days—no
effect.
Mice—3 percent in diet for 80 weeks—no
effect.
Man—FDA allows silicones as food additives at
up to 10 ppn.
The major deficiency in knowledge of the silicones
appears to be in their fate in the environment and the
toxicity of their breakdown products.
The silicone transformer fluids currently cost up
to twice as much as PCBs on a volume basis.
Dow Corning has completed evaluation of
polydimethyl siloxane as a high voltage insulating
fluid. They report, though, that a near term 100
percent replacement of PCBs in transformers by this
fluid is not possible. If a transformer market were to
develop for polydimethyl siloxane, the present domestic
capacity could be adequate to supply new
transformers. The time lag for a 100 percent
replacement of PCBs in transformers by polydimethyl
siloxane would be on the order of 5 to 10 years.
45
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3. Mineral Oils6
Mineral oils are widely used in transformers. The
flash point of mineral oils is a function of its
molecular weight. Since crude petroleun can be refined
to have any required molecular weight over a wide
range, it is possible to specify any particular flash
point that is desired for the minimal oil transformer
liquid. This approach has been taken by RTE
Corporation in the development of their proprietary
transformer liquid, which has the tradename RTEmp.
RTEmp is a highly refined paraffinic mineral oil
that has a flash point of 285°C, approximately the sane
as the 50CS silicone liquid proposed by Dow Corning as
a PCB substitute. To achieve this higher flash point,
the oil is refined to have a higher molecular weight
and consequently a higher viscosity, which reduces its
effectiveness in convective cooling.
The major current advantage of the high flash
point mineral oils is their low price relative to
silicone and askarel and their inherent
biodegradability and low toxicity.
4. Synthetic Hydrocarbons^
Certain mixtures of synthetic hydrocarbons may
result in a liquid having the high flash point
characteristics of RTEmp or silicone combined with the
46
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relatively low viscosity and satisfactory heat transfer
characteristics. Examples of synthetic hydrocarbons
being tested as PCB substitutes include FR Dielectric
Fluid manufactured by Gulf Oil Chemical Company and
PAO-20E produced by Uniroyal Chemical.
Q
PAO-20E was designed for use in transformers.
Its dielectric strength (KV/0.25 cm) is 50, and its
dielectric constant is 2.15, as compared with 40 and
4.3, respectively, for PCB. It has a flash point of
276°C and a fire point of 307°C. Its acute oral LD50
(rats) is over 40 mg/kg.
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IV. SIGNIFICANT EXPOSURE/TOTALLY ENCLOSED MANNER
A number of persons commented on the Agency's proposed
definition of the term "significant exposure". This term
was defined as any exposure of human beings or the
environment to PCB chemical substances or PCB mixtures as
measured or detected by any scientifically acceptable
analytical method. The majority of the persons who
commented objected to the proposed definition (6, 31, 35,
38, 42, 46, 70, 81, 86, 94, 97, 116, 139, 140, 151, 167,
174, 208, 215, 216). Some persons stated that there was a
lack of adequate health and environmental effects data to
justify such a stringent position (31, 46, 140, 138, 215,
216). Some of these persons stated that the Agency's zero
exposure limit was unfounded particularly in light of the
Center for Disease Control (CDC) epidemiological study* on
the exposure of PCBs in Bloomington, Indiana. They also
contended that a National Cancer Institute (NCI) bioassay**
of Aroclor 1254 for possible carcinogenicity refuted earlier
data on the carcinogenicity of PCBs (82, 46).
*USDHEW, Center for Disease Control. Exposure to
Polychlorinated Biphenyls in Bloomington, Indiana.
Atlanta: Public Health Service, EPI-77-35-2, (May 26,
1978).
**USDHEW, PHS, NIH, NCI. Bioassay of Aroclor 1254 for
Possible Carcinogenicity. Washington: National Cancer
Institutes, Tech. Report Series No. 38, (1978).
48
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Two persons, however, agreed with the Agency's decision
to define "significant exposure" as any exposure (85, 182).
One person pointed out that the NCI and CDC studies do not
invalidate any of the results of previous studies indicating
that PCBs pose a carcinogenic risk to man. This person also
pointed out that scientists have observed other adverse
health effects from exposure to PCBs.
After reviewing all these comments and the CDC and NCI
studies, the Agency concludes that no change in its
evaluation of the health hazards of PCBs is warranted or
appropriate. The CDC study was not designed to determine
the carcinogenicity ot PCBs; therefore, that study is not
relevant for purposes of evaluating the carcinogenic risk
posed by PCBs. Furthermore, the study established that
humans exposed to PCBs had elevated serum levels of gamma
glutamyl transpeptidase (a liver enzyme) and triglycerides.
These effects indicate that PCBs cause enzyme induction and
may damage the liver in humans. The elevation of serum
triglyceride levels has additional significance in that such
elevations have been associated with atherosclerotic
cardiovascular disease. In sum, it is apparent that the CDC
study, rather than undermining the Agency's conclusions
about the hazards of PCBs, supports these conclusions.
The NCI study cannot be considered to establish
non-carcinogenicity. The study showed certain trends which
raise concern about the carcinogenicity of Aroclor 1254.
49
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For example, liver and gastrointestinal tumors were
found in rats treated with Aroclor 1254 but not in controls.
The incidence of these tumors was not statistically
significant. However, lack of statistical significance may
be a result of insufficient numbers of animals used in the
experiment.
In conclusion, the comments submitted and the CDC and
NCI studies do not warrant any change in the Agency's
evaluation of the adverse health and environmental effects
caused by PCBs. In particular, no acceptable reason has
been provided for rejecting the results of several studies
which indicate that Aroclor 1254 and other PCB mixtures are
carcinogens and cause numerous other adverse effects.
Therefore, the Agency adheres to its conclusion that the
release of any quantity of PCBs into the environment is
significant.
Further objections to the definition of "significant
exposure" were that the proposed definition makes compliance
difficult and could deter clean-up of existing contamination
(31, 46, 70, 16, 139, 140, 151, 167, 208, 216). Persons
stated that any housekeeping or maintenance operation will
necessitate some human or environmental exposure to PCBs.
To alleviate this problem some persons suggested that the
Agency take into consideration, when defining "significant
exposure", such factors as (1) industry's existing safe
50
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handling practices, (2) Occupational Safety and Health
Administration (OSHA) regulations which control a
substantial portion of the potential worker exposure from
maintenance and housekeeping operations, and (3) the
distinction between existing and newly introduced PCBs.
These comments indicate a misunderstanding of the
Agency's criteria for defining "totally enclosed manner."
The Administrator is required by §6(e)(2)(B) to define by
rule the term "totally enclosed manner" as the manner which
will ensure that any exposure of human beings or the
environment to a PCB will be insignificant. This language
clearly indicates that the Agency's definition of "totally
enclosed manner" is to be based strictly upon health and
environmental factors. Nowhere does TSCA state that in
defining "totally enclosed manner", the Agency is to
consider technological feasibility, economic impact, or
current industry practices. It is the Agency's
understanding that this same rationale can be applied to
defining "significant exposure". As General Electric (58)
commented, the term "significant exposure" is different from
the definition of "unreasonable risk" and is used solely for
the purposes of defining "totally enclosed manner".
Thus although such factors as technological feasibility,
economic impact, or current industry practices are not
considered in determining "significant exposure", they are
51
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considered, among other factors, by the Agency in deciding
whether or not an activity presents an "unreasonable risk"
to health and the environment. If an activity is found not
to present an "unreasonable risk", an authorization and an
exemption for such an activity to take place in a
non-totally enclosed manner may be granted.
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V. PCB DEFINITION: 50 PPM
A large number of persons representing industry and
environmental action groups commented on the Agency's
decision to lower the definition of "PCB Mixture" from 500
ppm to 50 ppm PCB. Some persons were concerned that 50 ppm
was too high (53, 84, 92, 126, 211, VIII TR, p. 172-178)
because there existed a health and environmental risk from
PCBs even at levels below 50 ppm. The majority of these
persons suggested that EPA lower the level at which PCBs
would be regulated.
Three persons agreed with the Agency's decision and
reasons, as stated in the proposed rule, for lowering the
level defining a "PCB Mixture" to 50 ppm (57, 85, 101). One
person stated that lowering the definition to 50 ppm would
not have a detrimental ettect on his industry (158).
The majority of persons commenting on this action
disagreed with the Agency's proposal to lower the definition
of "PCB Mixture" to 50 ppm. Their first objection was based
upon what they perceived to be either the lack of sufficient
economic information to determine the impact or the
substantially greater economic impact that would be incurred
by industry and the national economy by lowering the
definition from 500 to 50 ppm. This impact, they thought,
was unreasonable and, therefore, contrary to Congress'
intent (3, 4, 6, 11, 15, 17, 20, 25, 31, 35, 36, 37, 46, 49,
53
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55, 58, 62, 69, 70, 71, 72, 75, 80, 87, 89, 90, 91, 93, 94,
95, 96, 97, 99, 100, 104, 106, 109, 116, 122, 123, 133, 134,
137, 138, 139, 140, 145, 146, 147, 150, 151, 152, 156, 161,
165, 167, 170, 174, 178, 189, 190, 191, 201, 202, 208, 216,
IV TR, p. 7, V TR, p. 41).
These persons attributed the impact to a variety of
reasons. First, they thought that lowering the
concentration for regulating PCBs would require the affected
industries to spend more money on the additional
requirements for recordkeeping, testing, draining and
flushing, specialized storage and containers. Second, they
thought the affected businesses would incur a loss as a
result of the premature disposal of PCB Articles and
PCB-contaminated fluids. Third, they thought the
restrictions on allowable repair may cause some industries
to reduce their maintenance force. Lastly, they felt that
industry would incur a loss from shut down of certain PCB
Articles while these articles were being replaced or were
being serviced in order to bring the article into compliance
with the rule. These impacts, they believed, would affect
all sectors of the economy including industries, consumers,
and workers.
A substantial number of comments were received
indicating that the Agency was lacking prudence in lowering
the definition of "PCB Mixture" to 50 ppm. They felt that
by banning the current industry practice of burning of PCB
54
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contaminated fuels and by indirectly causing an increased
demand for fuel needed to transport PCBs to approved
incinerators, the Agency was aggravating energy problems in
the U.S. (11, 29, 36, 47, 49, 55, 134, 150, 198).
The Agency has reviewed all the comments and the
accompanying economic data that was submitted in regard to
this 50 ppm vs. 500 ppm issue. None of these comments
provide evidence that changes the Agency's finding that 50
ppm is the most reasonable concentration at which to
regulate PCBs. (For a thorough discussion of the Agency's
rationale for regulating PCB above 50 ppm see section II.B
in the Preamble to the final rule.)
The Agency, however, has modified the rule to reduce the
economic consequences to industry of the restrictions on
PCBs and PCB Articles containing greater than 50 ppm PCB to
the extent possible without compromising necessary
protection to health and the environment. (For a discussion
of the Agency's justification for reaching these
conclusions, see section III, Changes in Subpart B:
Disposal of PCBs and PCB Items, as found in the Preamble to
the rule). First, the Agency is allowing persons to dispose
of PCB-contaminated fluids between 50 and 500 ppm PCB, in
high efficiency boilers. Second, for those industries who
do not have access to high efficiency boilers or who prefer
landfill disposal, the Agency is permitting the use of
55
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chemical waste landfills tor the disposal of such PCB-
contaminated fluids, subject to certain conditions. Third,
the Agency is permitting the recycling of mineral oil.
Lastly, the Agency has decided to allow persons to drain
mineral oil transformer fluids contaminated with PCBs in the
range of 50 to 500 ppm into collection tanks and test the
batched mineral oil instead of requiring them to test each
individual transformer. These practices will substantially
reduce the cost of disposal and testing.
The Agency believes that the changes that have been made
in the rule, particularly the changes in testing and
disposal requirements for PCB liquids, will permit the use
of PCB-contaminated mineral oil dielectric fluid as a fuel
and will therefore alleviate some of the cost to the
consumer and the power industry for energy. In addition, by
permitting other methods of disposal that may be more
conveniently located, the Agency is also reducing the demand
for fuel needed to transport PCBs and PCB Items to disposal
facilities.
Some persons objected to the proposed definition because
they did not believe that the Agency had sufficient health
and environmental justification for regulating PCB at 50 ppm
particularly in light of the economic impact. These
persons, in general, felt that the economic impact far
outweighed the adverse health and environmental effects
56
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(11, 15, 31, 36, 69, 70, 71, 81, 89, 91, 93, 94, 95, 100,
109, 140, 145, 146, 147, 148, 150, 156, 165, 198, IV TR, p.
7). In some cases these persons felt that there was no data
that suggested that there was any health and environmental
hazard from PCBs (6, 29, 59, 96, 97, 116, 199, 122, 123,
132, 172, 191).
The Agency disagrees that there are insufficient adverse
health effects data to warrant regulations below 500 ppm.
PCBs at levels below 500 ppm have been shown to cause a
variety of adverse health effects in animals including
malignant and benign tumors, enzyme induction, immunological
suppression, and fetotoxic, mutagenic, and reproductive
effects. (A more detailed discussion of these health
effects is discussed in Section II of this document.)
Some persons objected to the proposed 50 ppm definition
for reasons of inadequate analytical chemistry capability.
These persons contended that reliable analytical results
were unobtainable because either the methods were invalid or
because they were unable to find a laboratory that was able
to supply reliable results (18, 29, 95, 97, 202). Other
persons objected because there were not enough laboratories
to perform these tests (31, 95) or because the already
existing laboratories would become overburdened with work
thus aggravating the delay in receipt of results (88).
57
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They felt that unless there was a valid method for analyzing
PCBs at low levels in oils and chemical products such as
pigments, industry could not be expected to comply with the
rule.
The Agency disagrees with these comments. A variety of
accepted analytical methods for measuring the concentration
of PCBs in several media are currently available. A number
of these methods are described in the Preamble to the rule
in Section III. In addition, commercial and industrial
laboratories are capable of using these methods to produce
valid analytical results for PCBs. Industries with i
specialized analytical expertise for their product, e.g.,
pigments, will be expected to adopt appropriate PCB
analytical methods to determine PCB concentrations in their
processes or products.
Some commentors thought that because 1) EPA was
increasing the amount of PCBs that had to be handled by
lowering the applicable PCB concentration from 500 to 50 ppm
and 2) the distances to EPA approved incinerator or disposal
facilities may be far, EPA was actually increasing the
chances that this material might be accidentally released to
the environment (36, 81, 90, 146, 152, 172, 198, IV TR, p.
7).
As a result of the Agency's decision to permit certain
PCBs and PCB Items to be disposed of in chemical waste
landfills and high efficiency boilers in addition to high
temperature incinerators, the number of approved facilities
58
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will be expanded. This should reduce the likelihood of
environmental contamination from spills as the. distance over
which these materials must be transported is reduced. In
addition, the Agency is also requiring persons who possess
PCBs to comply with certain spill prevention practices
(see Preamble section V.C.3).
One person stated that the proposed 50 ppm definition
would have a disproportionate impact on small businesses
because in most cases small businesses are unable to perform
their own testing. They must therefore rely on independent
organizations and would need substantially more time to test
for PCBs than would be needed by large businesses who could
perform their own testing. The commentor suggested that
the delay in receipt of the results for transformer testing
could increase the time that the transformer is out of
service (87).
The Agency is aware that small businesses have to rely
on outside testing laboratories to a greater extent than
large businesses. However, the final rules greatly reduce
the need for testing by allowing persons to make certain
assumptions about the transformer, based upon its history.
This alternative benefits small and large businesses
equally.
A variety of alternative regulatory techniques other
than the ones adopted by the Agency were suggested. A
number of persons recommended that EPA raise the lower level
at which the Agency is regulating PCBs and PCB Articles to
59
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levels above 50 ppm and/or postpone the effective date by
which persons must comply with this level. (500 ppm was the
most frequently recommended level.) (31, 34, 36, 37, 49, 54,
59, 72, 75, 81, 87, 89, 91, 94, 95, 102, 104, 116, 119, 122,
123, 132, 133, 137, 139, 146, 150, 156, 161, 174, 188, 189,
190, 191, V TR p. 139) Others suggested that EPA apply the
restrictions on the disposal of articles that contain
greater than 50 ppm only if the total amount of PCBs in the
articles exceeds a specified amount (15, 49, V TR, p. 21).
The Agency considered these suggested alternatives and
believes that the approach that it has taken in the final
rule is the best method for both controlling the risks from
PCB and minimizing the economic impact.
The Agency believes that the first alternative is
unacceptable because it would allow a substantial amount of
PCB to escape to the environment since many activities
involving PCB-contaminated materials would go unregulated.
For the most frequently mentioned cut-off level, 500 ppm,
the Agency has predicted that at least 1 million pounds of
existing PCBs (using data developed by Versar) and 100,000
to 500,000 pounds per year of newly manufactured PCBs (using
data from manufacturing petitions) could escape to the
environment. The later numbers are based upon the
assumption that the 60,000 or so pounds that industry
suggested is an underestimate. The Agency believes that
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VI. DILUTION
One pigment manufacturer stated that some persons in the
pigment industry would have difficulty complying with the
anti-dilution clause in the proposed rule (VII TR, p. 9).
He stated that some pigment manufacturers produce pigments
in batches and then blend the batches to insure uniformity.
Two persons stated that because, as they believed, the
dilution constraint was aimed at persons who might consider
diluting in ordei: to avoid complying with EPA's disposal
procedures, EPA should qualify the rule by stating that
normal manufacturing operations such as blending do not
constitute "dilution" (174 VII TR, p. 9,).
The Agency agrees that the blending and subsequent use
of chemicals such as pigments was not the type of dilution
that EPA wanted to control. Person's who, for operational
reasons, dilute their PCBs in a manner not specifically
authorized by EPA, may request an exemption from the
prohibitions on (dilution. These exemptions will be dealt
with on a case-by-case basis. See section II.C of the
Preamble for a discussion of the dilution provisions.
One person asked that reduction of PCB concentration
that occurs during an authorized activity, such as refilling
hydraulic systems, not be subject to the prohibitions on
dilution (101) .
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chere are some pigment manufacturers that have not submitted
an exemption request because they have assumed, erroneously,
that they do not need to do so.
The second alternative is a more complicated approach to
implement because of the difficulty with using poundage
instead of concentration limits as a trigger for requiring
compliance with restricted disposal procedures. The problem
becomes particularly pronounced when a volume of PCB liquid
is in someway combined with other PCB liquids changing the
pounds of PCB per container. The Agency believes that its
use of concentrations to define applicability is much
simpler, more easily implemented, and achieves the same goal
of defining a reasonable level at which to regulate PCBs.
As discussed above, alternative methods of disposal such as
high efficiency boilers, chemical waste landfills, and the
use of batch testing should substantially reduce the cost of
this rule.
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One person also objected to the restrictions against
unintentional dilution as contained in the definition of PCB
mixture (29). He stated that EPA needs to distinguish more
adequately between dilution to avoid disposal compliance and
dilution from unintentional contamination. He also
recommended that EPA exclude non-PCB contaminated fluids
from the definition of PCB mixture when the PCB
concentration is less than 50 ppm (29).
The Agency agrees with this comment and again has
accordingly modified the final rule by deleting the defined
term "PCB Mixture" and by explaining in the Preamble (see
sections II.C.4.a and III.E of the Preamble) the
circumstances under which intentional and unintentional
dilution resulting in improper disposal of PCBs or PCB
Articles, constitutes a violation of the rule. As part of
these changes, the final rule no longer restricts the
disposal of PCBs that contain leas than 50 ppm PCB as long
as the PCB concentration was the result of activities
permitted by an authorization. The Agency, however, is
restricting the disposal of PCB-contaminated fluid above 50
ppm whether or not the PCBs are present as a result of
unintentional contamination. The Agency believes that
whether or not PCBs are the result of intentional or
unintentional action, PCBs above 50 ppm pose a health
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and environmental risk. (See section II.B of the Preamble
for a more explicit discussion of the Agency's reasons for
choosing 50 ppm as the cut-off concentration.)
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VII. TRANSFORMERS
The Agency's proposal to regulate mineral oil
transformers that are contaminated with PCBs resulted
in a large number of comments, especially from electric
utilities and transformer servicing and manufacturing
companies. A few comments argued that the rule, as it
related to PCB and mineral oil transformers, went
beyond the intent of the TSCA (46, 49, 97, 156, 169,
III TR, p. 124, IV TR, p. 5).
The Agency believes TSCA is clear in giving EPA
authority to regulate the manufacturing, processing,
distribution in commerce, and use of PCBs in
transformers. Transformers, inasmuch as they contain
PCBs or PCB contamination, are subject to control under
the authority of TSCA. (See Section XII of this
Support Document for a discussion of the justification
for regulating PCB Articles and PCB Equipment.) The
extent of controls on transformers has been determined
by a process of considering both the clear benefits
resulting from transformer activities and the potential
environmental and human hazards that can result from
those activities.
Many of those commenting expressed the belief that
the environmental, economic, and energy trade-offs had
not been fully and properly weighed (11, 35, 44, 46,
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48f 49, 53, 55, 57, 60, 70, 71, 82, 83, 91, 96, 97,
100, 109, 110, 121, 129, 131, 134, 137, 140, 150, 156,
167, 170, 189, 190, 196, 208, 210, 216, 218, I TR, p.
22, I TR, p. 118, II TR, p. 6-7, II TR, p. 60, III TR,
p. 138, VII TR, p. 45-48).
In proposing the PCB regulation as it applies to
transformers, the Agency weighed all environmental,
health, and economic (including energy) factors
available to it at the tine. In the Preamble to the
proposed regulation, the Agency noted a number of areas
in which more information relating to these factors
would be particularly useful. Largely as a result of
data submitted in response to the Agency's recmest for
additional information, a number of modifications to
the proposed regulation have been made. These changes
include allowing PCB Transformers to be reclassified as
PCB-Contaminated Transformers under certain conditions
and changing disposal and testing requirements for PCB-
contaminated mineral oil. (An extensive discussion of
the Agency's rationale is found in the Preamble to the
final rule in section II.C, Classification of
Transformers Under This Rule.)
Several comments requested that EPA impose a
moratorium on adopting the prohibition rule pending
further study of economics and acceptable levels of
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PCBs in the environment (48, 49, 91, 93, 210, I TR, p.
15).
The Agency is directed by TSCA to implement the
bans on PCB activities in keeping with the designated
timetables that are contained in the Act. In setting
specific dates for the prohibition of PCB activities,
Congress intended to give the Agency limited discretion
in the timing for implementing the PCB bans.
The proposed five year authorization period for
servicing PCB Transformers was strongly objected to by
many persons as being too short and therefore
unreasonable (11, 17, 20, 31, 32, 35, 37, 42, 53, 58,
71, 85, 88, 104, 156, 199, 210, I TR, p. 17). One
comment endorsed the servicing authorization of five
years provided the authorization was subject to further
renewal (89). One comment recommended shortening the
five year authorization period since the criteria in
§6(e)(3)(B) of TSCA called for annual exemptions
(83). Many comments suggested an authorization should
be granted for the useful life of the transformer (17,
36, 37, 54, 70, 82, 98, 156, 178, 189, I TR, p. 17).
The proposed five year authorization for servicing
transformers was not intended to signify Agency intent
to end those activities after five years. Its purpose
was to require a reassessment of the servicing
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limitation prior to the end of the five year period so
that factors such as new servicing technology could be
considered in deciding the need for authorizations
beyond the initial five year period. Due to the
Agency's desire to have exemptions and authorizations
expire at the same time, the Agency has changed the
five year authorization so that it will expire on July
1, 1984. (This issue is discussed in sections VIII.B
and IX.A of the Preamble).
Two persons objected to the differentiation made
between exemption requirements for servicing by owners
and non-owners (11, 156).
Under §6(e)(3) of TSCA, processing and
distribution in commerce of PCBs after July 1, 1979 are
not permitted unless an exemption has been granted by
EPA. If a person services his own transformer with his
own PCBs, processing and distribution in connerce do
not occur. However, if one is servicing another's
transformer and adds PCBs to that transformer so that
title to those PCBs is changed, processing and
distribution in commerce occurs. Because TSCA requires
an exemption for distribution in commerce after July lf
1979, the Agency must require a person who adds PCBs to
another's transformer to have an exemption after that
date.
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One person commented that the proposed rule would
have a greater impact on snail businesses whose sole
income comes from the repair of PCB Transformers than
it would have on companies such as General Electric and
Westinghouse who, in addition to repairing PCB
Transformers, also manufacture other electrical
articles and equipment (49).
The Agency acknowledges that this regulation could
have a greater impact on businesses who have smaller
profit margins and less diversified sources of
income. However, as one trade association noted, the
restriction on the rebuilding of PCB Transformers would
affect around only 10% of the total business for small
repair companies (VI TR, p. 79). Further, it is
reasonable to assume that the loss of this repair
activity can be compensated for by expansion into other
repair activities.
A large nunber of persons commenting objected to
the prohibition against rebuilding of PCB Transformers
(30, 57, 58, 89, 91, 93, 94, 123, 131, 137, 156, III
TR, p. 87-88, III TR, p. 124, VI TR, p. R). A number
of comments contended th^t rebuilding presented no risk
to man or the environment (9, 46, 49, 91, 93, 137, 210,
I TR, p. 18, III TR, p. 127, IV TR, p. 5, VII TR, p.
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53-55). Two comments were received expressing concern
for the exposure to workers during the rebuilding of
PCB Transformers (53, 74). Three comments recommended
that rebuilding be allowed at EPA-approved transformer
facilities using EPA standards for the rebuilding
activities (17, 48, 74). Three comments stated that
they had no serious objections to the restrictions on
rebuilding of PCB Transformers (46, 71, VII TR, p. 29).
None of the comments the Agency received presented
data that would change EPA's finding that continued
rebuilding of PCB Transformers would present an
unreasonable risk of injury to human health or the
environment. EPA decided to not develop rebuilding
standards because they would probably have an
unacceptably high economic impact. This issue is
discussed further in section IX.A.I, General Discussion
of Transformer Servicing, in the Preamble to the rule.
Several persons recommended that EPA either
require or at least permit PCB Transformers to be
drained, flushed, and refilled with non-PCB fluid, or,
on a voluntary basis, be permitted to perform such
actions (39, 53, 58, 77, 82, 85, 94, 104, 123, 144,
190, 204, VI TR, p. 162). Three persons stated that
acceptable substitutes for PCBs were available for both
topping-off and refilling (38, 58, 121). Some comments
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expressed apprehension about the availability of
acceptable substitutes (31, 35, 44, 11, 91, 104, 144,
VI TR, p. 59, VII TR, p. 51-52). Others objected to
the suggestion that PCB Transformers must be refilled
with non-PCB fluid (31, 153). One comment objected to
refilling and topping off with non-PCB fluid because it
would only add to the amount of material to be disposed
of (43).
EPA wishes to note that the use of substitutes for
topping off or refilling PCB Transformers is
optional. Owners or operators are not precluded from
adding a dielectric fluid with greater than 500 ppm PCB
to a PCB Transformer. Routine servicing and topping
off of PCB Transformers with additional PCBs is not
considered a potentially hazardous operation and is
consistent v/ith the authorization of continued use of
PCB Transformers.
Many of the comments received regarding mineral
oil transformers expressed concern that the
restrictions on the recycling of PCB-contaminated
mineral oil and transformer casings would result in the
waste of oil, valuable metals and other natural
resources (3, 11, 36, 46, 49, 55, 77, 82, 88, 97, 103,
107, 122, 137, 150, 151, 153, 156, 188, 210). The
majority of comments advocated permitting a disposal
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method, other than high temperature incineration for
mineral oil contaminated between 50 and 500 ppm PCB
(41, 46, 70, 71, 90, 93, 94, 102, 119).
Most of the persons commenting recommended the use
of contaminated mineral oil (mineral oil containing
between 50 and 500 ppm of PCBs) as a fuel in electric
utility boilers. They argued that this method of
disposal had two very positive effects; one, it would
reduce the economic costs of disposal, and, two, it
would utilize the fuel value of the oil thus reducing
the waste of natural resources (4, 28, 36, 37, 46, 58,
72, 88, 97, 100, 103, 111, 134, 144, 145, 147, 151,
156, 172, 190, 198, I TR, p. 142-143, I TR, p. 116, II
TR, p. 60, VI TR, p. 46). In addition, several
comments were made stating that the scarcity of
suitable disposal facilities makes disposal burdensome
and costly (11, 37, 46, 77, 82, 87, 88, 102, 156, 165,
172, 188, 201, I TR, p. 156, II TR, p. 60-61). Others
argued that the lack of disposal facilities would
increase the hazard of environmental contamination
created by transporting PCBs long distances to approved
facilities and would increase the length of storage
time (33, 77, 82, 144, 151, 198, 210). A few comments
suggested that contaminated mineral oil should be
permitted for reuse as recycled oil or used as a
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solvent for successive flushings of transformers. This
would further reduce the total amount of contaminated
mineral oil that will be disposed of, decrease the
demand for new mineral oil, and reduce the economic
impact of the rule (5, 27, 40, 42, 82, 156, I TR, p.
16). Several comments endorsed the EPA proposal which
did not place restrictions on the salvaging of mineral
oil transformers once the fluid had been drained from
then (40, 94, IV TR, p. 22).
The final rule represents a significant change
from the proposal on the disposal requirements for
mineral oils contaminated between 50 and 500 ppm PCB.
As noted above, a number of comments, particularly from
utilities, favored continuation of the existing
practice of burning waste mineral oil in power
generation boilers. On the basis of our analysis of
these comments, the rule has been changed to allow the
burning of such oil in high efficiency boilers. A
complete discussion on this change is contained in
section III.A, Mineral Oil Dielectric Fluid with 50 to
500 ppm PCB, in the Preamble to the rule.
In addition, the final rule allows the disposal of
PCB-contaminated mineral oil dielectric fluid and other
low concentration PCB liquid wastes in chemical waste
landfills. Chemical waste landfills have been shown to
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be an acceptable technique for disposing of low
concentration liquid wastes. These two alternatives
will reduce mineral oil disposal costs and lessen the
burden on incinerators.
Another area of concern to many of the persons
commenting were the testing requirenents for mineral
oil. The costs of testing were cited as extremely
burdensome (31, 35, 37, 49, 80, 83, 90, 91, 94, 100,
103, 108, 111, 113, 122, 137, 144, 145, 146, 147, 165,
176, 189, 201, I TR, p. 136, II TR, p. 51, II TR, p. 5-
6). Several alternatives were suggested for dealing
with the problems associated with testing mineral oil
transformers. The most commonly advocated suggestion
was to permit bulk storage and testing of mineral oil
for PCB contamination. This method would be preferable
because it would substantially reduce the economic
burden associated with testing, reduce the likelihood
of long delays in obtaining results, and reduce
interference in day to day business operation (4, 27,
37, 65, 87, 100, 103, 183, I TR, p. 15-16, I TR, p.
107, I TR, p. 131-132, I TR, p. 138).
Several comments recommended that the requirements
for testing of PCBs in non-PCB Transformers be deleted
because of high cost (123, 188, VI TR, p. 20). One
alternative suggested that FPA exempt mineral oil
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filled distribution transformers from sampling and
analysis for the purpose of labeling and disposal, if
the unit was originally a mineral oil transformer and
there had been no servicing that would have made
contamination possible (88, 108).
Some comments stated that there are not sufficient
laboratories qualified to analyze PCBs to meet the
demand created in the proposal. They also expressed
concern about the divergent results reported by
different laboratories analyzing identical samples, and
they feared that increased demand would result in the
establishment of many unqualified laboratories because
EPA has not established testing standards for PCBs (31,
46, 88, 95, 144, 172, 190, 210, II TR, p. 57, I TR, p.
139-140).
The Agency is addressing the issue of testing
burdens and costs by allowing persons to assume that
mineral oil from mineral oil transformers is
contaminated with PCBs between 50 and 500 ppm PCB.
This assumption therefore permits these persons to
dispose of their mineral oil in high efficiency boilers
or chemical waste landfills in addition to the proposed
method of disposal in high temperature incinerators.
This greatly reduces the need to test mineral oil for
PCB concentration. Testing may be desired to determine
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if the PCB concentration is below 50 ppm in order to
use or dispose of the oil with fewer restrictions.
In instances where testing is to be performed,
batch testing of the mineral oil is allowable, rather
than requiring testing of the oil fron each individual
transformer. As indicated in comments, batching of
mineral oil is common industry practice and the Agency
sees little environmental advantage to requiring
individual transformer testing. In addition, batch
testing will result in additional testirtg cost
savings. (A more complete discussion on transformer
testing and batch testing is provided in the Preamble
to the rule in section II.C.4.a, Determining
Appropriate (Transformer) Categories, and in section
III.E, Batch Testing of Mineral Oil Dielectric Fluid,
respectively.)
The Agency has responded to the concerns about
testing methods and consistent results by adding a new
section to the Preamble of the rule, section XII, Test
Procedures for PCB, that describes the approach for
improving testing results for PCBs.
The disposal and salvage of drained mineral oil
transformers are essentially not controlled by this
rule, which is unchanged from the proposal.
Several persons requested that EPA revise the rule
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to deal with mineral oil transformers and equipment
under a less restrictive set of rules (46, 97, 134).
Others desired that all mineral oil filled transformers
be exempted from the rule (4, 87, 147, 189, VI TR, p.
17-18). A few comments recommended that transformers
containing mineral oil with less than 500 ppm PCB be
excluded from the rule (110, 129, 134, 139, I TR, p.
15). Several comments advocated the partial or total
exclusion of certain types of transformers containing
less than a certain number of gallons of fluid (83,
147, 156), and one comment was received suggesting that
only mineral oil transformers past a certain age should
be subject to regulation (11).
No evidence has been presented that would convince
EPA to be less restrictive or to exclude certain
classes of mineral oil transformers from control under
this regulation on the basis of size, age, or
manufacturer. None of the comments were able to
disprove the Agency's belief that PCB contamination
results both from previous manufacturing practices and
past and present service practices.
A few comments were received advocating a
requirement that all transformers manufactured after
January 1, 1979 be labeled "No PCBs" (4, 102, 109,
144). Other comments were received that stated
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existing narking requirements were sufficient (46, 91,
93, 94).
The narking requirements for PCBs have been
modified to reflect EPA's lowering of the applicable
PCB concentration to 50 ppm. All containers of PCB-
contaminated mineral oil that have 50 ppm or greater of
PCBs are required to be marked, but PCB-Contaminated
Transformers are not required to be marked since all
transformers are either marked as PCB Transformers or
are assumed to be PCB-Contaminated Transformers. A
more complete discussion of marking changes is
contained in the Preamble to the rule; section IV,
Changes in Subpart C: Marking of PCBs and PCB Items.
The Agency does not agree with the recommendation
to place "No PCBs" labels on transformers manufactured
after January 1, 1979 because of the continuing
potential to contaminate transformers with PCBs during
servicing operations.
One person objected to the proposed 50 ppm cut-off
concentration because he thought that regulation of
PCB-Contaminated Transformers would create an increased
demand for naphthenic oil, a replacement transformer
fluid that is in short supply. He thought that the
rule would worsen an already critical situation and
make it difficult to maintain equipment (88).
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The Agency wishes to clarify that this connent
presumes that EPA was prohibiting recycling transformer
oils containing more than 50 ppm PCB. This is not the
case. The Agency, in its authorization for servicing
PCB-Contaminated Transformers, permits the recycling of
dielectric fluid with less than 500 ppm PCB for use in
PCB-Contaminated Transformers. The Agency, aware that
the proposal could have been more direct, has made this
point more explicitly in the final rule in
§761.31(a)(3).
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VIII. RAILROADS
A number of comments were made by affected parties that
were critical of the Agency's proposal. The Agency proposed
that railroad transfomers that use PCB dielectric fluid,
reduce the PCB concentration in the dielectric fluid to
less than 40,000 ppm PCB at the end of 15 months and to
1,000 ppm at the end of three years. Two commentors
indicated that due to the availability of substitutes, the
requirements for draining and refilling PCBs for use in this
application should be more stringent (53, 85). Other
commentors stated that the schedule was too stringent
because analysis has not yet been completed on the technical
and safety aspects of refilling railroad transformers with
non-PCB fluid. Therefore, these persons thought that
requirements for refilling transformers in 15 months and
restrictions on the allowable residual PCB levels in those
transformers should be delayed until that analysis is
completed (12, 13, 33, 128, 149, 197). Comments were also
submitted which expressed concern that 40,000 ppm PCB (4% on
dry weight basis) would be difficult to achieve using
standard refilling practices. They recommended a slightly
higher level of 6% PCB (33, IX TR, p. 125).
The Agency agrees that additional data on the technical
feasibility and safety of potential substitutes used in a
refilling program would be extremely useful and has,
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therefore, postponed the date by which a 1,000 ppra level
must be achieved. This delay will allow the railroad
industry a reasonable amount of time to complete the study
and to reduce their PCB concentrations to a level that will
not present an unreasonable risk to health and the
environment. In addition, the Agency agrees that routine
refilling is not likely to reduce PCB concentrations to 4%
PCB and has, therefore, raised the allowable concentration
of PCB from four percent to six percent. The rationale for
these decisions is discussed in depth in section IX.B of the
Preamble.
Some comments were also made urging that the rule not
apply to equipment that will be retired as a result of the
Northeast corridor power conversion (VIII TR, p. 196, IX TR,
p. 159, IX TR, p. 177).
In response to the railroad industry's concern about
completing and reviewing the safety study on non-PCB
substitution, EPA postponed, as explained above, the date by
which the initial refilling was to be completed to January
1, 1982. Originally this coincided with the schedule for
the Northeast power conversion. However, recently the
Department of Transportation announced that the project will
not be completed until the Fall of 1983. Although the date
for this initial refilling does not coincide with the new
DOT schedule for power conversion, EPA has decided not to
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again postpone the date because the economic impact of the
proposed rule has already been significantly reduced by
postponing to January 1, 1982, the date of initial refilling
to achieve a 60,000 ppm PCB residual. The PCB concentration
in all PCB railroad transformers will have to be further
reduced to 1,000 ppm by January 1, 1984.
Since the DOT change-over will not occur until late
1983, almost 90 percent of the time period authorized for
operation at 60,000 ppm will be available for the older
locomotives before the change-over forces them out of
service. This means that the railroads will not have to
spend large amounts of capital for PCB reduction and then
shortly thereafter phase out the use of the older railroad
transformers.
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IX. MINING
Few comments were made regarding the proposed
authorization tor PCB use and servicing in underground coal
mining. One commentor essentially supported the proposal (I
TR, p. 6-34). Another commentor briefly criticized the
proposal as placing too much emphasis on economic factors
(53). The Agency disagrees with this latter comment
inasmuch as the schedule for removal of PCB motors and
loaders is based on the rate at which this equipment can be
substituted with non-PCB Equipment or can be modified to
accomodate non-PCB fluids without disrupting the U.S.'s coal
production.
*
The Agency believes that the phased removal approach it
has taken will substantially reduce the cost of immediate
removal while not creating an unreasonable risk to health
and the environment. For a more detailed discussion of this
use of PCBs, see section IX.C of the Preamble.
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X. HYDRAULIC SYSTEMS
The proposed rule authorized the use and regulated the
removal of PCBs from hydraulic die casting systems which are
machines used to cast metals under high pressure and are a
major source ot PCB-contaminated hydraulic fluid. During
the comment period the : gency received comments explaining
that there are other types of similar hydraulic equipment
that are not classified as "die casting" hydraulic equipment
but which should logically be treated the same as hydraulic
die casting equipment for purposes of this regulation (15,
59, 101).
The Agency agrees with this comment and has, therefore,
broadened the applicability of the authorization to cover
all hydraulic systems that use PCB-contaminated hydraulic
fluid.
Some comments stated that the proposed semi-annual
requirements for testing of hydraulic systems and
replacement of the fluid were impractical due to testing
difficulties and production disruptions (15, 59, 101).
The Agency has taken note of this concern and is now
requiring that the system be tested within six months from
the effective date of the rule and then only annually
thereafter until the PCB concentration is below 50 ppnM
Refilling, if required, must take place within six months
after testing. This change from semi-annual to annual
testing and refilling will be less disruptive as most
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systems undergo repair or overhaul at least once annually
(see section IX.E of the Preamble).
Comments from industry also noted difficulties in
reducing the PCS level in a hydraulic system's fluid to less
than 50 ppm (15, 101). One non-industrial commentor was
critical of the Agency for not requiring reduction of the
concentration of PCBs to undetectable levels (V TR, p. 163).
The Agency agrees with this first comment that it would
be difficult to reduce PCB levels in hydraulic systems to
levels below 50 ppm. Reducing PCB concentrations to 50 ppm
would require relatively few flushings; whereas, to achieve
and maintain levels substantially below 50 ppm is likely to
require a large number .of flushings. This is due to the
residual levels ot PCBs that are found in most systems that
ever used or that were ever contaminated with PCBs and which
are likely to recontaminate the purified fluid with minute
amounts of PCBs. These residual PCBs are not likely to
raise the fluid's PCB concentration to levels above 50 ppm
but may raise the PCB concentration from undetectable levels
to detectable levels. (For a more extensive discussion of
this 50 ppm subject as it relates to all uses of PCBs, see
the Preamble to the rule section I.B)
A comment was made that once a hydraulic system is
tested and found to contain less than 50 ppm PCB, the
Agency's proposed requirement that testing be performed
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again after at least three months is unnecessary (15). The
Agency agrees with this comment and has deleted that
requirement.
One comment was received that suggested hydraulic
systems of less than 55 gallons not be covered by the rule
(15). The commentor stated that since the capacity of
systems which hold less than a 55 gallons is small, they
have tended to be easier to top and refill in the past and
thus are less likely to contain high PCB levels.
The Agency feels that testing is necessary in order that
owners of all hydraulic systems that ever contained PCBs
accurately determine the PCB levels contained in all their
hydraulic systems. In addition, the Agency has no reason to
assume that all small hydraulic systems are better
maintained than larger systems. The one comment EPA
received may not necessarily be representative of all owners
of such hydraulic systems.
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XI. HEAT TRANSFER SYSTEMS
In the proposed rule, the Agency did not authorize the
use or servicing of heat transfer systenC ocehl tats <.c iSCajpm
or greater PCBs. At the time of the proposal, the Agency
did not have adequate data on the use of heat transfer
systems to propose an authorization. The Agency received
very few comments on this use of PCBs.
Two commentors were critical of the Agency's lack of a
proposed authorization (81, 116). One commentor, a
manufacturer of heat transfer fluids, said that as many as
450 heat transfer systems may have been contaminated with
PCBs but that the potential for exposure to PCBs from these
systems is low. He said that the pump seal, which is the
highest risk area for leakage, is monitored and inspected so
that a leak would be rapidly detected (81). The other
commentor addressed the need for a servicing authorization
for heat transfer systems, noting that the environmental
risks presented by continued use and servicing are no
greater than for other PCB activities that EPA proposed
authorizing (116).
The Agency understands the need for a use and servicing
authorization for owners of heat transfer systems. (See
section IX.D of the Preamble for a discussion of the
Agency's reasons for authorizing this use.) These
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activities are authorized until July 1, 1984 under the
condition that all systems that have ever contained PCBs are
tested to determine their current PCB levels. Any system
found to contain more than 50 ppm PCB must be drained within
six months and refilled with fluid containing less than 50
ppm PCBs. Topping off a heat transfer system with non-PCB
fluids can also be conducted to reduce PCB concentrations
below 50 ppm. Annual testing will be required until a 50
ppm or less PCB concentration is achieved. The first
testing must be by October 1, 1979. This date was chosen on
the basis of a commentor's suggestion that considerably more
than the 30 days that was proposed would be needed for
testing of a hydraulic or heat transfer system (15).
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XII. PCB ARTICLES AND PCB EQUIPMENT
A number ot commentors (1, 2, 7, 16, 46, 52, 53, 58, 66,
86, 115, 120, 130, 156, 157) contended that the legislative
history of §6(e) of TSCA demonstrates that this provision
does not give the Agency authority to regulate PCB Articles
and PCB Equipment. However, another commentor (182) noted
that the legislative history for §6(e) does support such
regulation by the Agency.
EPA has reviewed the legislative history of §6(e) in
light of the various comments received concerning regulation
of PCB Articles and Equipment. The legislative history
indicates (1) that the words "polychlorinated biphenyls" as
used in §6(e) are intended to include PCB Articles and PCB
Equipment and (2) that comprehensive and direct regulation
of PCB Articles and Equipment was contemplated.
Illustrative material from the legislative history, which
has led the Agency to the above conclusions, is given in the
following paragraphs.
Although commentors (46, 50) have cited Congressman
Gude, they have not cited the following statements by the
Congressman. These statements indicate that direct
regulation of PCB Articles and Equipment was contemplated
under §6(e). Mr. Gude said:
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...our amendment Ion PCB'sJ does not
affect small business except in the
handling of articles that have PCBs
in them;...
For example, an electric company must
show that continued use of PCB's in
transformers is necessary to
guarantee safety from fire and that
they are making a good faith effort
to find substitutes.
122 Cong. Rec. H8830-31 (daily ed., August 23, 1976).
Similarly, Senator Nelson (the Senate sponsor of the PCB
amendment) assumed there would be direct regulation of PCB
Articles and Equipment under his amendment. He stated:
...this IPCBJ amendment provides over
a period of time the elimination of
the use in open or closed systems of
PCB's, polychlorinated biphenyls,
unless the EPA administrator finds
that there is not a serious health
hazard.
Second. The manufacture of all PCBs
would be banned effective two years
from the date of enactment; and the
processing and distribution of all
PCBs would be banned six months
after that - 2 1/2 years after
enactment - unless the administrator
finds that no reasonable risk of
injury to health or the environment
90
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is presented by PCBs. This would
effectively ban all PCB use,
including closed uses, such as in
electrical capacitors and
transformers.
122 Cong. Rec. S4408 (daily ed., March 26, 1976 with
emphasis added). These remarks by Senator Nelson clearly
indicate that direct regulation of PCB Articles and
Equipment was contemplated.
Senator Nelson's discussion of the labeling and disposal
provisions of §6(e) also establishes that regulation of PCB
Articles and Equipment was intended. He stated:
Within 6 months after enactment, EPA
is required to issue regulations for
the first [requirement], disposal of
PCB's and second, labeling with
warnings and instructions of all
products containing PCB's with
respect to their use and disposal.
122 Cong. Rec. S4408 (daily ed., March 26, 1976 with em-
phasis added). The reference to "products containing PCB's"
indicates that PCB Articles and Equipment are to be
regulated.
In summary, the legislative history of §6(e) sup-
ports and requires direct regulation by the Agency of PCB
Articles and PCB Equipment.
91
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XIII. PIGMENTS
In the proposed rule, the Agency redefined the lower
concentration of PCB which constitutes a "PCB Mixture" from
500 to 50 ppm. In effect, this would result in a ban on the
manufacture, processing, distribution in commerce, and use
of PCBs as they appear at 50 ppm or greater. This
prohibition includes even those processes which
inadvertently produce PCBs in excess of 50 ppm at any step
in the manufacturing process.
A number of persons objected to the proposal of lowering
the concentration of PCB regulated under this rule because
it would cause many pigment manufacturers and processors to
close down until process changes could be made. They felt
that no one would be able to reduce their concentrations to
less than 50 ppm by the effective date of the rule (14, 39W
43, 63, 177, VIII TR, p. 6, p. 106-107, p. 121, p. 125, p.
136, pp. 151). These persons further stated that there
currently is no valid method available for determining the
concentration of PCBs in certain pigments (14, 43, 118, VIII
TR, p. 10, p. 14, p. 105, p. 125, p. 135, p. 150-151) and,
therefore, no way of knowing conclusively whether or not
they are in conflict with the rule.
92
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To circumvent these problems, a number of persons
requested that either the Agency maintain the 500 ppm
definition of PCB for the next two years or authorize the
pigment industries to manufacture and process PCB
contaminated mixtures containing over 50 ppm PCB for the
next two years (14, 39, 63, 118, VIII TR, p. 6, p. 44-45, p.
124, p. 137, p. 151). It was thought that this alternative,
in comparison to the formal exemption rulemaking process,
would be less demanding of administrative resources (VIII
TR, p. 21, p. 151). One person (63) suggested that the
Agency grant a six month exemption from the ban on
distribution in commerce in order to allow suppliers to sell
their inventory. In either case they thought that they
would need from six months to three years to both develop a
valid analytical method for quantifying PCB in pigments and
to convert to new technology to reduce or eliminate PCBs
from pigments (118, VIII TR, p. 6).
The Agency does not believe that a 500 ppm cut-otf
concentration is an acceptable alternative because (1) there
would be a substantial amount of PCBs between 50 and 500 ppm
that would go unregulated and (2) the pigment industry has
indicated that it is possible to reduce PCB concentrations
in pigments to less than 50 ppm. The Agency believes that
the authorization and exemption processes are the most
93
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effective way to deal with any difficulties. The
authorization and exemption processes allow the Agency to
tailor the compliance requirements and to be informed as to
which companies are having problems and how they are
disposing of their waste streams. (See section IX of the
Preamble.)
In this final rule, the Agency has authorized the
processing, distribution in commerce, and use of pigments
containing PCBs until January 1, 1982. However, persons who
manufacture these pigments must petition for an exemption if
they want to manufacture pigments containing 50 ppm or more
of PCBs after the effective date of this rule. Similarly,
persons must file exemption petitions if they wish to
process or distribute in commerce pigments which contain 50
ppm or more of PCBs after July 1, 1979.
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XIV. PROCESS CONTAMINATION
In the proposed rule, the Agency banned the manufacture
of chemicals inadvertently contaminated with PCBs in excess
of 50 ppm, including those chemicals that are manufactured
for site-limited use. Some persons objected to this ban
because (in the absense of exemptions) t'ai^ould cause some
industries to shut down their operations (136, 161, 39) and
would unfairly favor foreign products (136). These persons
suggested that as alternatives, EPA consider raising the
level for controlling PCBs to 500 ppm or specifically
exclude unintentionally produced PCBs from the rule (136,
161).
None of these persons provided the Agency with any
economic data that allows EPA to determine the magnitude of
economic impact of this rule on persons who manufacture '
chemicals contaminated with PCBs. Because of the
substantial amounts of PCBs that are produced in chemicals
that contain between 50 and 500 ppm PCB (EPA estimates
100,000 to 500,000 pounds of PCB per year based on data
included in exemption petitions), the Agency believes that
excluding these chemicals from the rule is not an
appropriate alternative. In some cases, more careful
quality control of the production operations can reduce or
eliminate these PCB impurities. Persons may, however,
request an exemption from the January 1, 1979
95
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manufacturing bans and the July 1, 1979 processing and
distribution in commerce bans on PCBs. Information
submitted in these requests should adequately provide the
Agency with the information it needs to determine whether or
not such exemption would present an unreasonable risk. (See
section VI.C.I of tter Preamble for additional discussion of
this process contamination issue).
Two persons (124, 136) commented that the Agency should
consider the use of authorities within TSCA other than §6(e)
to control inadvertently manufactured PCBs. It was
indicated that §6(b) of TSCA was intended to be the
appropriate authority to control chemical processes.
The broad coverage of §6(e) indicates that EPA has the
authority to control inadvertently manufactured PCBs.
Further, although §6(e)(5) gives EPA the prerogative to use
other authorities, EPA is not required to use these other
authorities. The Agency has reviewed the various regulatory
alternatives including TSCA §6(b) and believes that §6(e) is
a less cumbersome and more expedient way in which to control
inadvertently manufactured PCBs than regulation under other
TSCA or EPA authorities.
One person (174) commented that the Agency was
improperly using the term "manufacture" by applying it to
96
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chemicals manufactured for use as an intermediate. The
commentor suggested that the regulation's application be
limited to the manufacture of PCBs for distribution in
commerce and not for on-site use. This person asserted that
the Agency was overextending the accepted definition of an
intermediate as established in the inventory rules which
defines an intermediate as a chemical substance that is
removed from the equipment in which it is manufactured. In
addition, this person thought that site-limited
intermediates present little, if any, threat to either
health or the environment.
The Agency disagrees with this comment. For the
purposes of the inventory rule, §710.4(d) excludes certain
chemicals from the requirements for reporting, including
intermediates which are not removed from the equipment in
which they were manufactured. However, such intermediates
are still specifically considered to be "manufactured and
processed for a commercial purpose" for the purposes of §8
and §6 of TSCA.
The manufacture and processing of chemicals at a site
could present exposure problems to workers and the
environment. Because of the risks associated with such
exposure to PCBs, the rule prohibits all manufacturing and
processing and does not exempt "site limited" activities.
This is in keeping with the inventory rule which requires
persons to identify those intermediates which have
site-limited use.
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XV. ELECTROMAGNETS
The Agency has become aware thaz: PCBs have also been
used in large electromagnets that are designed to remove
tramp iron from non-magnetic commodities such as coal and
grain. One person stated that he did not see any
significant difference between the environmental threat of
an electromagnet and an askarel transformer and suggested
that they be handled similarly (X TR, p. 165). Other
persons stated that their electromagnets are enclosed in a
solid steel casing and have never experienced failure in
their many years of use (137, 31).
Tter Agency agrees that use of PCBs in intact,
non-leaking electromagnets are like transformers that are
used in a totally enclosed manner. Electromagnets are
constructed such that the PCBs are enclosed in completely
welded structures and, historically, have been subject to
few leakages. Therefore, use of these electromagnets is
permitted; however, like transformers, rebuildings of
electromagnets is not permitted. (See section IX.H of the
Preamble for additional discussion.)
98
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XVI. MICROSCOPY
Historically, there have been three uses for PCBs in the
field of microscopy. The first application is the use of
PCBs as an immersion oil. The second microscopic
application is the use of PCBs as a refractive index oil.
The third application is the use of PCBs as a mounting
medium. This technique is particularly important to
scientists who need to preserve, for future reference, a
microscopic sized particle. According to one person (76),
it is also used in air pollution and criminology labs for
particle identification. In the mounting medium method,
PCBs are used as the medium in which the particle is placed
and covered with a glass slip usually for permanent
reference.
During the PCB Ban Hearing representatives from the
field of microscopy agreed that of the three microsopic
uses, use as a mounting medium is the only application for
which PCBs are essential (X TR, p. 13, p. 50-51, p. 65-66,
p. 69-70). All the microscopists indicated that suitable
substitutes for PCBs as an immersion oil and as a
99
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refractive index oil exist (10, X TR, p. 18, p. 74, p. 76).
However, there are currently no substitutes for PCBs as a
mounting medium with the desirable physical properties that
characterize PCBs (10, X TR, p. 18, p. 87). In addition,
these persons stated or implied that extremely small
quantities of PCBs are used for each application and, over
time, the total quantities used are also small (127, X TR,
p. 5, p. 46-47). Some persons recommended that EPA require
special protective garments, vapor hoods, and instructions
and training in handling and disposal for these PCB uses
(23, X TR, p. 26-28; p. 90). These recommendations however
were challenged by other participants at the hearing. At
least one person pointed out that the use of a fume hood
would create a problem because of the likelihood that the
air movement may cause the loss of the particle being
studied (X TR, p. 46). It was also pointed out that a
substantial amount of exposure to PCBs has been minimized
because of the extremely high viscosity of Aroclor 5442
which aids in preventing spillage (X TR, p. 28) and the
extremely small amounts of PCBs which are used (76, X TR, p,
46, p. 60). Further, it appears from the comments at the
hearings that meticulous and careful procedures are typical
because of the nature of laboratory work (X TR, p. 27, p.
46, p. 59).
100
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The Agency believes that exposure to PCBs used as a
mounting medium will be minimal because of the small amounts
that are used at any one time and the careful nature of the
work. For these reasons and because no one presented any
convincing evidence indicating that the risk from the use of
PCBs as a mounting medium outweighs the benefits, the Agency
has decided to authorize this processing, distribution in
commerce, and use until July 1, 1984; however, after July 1,
1979 persons will have to obtain an exemption to process and
distribute in commerce PCBs for microscopy.
101
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XVII. WASTE OIL
The Agency proposed prohibiting the use of used
("waste") oil containing any detectable amount of PCB as a
sealant, coating, or dust control agent. It was understood
that the use of waste oil as a dust control agent is
widespread on unpaved roadways. Few comments were received
on the proposal and its impact on road oiling.
One environmental group commented favorably upon the
proposed ban of this activity, citing potential widespread
environmental and human exposure to PCBs resulting from this
use ot waste oil (85). Another commentor cited a lack of
substitutes for waste oil on uncovered roadways other than
paving, which he characterized as expensive, or watering,
which he said is less efficient (15). One manufacturer of a
substitute for waste oil that is used to control dust
commented about the advantages of his product over waste
oil with respect to both cost and performance (217).
The Agency agrees that use of PCBs as sealants,
coatings, and dust control agents provides a direct route
for entry of PCBs into the environment. Further, it is the
Agency's understanding that substitutes for PCBs as a dust
control agents are available. In the absence of any
convincing data to the contrary, the Agency has decided to
maintain its ban on these uses. For a more detailed
discussion of this determination, see section VI.A.I of the
Preamble.
102
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XVIII. NATURAL GAS COMPRESSORS
The proposed rule contained no authorization for the use
or servicing of PCB-containing natural gas compressors
since, at the time of proposal, the Agency had virtually no
knowledge of this application of PCBs. During the comment
period, a few persons submitted comments indicating that
PCBs were used in compressors in natural gas pipelines. One
of the commentors cautioned EPA that the implementation of
the 50 ppm cut-off concentration for the regulation of most
uses of PCBs could impact the nation's ability (1) to
maintain its productive capacity and (2) to assure an
adequate, clean fossil energy supply at a reasonable cost
(29). Because natural gas systems are not designed with
backup compressors, any unscheduled or extended loss of
compression decreases the capacity of the system,
exacerbating the present natural gas shortage. This person
noted that the economic impact of reduced gas quantities was
not evaluated in the economic study entitled Microeconomic
Impacts of the Proposed PCB Ban Regulation.
Another person indicated that the ban on the use of
articles contaminated with 50 ppm PCB or greater, although
originally appearing to be burdensome, will now cause him
little economic impact (138). He stated that, by the
103
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effective date of the regulation, his company will be able
to achieve a sufficiently low concentration of PCBs in the
lubricants by flushing the system one additional time.
The Agency has considered these comments and the
potential energy and economic impacts of an immediate ban on
the use and servicing of PCB-containing natural gas
compressors. The final rule authorizes the use of PCBs
above 50 ppm in natural gas compressors until May 1, 1980,
The Agency believes that by this date owners and operators
will have had sufficient time to drain/ flush, and replace
the compressors' fluid so that the fluid will contain PCBs
below 50 ppm. A more in-depth discussion of the Agency's
rationale for this use is found in section IX.I of the
Preamble.
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XIX. REVISED VERSAR REPORT
The study entitled Microeconomic Impacts of the Proposed
PCS Ban Regulations (the proposed Versar Report) was made
available in May 1978 as part of EPA's Draft Support
Document for the proposed PCB ban regulation. As a part of
the Final Support Document for the final regulation, EPA
requested Versar to revise the Versar Report to reflect data
submitted -in comments and at the informal hearing on the
proposed PCB rule.
By letter dated September 1, 1978, Electronic Industries
Association (EIA) sought to reopen the comment period for
comment on the then unwritten Revised Versar Report. EPA,
however, did not reopen the comment period. The Agency re-
sponded to the EIA request by letter dated December 13,
1978, stating (1) that EPA had already extended the comment
period from September 15, 1978 to October 10, 1978 and (2)
that the PCB rulemaking had to be brought to a close in view
of the deadlines imposed by §6(e) of TSCA for the regulation
of PCBs. The Agency also noted that the nature of the
Revised Versar Report does not require reopening of the
comment period. EPA stated:
The purpose of the revised Versar
Report is to determine the economic impact
of the expected PCB ban regulation in light
of the facts submitted at the informal
105
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hearing (including the prior Versar Report)
and in comments. This does not constitute
an action which would call for reopening
of the record. See e.g.. International
Harvester Company v. Ruckelshaus, 478 F.2d
615, 632 n. 51 (D.C. Cir. 1973).
The letter was from Peter P. Principe, Chairman of PCS
Hearing Panel to Steven S. Rosenthal, attorney for
Electronic Industries Association dated December 13, 1978.
EIA renewed its request for an extension of the comment
period by letter from Mr. Rosenthal dated December 19, 1978.
EPA is treating this letter as a comment and reiterates its
response made to EIA by letter on December 13, 1978. As
earlier stated, the purpose of the Revised Versar Report is
to incorporate economic data supplied in written comments
and at the informal hearing into the Versar Report which was
previously prepared for the proposed rule. Revisions of
this nature by a contractor do not require reopening of the
comment period. Accordingly, EPA has not reopened the
comment period.
The National Academy of Sciences has developed a draft
report entitled, Polychlorinated Biphenyls, which includes
sections on economic analysis of PCB control strategies.
This draft report was not used by the Agency in the
development of the final PCB rule because the report was
only in draft form and not available for citation. Since
the EPA was under a statutory deadline to promulgate the PCB
rules, the Agency chose not to wait for an opportunity to
consider the final report.
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Appendix I: LIST OF MAJOR COMMENTS
Main Comments
1. Advance Transformer Co.
2. Air-Conditioning and Refrigeration Institute
3. Alabama Power Co.
4. Allegheny Power Service Corp.
5. Allied Chemical Corp.
6. The Aluminum Association, Inc.
7. Amana Refrigeration, Inc.
8. AMAX Environmental Services, Inc.
9. American Electric Apparatus Repair Corp.
10. American Institute for Conservation of Historic and
Artistic Works
11. American Public Power Association
12. American Public Transit Association
13. AMTRAK
14. Apollo Colors, Inc.
15. Armco Steel Corp.
16. Association of Home Appliances Manufacturers I
17. Atlantic City Electric Co.
18. Baltimore Gas and Electric Co.
19. Bartlett, Louise
20. Bethlehem Steel Corp.
21. Boston Edison Co.
107
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22. Brown Co.
23. Center for Occupational Hazards, Inc.
24. Central Vermont Public Service Corp.
25. Chemetron Pigments Corp.
26. Chemical Waste Management Limited
27. Cincinnati Gas and Electric Co.
28. Cleveland Electric Illuminating Co.
29. Columbia Gas System Service Corp.
30. Columbus and Southern Ohio Electric Co.
31. Commonwealth Edison Co.
32. Consolidated Edison Company of New York, Inc.
33. Consolidated Rail Corp.
34. Consumers Power Co.
35. Dayton Power and Light Co.
36. Department of Water and Power of the City of Los Angeles
37. Detroit Edison
38. Dow Corning Corp.
39. Dry Color Manufacturers Association
40. Duke Power Co.
41. E.I. DuPont de Nemours and Co.
42. Duquesne Light Co.
43. Dyes Environmental and Toxicology Organization, Inc.
44. Eastern Iowa Light and Power Corp.
45. Eastern Utilities Associates
108
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46. Edison Electric Institute
47. Edison Sault Electric Co.
48. Electric Equipment Co.
49. Electrical Apparatus Service Association, Inc.
50. Electronics Industries Association
51. Ellish, Andrew
52. Emerson Quiet Kool Co.
53. Environmental Defense Fund
54. EUA Service Corp.
55. Florida Public Utilities Co.
56. Ford Motor Co.
57. Fort Howard Paper Co.
58. General Electric Co.
59. General Motors Corp.
60. GPU Service Corp.
61. A.P. Green Refractories Co.
62. Gulf Power Co.
63. Harmon Colors Corp.
64. Hartzler, Emma
65. Hawaiian Electric Co., Inc.
66. Honeywell Information System Inc.
67. Iliff, George W.
68. International Business Machines
69. Interstate Power Co.
70. Iowa-Illinois Gas and Electric Co.
109
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71. Iowa Power and Light Co.
72. Iowa Public Service Co.
73. Joy Manufacturing Co.
74. Kiggans, Michael
i
75. Loup Power District
76. Walter C. McCrone Associates, Inc.
77. Mead Corp.
78. Middle South Services Inc.
79. Minnesota Pollution Control Agency
r ' 80. Minnkota Power Cooperative, Inc.
81. Monsanto Co.
82. National Electrical Manufacturers Association
83. National Rural Electric Corporative Association
84. National Wildlife Federation
85. Natural Resources Defense Council, Inc.
86. NCR Corp.
87. Nebraska Power Industry Committee
88. Nebraska Public Power District
89. NEGEA Service Corp.
90. New England Power Co.
91. New York Power Pool
92. New York State Department of Environmental
Conservation
93. Niagara Mohawk Power Corp.
94. Northeast Utilities
95. Northern States Power Co.
110
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96. Ohio Edison Co.
97. Ohio Transformer Corp.
98. Olin Corp.
99. Omaha Public Power District
100. Otter Tail Power Co.
101. Outboard Marine Corp.
102. Pacific Gas and Electric Co.
103. Penelec-GPU
104. Phillips Petroleum Co.
105. Phthalchem Inc.
106. Pope Chemical Corp.
107. Port Authority of New York and New Jersey
108. Public Service Company of Colorado
109. Public Service Company of New Hampshire
110. Public Service Electric and Gas Co.
111. Public Service of Indiana
112. Public Utility District No. 1 of Okanogan
County
113. Puget Sound Power and Light Co.
114. RADCO Industries, Inc.
115. RCA Corp.
116. Reynolds Aluminum
117. Reynolds Tobacco Co.
118. Ridgeway Color and Chemical Co.
119. Rochester Gas and Electric Corp.
120. Rockwell International
111
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121. RTE Corp.
122. Salt River Project
123. San Antonio, Texas, City of Public Service Board of
124. SCA Services, Inc.
125. Sierra Club
126. Sierra Club's Task Force (Thomas Murphy)
127. Smithsonian Institution
128. Southeastern Pennsylvania Transit Authority
129. Southern California Edison Co.
130. Sprague Electic Co.
131. Springfield, Missouri, City Utilities of
132. Stauffer Chemical Co.
133. Sun Chemical Corp.
134. T&R Electric Supply Co., Inc.
135. Tenneco, Inc.
136. Tennessee Eastman Co.
137. Tennessee Valley Authority
138. Texas Eastern Transmission Corp.
139. Texas Electric Service Co.
140. Texas Power and Light Co.
141. Tivian Laboratories, Inc.
142. Transformer Sales Co.
143. Union Carbide Corp.
144. Union Electric Co.
145. United Illuminating Co.
146. United Power Association
112
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147. U.S. Department of Agriculture, Rural Electrification
Administration
148. U.S. Department of Health Education and
Welfare, Public Health Service, Center for
Disease Control
149. United States Department of Transportation, Federal
Railroad Administration
150. Vermont Electric Power Co., Inc.
151. Virginia Electric and Power Co., Inc.
152. Virginia Fibre Corp.
153. Wallingford, Connecticut, Town of
154. Waste Management, Inc.
155. Water and Wastewater Equipment Manufacturers
Association, Inc.
156. Westinghouse Electric Corp.
157. Xerox Corp.
113
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Reply Comments
158. AEROVOX Industries, Inc.
159. Air-Conditioning and Refrigeration Institute
160. Alleghany Power Services Corp.
161. Aluminum Company of America
162. American Institue for Conservation of Historic
and Artistic Works
163. AMTRAK
164. Arizona Public Service Co.
165. Arkansas Power and Light Co.
166. Associaition of Home Appliance Manufacturers
167. Burleson, Rep. Omar
168. Canadian Embassy
169. Carolina Power and Light Co.
170. Collins, Rep. James M.
171. Consumers Power Company
172. Crown Zellerbach Environmental Services
173. Dayton Power and Light Co.
174. Dow Corning Corp.
175. Dry Colors Manufacturers Association
176. Duke Power Co.
177. E.I. DuPont de Nemours and Co.
178. Eastern Iowa Light and Power Cooperative
179. Edison Electric Institute
180. Electronic Industries Association
114
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181. Emerson Quiet Kool Co.
182. Environmental Defense Fund
183. Environmental Research Group, Inc.
184. Florida Power and Light Co.
185. Forging Industry Association
186. General Electric Co.
187. General Motors Corp.
188. GPU Service Corp.
189. GTE Service Corp.
190. International Minerals and Chemical Corp.
191. Iowa Electric Light and Power Co.
192. Joy Manufacturing Co.
193. Kiggans, Michael
194. Walter C. McCrone Associates, Inc.
195. McCrone Research Institute
196. McGovern, Sen. George
197. Metropolitan Transportation Authority
198. Minnesota Power and Light Co.
199. National Electrical Manufacturers Association
200. Northern States Power Company
201. Orange and Rockland Utilities, Inc.
202. Philadelphia Electric Co.
203. Phillips Petroleum Co.
204. RTE Corp.
205. Society of Die Casting Engineers, Inc.
206. Smithsonian Institution
115
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207. T&R Electric Supply Co., Inc.
208. Teague, Rep. 01in E.
209. Tennessee Eastman Co.
210. Transformer Consultants
211. U.S., Department of the Interior
212. U.S., Department of Health Education and Welfare,
Public Health Service, Center for Disease Control
213. U.S., Department of Transportation, Federal Railroad
Administration
214. VERSAR, Inc.
215. Westinghouse Electric Corp.
216. Wilson, Rep. Charles
217. Witco Chemical Corp.
218. Wright, Rep. James
116
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Hearing Transcripts
I TR
II TR
III TR
IV TR
V TR
VI TR
VII TR
VIII TR
IX TR
X TR
Cross-Examination
August 21, 1978
August 22, 1978
August 23, 1978
August 24, 1978
August 25, 1978
August 28, 1978
August 29, 1978
August 30, 1978
August 31, 1978
September 1, 1978
September 26, 1978
117
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FOOTNOTES
Section II - Significance of Release of PCRs to the
Environnent
1. World Health Organization; Environmental
Health Criteria 2: Polychlorinated
Biphenyls and Polychlorinated Terphenyls;
Geneva. (1976), pp. 43-44.
2. Ibid., pp. 44-45.
3. EPA; 42 F.R. 6532, February 2, 1977. "Toxic
Pollutant Effluent Standards - Standards for
Polychlorinated Biphenyls (PCRs), Final
Decision;" (Hereinafter referred to as EPA
Final Decision); pp. 6537-8.
4. Ibid., 42 Fed. Reg. 6538.
5. Ibid., 42 Fed. Reg. 6537.
5a. Bahn, Anita K., Report on Paulsboro, N.J.,
Mobil Oil Plant Study.Philadelphia:
Departnent of Community Medicine, University
of Pa., School of Medicine, (April 27,
1976).
6. NIOSH; Criteria for a Reconnended
Standard; Occupational Exposure to
Polychlorinated Biphenyls (PCBs);
(Hereinafter referred to as MIOSH Criteria);
V7ashington, (September 1977), p. 65.
7. Ibid., p. 98.
8. Ibid., pp. 98-99.
9. Ibid., EPA Final Decision; 42 Fed. Reg.
6535.
10. Ibid.
11. Ibid., 42 Fed. Reg. 6535-36.
118
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12. Ibid., 42 Fed. Reg. 5536.
13. (JSDHEW, Center for Disease Control.
Exposure to Polyc.hlorinated Biphenyls in
Bloomington, Indiana. (Hereinafter referred
to as CDC Study) Atlanta: Public Health
Service, EPI-77-35-2, (May 26, 1978), pp.
4-6
14. Alvares, Alvito P. et al.; "Alternation in
Drug Metabolism in Workers Exposed to
Polychlorinated Biphenyls"; Clinical
Pharmacology and therapeutics, 22:2, pp.
140-146.
15. Id., EPA Final Decision; 42 Fed. Reg. 6536.
16. Ibid.
17. Ibid.
10. Id., NIOSH Criteria; pp. 73-74.
19. Id., EPA Final Decision; 42 Fed. Reg. 6535.
20. Id., NIOSH Criteria; pp. 74-75, 87.
21. Wyndhan, C., Devenish, J.; Safe, S. "The In
Vitro Metabolism, Macroiaolecular Binding and
Bacteria Mutagenicity of 4-Chlorobiphenyl -
A Model PCB .Substrate. "Research
Communication in Chenical Pathology and
Pharnacology," 15:3 (November 1976): pp.
563-570.
22. Id., NIOSH Criteria; p. 119.
23. Id., EPA Final Decision; 42 Fed. Reg. 6537.
24. Id., NIOSH Criteria; pp. 78, Rl-82.
25. USDHEW, PHS, MIH, NCI. Bioassay of Aroclor
1254 for Possible Carcinogenicity.
Washington: National Cancer Institute,
Tech. Report Series No. 38, (1978), pp. 15-
21
119
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26. Id., NIOSH Criteria; pp. 74-75.
27. Id., EPA Final Decision; 42 Fed. Reg. 6537.
28. Id., NIOSH Criteria; p. 54.
2°). Ibid., pp. 41-42.
30. Id., CDC Study.
31. Ibid., NIOSH Criteria; pp. 49-53.
32a. Ibid., NIOSH Criteria; pp. 47-48;
32b. Ibid., EPA Final Decision, 42 Fed. Reg.
6537.
33. Ibid., p. 6535.
34. Ibid., p. 6534.
35. Ibid.
36. Ibid.
37. Ibid.
38. Ibid., p. 6543.
39. Ibid., pp. 6542, 6533.
40. Ibid., pp. 6541-3.
41. Ibid.
42a. E.G., 41 F.R. 21402, May 25, 1976. "Health
Risk and Econonic Impact Assessnents of
Suspected Carcinogens: Interin Procedures
and Guidelines."
42b. E.G., EPA 41 F.R. 7552, February 19, 1976.
"Valsicol Chenical Co. RT AL. Consolidated
Heptachlor/Chlordane Hearinq: Notice of
Intent to Suspend and Findings of the
Inninent Hazard Posed by Registrations of
Pesticides Containing Heptachlor or
120
-------
Chlordane."
43a. E.G., See RDF v. EPA, 510 F2d 1292 at 1298
(n.C. Cir. 1975).
43b. EOF v. EPA; 548 F2d 998 at 1006 (D.C. Cir.
1976).
44a. Blau, G. E. , and Neely, W. Brock.
"Mathematical Model Buidling with an
Application to Determine the Distribution of
Dursban Insecticide Added to a Simulated
Ecosystem." Adv. Ecology Res. 2 (1975):
pp. 133-163.
44h. *USKPA, OTS. A First Order Mass Balance
Model for Sources, Distribution and Fate of
PCBs in the Environment.Washington,DC,
Versar, Inc. EPA 560/6-77-006, (July 1977).
45. Hutzinger, S.; Safe, S. ; and Zitko, v. The
Chemistry of PCRs. CRC Press, Cleveland,
Ohio (1974).
46. Ibid.
47. USDHEW, NIOSH. The Toxic Substances List -
1973 Edition. Rockville, fid.: (June 1973),
p. 95.
48. Sodergren, A. "Chlorinated Hydrocarbon
Residue in Airborne Fallout." Nature
236;(April 21, 1972): p. 395.
49a. Maugh, Thomas H. II. "DDT: An Unrecognized
Source of Polychlorinate-l P>iphenyls."
Science 180 (May 1973): pp. 57P-579.
49b. *Metcalf, Robert L.; Sanborn, James; Po Yung
Lu; Nye, Donald. Proceedings, National
Conference on PCPs. EPA-560/6-75-004
(1976), p. 243
50. Yoshinura, Hidetoshi, and Yamonoto, Hiroaki,
"Metabolic Studies on PCBs. I Metabolic
Fate of 3,4,3',4'-tetrachlorobiphenyl in
121
-------
Rats." Chenical Pharn. Bulletin, 21:5
(1973),p. 1168.
51. Berlin, Flath; Gaqe, John; Holm, Stina,
"Distribution and Metabolism of 2,4,5,2',
5-Pentachlorobiphenyl." Archive of
Environmental Health, 30 (March 1975),
p. 141.
52a. Canada, Environnent Canada. Background to
the Regulation of Polychlorinated Riphenyls
(PCB) in Canada. Ottawa: Task Force on
PCB, Technical Report 76:1 (April 1,
1976): pp. 41-41.
52b. Jansson, B.; Jensen, S.; Olsson, M.;
Sundstron, G.; and Vaz, R. "Identification
by GC-MS of Phenolic Metabolites of PCB and
p.p'-DDE Isolated fron Baltic Guillemot and
Seal." Anbio 4:2 (1075): pp. 93-96.
53. Ibid., 52a.
54. Ibid., 52a.
55. Ibid., Hutzinger, Safe, and Zitko; and
Monsanto Chenical Conpany, Aroclor
Plasticizers. St. Louis, MO: Orqanic
Chemicals Division, Technical Bulletin,
0/PL-306A (undated).
56. Hanelink, Jerry L.; Waybrant, Ronald C.;
Ball, Robert C. "A Proposal: Exchange
Equilibria Control the Degree Chlorinated
Hydrocarbons are Biologically Magnified in
Lentic Environments." Transactions of the
American Fisheries Society 100:2 (April
1971): pp. 207-214.
57. Mebeker, A.V. Proceedings, National
Conference on PCBs, EPA 560/6-75-004 (1976),
p. 284.
58. Denbigh, Kenneth. Principles of Chenical
Equilibria With Application in Chemistry and
Chemical Engineering. Canbridge:
University Press, (1955), 268-272.
122
-------
59. Ibid.
60. Mackay, Donald, and Leinonen, Paul J.,
"Rate of Evaporation of Low-Solubility
Contaminants From Water Bodies to
Atmosphere ." Environmental Scienco antj
Technology, 9 (December 1975), p. 1178.
61. Id., A. Soderqren, p. 395.
62. Harvey, G.R., and Steinhauser, W.G.
"Atmospheric Transport of Polychlorinated
Biphenyls to the North Atlantic."
Atmospheric Environment, 8 (1974), p. 777.
63a. *Lunde, Gulbrand. "Long-Range Aerial
Transnission of Organic Micropollutants."
Anbio 5-6 (1976): pp. 207-208.
63b. Suffet, I. H., gen. ed. Fate of Pollutants
in the Air and Water Environments. New
York:John Wiley & Sons, 1977, Vol. 8:
"Basic Consideration about Trace
Constituents in the Atmoshpere as Related to
the Fate of Global Pollutants." C. E.
Junge, pp. 7-25.
64. Selikoff, Irving J. "Polychlorinated
Biphenyls - Environmental Inpact - A Review
by the Panel on Hazardous Trace Substances,
March 1972. Environmental Research 5:3
(September 1972) Academic Press, New York
and London.
65. Id., G.R. Harvey et al., p. 395.
66. Ibid., USEPA, OTS. A First Order Mass
Balance.
67. USEPA, OTS. PCBs in the United States.
Indsutiral Use and Environmental
Distribution. February 25, 1976 EPA 560/6-
76-005. Versar, Inc.
68. Id., D. Mackay et al., p. 1178.
123
-------
69. Nisbet, I.C.T., and Sarofin, A.F. "Rates and
Routes of Transport of PCBs in the
Environment." Environmental Health
Prospectives (April 1972), p. 1.
70. Risebrough R.W., et al., "Transfer of
Chlorinated Biphenyls to Antarctica," Nature
264 (December 23/30, 1976), p. 738.
71. Ibid., USEPA, OTS PCBs in the United States,
Industrial Use and Environmental
Distribution.
72. Id., USEPA, OTS. A First Order Mass
Balance.
73. Id., USEPA, OTS., PCBs in the United States.
74. Id., Monsanto Chemical Company.
75. Hague, Rizwanual et al., "Aqueous Solubility
Absorption and Vapor by Polychlorinated
Biphenyl Aroclor 1254." Environmental
Science and Technology: 8:2 (February
1974) , p. 139.
76. World Almanac and Book of Facts.
"Heterological Monthly Temperature and
Precipitation". (1977).
77. Bartha, Richard and Praner, David "Pesticide
Transformation to Aniline and Azo Compounds
in Soils." Science 156 (June 23, 1976),
p. 1617.
78. Hesse, J.L. Proceedings, National Conference
on PCBs, EPA 560/6-76-004 (1976), p. 127.
79. Holden, A.V. "Source of Polychlorinated
Biphenyls Contamination in the Marine
Environment." Nature 22B (December 10,
1970), p. 1220.
80. Oloffs, P.C., Albright, L.J., Szeto, S.Y.,
and Law, J. "Factors Affecting the Behavior
of Five Chlorinated Hydrocarbons in Two
124
-------
Natural Waters and Their Sedinents."
Journal Fisheries Research Board of Canada.
30:11 (1973), p. 1619.
81. Veith, r,.D. and Comstock, V.M. "Apparatus
for Continuously Saturating Water With
Hydrophobia Organic Transformers." Journal
Fisheries Research Board of Canada. 32:10
(1975), p.1849.
82. Environnental Defense Fund (EDF) and New
York Public Interest Research Group, Inc.
(PIRG). Troubled Waters; Toxic Chemicals in
the Hudson River. 4 (1977).
83. Ibid.
84. New York State Department of Environnental
Conservation, Hudson River PCB Study
Description and~Detailed Work Plan.
Albany: Bureau of Water Research (1977).
85. Ibid.
86. Id., Mackay et al.
87a. Ibid., USEPA, OTS. PCBs in the United
States. Industrial Use and Environnental
Distribution.
87b. USEPA, Working Group on Pesticides. Ground
Disposal of Pesticides: The Problen and
Criteria for Guidelines. Washington, D.C.
PB197-144, (March 1970).
87c. Ibid., Nisbet, I.C.T. et al.
88a. Ibid., USEPA, OTS. PCBs in the United
States. Industrial Use and Environnental
Distribution.
88b. Ibid., Nisbet, I.C.T. et al.
89. Id., USEPA, OTS. PCBs in the United States.
90. Carey, A.E. and Gowen, J.A., proceedings,
125
-------
National Conference on PCBs, EPA-560/6-76-
004 (1976), p. 195.
91. Hesse, J.L.f Proceedings, National
Conference on PCBs, EPA 560/6-75-004 (1976),
p. 127.
92. Ibid.
93. Murphy, Thomas J., Precipitation: A
Significant Source of Phosphous and PCBs to
Lake Michigan Evanston, 111. 10th Great
Lakes Regional Meeting of the ACS, (June 17,
1976).
94. Nebeker, A.V., Proceedings, National
Conference on PCBs, EPA 560/6-75-004 (1976),
p. 284.
95. "Report of a New Chemical Hazard." New
Scientist, 32 (December 15, 1966), p. 612.
96. Id., R.W. Risebrough et al.
97. Bidleman, T.F. and Olney, C.E., "Chlorinated
Hydrocarbons in the Sargasso Sea Atmoshpere
and Surface Water." Science 183 (October 1,
1973), p. 516.
98. USEPA, OTS. Environmental Levels of PCBs.
Washington, D.C.: Unpublished Report by
Doris J. Ruopp and Vincent J. Decabio,
(undated).
99. Bowes, G.W. and Jonkel, C.J., "Presence and
Distribution of Polychlorinated Biphenyls
(PCB) in Arctic and Subarctic Marine Food
Chains." Journal Fisheries Board of Canada,
32:11 (1975), p. 2111.
100. Environment Canada, Health and Welfare
Canada. Background to the Regulation of
Polychlorinated Biphenyls (PCB) in Canada.
A Report of the Task Force on PCB, April 1,
1976 to the Environment Contaminants
Committee of Environment Canada and Health
126
-------
and Welfare Canada. Technical Report 76-1.
101. Id., Selikoff, Irving J., p. 249.
127
-------
Section III - PCB Substitutes
1. USEPA, OTS. PCBs in the United States
Industrial has use and Environmental
Distribution February 25, 1976. EPA 560/6-
76-005. Versar, Inc; pp. 230-231.
2. 42 FR 55026, October 12, 1977. "TSCA
Interagency Testing Committee-Initial Report
to the Administrator, EPA."
3. Ibid., USEPA, OTS., pp. 232-233.
4. Id., p. 264.
5. Id., pp. 264-266.
6. Id., p. 267.
7. Id., pp. 267-268.
8. Uniroyal Chemical, Letter from
R. A. Stengard to Peter P. Principe, USEPA,
OTS, April 23, 1978, with enclosures.
128
-------
EPA 230-03/79-001
PCB MANUFACTURING, PROCESSING, DISTRIBUTION
IN COMMERCE, AND USE BAN REGULATION:
ECONOMIC IMPACT ANALYSIS
MARCH 1979
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF PLANNING AND MANAGEMENT
WASHINGTON, D.C. 20460
-------
This document is available in limited quantities through the U.S.
Environmental Protection Agency, Industry Assistance Office, Office of
Toxic Substances (TS-793), 401 M Street, S.W., Washington, D.C. 20460.
This document will subsequently be available through the National
Technical Information Service, Springfield, Virginia, 22151.
-------
EPA 230-03/^79-001
FCB MANUFACTURING, PROCESSING, DISTRIBUTION
IN COMMEBCE, AND USE BAN REGULATION:
ECONOMIC IMPACT ANALYSIS
Final Report
Submitted to:
U.S. Environmental Protection Agency
Office of Planning and Management
Washington, D.C.
Attention: Mr. Stephen R. Weil
Project Officer
Contract No. 68-01-4771
March 30, 1979
-------
This report has been reviewed by the Office of Planning and
Management, U.S. Environmental Protection Agency, and approved for
publication. Approval does not necessarily signify that the contents
reflect the views and policies of the Environmental Protection Agency, nor
does mention of trade names or commercial products constitute endorsement
or recommendation for use.
-------
PREFACE
This report was prepared by Versar, Inc., for the Office of Planning
and Management of the U.S. Environmental Protection Agency. The report
summarizes Versar's estimates of the probable costs and impacts of
complying with the PCB Manufacturing, Processing, Distribution in Commerce,
and Use Ban Regulation - 40 CFR Part 761. This regulation implements the
requirements of Sections 6{e)(2) and 6(e)(3) of the Toxic Substances
Control Act.
Versar's analysis of the economic impacts of the proposed PCB Ban
Regulation was summarized in the report "Microeconomic Impacts of the
Proposed 'PCB Ban Regulations'" dated May 16, 1978. The promulgated
regulations incorporate a significant number of changes that were made to
the proposed regulations. In addition, considerable additional information
on the economic impacts of the regulation has been added to the rulemaking
record as the result of written comments on the proposed regulation and two
weeks of public hearings. This report is a revision of the report on the
proposed regulations and is based on the promulgated regulations and the
information available from the rulemaking record.
This revised report was prepared by Mr. Robert A. Westin, Principal
Investigator, and Mr. Bruce Woodcock. Assistance in the handling of data
and the preparation of final copy was provided by Ms. Juliet Ballance and
Mrs. Rebecca Brown of the Versar staff. Special acknowledgement is given
to the close support received from Mr. Stephen R. Weil, EPA Project
Officer, and Mr. Steven B. Malkenson who was the EPA Project Officer during
the preparation of early drafts of this report.
-------
TABLE CF CONTENTS
Page
1.0 INTRODUCTICN 1
1.1 History of PCB Use 1
1.2 Regulatory Action on PCBs 3
2.0 METHODOLOGY FOR ECONOMIC IMPACT ANALYSIS CF THE PCB BAN
REGULATIONS 8
2.1 General Approach 8
2.2 Data Base for Economic Bnpact Analysis 10
3.0 IMPACT CF BAN CN THE DISTRIBUTION CF PCB CAPACITORS AND
EQUIPMENT 11
3.1 Present Status 11
3.1.1 PCB Capacitors 11
3.1.2 PCB Equipment 12
3.2 Requirements of the Regulation 14
3.3 Economic Impact of the Regulation 14
3.4 PCBs Controlled by the Regulation 20
3.5 Summary - Economic Impacts 22
3.6 Cost Per Pound of PCBs Kept Fran the liwironroent . 22
4.0 IMPACTS ON USERS OF ASKAREL TRANSFORMERS 23
4.1 Present Status 23
4.2 Requirements of the Regulation 24
4.3 Econonic Impact of the Regulation 25
4.4 PCBs Controlled by the Regulation 30
4.5 Summary - Economic Itnpacts 31
4.6 Cost Per Pound of PCBs Kept from the Environment . 31
-------
TABLE CF CONTENTS (Continued)
Page
5.0 RAILROAD LOCOMOTIVE TRANSFORMERS 32
5.1 Present Ownership and Use Plans 32
5.2 Requirements of the PCB Ban Regulations 33
5.3 Cost Impacts of the PCB Ban Regulations 35
5.4 PCBs Controlled by the Regulations 42
5.5 Stannary - Economic Impacts 42
5.6 Cost Per Pound of PCBs Kept from the Environment. . 43
6.0 OTT.-FTT.TJD POWER AND DISTRIBUTION TRANSFORMERS 44
6.1 Present Contamination of Oil-Filled Transformers . 44
6.2 Requirements of the PCB Ban Regulation 56
6.3 Cost Impacts of the PCB Ban Regulation 59
6.4 PCBs Controlled by the Regulation 70
6.5 Summary - Economic Impacts 71
6.6 Cost Per Pound of PCBs Kept from the Environment . 71
7.0 IMPACTS ON TRANSFORMER SERVICE COMPANIES 72
7.1 Present Status 72
7.2 Requirements of the Regulation 72
7.3 Impact of the Regulation 72
7.4 PCBs Controlled by the Regulation 73
7.5 Summary - Economic Impacts 73
8.0 MINING MACHINERY 74
8.1 Current Use of PCB-Cooled Mining Machinery Motors . 74
8.2 Requirements of the Regulations 76
8.3 Compliance Costs 76
8.4 PCBs Controlled by the Regulation 80
111
-------
TABIE CF CONTENTS (Continued)
Page
8.5 Summary - Econanic Impacts 80
8.6 Cost Per Pound of PCBs Kept from the Environment . 81
9.0 ELECnK24AGNETS 82
9.1 Current Usage 82
9.2 Requirements of the PCS Ban Regulations 83
9.3 Cost Impacts of the PCB Ban Regulations 83
9.4 PCBs Controlled by the Regulation 84
9.5 Summary - Economic Impacts 85
9.6 Cost Per Pound of PCBs Kept from the Environment . 85
10.0 KKDRAULIC SYSTEMS 86
10.1 Present Use of PCBs in Hydraulic Systems .... 86
10.2 Requirements of the PCB Ban Regulation 91
10.3 Cost Irpacts of the PCB Ban Regulation 91
10.4 PCBs Controlled by the Regulation 96
10.5 Summary - Economic Impacts 95
10.6 Cost Per Pound of PCBs Kept from the Environment. 97
11.0 HEAT TRANSFER SYSTEMS 98
11.1 Present Use of PCBs in Heat Transfer Systems . . 98
11.2 Requirements of the PCB Ban Regulation 98
11.3 Cost Impacts of the PCB Ban Regulation 99
11.4 PCBs Controlled by the Regulation 104
11.5 Summary - Econanic Impacts 105
11.6 Cost Per Pound of PCBs Kept fron the Environment. 105
IV
-------
TABLE CF CONTENTS (Continued)
Page
12.0 COMPRESSORS 106
12.1 Requirements 106
12.2 Drpacts of the PCS Ban Regulation 106
12.3 PCBs Controlled by the Regulation 107
13.0 RECLAIMED OIL 108
13.1 Present Status of PCBs in Reclaimed Oil 108
13.2 Requirements of the Proposed Regulations .... 112
13.3 Sources and Amounts of Contaminated Waste Oil . . 113
13.4 Compliance Costs 115
13.5 PCBs Controlled by the Regulation 120
13.6 Summary - Economic Impacts 122
13.7 Cost Per Pound of PCBs Kept fron the Enviroiment. 122
14.0 PCBs AS UNINTENTIONAL PRODUCT CONTAMINANTS 123
14.1 Current Production 123
14.2 Requirements of the PCB Ban Regulations 126
14.3 Economic Impact 126
14.4 PCBs Controlled by the Regulation 133
14.5 Summary - Economic Impacts 133
14.6 Cost Per Pound of PCBs Kept from the Environment. 134
15.0 SPILL MATERIALS: 50 ppm TO 499 ppm PCBs 135
16.0 CAPACITOR MANUFACTURING 136
16.1 Present Use of PCBs 136
16.2 Requirements of the PCB Ban Regulation 138
16.3 Cost Impacts of the PCB Ban Regulation 138
16.4 PCBs Controlled by the Regulation 139
v
-------
TABLE CF CONTENTS (Continued)
Page
16.5 Summary - Econonic Impacts 140
16.6 Cost Per Pound of PCBs Kept from the Environment. 140
17.0 BAN CN THE MANUFACTURE CF NEW PCB TRANSFORMERS .... 141
17.1 Requirements of the Regulations 141
17.2 Industry Structure, Production, and Sales .... 141
17.3 Substitutes for PCB Transformers 142
17.4 Relative Prices of Non-PCB Transformers 149
17.5 Compliance Costs 150
17.6 PCBs Controlled by the Regulation 151
17.7 Sunmary - Economic Jinpacts 152
17.8 Cost Per Pound of PCBs Kept Fran the Envirorment. 152
18.0 SUMMARY 153
18.1 Transitional Cost Impacts 153
18.2 Long Term Cost Impacts 153
18.3 Cost Per Pouni of PCBs Kept fron the Environment. 153
REFERENCES
VI
-------
LIST OF TABLES
4.1-1
5.1-1
5.3-1
5.3-2
5.3-3
5.3-4
6.1-1
6.1-2
6.1-3
6.1-4
6.1-5
6.3-1
6.3-2
Estimated Number of PCB Transformers in Service
Sunmary of PCB Cooled Railroad Transformers in Service. . . .
Retrofill of PCB Railroad Transformer with Silicone
Cost of Retrofilling Railroad Transformers to Meet January 1,
1982 Limit of 6% PCBs: $21.99/gal
Retrofill of Contaminated Silicone Filled Transformer ....
Cost of Analyzing Silicone Oil for the Presence of PCBs in
Retrofilled Railroad Transformers
Utility Reports of PCB Contamination of Oil Filled Trans-
formers with Concentrations above 50 ppm
Transformer Manufacturer and Service Company Reports of PCB
Contamination of Oil Filled Transformers above 50 ppm ....
Edison Electric Institute Summary of Contaminated Trans-
former Data Submitted by Electric Utilities
Edison Electric Institute Summary of Contaminated Trans-
former Data Submitted by Transformer Companies
Estimated Amounts of PCBs in Oil-Filled Transformers
Used Transformer Oil Available for Reclamation
Estimated Supply of Transformer Oil Available for Recycling
Page
24
34
37
38
40
42
45
49
52
54
57
62
for Sale 63
6.3-3 Cost of Disposal of Transformer Oil from Small Utilities,
Transformer Repair Shops, and Other Sources 69
8.1-1 Use of PCB-Cooled Electric Motors in Mining Machinery .... 75
8.3-1 Cost Impact of Forced Retirement of PCB Continuous Miners . . 78
11.3-1 Cost of Retrofilling Heat Transfer Systems to Meet 50 ppm
Limit on PCB Concentration 102
VII
-------
LIST CF TABLES (Continued)
Page
13.1-1 New Oil Usage and Waste Oil Availability for Recycling
in 1975 109
13.4-1 Cost of Substituting COHEREX®for Used Motor Oil in Road
Oiling for Dust Control 118
16.1-1 Major Types and Uses of PCB Capacitors 137
17.2-1 U.S. Transformer Manufacturers that Used PCBs After 1970. . . 143
17.4-1 Relative Transformer Prices 149
18.1-1 Transitional Cost Impacts 154
18.2-1 Long Term Cost Impacts 157
18.3-1 Economic Costs of the PCB Ban Regulation 158
Vlll
-------
LIST OF FIGURES
1.2-1 Section 6(e), Toxic Substances Control Act 5
10.1-1 Calculation of Nunber of Die-Casting Machines that Used
FOB Based Hydraulic Fluids 89
13.1-1 Distribution and Utilization of Waste Oil in the United
States During 1970-71 Ill
-------
-------
1.0 INTRODUCTION
1.1 History of PCB Use
Commercial PCBs are manufactured by the direct chlorination of
the chemical "biphenyl." The result of this reaction is a mixture of
chlorinated biphenyl molecules that differ in the number and arrangement of
chlorine atoms attached to the biphenyl rings. The final product may
contain between 21% and 68% chlorine by weight, depending on the amount of
chlorine introduced to the reaction vessel. PCBs, therefore, are mixtures
of various kinds of polychlorinated biphenyls.
The first commercial production of PCBs in the United States was
in 1929. Almost all of the PCBs that have been produced in the U.S. were
manufactured by Monsanto Industrial Chemicals Company which marketed
various mixtures under the trade names Aroclor® 1016 and Aroclor® 12xx,
with the last two digits denoting the average percent chlorine in the
mixture. The commercial PCBs varied from Aroclor® 1221 (similar in
physical properties to a light oil) to Aroclor® 1268 (a waxy solid).
Monsanto also used PCBs in some commercial products formulated for specific
purposes, including certain types of Pydraul® hydraulic fluids, Therminol®
heat transfer fluids, Turbinol® compressor fluids, and Santovac® vacuum
pump fluids. In addition, Monsanto produced various mixtures of
polychlorinated terphenyls (PCTs), all of which contained up to 1% PCBs as
unintentional byproducts. The PCTs were marketed under the trade name
Aroclor® 54xx, with the final digits again denoting the average chlorine
content. The PCTs were also marketed as constituents of some Pydraul®
hydraulic fluids (Versar, 1976a).*
PCBs in general were noted for their excellent chemical
stability, low solubility in water, and low price. The various commercial
*Versar, Inc., 1976a. PCSs in the United States; Industrial Use and
Environmental Distribution, Springfield, Va.: National Technical
Information Service (NTIS PB 252-012/3WP), February, 1976.
-------
mixtures covered a wide range of viscosities, melting points, and boiling
points and were used in a number of applications including as a plasticizer
for plastics, paints, and caulking compounds; as a dielectric liquid in
electrical transformers, motors, electromagnets, and capacitors; as a dye
carrier in certain carbonless copy papers and printing inks; and as an
additive to certain greases, lubricating oils, casting waxes, hydraulic
fluids, heat transfer liouids, compressor liquids, and vacuum pump liquids.
The various uses of PCBs were described in a report published in early 1976
(Versar, 1976a); estimated use of PCBs in each application and the present
environmental distribution of the PCBs are summarized in Table 1.1-1.
PCBs were not generally recognized as being toxic until after the
occurrence in 1968 of widespread poisoning in Japan caused by the
accidental introduction of PCBs into cooking oil. The resulting acute
symptoms became known as "Yusho" disease, and it affected 1291 people*. In
1969, analytical procedures were developed that enabled PCBs to be
identified in concentrations of parts per million in environmental samples.
In 1970, PCBs were identified as the contaminant in coho salmon from Lake
Michigan that had affected the reproduction rate of commercial mink fed
contaminated fish. The mink reproductive problems had first been reported
in 1965; identification of PCBs as the cause awaited development of
satisfactory analytical procedures (Stendell, 1975).**
*For a comprehensive review and discussion of the literature describing
the toxicity of PCBs and the details of the YUSHO incident, see:
1S1IC6H, Criteria for a Recommended Standard... .Occupational Exposure to
Polychlorinated Biphenyls (PCBs), Washington, D.C.: U.S. Government
Printing Office, 1977, pp.40-49.
**Stendell, Ray C. 1975. "Summary of Recent Information Regarding
Effects of PCB's on Birds and Mammals" in Conference Proceedings,
National Conference on Polychlorinated Biphenyls, November 19-21, 1975,
Chicago, Illinois"Washington, D.C.:Office of Toxic Substances, U.S.
Environmental Protection Agency (Report No. EPA-560/6-75-004).
-------
In 1972, Monsanto voluntarily restricted the sale of PCBs to the
manufacture and maintenance of electrical transformers and capacitors and
introduced the product Aroclor® 1016 as a more biodegradable dielectric
liquid for use in capacitors (Wood, 1975).* Monsanto then contacted their
customers to recommend that heat transfer systems containing PCS based
Therminol* fluids be drained, flushed, and refilled with non-PCB liquids
and that hydraulic systems containing PCB based Pydraul® fluids be topped
off as required with compatible non-PCB liquids (Versar, 1978, p. 75).**
Following Monsanto's action in 1972, the only U.S. production of
PCBs for "open" system use was by Geneva Industries which manufactured
about one million pounds of PCB based heat transfer liquid between 1972 and
1974 (Versar, 1978, p. 4). PCBs were also imported after 1972 for use in
maintaining electric motors in certain coal mining machines, and for use in
some types of investment casting waxes.
1.2 Regulatory Action on PCBs
In 1973, the U.S. Pood and Drug Administration (FDA) established
temporary tolerances for PCBs in food, and FDA surveillance resulted in the
rejection of numerous lots of fish and occasional lots of chickens and eggs
(FDA, 1973).*** By 1975, there was significant evidence of PCBs in
industrial effluents and in the environment, and reports of PCB
contamination were being featured in the non-technical press. On March 26,
*Wbod, David (Monsanto). 1975. "Chlorinated Biphenyl Dielectrics, Their
Utility and Potential Substitutes" in Conference Proceedings, National
Conference on Polychlorinated Biphenyls, November 19-21, 1975,
Chicago, Illinois Washington, D. C. : Office of Toxic Substances,
U.S. Environmental Protection Agency (Report No. 5PA-560/6-75-004)
pp. 317-322.
**Versar, Inc. 1978. Microeconomic Impacts of the Proposed 'PCB Ban
Regulations' (EPA 560/6-77-035), Springfield, Va.: National Technical
Information Service (NTIS PB 281-881/3WP). May, 1978.
***FDA. 1973. "Polychlorinated Biphenyls - Contamination of Animal Feeds,
Foods, and Food Packaging Materials," Federal Register, July 6, 1973,
pp. 18096-18103.
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1976, Senator Gaylord Nelson of Wisconsin introduced into the Senate an
amendment to the Toxic Substances Control Act (TSCA) that required the
eventual elimination of the use of PCBs in the United States. This
amendment was the basis of Section 6(e) of TSCA (Figure 1.2-1), and the
eventual ban on the manufacture of PCBs became a legislated requirement on
October 11, 1976, when TSCA was signed into law.
Concurrent with the consideration of the PCB amendment to TSCA,
the EPA proposed toxic pollutant effluent standards for PCBs under Section
307(a) of the Federal Water Pollution Control Act (EPA, 1976).* This
proposed regulation would have imposed severe limitations on PCB discharges
by capacitor and transformer manufacturers who used PCBs. Following
extensive hearings, the PCB effluent standard was promulgated on February
2, 1977 (EPA, 1977d).** The regulation required that all PCB manufacturers
and those transformer manufacturers and capacitor manufacturers using PCBs
eliminate PCBs from their effluent water by February 2, 1978. The one-year
compliance deadline for manufacturers of electrical equipment was
established to enable plants to phase out the use of PCBs, convert to
substitutes, make appropriate technological or process changes, or take
such other steps as necessary to achieve compliance.
Section 6(e) of the Toxic Substances Control Act (TSCA) required
the EPA to requlate the marking and disposal of existing PCBs. The
manufacture of PCBs and their handling and use in other than a totally
enclosed manner was banned effective January 1, 1978. The act also
completely banned the manufacture of PCBs after January 1, 1979, and their
distribution in commerce effective July 1, 1979. Finally, the act
authorized the EPA to grant exemptions and authorizations under certain
conditions.
*EPA. 1976. "Water Program - Proposed Toxic Pollutant Effluent Standards
for Polychlorinated Biphenyls," Federal Register, July 23, 1976, pp.
30468-30477. *
**EPA. 1977d. "Proposed Toxic Pollutant Effluent Standards for
Polychlorinated Biphenyls (PCBs): Final Decision," Federal Register,
February 2, 1977, pp. 6531-6555.
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Figure 1.2-1
Section 6(e), Toxic Substances Control Act
PUBLIC LAW 94-4^9— OCT. 11, 1976
90 STAT. 2025
(e) POL.YCIILOKIXATKU Bii'HENYLS.— (1) Within six months after Rules.
the effective date of this Act the Administrator shall promulgate
rules to—•
(A) prescribe methods for the disj»osal of ]>olych)oriiiated
biphejiyls, and
(B) require ]>olychlorinated biphenyls to l>e marked with clear
and adequate warnings, and insti net ions with rcsjiect to their
pitx-essing, distribution in commerce, use. or di?j>osal or with
resjH-ct t o any comhi nation of such activities.
Kcquiremcnts prescribed by rules undei this paragraph shall lie con-
sistent with the mjiiiruncnis of paragraphs (-2) and (3).
t'2)(A) K.xrept as pnivided under sul/paragraph (B), effective one
year after the ell'ecthe date of this Act no j>erson may manufacture,
process, or distribute in commerce, or use any jtolychlorinated biphenyl
in an\ manner other thai, in a totally enclosed manner.
(B) The Administrator may by rule authorize the manufacture,
processing, distribution in commerce or use (or any combination of
such activities) of any jiolychlorinaU-d biphenyl in a manner other than
in a tofalK enclosed manner if the Administrator finds that such manu-
facture, puicessing. di.-lribution in commerce, or use (or combination
of such activities) will not present an unreasonable risk of injury to
lic:i It h or f he en vi ronment.
(C') For the purposes of this paiagraph. the u-rin "totally enclosed "TntalK me;
manner" means any manner which will ensure that any exposure of manner."
human beings or the environment to a polychlorinated bijihenyl will
IK- ir.-ignihVant as di-termined by the Administrator by rule.
(H) (A) Kxcept as j>rovided in subparagraphs (B) and (C1) —
(i) no ]ierson may manufacture any polychlorinated bij'henyl
aftei two veal's after the effective date of this Act. and
(ii) no j>e:-son may piocess or distribute in commerce any J»oly-
chlorinated biphenyl after two and one-half years after such date.
(B) Any jicrson may petition the Administrator for an exemption Petition for
from the requirements of subparngraph (A), and the Administrator exemption.
may grant by rule such an exemption if the Administrator finds
that—
(i) an unreasonable risk of injury to health or environment
would not result, and
(ii) good faith efforts have Ix-en made to develop a chemical
substance which does not present an unreasonable risk of injury
to health or the environment and which may !>e su!•-•titmet! for
such polychlorinated biphenyl.
An exemption granted under this subparagraph shall be subject to
such terms and conditions as the Administrator may presrrilie and
shall be in effect for such period (but not more than one year from
the date if is granted) as the Administrator may prescribe.
(C) Suhparagraph (A) shall not apply to the distribution in com-
merce of any j>ol\chlorinated biphenyl if such polychlorinated
biphenyl was sold for purpor-es other than resale before two and one
half < ears after the date of enactment of this Act.
(-}') Any rule under paragraph (1), (2)(B). or (3)(B) shall !*•
promulgated in accordance with paragraphs (2), (3). and (4) of sub-
>(-c!ion (c).
(5) This subsection does not limit the authority of the Adminis-
trator, under any other provision of this Act 01 any other Federal law.
to lake action lespecting any pohchlorinated hiphenyl.
T.rms and
conditions.
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Regulatory implementation of the various requirements of Section
6(e) of TSCA has occurred in several steps. EPA proposed regulations on
the marking and disposal of PCBs on May 24, 1977 (EPA, 1977a),* and made
available a support document (EPA, 1977c)** and a contractor's report on
the estimated economic impacts of the proposed regulations (Versar,
1977).*** Written comments on the proposed rule were accepted by the EPA
and informal hearings were held during the period June 24-29, 1977. The
final regulations were promulgated on February 17, 1978 (EPA, 1978a),****
and corrections were published on August 2, 1978 (EPA, 1978b).*****
The EPA held public meetings on the remaining use ban provisions
of Section 6(e) on July 15, 1977, in Washington, D.C., and on July 19,
1977, in Chicago, Illinois. On December 30, 1977, the EPA announced that
it would not implement the ban on activities conducted in other than a
totally enclosed manner (Section 6(e)(2)) until after formal regulations
were promulgated (SPA, 1977b).****** These use ban regulations were
proposed on June 7, 1978 (EPA, 1978e).******* At the same time, the EPA
*EPA 1977a. "Polychlorinated Biphenyls (FCBs), Ibxic Substance
Control," Federal Register. May 24, 1977, pp. 26564-26577.
**EPA. 1977c. PCS Marking and Disposal Regulations - Support
Document, (OTS-068005) Washington, D.C.:Office of Toxic
Substances, U.S. Environmental Protection Agency, undated.
***Versar, Inc. 1977. Microeconpmic Impacts of the Proposed Marking
and Disposal Regulations for PCBs (EPA 560/67-77-013),
Springfield,Virginia:National Technical Information Service,
(OTIS PB 267-833/2WP), April, 1977.
****EPA. 1978a. "Polychlorinated Biphenyls (PCBs), Disposal and
Marking." Federal Register. February 17, 1978, pp. 7150-7164.
*****EPA. 1978b. "Polychlorinated Biphenyls (PCB's), Addendum to
Preamble and Corrections to Final Rule." Federal Register.
August 2, 1978, pp. 33918-33920.
******EPA. 1977b. "Polychlorinated Biphenyls (PCBs), Toxic Substance
Control." Federal Register. December 30, 1977, p. 65264.
*******EPA. 1978e. "Polychlorinated Biphenyls (PCB's), Manufacturing,
Processing, Distribution in Commerce, and Use Bans," Federal
Register, June 7, 1978, pp. 24802-24817.
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made available a support document (EPA, 1978c)* and a contractor's report
on the estimated economic impacts (Versar, 1978). In the preamble to the
proposed regulation, the EPA asked for written comments on specific
technical aspects of the regulation. Written comments were accepted until
the start of the hearings which were held in Washington, D.C., from August
21 through September 1, 1978. Opportunity for cross examination of the EPA
economics contractor was granted to the Edison Electric Institute and the
Electronic Industries Association on September 26, 1978, and reply comments
on the proposed regulation were accepted for one week after that date.
Versar's previous report on the economic impact of the PCB Ban
Regulations (Versar, 1978) was based on the proposed regulations and the
data available in May 1978. EPA has since considered several hundred
written main comments and reply comments and the information presented at
ten days of informal hearings and has revised many of the details of the
proposed regulations. The information presented to the EPA since the
regulations were proposed has also significantly augmented the data
available to Versar. The purpose of this report is to revise the economic
analysis performed in May, 1978, to reflect the changes in the regulation
and to incorporate additional information (1) that has been made available
to the EPA as a result of the rulemaking, and (2) that has been included in
the rulemaking record.
*EPA. 1978c. Office of toxic Substances. Support Document/Draft
Voluntary Environmental Impact Statement for Polychlorinated
Biphenyls (PCBs) Manufacturing, Processing, Distribution in Commerce,
and Use Ban Regulation (Section 6(e) of TSCA).Washington, D.C.:
U.S. Environmental Protection Agency. May 1978.
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2.0 METHODOLOGY FOR ECONOMIC IMPACT ANALYSIS OF THE PCB BAN REGULATIONS
2.1 General Approach
Section 6(e) of the Toxic Substances Control Act (TSCA)
established specific dates for the banning of activities involving the
manufacture, processing, distrioution in commerce, and use of PCBs. TSCA
also authorized the EPA to grant exemptions from the rule or to author-
ize specific activities that v>ould otherwise be banned. These exemptions
and authorizations may be granted only if the EPA makes a formal finding
that the activities "do not present an unreasonable risk of injury to
health or the environment."
If the EPA had not promulgated the PCB ban regulations, the
requirements of TSCA could have taken full effect on the dates specified in
the act. The effect of the discretionary actions that the EPA has taken by
promulgating the regulations is to reduce the economic impact of the
legislated requirements in certain cases.
Since the EPA defined in the regulation those materials and
manufactured products that are subject to the legislated requirements, it
is difficult to separate the economic consequences of the act from the
economic impact of the regulation. Calculation of total economic impacts
is further complicated by the compliance actions taken by industry in
anticipation of the regulations.
This analysis is limited to impacts expected to result from the
PCB ban regulations. These impacts are the incremental changes from a base
condition assumed to be the industry practices in 1975 as modified by the
PCB effluent standards and by the PCB Disposal and Marking Regulations.
Increased industry costs caused by the use of substitutes for PCBs and the
resulting product development costs or the costs of discontinuing certain
products are the basis of the calculation of cost impacts. Each affected
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industry is considered separately, and lonq-term economic impacts are
calculated by predicting long-term practices and comparing the resulting
costs to those that would have been incurred under the base period
conditions. Transitional costs are also calculated where there will be a
significant capital investment required to comply with the ban regulations
or where there will be a prolonged period of adjustment of industrial
practices. The economic impact analysis is limited to directly affected
industries and to their suppliers and customers. The analysis does not
evaluate (1) minor secondary impacts and ripple effects of the regulations,
(2) benefits to health or the environment from the ban, or (3) the extent
to which exemptions that may be granted by the EPA will reduce these costs.
In general, the methodology used to estimate the economic impacts
of the PCB Ban Regulations is the same as that used in previously published
studies of the economic impacts of the Proposed PCB Ban Regulations
(Versar, 1978), of the Proposed PCB Marking and Disposal Regulations
(Versar, 1977), and of the Proposed PCB Effluent Standards (Jack Faucett
Associates, 1976).* All of the cited economic impact studies, including
this one, have been limited to an evaluation of the costs of the
regulations.
*Jack Faucett Associates, Inc. 1976. Economic Analysis of Proposed Toxic
Pollutant Effluent Standards for Polychlorinated Biphenyls;""
Transformer, Capacitor, and PCB Manufacturers (EPA 230/1-76-008),
Washington, D.C.: Office of Water Planning and Standards, U.S.
Environmental Protection Agency. October 1976.
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2.2 Data Base for Economic Impact Analysis
Tnis report's analysis of the economic impacts of the final PCB
Ban Regulations is based on the following data:
« Published reports as referenced in the Official Record of
rulemaking including the previous Versar report "Microeconanic
Impacts of the Proposed 'PCB Ban Regulations'" (Versar, 1978).
• Written comments on the Proposed PCB Ban Regulations
received by EPA and made part of the official record of
rulemaking.
• Oral comments presented at the public hearings on the proposed
rule (August 21 through September 1, 1979). Verbatim
transcripts of these hearings are part of the official record
of rulemaking.
• Reply comments on the proposed rule received by EPA subsequent
to August 21, 1978, and made part of the official record.
• Information on the sampling protocols used by utilities in
selecting oil filled transformers to be tested for the presence
of PCBs. This information was obtained by Versar through phone
conversations with representatives of companies that presented
data on the extent of PCB contamination of transformer oil in
their written or oral comments on the proposed regulation.
10
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3.0 IMPACT OF BAN ON 'THE DISTRIBUTION OF PCS CAPACITORS AMD EQUIPMENT
3.1 Present Status
3.1.1 PCB Capacitors
The use of PCBs in small capacitors has been gradually phased out
over the past two years. Although several manufacturers were using PCBs in
at least a portion of their 1978 production of small capacitors, most
capacitors manufactured during 1978 do not use PCSs. Most small capacitors
are used in the manufacture of new appliances and lighting fixtures: the
use of capacitors as repair parts accounts for a comparatively small
percentage of the total demand for these items.
Emerson Quiet Kool Company estimated that it would have an
inventory of approximately 30/000 PCB capacitors as of January 1, 1979, and
that this inventory would represent an investment of $120,000.* Advance
Transformer estimated that they might have 100,000 PCB capacitors in
inventory on January 1, 1979, that were not built into ballasts or other
equipment.** It is not possible to extrapolate this data to an estimate of
the total inventories of capacitors that may remain unused on July 1, 1979.
If each company normally carries a two-month inventory of capacitors and if
only ten percent of these contained PCBs on January 1, the value of small
PCB capacitors in the inventory of equipment manufacturers would have
been one sixtieth of annual capacitor sales of $95 million, or
approximately $1.5 million on January 1, 1979. The number of PCB
capacitors remaining in inventory on July 1, 1979, will probably depend on
the policies of various companies regarding the maintenance of spare parts
for obsolete equipment. There will apparently be sufficient time available
for manufacturers to use their inventories of PCB capacitors that are
components of presently manufactured products.
*Letter from George Hakin (Emerson Quiet Kool Company) to EPA, dated
August 2, 1978.
**0ral comments of Ernest Freegard (Advance Transformer Company) at the
Hearings on the PCB Ban Regulation, August 23, 1978.
11
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3.1.2 PCB Equipment
Most capacitors used in appliances and lighting fixtures
manufactured during 1978 do not contain PC3s. There is no easy way to
distinguish which appliances do contain PCB capacitors. The provisions of
the PCB Disposal and Marking Regulations that require that non-PCB
capacitors and non-PCB fluorescent light ballasts be distinguishable from
PCB units did not become effective until July 1, 1978 (SPA, 1978a). The
regulations that require equipment containing PCB capacitors be so marked
apply only to equipment manufactured after December 31, 1978 (EPA, 1978b).
There are also considerable numbers of PCB capacitors presently in
inventory in electrical subassemblies such as fluorescent light ballasts.
According to Mr. Ray Clark, the manufacturers of fluorescent light fixtures
normally carry a 60-day supply of ballasts in inventory, and he estimated
that about one million of the seven million ballasts in their inventories
on January 1, 1979, would contain PCB capacitors.* Not all of these
ballasts are used within sixty days. Manufacturers of lighting fixtures
also maintain inventories of the less common and obsolete ballasts for use
as replacement parts in existing fixtures. Some of these ballasts may
remain in inventory for as long as thirty years.** According to Mr.
Freegard, the percentage of production of ballasts by Advance Transformer
Company that involves the slow moving types is less than ten percent of the
fluorescent light ballasts and perhaps slightly more than ten percent of
the ballasts for high intensity discharge (mercury arc and sodium arc)
lighting ballasts.***
*Oral comments of N. Ray Clark (Universal Manufacturing Corporation) at
the hearings on the PCB Ban Regulation, August 28, 1978.
**0ral comments of Herbert Rowe (Electronic Industries Association) at the
hearings on the PCB Ban Regulation, August 23, 1978.
***0ral comments of Ernest Freegard (Advance Transformer Company) at the
hearings on the PCB Ban Regulation, August 23, 1978.
12
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Electrical equipment containing PCB capacitors may pass through
several hands prior to its sale to the final consumer. For instance, air
conditioning units are distributed by the manufacturer to retailers under a
conditional sales agreement which allows the units to be returned to the
manufacturer if they are not sold during the summer season. The unsold
units are then stored during the winter and sent to retailers the following
spring. Amana Refrigeration stated that "There is customarily a large
amount of carry-over merchandise left over in the distribution channel
after the primary selling season has ended. It is not uncommon for a
dealer or distributor to have an inventory containing air conditioning
equipment which is three to four years old."*
Microwave ovens do not have the seasonal sales pattern of air
conditioning units, but inventory carry-over is still significant. Mr.
Weizeorick of the Association of Home Appliance Manufacturers calculated
the rate of sales of each year's production to be 54% per year based on a
total durable goods inventory equal to 72% of annual shipments. Carry-over
from the production years 1975 through 1977 would therefore be expected to
be 239,000 units on December 31, 1973, and 120,000 units on June 1, 1979.**
Inventories of lighting ballasts and fixtures might be expected to turn
over more rapidly. However, many of these items are manufactured as
components of equipment such as subway cars and highway luminaries which
will be classified as PCB equipment and which have longer lead times prior
to final sale to the user.
*"Comments of Amana Refrigeration, Inc " submitted to EPA as an
attachment to a letter dated August 4, 1978, from Arthur Herold of
Webster and Chamberlain.
**Letter from J.T. Weizeorick (Association of Home Appliance Manufacturers)
to Steven Sosenthal (Covington and Burling) dated September 7, 1978
(Appendix III). This letter was submitted to the EPA as an attachment
to"a letter from Mr. Rosenthal dated September 12, 1978.
13
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The manufacture of appliances using PC3 capacitors is not banned
until July 1, 1979, but any such appliances manufactured during 1979 must
have the PCB equipment label applied. 'Therefore, it will be easier to
identify equipment containing PCB capacitors that was manufactured during
1979 than that manufactured in 1977 and 1978.
3.2 Requirements of the Regulation
Sale of new PCB capacitors; The sale of new PCB capacitors is
banned after June 30, 1979, unless EPA grants a specific
exemption from this "distribution in commerce" ban requirement.
Manufacture of PCB equipment; The use of PCB capacitors in the
manufacture of new equipment such as television sets, microwave
ovens, and fluorescent light ballasts and fixtures is considered
a totally enclosed processing of PCBs. Since all processing is
banned after June 30, 1979, PCB capacitors and subassemblies
containing PCB capacitors will have to be used by June 30
unless a petition for an exemption from this processing ban
requirement is granted by the EPA.
Sale of new PCB equipment; The sale of new PCB equipment is
banned after June"30, 1979, unless EPA grants a specific
exemption from this "distribution in commerce" ban requirement.
Exemption requirements; EPA has not yet stated the conditions
under which petitions for exemptions from these ban provisions
will be accepted or the conditions under which exemptions will be
granted except to state that any exemptions granted will be for a
period of only one year. EPA has suggested that exemptions may
be granted only under those conditions (1) that will result in
no significant threat to health or the environment and (2) where
a good faith effort to develop substitutes for the PCB capacitors
has been demonstrated.
3.3 Economic Impact of the Regulation
3.3.1 PCB Capacitors
The regulation bans the distribution in commerce after
July 1, 1979, of PCB capacitors unless the EPA grants exemptions from this
14
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requirement. If the EPA grants a complete exemption from this requirement,
there could be zero economic impact. If the EPA does not grant any
exemptions, the effect of the regulation would be to require that all small
PCS capacitors be sold to the ultimate users by July 1, 1979, and that any
PC3 capacitors remaining in the distribution channels at that time be
disposed of in accordance with the disposal requirements.
The economic impacts resulting from the ban on "distribution in
commerce" will depend on the extent to which EPA grants exemptions. The
number of individual small capacitors maintained in inventory as spare
parts is not known but is probably no more than a few percent of one year's
production of PCBs. Many of these capacitors might be relatively old,
having been left over from production runs of unusual types and then kept
as spares to replace units that fail in service. A rough estimate of the
value of small capacitors remaining in inventory on July 1, 1979, would be
that the parts inventory would equal two percent of annual production of
small capacitors and that one half of these might still be PCBs. The value
of small industrial capacitors was previously reported to be $94.5 million
in 1976 (Versar, 1978, pp. 97-98). The manufactured cost of remaining
inventories of PCS capacitors would therefore be (2% x 1/2 PCBs x $94.5
million=) $1 million. The economic loss resulting from a ban on the sale
of these capacitors might be larger than this amount if equipment that is
otherwise usable must be scrapped because no replacement capacitors are
available. However, no information is available to support an estimate of
the resulting costs.
It is anticipated that additional information will be made available to
EPA in petitions for exemptions from the ban on sale of capacitors. This
information will enable EPA to more accurately estimate economic impacts of
their decisions on the exemption petitions.
15
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3.3.2 PC3 Equipment
Compliance with this regulation would require that all
inventories of subassemblies, appliances, and lighting fixtures containing
capacitors on July 1, 1979, be examined to determine whether any of the
capacitors contain PCBs. Any PCB capacitors that are found will have to be
replaced with non-PCE capacitors before the subassembly, appliance, or
lighting fixture can be sold.
A ban on the distribution in commerce of equipment containing PCB
capacitors will have a greater impact than a ban on the sale of capacitors
because the equipment ban will involve more items and because it will be
more difficult to identify the banned items. The major cost of the
regulation would result from the efforts to identify which equipment
contains the PCS capacitors so that they could be replaced with non-PCB
units.
A rough estimate of the total number of items in inventory that
will have to be checked to determine whether they contain PCB capacitors
can be calculated from information presented by the industry. Aerovox
reportedly has about 24% of the market for small industrial capacitors
(Versar, 1978, p. 103) and has stated that their production rate is 80,000
units per day.* If the average unit cost of Aerovox production is
representative of the industry, this would imply an annual production of
(80,000 units per day x 250 days/0.24 market share=) 83.3 million
capacitors per year. Uie average cost would therefore be ($94.5
million/83.3 million units) = $1.13 per capacitor. If dealer inventories
equal 70% of annual shipments, this implies that there will be (33.3
million units per year x .7 = ) 58.3 million separate pieces of equipment
containing small capacitors in inventory at any given time.
The inventory model suggested by Mr. Vfeizeorick can be modified
to calculate the fraction of units in inventory on July 1, 1979, that will
*Letter from Clifford H. Tuttle (Aerovox Industries, Inc.) to EPA dated
August 15, 1978.
16
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contain PCB capacitors. This model assumes that production of capacitors
is constant at Po units per year, that the ratio of inventory to sales is
equal to 0.71, and that the probability of sale of any given item is not
proportional to the time it has been in inventory. Mr. Weizeorick stated
the relationship between inventory, production, and sales by the
differential equation
^i= P-S
dt P b
where i = inventory at time t
P = production rate, units per year
S = sales rate, units per year
and solved this equation for the condition
t < 0, P = 0
t > 1, P = 0
0 <_ t <_ 1, P = P
However, starting at about the beginning of 1977, some of the
production of capacitors was of non-PCB units, and by the end of 1978, all
of the capacitors being produced were non-PCB types. If it is assumed .that
the proportion of PCB capacitors used by equipment manufacturers decreased
linearly from 100% PCB on January 1, 1977, to 0% on December 31, 1978, the
production rate of equipment containing PCB capacitors during these two
years could be expressed by the equation:
p = PQ (1 - |), t = 0 to 2
where Po = constant production rate using all capacitors
P = production rate using PCB capacitors
t = years after January 1, 1977.
17
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'The differential equation for the inventory of PCB items during
these two years would then be expressed as
and since:
5 = 771 <3)
andP=Po (l-f), (2)
then |i = FQ (l - |) - -^ from t = 0 to t = 2 (4)
In linear form, this equation can be written:
FJ / t\]
dl + [TTT " P0 v1 ~ 2/J fc (5)
which has the solution
i = 71 P 1 — — 4- ' "^ n _ o ""'-/•'•'-) /c\
X — ./i r_ li 7 9 \J- c 'I VO/
where i = .71 P at t = 0
o
Evaluating for the inventory at the end of 1978 (i.e., t = 2),
i = .334, or 33.4% of equipment in inventory on January 1, 1979, contained
PCB capacitors.
Assuming that no PCB equipment was made after January 1, 1979, the
differential equation for the inventory would be written
Since S = -=p this can Le written as
di + -=i dt = 0 (8)
which has the solution
t
_
i = i e *71 for i = i at t = 0 (9)
18
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On July 1, 1979, (t = 1/2), the inventory of PCS items, will
therefore be equal to .49 of the initial inventory at the beginning of the
year, or equal to (.49 x .334 x P = ) 16.4% of the total inventory.
Based on these calculations, the inventory of equipment
containing capacitors on July 1, 1979, will consist of 58.3 million items,
of which 9.56 million will contain PC3 capacitors. These capacitors will
have an estimated manufacturers' sales price of (9.56 million capacitors at
$1.13 = ) $10.85 millon. These estimates will be higher than the actual
inventory of PCB capacitors to the extent that dealers succeed in selling
their oldest stock first.
If the EPA does not grant exemptions from the ban on the sale of
equipment containing PCB capacitors, the dealers may have to open many of
the 58.3 million items to determine which items contain PCB capacitors, and
then replace the capacitors in 9.56 million items with non-PCB capacitors.
Major cost items for the inspection program will be labor, customer
discounts required to offset the damage to the packing cartons, and
supervision. In most instances, the equipment will have to be partially
disassembled in order to expose the capacitor. Mr. Weizeorick suggested a
cost of $40 per unit based on $20 labor, $10 administrative cost, and $10
reduced value caused by damage. This implies a total program cost of $2.33
billion to inspect all 58.3 million items. It is possible that at least
some of the units could be identified as not containing PCB capacitors by
checking each unit serial numbering and information supplied by the
manufacturer. However, even if the labor and administrative expenses could
be cut by a factor of three to an average of $10 per unit by identifying
serial numbers and therefore not having to disassemble the units, the
inspection program would still cost in excess of $1 billion.
The second portion of this program will consist of replacing the
capacitors in the 9.56 million pieces of equipment that are found to
contain PCB capacitors. Mr. Weizeorick suggested a rework cost of $75 per
unit implying a total cost of $717 million. This is undoubtedly high,
since many of the suspect itans are fluorescent light fixtures that retail
for about $10 per unit. There is not sufficient information to estimate
19
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the proportion of the 58.3 million units in inventory that would be sold at
distress prices before July 1, 1979, or scrapped rather than being
inspected. However, it must be concluded that the total inspection costs,
rework costs, and losses due to forced sales could easily exceed $1
billion.
•••'.•*
The calculated costs resulting from the ban on distribution in
commerce of equipment containing PCS capacitors is admittedly based on a
number of assumptions. However, it is anticipated that additional
information on the economic impacts will be presented to the EPA by the
manufacturers and distributors of this equipment together with their
petitions for exemptions from these requirements.
The final cost impact of these regulations will result from the
requirement that impacted manufacturers and distributors of PCB equipment
apply for exemptions. These petitions will require that detailed cost
estimates be prepared which in turn will require the participation of
corporate marketing, accounting, and legal staff. Each petition would
likely require anywhere from 3 to 30 man days of effort to prepare, and
cost a total of $1,000 to $10,000 based on total burdened labor at $42 per
hour. EPA has not yet announced its policy on accepting class action
petitions. If each manufacturer and retailer is required to apply
separately, perhaps 1,000 to 10,000 petitions will be filed, at a total
cost of about $10 million.
3.4 PCBs Controlled by the Regulation
Total consumption of PCBs by the capacitor manufacturing industry
during 1975 was about 21 million pounds, of which 55% was used in small
industrial and appliance capacitors (Versar 1976a, p. 6). If total
production of these small capacitors was 83.3 million units, the average
capacitor contained (21 million x .55/83.3 million - ) 0.14 pounds of PCBs.
20
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The ban on the sales of spare capacitors would affect $1 million
worth of capacitors containing a total of ($1 million x 0.14 Ib PCS per
unit/$1.13 per unit = ) 124,000 Ib PCSs. The capacitors removed from
equipment in inventory would contain (9.56 million units x 0.14 Ib PC3 per
unit = ) 1,340,000 Ib PCBs.
It is assumed that the spare capacitors are still owned by
manufacturers of PCB equipment and will have to be disposed of in approved
chemical waste landfills. The capacitors in equipTjent are assumed to be in
dealers inventories, and these may be disposed of in municipal trash.
The failure rate of small capacitors is about 0.2% per year, of
which 10% leak on failure.* If the average appliance lasts twenty years,
each capacitor would have a (20 years x 0.2% probability of failure per
year = ) 4% probability of failure.
The effect of the regulation will be to prevent the loss of PCBs
to the environment by capacitors that fail and leak in service. If it is
assumed that all the PCBs in leaking capacitors enter the environment, the
effect of the regulation would be to reduce the loss of PCBs from equipment
by (1,340,000 pounds PCBs x 4% fail x 10% leak = ) 5,360 pounds of PCBs.
The rest of the PCBs in capacitors installed in equipment will end up in
municipal landfills whether they are removed in 1979 or when the equipment
fails.
All of the spare capacitors will have to be disposed of in
chemical waste landfills, thereby preventing the entry into the environment
of (124,000 pounds x 4% fail x 10% leak = ) 496 pounds PCBs that would have
occurred had these capacitors been used.
•"Letter from George Hakin (Emerson Quiet Kool Co.) to EPA dated September
6, 1978.
21
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Municipal landfills are not as safe a repository for PCBs as are
approved chemical waste landfills. However, PCBs are rather inrnobile in
material with high organic content and would not be expected to leach out
of municipal waste if present in low concentrations. No information is
available on which any estimate can be made as to the fraction of the PCBs
from intact capacitors that are expected to leach from municipal landfills.
3.5 Summary - Economic Impacts
Inventory losses: Spare capacitors $1 million
This cost will be reduced significantly
or eliminatead if SPA grants exemptions
from the "distribution in commerce" ban.
Inspection and rework: PCB Equipment $1 billion
Ihis cost will be reduced significantly
or eliminated if EPA grants exemptions
from the 'distribution in commerce" ban.
Petition costs: $10 million*
3.6 Cost Per Pound of PCBs Kept From the Environment
Spare capacitors: $1 million .,._ .... , TV^,
500 pounds = $2'°°° P^ P°md ^
This cost will be reduced significantly
or eliminated if EPA grants exemptions
from the "distribution in commerce" ban.
Capacitors in equipment: 536QXpounds = $187'°°° P637 P°und PC3
This cost will be reduced significantly
or eliminated if EPA grants exemptions
from the "distribution in commerce" ban.
*May be significantly reduced if EPA accepts class action petitions for
exemptions to the ban on "distribution in commerce."
22
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4.0 IMPACTS ON USERS OF ASKAREL TRANSFORMERS
4.1 Present Status
In calculating the economic impact of the PCB Disposal and
Marking Regulations, Versar estimated that there are about 140,000
transformers presently in service that were manufactured as PCB (askarel)
transformers (Versar, 1977). These transformers were originally filled
with a coolant liquid that contained from 60% to 100% PCSs. Although over
100 of these transformers have been retrofilled with silicone or
hydrocarbon coolant liquids, none of them have been sufficiently
decontaminated so that the concentration of residual PCBs is below 500
ppm.*
Approximately 1000 of the askarel transformers are installed on
railway locomotives and commuter cars (Versar 1978, p. 19). These units
are addressed specifically by the PCB ban regulations, and the impact of
the regulations on these units is discussed in Chapter 5. Of the remaining
units, most are pad mounted distribution and power transformers located in
buildings and in electric generating stations, with a substantial number of
askarel precipitator transformers being mounted on stacks. It is estimated
that askarel transformers each contain an average of 2,500 pounds of PCB.
The distribution of ownership of these askarel transformers was previously
estimated to be as described in Table 4.1-1. No additional information on
the ownership of askarel transformers was presented in the written or oral
comments submitted to EPA after the PCB Ban Regulations were proposed.
*Enclosure with letter from Terry Michaud (Dow Corning Corp.) to EPA dated
August 1, 1978.
23
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Table 4.1-1*
Estimated Number of PCB Transformers in Service
Category of User Number of Units PCB Content-Pounds
"** Utilities 42,000 105,000,000
Industrial and Commercial 97,000 191,000,000
Railroad 1,000 4,000,000
*Source: Versar, 1978, p. 19.
The PCB Ban Regulations define askarel transformers as being any
transformers that are filled with a liquid containing PCBs in
concentrations exceeding 500 ppm. This chapter discusses the impact of the
regulation on transformers that were originally filled with a PCB based
dielectric fluid. Chapter 6 discusses the impact of the regulation on
those transformers that were originally filled with mineral oil but which
have since become contaminated with PCBs in concentrations above 500 ppm.
4.2 Requirements of the Regulation
Rebuilding and major maintenance; The regulations forbid the
removal of the core and coils from the transformer. As a
result, any significant electrical problem involving the
windings of an askarel transformer will result in thexunit being
scrapped. However, retrofilling a PCB transformer several tiroes
with a non-PCB liquid may reduce the residual concentration of
PCBs to below 500 ppm. The ban on rebuilding does not apply to
such decontaminated transformers.
Minor maintenance: There are no restrictions on the performance
of maintenance that do not require removal of the coils.
After July 1, 1979, transformer service companies cannot sell
used or reclaimed askarel unless they have petitioned for an
exemption from the provisions of the regulation which ban the
processing of PCBs prior to their distribution in commerce.
24
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Reclaiming PCS askarel; After June 30, 1979, PCBs may be
reclaimed for reuse only by those who have petitioned the EPA
and been granted an exemption from the "processing" bans.
Storage of PCS askarel: Storage prior to use or resale must be
in a specially marked area which meets the requirements
established by the disposal regulations.
Disposal of failed transformers and PCS based askarel; No
change from the previously promulgated Disposal and Marking
Regulations.
Retrofill with non-PCB fluid; Authorized without restriction.
The retrofilled transformer must continue to be considered a PCB
transformer, until the liquid has been tested at least three
months after the transformer was returned to service and
found to contain less than 500 ppm PCBs. The transformer is
then classified as a PCB contaminated transformer.
4.3 Economic Impact of the Regulation
Foregone savings from rebuilding
Askarel transformers have a normal service life of 30 to 40
years or more (Versar 1978, p. 7). Premature failure can occur as the
result of electrical breakdown of the insulation or distortion of the coils
caused by severe overload conditions. Normal industrial practice has been
to rebuild failed askarel transformers by removing the core and coils,
burning off the coils, and rewinding the coils using new wire on the
original core. This repair normally costs about 60% of the price of a new
transformer, and the repairs take about 25% as long as normal delivery of a
new unit.* This rebuilding service is offered by both the original
manufacturers of the transformers and by approximately 300 small
transformer service companies.**
Based on an average price of $20,000 per new transformer (Versar
1978, p. 20), the ban on rebuilding askarel transformers will result in
foregone savings of ($20,000 x (1-60%) = ) $8,000 per transformer. In
addition, the ban will increase the time required to restore service from
*0ral comments of Mr. Lynwood Holley (American Electric Apparatus Repair
Corporation) at the hearings on the PCB Ban Regulations, August 28, 1978.
**0ral comments of Robert Sandman (Sandman Electric Company) at the
hearings on the PCB Ban Regulations, August 28, 1978.
25
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the present one to two ninths to six months or more, depending on the
availabilty of a satisfactory new transformer*. The out-of-service time
might even be longer than would be expected based on past practices becau;
the ban on the manufacture of new askarel transformers will require that
each installation of existing aslcarel transformers be redesignea when the
transformer fails and must be replaced. Adequate replacement transformers
are usually available in a number of designs including oil-filled
transformers with protective vaults and sprinklers, high fire point
liquid-filled transformers, and various types of dry transformers.
However, none of these designs are direct replacements for existing askare
transformers, so a certain amount of engineering time must be added to the
normal delivery time for a new unit.
An active market in used askarel transformers existed in the past
but that market has declined over the past year due to uncertainties about
the restrictions that SPA was expected to impose on the use of these units
The PCB ban regulations do not affect the resale and reuse of askarel
transformers by users, and units removed from service because of changes ii
service demands might be made available as replacement units for some of
the failed askarel transformers. However, the risk of a spill occuring
during transport of an askarel transformer and the high potential liability
incurred by any spill of PCBs will probably limit any market in used
askarel transformers.
iSSot enough information is available to estimate the proportion of
askarel transformers that would have been scrapped due to obsolescence
rather than due to electrical failure; most existing askarel transformers
have not been in service long enough for either aging or changing service
demands to be significant. Assuming as an example that from one third to
two thirds of the existing askarel transformers would have been rebuilt if
it were not for the ban on rebuilding, the total foregone savings would be
$8,000 per unit x 1/3 to 2/3 of the 140,000 units in service (Versar, 1978
pg. 21), or a total of $373 million to $747 million over the next 40 years.
*Letter fron Robert L. Sandman (Electrical Apparatus Service Association,
Inc.) to EPA (PCB Ban Regulation Hearing Record), Undated.
26
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These foregone savings will not be distributed evenly over the
next 40 years because present failure rates of askarel transformers are
relatively low. The failure rate is likely to increase as the average age
of the transformers increases. It was previously estimated that
approximately 80,000 gallons of PCBs were used in the repair of askarel
transformers in 1974 (Versar, 1976a). This is enough PCB to fill 335
transformers with an average capacity of 240 gallons of liquid (Versar
1978, p. 21). Many transformer service companies have also used reclaimed
askarel in rebuilt transformers, so the actual number of transformers
rebuilt may be three to four times the number calculated from data on the
use of new askarel (approximately 1200 per year). The amount of business
lost to the transformer rebuilding industry due to the ban on the
rebuilding of askarel transformers might be as much as (1200 transformers
per year x $12,000 per unit = ) $14.4 million per year. The transformer
manufacturers would supply new units to replace those not rebuilt at an
average cost of $20,000, so increased costs due to the regulation may be
about (1200 units x $8,000 =) $9.6 million per year. Increased labor
requirements by the manufacturers are expected to offset any job losses by
the repair shops, and in fact little unemployment is expected in the
transformer service industry because nearly all of the 300 companies that
service askarel transformers also service oil-filled transformers. Since
about 97% of large, pad mounted, liquid-filled transformers contain mineral
oil, the ban on the rebuilding of askarel transformers should have a
relatively small impact on the level of transformer repair business.
Lost service time
The delay in replacing failed askarel transformers might
increase in some cases from the present four weeks required to rebuild a
unit to as much as six months (Versar 1978, p. 21). This delay could have
serious economic impacts on any industrial plant that was dependent on a
single transformer for its power. Rental units might be available, but at
a higher cost to the plant. The previous estimate of increased rental
27
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costs for temporary replacement transformers was $2,380,000 per year
starting in 1979 (Versar, 1973). No additional data were submitted to the
SPA in written or oral comments on the proposed regulation that would
support any revision of this estimate.
Limitations on sale of reclaimed askarel
The regulations do not impose any restrictions on the processing
of PCB based askarel by the owner of a transformer or by a service company
that returns the askarel to transformers having the same owner. Therefore,
there will be no restrictions on the present maintenance practice of
periodically filtering the askarel in operating transformers to reduce the
moisture content and improve its electrical properties. However, after
June 30, 1979, sale of PCBs will be allowed only if the owner has
petitioned the EPA for and been granted an exemption from the ban on the
distribution in commerce of PCBs. If the EPA does not grant exemptions,
there will be a lack of available PCBs to top off askarel transformers that
may develop small leaks and to replace the PCBs absorbed by the filtering
material when askarel is routinely filtered. However, since it is
technically feasible to dilute askarel with various solvents, including
trichlorobenzene, RTQnp®, and Iralec®, without damaging its electrical
properties, there may be little economic impact caused by the ban on sale
of new and reclaimed PCBs. It should be noted that PCBs from PCB
tranformers that have been disposed of or are designated for disposal must
be incinerated and therefore are not available for recycle or reuse.
Disposal of failed transformers and askarel liquids
The PCB Ban Regulations do not change the requirements
previously ijnposed by the PCB Disposal and Marking Regulations in this area
(EPA, 1978a), and therefore there are no additional economic impacts.
Retrofill with non-PCB fluid
The PCB Ban Regulations clarify the conditions under which a
retrofilled transformer may be considered to be in the same class as oil-
28
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filled transformers for purposes of servicing and disposal. However, the
regulations do not establish any limitations on retrofilling. Therefore,
the effect of the regulations may be to reduce servicing problems when
make-up askarel is no longer available and to reduce eventual disposal
costs in some cases.
Ban on sale of PC3s
Effective July 1, 1979, neither unused PC3s nor reclaimed PCB
based askarel will be allowed to be sold unless the seller has petitioned
for and been granted an exemption by the EPA from the "distribution in
commerce" ban. If the EPA does not grant exemptions, there will be a lack
of available PCBs to replace askarels lost through small leaks or to
replace the PCBs absorbed by the filtering material when askarel is
routinely filtered. However, since it is technically feasible to dilute
askarel with various solvents, including trichlorobenzene, RTEmp®, and
Iralec®, without damaging its electrical properties*, there may be little
economic impact caused by the ban on the sale of new and reclaimed PCBs.
Ban on processing PCBs for sale
The Toxic Substances Control Act defines the processing of a
chemical as "the preparation of a chemical substance or mixture, after its
manufacture, for distribution in commerce..." (Section 3(10)). Therefore,
activities with PCBs that do not involve its sale are not considered to be
"processing" as defined by the Act, and such activities performed for the
purposes of maintaining transformers in other than a "totally enclosed
manner" are specifically authorized by the regulation until July 1, 1984.
This means that there are no restrictions on the filtering or other
handling of askarel unless there is a change in the ownership of PCBs.
Transformer askarel can continue to be tested and maintained by either the
owner of the transformer or by a service company, but no PCBs can be added
to the transformer except those that were owned by the owner of the
*01msted, J. (1977) "Comments and Recommendations on Makeup Fluid for
Askarel Transformers", Waukesha, WI.: RTE Corporation, November 15, 1977.
(Submitted to the PCB Regulation Hearing Record as an attachment to RTE
Corporation "Main Comments").
29
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transformer no later than 30 days after the effective date of the
regulation. In addition, "processing" and "distribution in commerce" for
purposes of disposal are specifically authorized by the regulation.
'fine only significant impact of this provision will be to ban the
salvaging of used PCBs by transformer service companies for use in
maintenance of other transformers. However, the major use of such
reclaimed askarels has been in rebuilt transformers, and the rebuilding of
askarel transformers is being specifically banned. The economic impacts of
the ban on "processing" PCB based askarels have been included in the
estimated cost of the ban on rebuilding askarel transformers.
Disposal of failed transformers and askarel liquids
The PCB Ban Regulations do not change the requirements
previously imposed by the PCB Disposal and Marking Regulations in this area
(EPA, 1978a), and therefore there are no additional economic impacts.
Retrofill with non-PC3 fluid
The PCB Ban Regulations clarify the conditions under which a
retrofilled transformer may be considered to be in the same class as
oil-filled transformers for purposes of servicing and disposal. The
regulations do not establish any limitations on retrofilling. The effect
of retrofilling may be to reduce servicing problems when make-up askarel is
no longer available and to reduce eventual disposal costs in some cases.
The ban regulations impose no economic costs relative to retrofilling of
askarel transformers.
4.4 PCBs Controlled by the Regulation
The ban on rebuilding askarel transformers will eliminate the
loss of PCBs to the atmosphere that occurs when a transformer is baked-out
prior to removal of the coils. There is no information available on the
PCB losses that occur during this process. However, if total losses of
PCBs during rebuilding of an askarel transformer were controlled to one to
ten pounds per unit, the regulation would reduce the entry of PCBs into the
environment by (1 to 10 Ibs per unit x 1/3 to 2/3 of 139,000 units = )
47,000 to 925,000 Ibs.
30
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The ban on the sale of PCBs should accelerate the retirement of
askarel transferors, but there is not sufficient information available to
estimate the effect this will have on the amount of PCBs entering the
environment.
4.5 Summary - Economic Impacts
Foregone savings from rebuilding: $9.6 million (1979); $373
million to $747 million
total
Lost service time (increased
rental of replacanent transformers): $2.38 million per year
4.6 Cost Per Pound of PCBs Keot from the Environment
Ban on rebuilding
$373 million to $747 million +23.8 million* _ ,..__
47,000 to 925,000 B, ' £f
*Present value of one dollar per year indefinitely discounted at 10% equals
$10.
31
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5.0 RAILROAD LOCOMOTIVE TRANSFORMERS
5.1 Present Ownership and Use Plans
Many of the major railroads in the northeastern United States are
electrified. High voltage alternating current is supplied at 25 hz, 11,000
volts, by overhead catenaries to electric locomotives and multiple unit
electric commuter cars (MUEC). Transformers on board the locomotives and
MUEC cars reduce the voltage to the level required by the traction motors.
These transformers are specially designed to fit into the limited space
available on the car or locomotive and are built to withstand severe shock
and vibration. The transformers incorporate a pump to force the coolant
liquid through cooling fins and thereby improve the thermal efficiency of
the units. It has been standard practice to use PCB based askarel coolant
liquids in these transformers because of the possibility of a severe fire
should a derailment occur in one of the tunnels leading into New York City.
The federally funded Northeast Corridor Improvement Project is
upgrading much of the power distribution system between Washington, D.C.
and New York City. According to Mr. Clifford Gannett of the Federal
Railroad Administration, the scheduled completion date for conversion of
the power on this portion of the railroad system is now September, 1983*.
The conversion of the catenary power to 60 hz, 25,000 volts, will have a
major effect on the continued use of many of the present askarel
transformers on locomotives and MUEC cars operating in this area. Although
some of the newer equipment can be converted to operate at the higher
voltages by changing internal taps in the transformers, many of the
*Original information indicated 3rd quarter of 1982. Letter from Clifford
Gannett (Federal Railroad Administration) to EPA dated September 18,
1978. Subsequent press reports indicated completion in September of
1983. This was confirmed by a telephone call to Mr. Gannett in February
1979 (See telephone memo dated February, 1979 from Harold Snyder,
OTS/EPA to record.)
32
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transformers will have to be replaced, and the railroads intend to scrap
many of the oldest cars and locomotives rather than to invest in the new
transformers that would be required to keep them operating. Table 5.1-1
lists the ownership of the MUEC cars and locomotives using PCS cooled
transformers that are presently in service and summarizes the effect of the
voltage conversion on the continued use of these transformers.
5.2 Requirements of the PCS Ban Regulations
Use of PCB railroad transformers: Authorized until July 1, 1984
subject to the following limits on the concentration of PCBs in
the dielectric liquid:
After January 1, 1982: 6% PCBs maximum
After January 1, 1984: 0.1% PCBs maximum
Servicing and retrofilling of PCB railroad transformers and
treatment of PCBs in other than a totally enclosed manner:
Authorized until July 1, 1984, provided that there is no change
in the ownership of any PCBs.
Processing of PCB contaminated liquid prior to sale for
servicing transformers: Banned after July 1, 1979, unless EPA
grants an exemption from the "processing" ban regulation.
Sale of PCBs for servicing railroad transformers: Banned
after July 1, 1979, unless EPA grants an exemption from the
"distribution in commerce" ban regulation.
Testing of liquid in PCB railroad transformers to determine
concentration of PCBs: Required immediately after any servicing
that is performed to reduce the concentration of PCBs and again
12 to 24 months later. Records of these analyses must be
maintained until January 1, 1991.
Rebuilding PCB railroad transformers in other than a totally
enclosed manner: authorized until July 1, 1984. However, any
transformer rebuilt after January 1, 1982, must be refilled with
liquid containing less than 50 ppm PCBs.
33
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Maximum concentration of PCBs in liquid used to service or top
off railroad transformers:
No restriction until January 1, 1982. 6% PCBs from
January 1, 1982, until January 1, 1984. 0.1% PCBs after
January 1, 1984.
5.3 Cost Impacts of the PCB Ban Regulations
July 1, 1984 deadline on continued use of PCB railroad
transformers;
It has not been demonstrated that it is technically possible to
reduce the concentration of PCBs in PCB railroad transformers to below the
500 ppm level that is used to distinguish "PCB transformers" from "PCB
contaninated transformers." It is anticipated that EPA will review the
technology of retrofilling and processing of transformer liquids before the
July 1, 1984, ban on the use of railroad transformers containing more than
500 ppm PCBs to assure that this requirement does not cause substantial
economic impacts. Compliance with these regulations will therefore require
that the affected railroads maintain close communication with EPA to
resolve any unanticipated problems. There is not sufficient information in
the record to support any estimate of the costs that will be incurred by
the railroads in participating in the eventual review of these regulations.
Required reduction of PCB levels to below 6% by January 1, 1982;
It has been demonstrated that a single retrofilling procedure
consisting of draining, flushing, and refilling with non-PCB coolant liquid
can result in PCB concentrations substantially below 6% (Walsh, 1977;*
Foss, 1977**). The analysis of the impacts of the proposed PCB regulation
assumed a total materials and labor cost of $20 per gallon for retrofilling
*Walsh, E.J., D.E. Voytik and H.A. Pearce, (Westinghouse Electric Corp.)
1977. Evaluation of Silicone Fluid for Replacement of PCB Coolants in
Railway Industry, Final Report.Report No. DOT-TSC-1294.Cambridge,
Ma.: Transportation Systems Center, U.S. DOT. December 1977
(attachment to reply comments from Clifford Gannett (Federal
Railroad Administration)).
**Foss, Stephen D., John B. Higgins, Donald L. Johnston, and James M.
McQuade (General Electric Co.). 1977. Retrofilling of Railroad
Transformers. Cambridge, Ma.: Transportation Systems Center, U.S.
DOT, July 1978 (attachment to reply comments from Clifford Gannett
(Federal Railroad Administration)).
35
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a transformer a single time with silicone liquid (Versar, 1978). A revised
estimate for the cost of retrofilling a transformer based on the procedure
developed by Dow Corning Corporation (Page, 1977)* is summarized in Table
5.3-1. The use of silicone at $12 per gallon (Versar, 1978, p. 30) in
estimating retrofill costs should give an upperbound but reasonable figure
because, although the alternative liquids may be cheaper, only silicone can
be treated to remove dissolved PCBs by filtration.
The total cost of retrofilling the 964 existing PCB railroad
transformers is calculated in Table 5.3-2 to be $6.6 million. Many of
these transformers will be scrapped in late 1982 when the scheduled voltage
change on the Northeast Corridor is made. It is therefore possible that at
least some of the transformers will be replaced prior to January 1, 1982,
with units which can operate at both the present voltage and the higher
voltage that is planned. If this replacement is made prior to the date
specified for the 6% PCB limit, the present transformers will not have to
be retrofilled. The cost of this retrofill requirement can be calculated
by assuming that all of the transformer replacements are made by January 1,
1982, and that retrofilling is only performed on the 665 transformers that
will remain in service under higher voltage conditions. The cost of this
limited retrofill program is calculated to be $3.7 million. If the
changeover does not occur until September, 1933, all of the cars will have
to be converted to non-PCB transformers in order to take advantage of the
remaining useful life of the exisitng equipment.
*Page, William C. and Terry Michaud (Dow Corning Corporation). 1977.
"Development of Methods to Retrofill Transformers with Silicone
Transformer Liquid," IEEE Paper 22-477 presented at the Electrical
Insulation Conference, Chicago, Illinois, September, 1977 (attachment
to letter from Terry Michaud to EPA dated August 1, 1978).
36
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Table 5.3-1
Retrofill of PCS Railroad Transformer with
Silicone - 300 Gallon Capacity Assumed
Cost
Procedure
Step
1 Hot drain askarel from
transformer (85% removal
- Foss, 1977)
2 Fill with 255 gallons
trichlorobenzene, circu-
late and drain
3 Fill with silicone
Dispose of liquid
(Rollins, 1978)***
Sub-total:
+ Labor Cost:
@ $15. per hour
Total cost per transformer:
Cost per gallon:
Materials
5 drums @ $25.00*
= $125.00
Estimated
Labor-man hours
2 hours
255 gal TCB @ $5.21 4 hours
= $1329.00
300 gal silicone 2 hours
@ $12.00 = $3600.00
10 drums @ ($115/drum
disposal + $27.28
transportation
@ $0.04/lb * $1423.00
$6477.00
8 hours § $15.00**
$120.00
$6477.00
$21.99
*Versar 1977, pp. 3-8.
**Versar 1978, p. 33.
***Rollins Environmental Service, Inc. 1978. Indemnified Disposal Service
for Polychlorinated Biphenyls (PCBs - Askarels), May 1, 1978.
Submitted as an attachment to letter from James Thompson (T&R
Electric Supply Co.) to EPA, dated August 28, 1978.
37
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Required reduction of PCS levels to below 0.1% by January lf
1984.
Reduction of the concentration of PCBs in each of 665 retrofilled
transformers from an assumed average concentration of 5% to 1,000 ppm will
require two separate retrofilling procedures, assuming that each retrofill
reduces the amount of PCBs in the transformer by at least 86%. It was
suggested that silicone liquid could be processed essentially in place to
reduce the concentration of PCBs and that this processing would cost $4,600
per transformer + $25 per gallon of liquid in the transformer, or an
average of $40.33 per gallon for a 300 gallon capacity transformer.* This
estimate was based on an assumed loss of ten pounds of silicone per gallon
of liquid treated by activated carbon, or a recovery efficiency of -25%
(i.e., 10 pounds of new silicone would be lost in processing and recovering
8 pounds of contaminated silicone). This analysis indicates that it would
be cheaper to use new silicone at $12 per gallon, even though activated
carbon has been shown to remove PCBs from silicone.** The cost of each
retrofill would be $15.14 per gallon as calculated in Table 5.3-3. Total
cost to the railroads for the two retrofill procedures required to reduce
the PCB concentration in each transformer to below 1000 ppm would then be
(170,000 gallons x 2 retrofills x $15.14 per gallon = ) about $5.15
million. This cost could be reduced if a less expensive disposal method
became available or if some way were developed to reclaim the silicone.
*Attachment 2 to "Comments on Proposed Regulations to Ban PCBs."
Submitted by General Electric Co. as a written comment to the SPA
Hearing Record on the PCB Ban Regulations. Undated.
**Dow Corning Corporation. Removal of PCB from Dow Corning 561®
Transformer Liquid by Charcoal Filtration, Midland, Michigan: Undated
TAscited in Versar, 1978, p. 29).
39
-------
Table 5.3-3
Retrofill of Contaminated Silicone Filled Transformer -
300 Gallon Capacity Assumed
Cost
Step Procedure
Materials
Labor-man hours
Hot drain silicone
(85% removal of liquid)
2 hours
Flush with 45 gallons $540.
silicone, (additional 3%
removal of PCBs)
Refill with 255 gal. $3060.
new silicone
($12/gallon)
2 hours
2 hours
Disposal of 6 drums
contaminated silicone
(§$142)
$ 852.
Sub-total:
$4452.
6 hours
Plus Labor Cost
§ $15/hour:
$90.
Total cost per transformer: $4542.
Average cost per gallon: $15.14
40
-------
It should be noted that the highest calculated total cost of the
retrofill program of $21.82/gallon (Table 5.3-1) + 2 x $15.14/gallon (Table
5.3-3) = $52.10/gal is somewhat less than the estimated cost of $78 per
gallon assumed by Charles Engelhardt of Amtrak and by Dean Aboudera of the
American Public Transit Association in their oral comments at the August
31, 1978, hearings on the proposed PCB Ban Regulation. However, it is felt
that the estimate of $52.10 per gallon is in fact an upper bound estimate
of the cost impact of the PCB Ban Regulation because of the opportunities
available for cost reduction by use of other materials being evaluated by
the Federal Railroad Administration such as RTElnp® and Iralec T-l®.*
Testing to determine concentration of PCBs in liquid.
Testing of the liquid in each railroad transformer that remains
in service will apparently be required four times: upon completion of each
of the three retrofill procedures and again 12 to 24 months after the
completion of the final retrofill. Only the initial testing will be
required for those transformers that are replaced in late 1982. There has
been no information submitted to the EPA on the recommended methodology or
estimated cost of analyzing samples of silicone oil for the presence of
PCBs. The methodology for this analysis should be about the same as for
PCBs in mineral oil, although the silicones would require additional
maintenance of the column in the gas chromatograph. Cost of each analysis
therefore might be $125 to $150, including order processing costs. Total
cost of the required analyses would be expected to be $440,000 as
calculated in Table 5.3-4.
*0ral comments by Clifford Gannett (Federal Railroad Administration) at
August 31, 1978 hearing.
41
-------
Table 5.3-4
Cost of Analyzing Silicone Oil for the Presence of PCBs
in Retrofilled Railroad Transformers
Initial retrofill: 964 Samples @ $150 = $144,600
3 x 665 transformers @ $150 = $299,250
Total analytical cost = $443,850.
5.4 PCBs Controlled by the Regulation
There are presently about 4,000,000 pounds of PCBs in use in
railroad transformers. The final disposal of this material was regulated
by the PCS Marking and Disposal Regulations. The effect of the present
regulations is to reduce the amount of PCBs lost by leakage of transformers
by requiring that the PCBs be removed from the transformers and be replaced
with other liquids. Although it was noted that railroad transformers often
lose liquid by leaks and venting, no information was presented to the
record that would support a quantitative estimate of the PCBs required to
top off these transformers to replace lost liquid. Therefore, no estimate
can be made of the effect of the required retrofill program on the entry of
PCBs into the environment.
5.5 Summary - Economic Impacts
Cost of reducing PCBs to 6%
$6.6 million
(silicone in 964 transfor-
mers) .
Cost of reducing PCBs to 1000 pptn $5.15 million (silicone in
665 transformers).
Analytical Costs:
$444,000
42
-------
5.6 Cost Per Pound of PCBs Kept from the Environment
At best, each retrofill prevents the entry into the environment
of the amount of PCBs removed from the transformers.
Reduce PCBs to 6%:
$ol6 I1lli??-'H $14°'!T = $1-75* per pound PCB
.94 x 4 million pounds t^ ^
Reduce PCBs to .1%:
$5.15 million + $300,000 _ e_0. , __
170,000 gallons x 8 lb/gal x 5.9% PCBs = $68* per pound PCB
*Assumes all PCBs would be lost to the environment if not removed by
retrofilling.
43
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6.0 OIL-FILLED POWER AND DISTRIBUTION TRANSFORMERS
6.1 Present Contamination of Oil Filled Transformers
The PCS ban regulations lower the level at which PCB contaminated
mineral oil is regulated from 500 ppm to 50 ppm. A mineral oil transformer
may fall into one of three categories. A mineral oil transformer that has
been tested and found to contain over 500 ppm PCBs is classified as a "PCB
Transformer." A transformer that has not been tested or that has been
tested and found to contain between 50 ppm and 500 ppm PCBs is a
"PCB-Contaminated Transformer." Transformers that have been tested and
found to contain less than 50 ppm PCBs are not subject to regulation.
Most liquid-filled transformers have been filled with
transformer oil, a non-chlorinated petroleum product similar to SAE 10
motor oil (Versar, 1976a, p. 255). These transformers are similar in
design to PCB askarel transformers, and many of the oil-filled transformers
were built in the same plants that manufactured askarel transformers
(Versar, 1976a, p. 84). The total number of oil-filled transformers
presently in service was previously estimated to be about 30,000,000
overhead and distribution transformers (each containing an average of 16
gallons of oil) and 5,000,000 other distribution and power transformers
(each containing an average of 250 gallons of oil) (Versar, 1978,
pp.36-39). It was also estimated that nearly all of the pole mounted
transformers and perhaps 80% of the other oil-filled transformers are owned
by electric utilities (Versar, 1978, pp. 39-40).
During the hearings on the proposed regulation, a number of
utilities and transformer repair companies presented information on the
results of sampling programs that they conducted to evaluate the extent of
PCB contamination of oil-filled transformers. This information is
summarized in Tables 6.1-1 and 6.1-2. The reply comment from the Edison
44
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Table 6.1-1 Notes
V Letters fron Nancy H. Gormley (Allegheny Power Service Corp.) to EPA
dated August 4, 1978 and September 7, 1978.
2/ Letter from Charles Dolloff (Boston Edison Co.) to EPA dated July 5,
1978.
3/ Letter from John Hughes (Commonwealth Edison) to EPA dated August 4,
1978.
4/ Letter from Nathan Haskell (Consumers Power Co.) to EPA dated August 7,
1978.
5/ "Supplemental Comments" submitted to EPA by Harold F. Fox (Dayton
Power and Light Company), August 18, 1978.
6/ Letter from Skiles Boyd (Detroit Edison) to EPA dated August 3, 1978.
7/ Written Comments - "Response Concerning EPA's Proposed PCB Bans " -
submitted by Duke Power Co., August 4, 1978 and oral comments by
Mr. N. J. Melton (Duke Power Co.) at the PCB Hearings, August 21, 1978.
8/ Letter from J.R. Thorpe (GPU Service Corp., a subsidiary of General
Public Utilities) to EPA dated August 4, 1978.
9/ Letter from Edmund Newton, Jr. (GPU Service Corporation) to EPA dated
October 6, 1978.
10/ Oral Comments of Lyle Salmela (Northern States Power Company/Mid-
Continent Area Power Pool) at PCB Hearings, August 22, 1978, (pp. 78-79
of transcript).
ll/ "Comments of Ottertail Power Co. on the Proposed Amendments to
40 CFR 761." Undated.
12/ Letter from William Gerstner and Paul Greiner (Edison Electric Institute)
to EPA dated August 7, 1978; Exhibit III.
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Table 6.1-2 Notes
1. Letter from William Gerstner and Paul Greiner (Edison Electric Institute)
to EPA dated August 7, 1978. Exhibit III.
2. Versar. 1978, p. 40. Confirmed in letter from James Young (General
Electric) to EPA dated October 6, 1978.
3. "Main Comments ..." submitted in writing to EPA by John Olmsted (RTE
Corporation) undated.
4. Letter from James Thompson (T&R Electric Supply Company, Inc.) to EPA
dated August 28, 1978.
5. "Response to June 7, 1978 Federal Register Regarding Proposed Change in
PCB Regulations" submitted to EPA by Stanley Meyers (Transformer
Consultants) as an attachment to letter dated September 13, 1978.
50
-------
Electric Institute (EEI) also summarized this information. The EEI summary
is included as Tables 6.1-3 and 6.1-4. Since the EEI tables use a
different definition of distribution transformers (including more than just
the pole mounted units) and include the results of sampling of oil storage
tanks in the totals, the resulting tables are not directly comparable to
6.1-1 and 6.1-2. However, the EEI apparently had access to some data on
oil-filled transformers that was not otherwise presented to the EPA.
The only data on contamination of oil-filled transformers that
were based on a reasonably random sample of transformers presently in
service were the data reported by Allegheny Power, Commonwealth Edison, and
TVA. The samples taken by Duke Power were from a population that excluded
the large transformers which Duke Power believed were not contaminated.
The other utilities sampled on the basis of convenience, usually sampling
transformers that were in the shop for repairs or that were being serviced
in the field. RTE Corporation reported data based on a planned random
sample of transformers which they had built. Although RTE reportedly has
never used PCBs in their manufacturing plant, they reported that the level
of PCBs seen in transformers was higher in the older units than in newer
ones (none of the transformers was found to be contaminated in
concentrations above 50 ppm). T&R reported a random sample of used
transformers and stated that they felt that the average concentration of
PCBs in oil was above 50 ppm because their holding tanks for reclaimed oil
contained more than 50 ppm PCBs. GE and Transformer Consultants reported
the results of analyses done on their own samples and for other companies;
these data may have also been reported by the owners of the transformers
and may therefore be duplicate information.
It is not possible to calculate statistics that describe all
transformers from the data that has been reported because of problems in
sampling protocols, possible double reporting of data, and uncertainties
51
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about the analytical methodology that was used in each case. However, from
inspection of the data, it might be reasonable to conclude that from 5% to
40% of pole mounted transformers and from 20% to 30% of other oil-filled
transformers are contaminated with PCBs in concentrations exceeding 50 ppm.
Contamination to levels above 500 ppm appears to he rare. Table 6.1-5
summarizes calculations of the amount of PCBs in all transformers and the
amount present in transformers contaminated above 50 ppm. Because of the
uncertainties in the data, the range of confidence in these estimates must
be at least a factor of four, i.e., each estimate should be bounded by a
range of -80% to +400%.
Approximately 80% of the oil-filled transformers are owned by
electric utilities, including the 149 class A and B operating companies and
approximately 1000 Rural Electric Cooperatives.* About eight million of
the pole mounted transformers are owned by the 1000 rural systems, of which
950 are distribution cooperatives that do not generate any power* and that
therefore do not have high efficiency boilers.
6.2 Requirements of the PC3 Ban Regulation
The regulation defines a class of PCB equipment called "PCB
Contaninated Transformers" and specifies certain exemptions from the
marking, disposal, and ban requirements that apply to other PCB equipment.
"PCB Contaminated Transformers" include (1) transformers which were not
originally filled with a PCB coolant liquid but that now are known to
contain a liquid contaminated with PCBs in concentrations from 50 ppm to
500 ppm, (2) oil-filled tranformers that have not been tested for PCBs, and
(3) transformers that were originally filled with PCB based askarel but
that have been decontaminated to the extent that the concentration of PCBs
is found to be below 500 ppm when tested after at least three months of
service following the last decontamination procedure.
*Ives, Joseph S. (National Rural Electric Cooperative Association).
Written statement dated August 7, 1978, and oral testimony at August 21,
1978 hearing.
56
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Table 6.1-5
Estimated Amounts of PCBs in Oil-Filled Transformers
Pole Mounted
Other
Average oil capacity,
gallons per transformer*
x 7.6 = Ib oil per transformer
Number of transformers in service*
% above 50 ppm
Number of transformers above 50 ppm
16 gal.
121.6 ID
30,000,000
10%
3,000,000
250 gal.
1900 Ib
5,000,000
25%
1,250,000
Pounds of oil in contaminated
transformers 364.8 million Ib 2,375 million Ib
Assumed average PCBs concentration 80 ppm 80 ppm
Pounds of PCBs in contaminated trans-
formers 29,184 Ib**
190,000 Ib**
Number of transformers below 50 ppm 27,000,000
3,750,000
Pounds of oil in non-contaminated
transformers
Assumed average PCB concentration
Pounds of PCBs in non-contaminated
transformers
Total pounds of PCBs
3,283 million Ib 7,125 million Ib
10 ppm 20 ppm
32,830 Ib**
62,000 Ib**
142.500 Ib**
332,500 Ib**
*Versar, 1978., pp. 36-40
**Confidence limits: - 80% + 400%
Total 400,000 Ib PCBs**
57
-------
The following provisions apply to "PCB Contaminated
Transformers":
• Continued use: defined as use in a totally enclosed manner,
and therefore not regulated.
• Marking: exempted from the requirement that a PCB
label be applied.
• Servicing and rebuilding in other than a totally enclosed
manner: authorized until July 1, 1984, provided there is no
change of ownership of liquid containing over 50 ppm PCBs.
(Note: reclaimed transformer oil may be presumed to contain
between 50 and 500 ppm PCBs unless it has been tested.)
• Reclaiming used transformer oil: authorized without
restriction for use by the owner of the oil in his own
transformers.
• Sale of reclaimed transformer oil: tested and found to
contain less than 50 ppm PCB: not regulated.
Not tested for PC3s or tested and found to contain 50 to 500
ppm PCB: banned after June 30, 1979, unless EPA grants an
exemption from the "distribution in commerce" bans. EPA has
not yet announced the conditions under which individual and
consolidated petitions for exemption will be accepted.
• Resale of used transformers: excluded by TSCA from the
"distribution in commerce" ban.
• Disposal of drained transformers: not restricted.
• Disposal of used transformer oil: tested and found to
contain no detectable PCBs: not regulated. (Testing may be
performed on batches of oil from different transformers,
i.e., testing of storage tanks is permitted.)
Tested and found to contain detectable PCBs in concentrations
below 50 ppm - not regulated, except the oil may not be used
58
-------
as a sealant, coating, or dust control agent (i.e., not
allowed as road oil or pesticide carrier).
Not tested or tested and found to contain 50 to 500 ppm PCBs:
storage and shipping containers must have PCS label. Storage
must be in special PCS storage areas and shipping vehicles
must be marked. Disposal must be in one of the following:
(1) In an approved PCS incinerator.
(2) In an approved chemical waste landfill.
(3) In a large (50 million 3TU per hour or larger)
high efficiency boiler that meets certain
specified operating criteria. The SPA Regional
Administrator must be notified 30 days before the
first time PC3 contaminated oil is burned.
(4) By any other method that has been demonstrated to
have as high a destruction efficiency for PCBs as
does a high efficiency boiler and that has been
approved for disposal of PCB-contaminated oil by
the EPA Regional Administrator.
6.3 Cost Impacts of the PCS Ban Regulation
The regulation does not affect the continued use or resale of PCB
contaminated transformers, nor does it affect the maintenance of these
transformers except to ban the sale of reclaimed contaminated fluid. The
only impacts will be on the reclamation and disposal of contaminated used
transformer oil and other contaminated transformer liquids.
July 1, 1984 deadline on rebuilding oil-filled transformers:
After July 1, 1984, rebuilding of oil-filled transformers will
only be allowed for those units that have been tested and found to contain
less than 50 ppm PCBs. It is anticipated that EPA will review the status
of the rebuilding of transformers and the occurrence of PCBs in the oil of
oil-filled transformers prior to the 1984 deadline. Those companies that
rebuild transformers *all therefore have to stay in close contact with EPA
and participate in the regulatory review process in order to ensure that
this deadline does not result in major unforeseen economic impacts. There
is not sufficient information to support any estimate of the costs to be
59
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incurred by the transformer service industry and by the users of oil-filled
transformers by participating in the eventual review of these regulations.
Reclamation of used fluid from PCB contaminated transformers;
According to Duke Power Company, reclaiming and reprocessing
transformer oil saves at least $.40 per gallon on the 170,000 gallons of
oil which they reprocess in-house each year.* The Cincinnati Gas and
Electric Company reported that they salvage 60,000 gallons of used
transformer oil each year from their transformer repair operations and that
this is reprocessed into 58,000 gallons of useable oil at a total cost of
$18,000 or $.31 per gallon.** New transformer oil presently costs about
$1.19 per gallon** and the price is expected to increase over the next few
years as supplies of naphthenic crude oil are depleted and transformer oil
must be made by the more expensive process of deeply dewaxing paraffinic
crude oil fractions.
Not all used transformer oil is reclaimed because smaller
transformer companies and utilities do not generate enough used oil to
justify the purchase of the necessary equipment. However, reclamation
appears to be the standard practice for most transformer repair shops and
major utilities. The regulations authorize the reclamation of used
transformer oil by utilities for use in their own transformers. The
regulation requires that all transformer oil be presumed to contain more
than 50 ppm PCBs unless it has been tested and found to contain less than
50 ppm PCBs. The sale of reclaimed transformer oil is banned after June
30, 1979, unless each batch has been shown to have less than 50 ppm PCBs or
EPA exempts the seller from this ban requirement. The EPA has not yet
*"Duke Power Company's Response —" dated August 4, 1978. Submitted to
EPA as a written main comment on the proposed PCB ban regulation.
**Letter from E. E. Galloway (The Cincinnati Gas and Electric Company) to
EPA dated August 4, 1978.
60
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established the basis on which it will accept individual or consolidated
petitions for exemption, nor has it announced the basis for granting such
exemptions. The filtering of oil by transformer service companies as a
part of routine field maintenance is allowed because the oil is returned to
the transformer from which it is taken and ownership of the oil does not
change, so there is no "distribution in-commerce" taking place.
As calculated in Table 6.3-1, approximately 78% of the
transformer oil is in transformers owned by large utilities, most of which
do their own routine maintenance.
Maintenance of most of the transformers not owned by the major
utilities is performed by transformer manufacturers and by independent
repair shops. About 8 million of the 30 million pole mounted distribution
transformers are owned by small distribution utilities most of which do not
repair their own transformers. As calculated in Table 6.3-1, the effect of
the ban on the sale of reclaimed oil is to eliminate the opportunity to
recycle 22% of the available oil unless each batch is tested and shown to
contain less than 50 ppm PCBs. If it is assumed that 4% of all oil becomes
available for recycling each year (equivalent to assuming an average of 25
years between major servicing operations on each transformer) and that 75%
of the oil was actually recycled, savings in 1978 would have been (1.73
billion gallons x 4% available x 75% reclaimed x $.40 to $.80 per gallon
savings per gallon reclaimed =) $20.8 million to $41.5 million. The cost
of the foregone savings from recycling in 1979 could be as much as 22% of
the 1978 savings, or $4.6 million to $9.2 million.
The actual reduction in the amount of oil reclaimed by
transformer shops will depend on the economics involved in testing the oil
to demonstrate that each batch contains less than 50 ppm PCBs. The total
amount of oil that could be reclaimed for purposes of resale by transformer
maintenance shops might be 11.4 million gallons per year as calculated in
Table 6.3-2. If this oil were accumulated in 1000 gallon batches prior to
OJ.
-------
Table 6.3-1
Used Transformer Oil Available for Reclamation
Bole Mounted
Transformers
Other
Average capacity-gallons
Total number in service
Owned by industry
Owned by small utilities
Owned by major utilities
Amount of oil in use
Total
Amount of oil used by major
utilities
Total
16
30,000,000
8,000,000
22,000,000
250
5,000,000
900,000
100,000
4,000,000
480 million gal 1,250 million gal
1,730 million gal
352 million gal 1,000 million gal
1,352 million gal
Percent of transformer oil used by major utilities:
1,352 million gal.
1,730 million gal. = 78%
Percent of transformer oil not available for recycling: 1-78% = 22%
62
-------
Table 6.3-2
Estimated Supply of Transformer Oil Available for Recycling for Sale
Total amount of oil 1.73 billion gallons
x fraction available each year 4%
x fraction to transformer repair companies 22%
x fraction assumed recoverable (not
too degraded by prolonged use) 75%
= Total annual supply of oil available
for recycling for sale 11.4 million gallons
63
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testing, all of the oil could be tested for PCBs by performing 11,400
analyses. Costs of such a routine sampling and analysis program were
previously estimated to be from $67 to $80 per sample (Versar 1978, p. 41)
The cost of performing such an analysis on a 1000-gallon tank full of oil
would be only $.08 per gallon. Testing to prove that the oil could be
reclaimed would be justified as long as the expected cost per gallon
reclaimed is less than the cost savings of $.40 per gallon achievable by
reclaiming the oil. Therefore, the analysis of 1000-gallon batches would
be justified if as few as one of every five batches were actually found to
have less than 50 ppm PCBs. If. the total amount of PCBs in transformers is
actually the 400,000 pounds estimated in Table 6.1-5, the average
concentration of PCBs in the 1.73 billion gallons of transformer oil that
is in use would be about 30 ppm. This implies that at least one half of
the batches of oil that are tested would have less than 50 ppm PCBs if care
were taken to avoid contamination of the oil with materials used with
askarel transformers. If only one half of the batches were in fact
contaminated to levels of less than 50 ppm, an expenditure of (11,400
analyses at $80 = ) $912,000 for chemical analyses would make available
(11.4 million gallons x 50% =) 5.7 million gallons of oil per year for
recycling and resale. If the recycling of this oil saves $.40 to $.80 per
gallon, the total cost of the ban on selling untested recycled transformer
oil would be reduced by (5.7 million gallons x $.40 to $.80 per gallon -
$912,000 testing cost = ) $1.368 to $3.468 million per year. Total costs
would then be ($4.6 to $9.2 million - $1.4 to $3.6 million = ) $3.2 to $5.
million per year. If, however, none of the batches of oil had over 50 ppm
PCBs, the total cost of the regulation would be the cost of the analyses
(or a total of $912,000 per year if testing were performed on batches of
1000 gallons) or even less if the average batch size were larger.
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Disposal; The PCB Ban Regulation authorizes the disposal of
transformer oil contaminated with 50 to 500 ppm PCBs in large, high
efficiency boilers meeting certain requirements of size, feed rate of the
contaminated oil, presence of excess oxygen in the stack gas, specified
instrumentation and monitoring procedures, and other specified operating
conditions. The contaminated oil would have to be handled and labeled as
PCBs during shipment and storage.
The regulations require that the EPA Regional Administrator be
notified at least 30 days before the first time each high efficiency boiler
is used to burn transformer oil known or presumed to be contaminated with
PCBs. The regulations further state that the contaminated oil cannot be
fed into the boiler during start-up or shut-down conditions and that the
oil can comprise only ten percent of the fuel while the boiler is
operating. Therefore, special holding tanks and metering pumps will be
required to feed the transformer oil into the fuel stream in a controlled
amount during periods of stable operation of the boiler.
A number of utilities have stated that they have power boilers
that operate at combustion conditions similar to those specified for PCB
incinerators.* A special holding tank and metering pumps will be required
to feed contaminated transformer oil into a high efficiency boiler.
Additional road construction, fencing, or other utilities may add to the
cost of equipping a boiler to burn transformer oil in compliance with the
regulation. This expenditure would probably only be made if justified by
savings resulting from (1) decreased disposal costs and (2) the value of
heat recovered in burning the transformer oil.
*Letter from Nancy Gormley (Allegheny Power Service Corporation) to EPA
dated August 4, 1978.
*Letter from James Mulloy (City of los Angeles Department of Water and
Power) to EPA dated August 7, 1978.
*Attachment to letter from L. John Cooper (Nebraska Public Power District)
to EPA dated August 4, 1978.
*"Comments of Otter Tail Power Company on the Proposed Amendments to 40 CFR
761." Submitted to EPA by Jay D. Myster, undated.
*Letter from S. A. Ali (Public Service Indiana) to SPA dated August 4,
1978.
65
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Disposal of used transformer oil in approved high temperature
PCS incinerators has been quoted to cost $.08 per pound in tank truck lots
(Rollins, 1978) plus perhaps $.02 per pound transportation (Versar, 1977,
pp. 2-32). This is roughly $.75 per gallon. T&R Electric estimated that
fuel oil to replace transformer oil used in their boiler would cost $.42
per gallon.* Shipping costs to move transformer oil in drums to boilers
equipped to burn it will probably not exceed the commercial trucking costs
of $2.70 per hundred pounds for trips under 100 miles (Versar 1977, p.
2-33). For transformer oil weighing 8 pounds per gallon, this is
equivalent to ($2.70/8 = ) $.34 per gallon. Shipment of large quantities
by tank truck would be considerably cheaper per gallon. The value of the
oil to the company that owns and burns it would be equal to the savings in
disposal cost ($.75 per gallon) plus the net fuel value ($.42 -$.34 = $.08
per gallon). Even though most utilities might be able to obtain fuel for
their power boilers at a lower cost than is paid by T&R Electric, the
savings in disposal cost of $.75 per gallon could quickly pay for the
estimated cost of installing additional handling facilities at the boiler.
Since the value of used transformer oil as fuel is roughly equal
to the cost of handling and transporting it, the total cost of disposal to
those utilities that have suitable boilers will be the cost of equipping
the boilers. There is not sufficient information in the record to support
an estimate of the cost of installing this equipment, but this alternative
disposal method should be considerably cheaper than commercial approved PCB
incineration for most of the 149 class A and B utilities.
*Letter from James Thompson (T&R Electric Supply Company, Inc.) to EPA
dated August 28, 1978/
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Satisfactory high efficiency incinerators will not be generally
available to the many distribution utilities, transformer repair shops, and
industrial owners of oil-filled transformers. For instance, T&R Electric
is a transformer repair shop that burns 200,000 gallons of used transformer
oil each year in a hot water generator which has a flame temperature of
1700° P.* The regulations will require that this oil be disposed of by
incineration in high efficiency boilers or by other approved methods. This
will result in increased costs to T&R Electric both to dispose of this oil
and to replace it.
If the requirement that waste oil be labeled as PCBs discourages
general handling of this material, the value of the used oil to the company
that generates it may be considerably less than its potential fuel value.
The result may be disposal costs of up to $.75 per gallon. Since much of
the waste oil is now used as supplemental fuel in small boilers that will
not meet the requirements established by the regulation, the opportunity
cost of the regulation may be up to ($.75 disposal cost + $.42 fuel value =
) $1.17 per gallon of the oil that is incinerated in approved PCB
incinerators.
The discussion of reclamation of used transformer oil concluded
that the value of reclaimed oil was such that testing of batches of oil to
demonstrate that the PCB content is below 50 ppm will be justified for most
of the transformer repair shops. The oil that will require disposal will
be those batches found to be contaminated above 50 ppm, that oil which has
degraded past the point where reclamation is feasible, and the oil
generated in small batches by junk yards and other industrial concerns that
handle transformers infrequently. It was estimated above that 5.7 million
gallons per year of available oil would be salvageable and contain less
than 50 ppm PCBs.
*Letter from James Thompson (T&R Electric Supply Company, Inc.) to EPA
dated August 28, 1978.
67
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The maximum economic cost would be incurred if the remaining oil were
disposed of in approved high temperature PCB incinerators. The total
annual cost of this incineration is calculated in Table 6.3-3 to be $11.1
million per year. This total would be reduced considerably if the large
utilities were willing to accept contaminated oil for burning in high
efficiency boilers from other sources, but the comments to the EPA by the
utilities did not express any interest in making this service generally
available.
The willingness of large utilities to make available their high
efficiency boilers for burning used transformer oil may be increased by the
willingness of the small utilities and transformer repair shops to pay up
to $.75 per gallon for this service. The large utilities would incur no
cost other than the cost of supervising the transfer of truck loads of
liquids to their storage tanks and the monitoring and record keeping costs
that are incurred by the regulations on any disposal of PCBs. Given a
perfect market/ the large utilities might be expected to be willing to pay
for the fuel value of the used oil. However, the market is likely to be
very imperfect, and the actual price charged by the utilities for this
service can therefore not be predicted. However, since the burning of oil
by the large utilities will not cost them anything, the price that is
charged will represent a transfer payment from the small transformer shops
and distribution utilities to the large utilities, and will not represent a
real economic cost. Real economic costs would result only from the higher
transportation costs of moving the oil to the large utilities and from the
greater value of the heat content of the oil to the smaller companies than
to the large utilities. These economic costs are likely to be only a small
fraction of the costs incurred by incineration of this oil in approved PCB
incinerators.
Marking and Storage Costs; The change in the definition of PCB
material from a concentration of 500 ppm to a concentration of 50 ppm
extends the impact of the PCB Marking and Disposal Regulations to all used
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TABLE 6.3-3
Cost of Disposal of Transformer Oil from
Small Utilities, Transformer Repair Shops, and Other Sources
Total Amount of Transformer Oil in Service
x Amount Available Each Year
x Amount Not Owned by Large Utilities
= Amount Available Per Year
Amount Reclaimed and less than 50 ppn PCBs
= Total Available for Fuel
x Cost of Incineration and Lost Fuel Value
= Maximum Cost Per Year:
1.7 billion gal.
4%
22%
15.2 million gal.
5.7 million gal.
9.5 million gal.
$1.17 per gal.
$11.1 million per year
69
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transformer oil that is being stored for disposal or reuse and to the oil
that is being transported for disposal. At a very minimum, special PCB
storage areas will be required at each of the 149 large utilities that
maintain their own transformers. These major storage areas were previous!
estimated to cost $2000 to construct and to result in annual operating
costs of $2,125 per year (Versar, 1977, pp. 2-6). Total costs incurred
because of the inclusion of transformer oil may therefore be equal to
($2000 per site x 149 locations = ) $300,000 in initial construction costs
and ($2125 x 149 = ) $320,000 per year thereafter. The regulation also
permits bulk storage of used transformer oil and the provisions of the
Spill Prevention Control and Countermeasure (SPCC) plans of the oil spill
prevention program become the storage criteria. Since almost all utilities
have SPCC plans, this option probably results in no additional costs being
incurred.
Additional marking costs will be incurred in applying PCB labels
to drums, tanks, and trucks used to transport used oil to the disposal
sites. Because any tank used to contain transformer oil must be considered
to be a PCB container, special decontamination will be required before it
could be used for any other service. Therefore, it is likely that each
high efficiency boiler facility will have a dedicated truck trailer tank
that is used to haul PCBs. Application of labels to these tanks will cost
only a few dollars per year.
6.4 PCBs Controlled by the Regulation
A certain amount of used transformer oil has been used in the
past as fuel in various boilers and power generating units. When possible
the oil has been reclaimed for use in transformers. Other uses include
road oiling and re-refining into lubricating oil. Only a very rough
estimate can be made of the amount of PCBs released to the environment by
past practices in handling used transformer oil.
If it is assumed that past practices resulted in the use of
one-half of the oil as fuel in boilers operating at conditions that
70
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destroyed 98% of the PCBs present and that the remaining PCBs would
eventually enter the environment, the burning would have been expected to
destroy (.98 x .5 x 400,000 Ib PCBs = ) 196,000 pounds of the PCBs in
transformer oil. The effect of the regulation is to require the eventual
disposal of all transformer oil in high efficiency boilers that will
destroy 99.9% of the PCBs present. Therefore, PCB releases to the
environment may be reduced from (400,000 - 196,000 = ) 204,000 pounds to
(400,000 x [1 - .999] = ) 400 pounds, or a net reduction of about 200,000
pounds of PCBs.
6.5 Summary - Economic Impacts:
Ban on reclaiming oil for resale:
$3.2 million to $5.6 million
per year (may be reduced if EPA
exempts processing and resale from
the ban requirements).
Limitations on disposal of con-
taminated transformer oil:
Cost of storage tanks, etc., cannot be estimated from
at high efficiency boilers: information in the record.
Cost of incinerating oil
generated by other than
large utilities:
Cost of special storage
area for transformer oil
at utilities:
Up to $11.1 million per year if
large utilities do not accept oil
for burning in their boilers.
Cost may be reduced considerably
if large utilities make this
service available.
$0 to $300,000 initially plus $0
to $320,000 per year starting 30
days after promulgation of the
regulation.
6.6 Cost Per Pound of PCBs Kept from the Environment
If it is assumed that the restrictions on disposal and
reclaiming of transformer oil will continue for the 30 year life of the
newest oil filled tranformers:
Ban on reclaiming and special disposal requirements =
$3.2 million to $5.6 million + 0 to $11.1 million + 0 to $.3 million _ g4gQ to $2550
200,000 lbs/30 years per pound PCBs
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7.0 IMPACTS ON TRANSFORMER SERVICE COMPANIES
7.1 Present Status
There are presently about 300 small companies that service the
transformers owned by snail utilities and by industry.* The services
offered by these companies include field testing and servicing of
transformers and complete shop maintenance and rebuilding services.
7.2 Requirements^of the Regulation
The regulation requires that all oil-filled transformers be
considered to be PCB contaminated transformers unless the concentration of
PCBs in the oil has been demonstrated by chemical analysis to be less than
50 ppm. The regulation bans the sale of any new or reclaimed transformer
liquids unless they are known to contain less than 50 ppm PCBs.
7.3 Impact of the Regulation
The major impact of the regulation on the small transformer
service companies results from the change in the definition of PCBs from a
concentration level of 500 ppm to a level of 50 ppm. Many of these
companies have discontinued servicing askarel transformers because of the
potential liability that could result from spills or worker exposure, and
because of the relatively high price of building the required storage areas
for PCB materials. Companies who do not have oil storage facilities
meeting SPCC requiraements are now required to install special storage
areas for the storage of oil filled transformers and used transformer oil.
Transformer service companies will face increased costs from the
ban on reclaiming PCB contaminated transformer oil for resale, and
*Letter from Robert L. Sandman (Electric Apparatus Service Association) to
EPA. Undated.
72
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increased disposal costs. These costs were discussed in detail in Chapter
6, and the companies should be able to pass them along to their customers.
The fact that the regulation allows reclamation of PC3 contaminated oil for
use in the owner's transformers but not for resale will provide an economic
incentive for utilities and large industrial concerns to perform their own
maintenance rather than contract it out. However, there is not sufficient
information available to support any quantitative estimate of the resulting
market shifts. The economic impact of restrictions on these activities
will be dependent on the extent to which EPA grants exemptions for these
activities.
7.4 PCBs Controlled by the Regulation
There was no information presented on the amount of PCBs entering
the environment as the result of improper storage of transformer oil by
transformer service shops. Therefore, no estimate can be made of the
reduction of PCBs entering the environment that will result from the
improvement of storage conditions at these facilities,
7-5 Summary - Economic Impacts
Information is not available from the record to make estimates of
these impacts.
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3.0 MINING flACHINERY*
8-1 Current Use of PCS-Cooled Mining Machinery Motors
In the late 1960s and early 1970s, PCBs were used as a motor
coolant in three types of electric motors manufactured by Reliance Slectri
for Joy Manufacturing Company. Joy used these motors in three models of
low seam mining machinery: CU43 continuous miners, 9CM continuous miners,
and 14BU10 loaders. Table 8.1-1 summarizes the production statistics and
present usage of these machines.
One small coal mining company in Pennsylvania is operating the
three remaining Model CU43 continuous miners known to be in service. This
company also has portions of several other CU43 miners which they have
purchased for parts. Two of the machines in use have had the PCB-coolant
replaced with a silicone fluid and two of the three motors on the third
miner have also been filled with silicone. If the motors were not
completely cleaned and rewound at the time the silicone fluid was
introduced, it is probable that the motors still contain low levels of
PCBs. For the purposes of this analysis, it will be assumed that they are
contaminated with PCBs at levels in excess of 50 ppm. Fifty-four of the
fifty-seven 9CM continuous miners sold in the United States were located b
Versar during the course of a telephone survey. Two of the three machines
which could not be located were recently sold on the used-machinery market
It is assumed that these two machines are still in use. Thirty-five of th
model 9CM miners are currently idle, fifteen are being used to mine coal,
three are in use for maintenance or construction, two are in use on spare
sections, and one is being used in a training program at a vocational
school.
The 14BU10 loaders were originally sold to eighty-eight
different mining operations, the majority of them small; sixty of these
mines have three or fewer of these loaders. Based upon the expected
service life of the machines and a survey of thirty-six mines, it is
estimated that essentially all of these loaders are still in service.
*A11 figures and information in this Chapter are from Versar, 1978, excep
where noted.
74
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.5
in
00
S
I
Cn
.5
in
-s
S3!
VO
O
2~
Q
-------
For the past few years, Joy has been converting the motors on the loaders
to air-oooling. As shown in Table 8.1-1, there are approximately 250
loaders and 17 spare motors that still contain PC3s.
The rtotors on the continuous miners and the loaders require
occasional topping-off with additional fluid at the mines. The amount of
fluid which is required is small but is necessary for the continued
operation of the machines.
8.2 Requirements of the Regulations
The PCS Ban Regulations require or permit the following with
respect to the continued use and servicing of PCB-cooled mining machinery
motors:
• PCBs may be used in mining equipment until January 1, 1982.
• PCBs may be added to mining equipment motors at the mines
until January 1, 1982.
• PCB motors in the loaders must be rebuilt as non-PCB cooled
motors whenever the motors are returned to a service shop
for servicing.
• PCB motors on continuous miners may be rebuilt as PCB motors
until January 1, 1980.
• Any PCBs used to service or repair PCB-cooled motors must be
stored in accordance with the storage for disposal
requirements of Annex III (§761.42).
• Processing and distribution in commerce of PCBs for purposes
of servicing mining equipment is permitted after July 1,
1979, for persons who are granted an exemption under TSCA
S6(e)(3)(B).
8.3 Compliance Costs
Continuous Miners; The regulations allow rebuilding of the
motors in the two models of Joy continuous miners as PCB motors until July
1, 1979. This deadline could be extended to January 1, 1980, if EPA grant;
the service shops an exemption from the "processing" and "distribution in
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commerce" bans. There are no non-PCB, motors that can be used in place of
the PCB motors on the continuous miners, and space limitations on the
machines prevent converting these notors to air cooling. Since the PCB
motors on the continuous miners require rebuilding after about 12 months of
service*, all of these machines will have to be retired from use within
about a year after the effective date of the ban on rebuilding the motors.
Because of the time limits in the authorization, the market for
used 9CM and CU43 continuous miners will virtually disappear. Though this
machinery may be technologically obsolete before January 1, 1982, there are
undoubtedly numerous small firms which cannot afford the capital investment
required for new machinery and thus rely on older used machines to fill
their needs. In addition, larger firms often use older machinery for spare
equipment or in mine construction. Therefore, the owners will be
confronted with equipment that they must retire prematurely/ losing the
remainder of the machine's useful life or the income that could result from
the sale of the machinery.
Eight companies still use 9CM or CU43 continuous miners for coal
production. Six of these companies are relatively small, with production
ranging from 0.7 to 4.2 million tons per year. The other two are large
conglomerates with much higher annual productions. In addition, six
machines are performing operations other than production. The market value
of these machines is roughly $40,000 each {Versar, 1978). Table 8.3-1
summarizes the costs that would be incurred by each of the companies that
still use the continuous miners for coal production. Table 8.3-1 omits the
42 miners that are idle or in non-production uses because the percentage of
those miners that have any value is not known. If each of them has a value
^Testimony of Mr. Ed Warner (Joy Manufacturing Co.) at the EPA PCB
Hearings, Chicago, Illinois, July 19, 1977.
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TABLE 8.3-1
Cost Inpact of Forced
Number of
Continuous
Corrpany Miners
No. Model OJ43
1* 3
2*
3*
4*
5
6*
7
3*
(Other Uses)
Retirement of PCE Continuous Miners
Number of
Continuous
Miners
Model 9CM
in Service
0
3
2
1
1
1
2
5
6
Opportunity
Cost Due to
Absence of
Used Eguipmenl
Market
$ 120,000
$ 120,000
$ 80,000
$ 40,000
$ 40,000
$ 40,000
$ 80,000
$ 200,000
$ 240,000
TOTAL 3 21 $ 960,000
* Small producer (less than five million tons per year total company
production).
78
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of $40,000, the additional cost could be as much as $1.7 million. In no
case does the economic impact exceed one percent of the value of the coal
mined annually by any of the affected companies. It is assumed that
replacement machinery could be obtained in time to prevent any inter-
ruptions in coal production.
Loaders: The PCS motors used on the loading machines can be
converted to air cooling at a cost of $3,100 per motor. The motors usually
require rebuilding after 18 to 24 months of service*, so most of the motors
will be available for this conversion without incurring additional downtime
for the machines. Joy Manufacturing Company has stated that its service
shop has the capacity to convert all of the PCB motors presently used on
loaders to air cooling by the end of 1981. Since the PCBs will be removed
from these motors for purposes of disposal, this activity is not affected
by the ban on "processing" of PCBs.
The total cost to convert the 517 PCB motors used on the loaders
will be (517 x $3,100 = ) $1.6 million. There should be no interruption of
coal production due to the conversion program because PCB motors will be
allowed to continue in use until January 1, 1982, and most of the
conversions will occur when the motors will require normal rebuilding. It
is anticipated that maintenance requirements will be greater for the air
cooled motors than for the PCB cooled motors, but it is not possible to
estimate the total economic impact of the resulting increased maintenance
costs.
Storage Costs; Each mine would be required to store PCBs used
for maintenance in a storage area that meets the requirements of Annex III.
Joy sells the PCBs in one gallon cans. A non-leaking 55 gallon drum
protected from the rain would meet the requirements of Annex III and would
be of sufficient size to store all the PCBs any mine would require. Each
of the 96 companies possibly involved (88 loader owners and 8 continuous
miner owners) would need such a storage area. The cost for a barrel and a
*Testimony of Mr. Ed Warner (Joy Manufacturing Company) at the EPA PCB
Hearings, Chicago, Illinois, July 19, 1977.
79
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label may amount to S50 each for a total cost of $4,800. The recordkeepina
required for storage areas may increase this cost by a factor of two to
three, for a maximum expected cost of $14,400.
Exemption Application: It is assumed that Joy Manufacturing will
apply for an exemption under TSCA §6(e)(3)(3) in order to be allowed to
rebuild the loader motors and to be allowed to distribute PCBs to the mines
for maintenance. The estimated $1,600 cost of preparing this petition is
developed in the chapter on unintentional product contaminants.
8.4 PCBs Controlled by the Regulation
The electric notors in use on mining machines contain about 2419
gallons of PCBs (Table 8.1-1). This is equivalent to about 27,500 pounds
of PCBs with a density of 11.37 pounds per gallon. The regulations will
stop the losses of PCBs from these motors by requiring that they be
scrapped or rebuilt as air cooled motors by January 1, 1982. There is no
information in the record on which to base any estimate of the rate at
which PCBs are lost from these motors. Therefore, no estimate can be made
of the number of pounds of PCBs that will be prevented from entering the
environment.
8.5 Sujrcnary-Economic Impacts
loaders - rebuild motors @$3,100 $1,600,000
Continuous Miners-premature scrapping 960,000
of 24 operating machines §$40,000
42 other miners 30 - $40,000 0 to 1,700,000
Storage costs - 96 storage areas 14,400
Exemption application 1,600
TOTAL $2,576,000
(plus up to $1,700,000
for idle miners)
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8.6 Cost Per Pound of PCBs Kept from the Environment
If it is assumed that the regulation will prevent the entry into
the environment of all the PCBs presently in use, and that all of the PCBs
would otherwise be lost:
Cost per pound = $2'57^ g^276'000 - 594 to 5155 per pound PCBs
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9.0 ELECTROMAGNETS*
9.1 Current Usage
Large electromagnets are installed over conveyor belts to retnov
tramp iron from non-magnetic commodities such as coal and grain. Most of
these electromagnets are cooled with 100 to 150 gallons of mineral oil.
Where increased fire safety was required, the magnets were often filled
with PCB based askarel liquid. The three magnet manufacturers who used
PCBs were:
Sterns Magnetics, Cudahy, Wis.
Eriez Magnets, Erie, Pa.
Dings Co., Milwaukee, Wis.
Dings Co. stopped using PCBs in mid-1976; the other two
manufacturers have not used PCBs since 1971 or 1972. A total of about 25C
PCB magnets were manufactured; approximately 200 of these may still be in
use in the United States. Most of the PCB magnets are being used in coal
mines, coal preparation plants, and in coal-fired generating stations. It
is possible, but not confirmed, that some of the PCB magnets may be used c
grain conveyors because of the flammability of grain dust.
The electromagnets are of completely welded construction, and
very few leakage incidents have occurred with either oil-filled or
PCB-filled magnets. Based on design considerations, electromagnets would
be expected to be less likely to fail than transformers. Ihose leaks tha
have occurred have been caused by physical abuse or lack of adequate
maintenance. Maintenance requirements do not expose workers or the
environment to contact with PCBs. Since the magnets are suspended over
conveyor belts, diking is not feasible, and any leakage would be
uncontrolled. However, PCBs dripping onto the coal would be expected to
destroyed in power generating boilers, thus making the only loss to the
environment that of leachate from contaminated coal in storage piles. Th
total amount of PCBs presently in use in electromagnets is probably (200
magnets x 135 gallons per magnet x 11 pounds per gallon x .7 pound PCB pe
pound askarel = ) 207,900 pounds of PCBs.
*A11 information in this chapter is from Versar, 1978, Chapter 9, except
noted.
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9.2 Requirements of the PC3 Ban Regulations
Continued use; PCB-filled electromagnets are defined as a
totally enclosed use of PC3s and therefore may continue to be used
indefinitely.
Servicing; Minor servicing which does not require the removal of
the coil fron the casing is authorized until July 1, 1984. Removal of the
coils is prohibited.
Sale of PCBs; Banned after July 1, 1979, unless EPA grants an
exemption from the "distribution in commerce" ban.
Reclaiming PCBs; For reuse by the owner of the PCB transformer
or electromagnet: authorized. For sale: banned unless an exemption is
granted by EPA.
Disposal; By incineration in an approved high tanperature PCB
incinerator. Drained PCB electromagnets may be disposed of in approved
chemical waste landfills; the liquids drained from the magnets must be
incinerated in approved incinerators.
9.3 Cost Impacts ofthe PCB Ban Regulations
Continued use; The regulations impose no additional requirements
beyond the labeling previously required by the PCB Disposal and Marking
Regulations (EPA, 1978a).
Ban on manufacture: The ban on the manufacture of new PCB
magnets is not expected to have a significant impact on either the
manufacturers or users of these magnets., According to the magnet
manufacturers, the PCB electromagnets could be replaced with oil-filled
units at an average cost of $8,000 per magnet. However, the use of mineral
oil in these applications would significantly increase the fire risks. The
manufacturers regularly furnish silicone-filled magnets for use where more
effective fire resistant characteristics are required than those achievable
with mineral oil. Such silicone-filled units are 40 to 50% more expensive
83
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than comparable oil-filled units; the average cost is $12,000 per magnet.
In addition, Eriez offers a proprietary air-cooled electromagnet which has
Underwriters Laboratory approval for use in dirty and dusty environments.
These units cost an average of $10,000 each.
Servicing: The PCS electromagnets are similar in construction tc
askarel transformers, and it is anticipated that the magnets are subject tc
the same failure mechanisms, expected service life, and service practices
as the transformers. If the average remaining service life of the PCS
electromagnets is ten years, the magnets would be expected to fail at the
rate of twenty units per year. Although rewinding failed magnet coils
would probably cost 60% of the cost of a new magnet, rebuilding is banned
by the regulation. The transportation and labor costs would be expected to
be the same whether a magnet is replaced or rebuilt, so the effect of the
ban on rebuilding is to forego a potential savings of 40% of the purchase
cost of a new magnet each time a PCS magnet fails. Total annual costs
would be expected to be (20 magnets per year x 40% of $12,000 per
magnet = ) $96,000 per year. Total costs attributable to the ban on
rebuilding PCB electromagnets will be $960,000.
Disposal; The PCB Ban Regulations authorize the disposal of
drained PCB electromagnets in chemical waste landfills. The previous PCB
Disposal and Marking Regulations (SPA, 1978a) authorized only incineration.
Since incineration is not available for magnets, a petition for alternating
disposal means would have had to have been submitted to the EPA each time a
magnet required disposal. There is no information in the record on which
to base an estimate of the cost of preparing and processing such petitions,
but this cost has been eliminated by the Ban Regulations.
9.4 PCBs Controlled by the Regulation
The PCB electromagnets presently in use contain about 207,900
pounds of PCBs. The regulations do not affect the continued use of these
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magnets. The effect of the ban on rebuilding these magnets will be to
eliminate the loss of PCBs to the atmosphere that might occur during the
rebuilding process. If these losses were 1 to 10 pounds per magnet, as
estimated in Chapter 4 for askarel transformers, the regulations vould be
expected to reduce the amount of PCBs entering the environment by (200
magnets x 1 to 10 pounds PC3s per .Tiagnet = ) 200 to 2000 pounds of PCBs.
9.5 Summary - Economic Impacts
Ban on rebuilding; $96,000 per year; $960,000 total.
Disposal; Elimination of costs of preparing and processing
petitions for disposal by means other than incineration.
9.6 Cost Per Pound of PCBs Kept from the Environment
Cost per pound - 20o1o°C pounds '
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10.0 HYERAULIC SYSTEMS
10.1 Present Use of PCBs in Hydraulic Systems
Prior to 1972, PCB based hydraulic fluids were marketed by
Monsanto under the trade name Pydraul® for use in hydraulic systems where
'' superior fire resistance was necessary for protection of life and
property.* A previous EPA sponsored study reported that sales of PCB based
hydraulic fluids during the period 1970-1971 totaled over 13.5 million
pounds to 585 different firms (Versar, 1978, p. 65). General Motors
Corporation reported that GM used PCB based fluids in the following types
of systems:**
Metal die-casting equipment
Trim press hydraulics
Plastic injection molding machines
Metal melting furnace tilt hydraulics
Industrial elevators
Iron foundry pouring equipment
Molten iron holding furnace equipment
Induction hardening machine hydraulics
Flame hardening equipment
Heat-treating furnace hydraulic systems
Forge furnace hydraulic systems
Forge press hydraulic systems
High tension welding machines
loading dock levelers
Fork lift trucks
Other small miscellaneous systems.
Uses of PCBs by GM were reported to be: Die-casting - 56%;
Foundry - 35%; other uses - 9%. A review of Monsanto"s customer list for
1970-71 indicated that 80% of the purchasers of hydraulic fluid were
primarily die-casting operations and the other 20% were primarily steel
companies (Versar, 1978, p. 65).
*Hesse, John L. 1975. "Polychlorinated Biphenyl Usage and Sources of Loss
to the Environment in Michigan." National Conference on Polychlorinated
Biphenyls, November 19-21, 1975, Chicago, Illinois.Washington, D. C.:
Office of Toxic Substances, U. S. Environmental Protection Agency (Report
No. EPA-560/67-75-004), p. 129.
**Letter from Mr. W. R. Johnson (General Motors Corporation) to EPA dated
August 7, 1978.
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When Monsanto discontinued the sale of PCB based hydraulic
fluids in 1972, they recommended to their customers (1) that there was no
need to drain the systems and (2) that compatible Monsanto hydraulic fluids
could be used to replace leakage. Most hydraulic systems require the
addition of new or reclaimed fluid at a rate of two to ten times the system
capacity each year to replace leakage losses. It is fairly common practice
to recover leaked fluid and to process it for reuse. Available data on
residual PCB levels in hydraulic systems indicate that the concentration of
PCBs ranges from 60 ppm to as high as 50% in a few machines (Versar 1978,
p. 65). The differences in concentration apparently reflect differences in
the rate of leakage from various machines and differing company maintenance
policies regarding periodic total replacement of hydraulic fluid.
Mr. Owain Powkes of RADCO Corp. reported that the hydraulic
fluid which is commercially reclaimed sometimes contains up to 6000 ppm
PCBs.* Therefore, it is possible that the use of reclaimed hydraulic fluid
has resulted in the PCB contamination of hydraulic systems which never
contained PCB based Pydraul® fluids.
Die-casting machines; The analysis of the proposed PCB Ban
Regulations suggested that PCB based hydraulic fluid may have been used in
as many as 1000 die casting machines. This estimate was based on the
assumptions that 80% of the hydraulic fluid sold during 1970-71 was used in
die-casting machines, that the annual makeup requirement of new fluid to
replace leakage is equal to the liquid capacity of the hydraulic system,
and that the average die-casting machine has a capacity of 500 gallons of
hydraulic fluid (Versar, 1978, pp. 65-66). Mr. Johnson of General Motors
suggested that this estimate may be in error because not all of the
hydraulic fluid purchased by companies classified as primarily die-casting
concerns was used in die-casting machines; GM used only 56% of their PCB
*Telephone conversation with L. Fourt (Versar), September 19, 1977, as
reported in Versar, 1978.
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hydraulic fluid in die-casting machines and the rest in associated
equipment and in their steel foundry operations.* The Outboard Marine
Corporation plant in Waukegan, Illinois, contains 135 die-casting machines,
60 associated trim presses, 30 electric melting furnaces, and several other
furnaces plus numerous other systems, all of vfriich contained PCB based
hydraulic fluid prior to 1971.** The average capacity of the die-casting
machines at Outboard Marine is 350 gallons; GM reported that its
die-casting machines had an average capacity of 460 gallons at one plant
and 1580 gallons at another plant.
Mr. William Sharp of the Society of Die Casting Engineers
stated that die-casting machines are long-lived pieces of equipment with
some 35- to 40-year-old machines still in operation. These machines are in
use by 1500 to 1800 separate companies, and perhaps 35% of the companies
used synthetic hydraulic fluids (not necessarily PCB based). There is a
very active market for used machines.***
Based on the available information and assuming that 80% of
the companies buying fluid had die-casting machines, that 60% of the fluid
purchased by these companies was used in this type of machine, and that the
average annual requirement for makeup fluid was equal to the system
capacity of 400 gallons, the number of die-casting machines that once used
PCB based fluid may have been as high as 700 machines as calculated in
Table 10.1-1. Mo information is available on the number of companies that
own PCB contaminated die casting machines. However, it should be noted
that not all the machines that used PCB based hydraulic fluid can be
identified from the records because many machines have been resold since
1971. If the total number of die-casting machines in use is 10,000 to
15,000 (estimate based on an average annual production of 500 machines and
an assumed average ownership of 6 to 10 machines per company), only 5 to
*Letter from Mr. W. R. Johnson (General Motors Corporation) to EPA dated
Ausgust 7, 1978.
**0ral testimony of Hugh Thomas (Outboard Marine Corporation) at the
hearings on the PCB Ban Regulations, August 25, 1978.
***0ral testimony by William Sharp (Society of Die Casting Engineers) at
the hearings on the PCB Ban Regulations, August 25, 1978.
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Figure 10.1-1
Calculation of Number of Die-Casting Machines that Used
PCS Based Hydraulic Fluids
Total sales of PCB hydraulic fluid,
1970-1971
-f- Number of years
= Annual sales of PCB hydraulic fluid
T- Weight of fluid per gal
= Gallons PCBs per year
x Assumed fraction purchasing companies
owning die-casting machines
= Gallons PCBs purchased by companies
owning die-casting machines
x Assumed: 60% used in die-casting
machines as makeup fluid
= Gallons per year used as makeup fluid
* Assumed: 400 gallons per year per
die-casting machine required as makeup
fluid
= Number of die-casting machines using PCB
based hydraulic fluid
13,500,000 pounds PCBs
6,750,000 pounds per year
11.5 pounds per gal
587,000 gallons per year
x .8
470,000
x .6
282,000
T 400
704
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7% of the machines presently in service ever used PCB based hydraulic
fluid. However, many of the other machines may presently be contaminated
with PCBs because of the practice of reclaiming hydraulic fluid.
Other hydraulic systems: General Motors reported use of PCB
based hydraulic fluids in systems ranging from 50 gallons to 4000 gallons,
with most of the systems being in the 300 gallon range.* Comments
submitted by Armco, Inc., (dated August 3, 1978) summarized the results of
testing 50 heat transfer and hydraulic systems with an average capacity of
422 gallons. This is reasonably consistent with an average hydraulic
system capacity of 350 gallons. It implies that perhaps 1,000 other
hydraulic systems used PCB based fluids in the years 1970-71, assuming
these systems require proportionately as much hydraulic fluid for makeup as
do die-casting machines. These systems were probably owned by all of the
companies having die-casting machines plus perhaps an additional 100 steel
companies.
Total PCBs presently in use; Total capacity of all of the
hydraulic systems that at one time used PCB based hydraulic fluids may be
(700 die-casting machines x 400 gallons per machine + 1000 other systems x
350 gallons per system = ) 630,000 gallons. GM reported that 80% of their
die casting systems have PCB concentrations below 500 ppm*; Outboard Marine
reported that recent spot checks of their machine show PCB levels around
100 ppm, compared to a range of 210 to 1400 ppm in 1976 and 1977**. It is
therefore likely that the average concentration of PCBs in hydraulic fluid
is between 100 ppm and 500 ppm if the single group of die casting machines
known to contain 50% PCB fluid is excluded as a special case. If the
average density of the presently used hydraulic fluid is ten pounds per
gallon, the total amount of PCBs in use in hydraulic systems may be
(630,000 gallons x 10 Ib per gallon x 100 ppm to 500 ppm PCBs = ) 630 to
3150 pounds of PCBs.
*Letter from W. R. Johnson (General Motors Corporation) to EPA dated
August 7, 1978.
**Letter from Hugh Thomas (Outboard Marine Corporation) to EPA dated August
3, 1978.
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10.2 Requirements of the PCB Ban Regulation
Continued use of hydraulic systems contaminated with PCBs in
excess of 50 ppm is authorized until January 1, 1984, subject to the
following requirements:
o Testing; Required for all machines that ever contained a
PCB based hydraulic fluid by July 1, 1979, and at least
annually thereafter as well as three months after each
refilling performed to reduce the concentration of PCBs to
below 50 ppm.
o Marking; Hydraulic systems containing liquids
contaminated with over 50 ppm PCBs must; have the special
PCB label applied.
° Retrofill; Retrofilling or topping off with a hydraulic
fluid containing less than 50 ppm PCBs is required within 6
months after any test which shows that the concentration
of PCBs exceeds 50 ppm.
o Disposal of contaminated fluid; Hydraulic fluid
containing over 50 ppm PCBs must be disposed of by
incineration in special approved PCS incinerators or by
incineration in other facilities such as high
efficiency boilers approved by the EPA Regional
Administrators. This material can also go to Chemical Waste
Landfills or high efficiency boilers if it is between 50 and
500 ppm.
o Storage; Special storage facilities required for the
storage for reuse or processing of hydraulic fluid
contaminated with more than 50 ppm PCBs.
° Disposal of contaminated machine after liquid is drained
for incineration; Essentially not regulated (either salvage
"or disposal as non-hazardous waste allowed) provided the
fluid is first drained from the machine and, if the fluid
contained over 1000 ppm PCBs, the hydraulic system is
flushed with clean solvent.
o Reclaiming of contaminated hydraulic fluid; Hydraulic
fluid contaminated with irore than 50 ppm PCBs may be
reclaimed for reuse in the owner's hydraulic systems only if
it is treated to reduce the concentration of PCBs to below
50 ppm. Reclaiming for purposes of resale is banned unless
this activity is exempted by the EPA.
10.3 Cost Impacts of the PCB Ban Regulation
Testing; Most of the hydraulic systems that once used PCB
based fluids have since been refilled with fluids based on phosphate
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esters. Analysis of phosphate esters for the presence of PCBs requires a
rather time consuming treatment of the sample and extraction of the PCBs
before injecting the prepared sample into a gas chromatograph. In their
written comment dated August 3, 1978, to the EPA on the proposed PCB Ban
Regulations, Armco Inc., stated that their average cost to analyze
hydraulic fluid for PCBs "...is probably closer to $200 than the Versar
estimate of $300, once the GC equipment is set up to specifically analyze
for PCBs. Laboratories which would only occasionally analyze such samples
would probably incur costs exceeding $300 per sample." Only seven of the
50 systems checked by Armco contained PCBs in excess of 1000 ppm.
Identification of all systems that contained PCB hydraulic
fluids will require the analysis of the fluid in many systems which might
have contained PCBs. As many as 2500 die-casting machines (Versar, 1978,
p. 75) and perhaps as many other hydraulic systems might have to be tested
to identify the approximately 1700 systems which used PCB fluid and to
evaluate the extent of contamination from the use of reclaimed fluid. The
cost of the required sampling and analysis program will include sampling
and administrative costs of perhaps $20 per system in addition to the
laboratory costs of perhaps $250. Costs for the analysis program required
by July 1, 1979, might total (1700 to 5000 systems x $270 per sample = )
$460,000 to $1,350,000. Since the average PCB concentration is probably in
the range of 100 to 500 ppm, most of the systems will have to be
retrofilled within six months and tested again within the next year. A
second retrofill and another test might be required. Total testing costs
could easily exceed $1,000,000,.
Since the concentration of PCBs will continually decrease in
the hydraulic systems because of retrofilling, leakage, and replacement of
the fluid, it is expected that the concentration of PCBs in almost all
systems will have decreased to less than 50 ppm by the end of the five
years authorized for continued use of contaminated system, and that the
testing requirements would not apply to the systems after that time.
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Retrofill; Based on the experience reported by GM and Arrr.co,
it is expected that most of the systems that ever used PCB based hydraulic
fluid will be found to be contaminated at levels exceeding 50 ppm. If this
is the case, retrofilling will be required for perhaps 1700 hydraulic
systems having an average capacity of about 400 gallons. Armco stated that
the Versar estimate of $14 per gallon for retrofilling was reasonable;* GM
estimated the material cost alone to be $17 to $19 per gallon;** Outboard
Marine estimated a cost of $8,000 for a 350 gallon system, or an average of
$23 per gallon.*** Total costs of the first retrofilling program would be
(175 systems x 400 gallons per system x $14 to $23 per gallon = )
$9,800,000 to $16,100,000. According to data presented by both Armco and
GM, such a retrofilling program might be expected to reduce the
concentration of PCBs in the liquid by about 90%. Perhaps 10% of these
systems might have PCBs in excess of 50 ppm after being retrofilled, so a
second retrofill, and in a few cases even a third retrofill, would be
required. Total costs for these subsequent retrofills might be $1,000,000
to $1,500,000.
Topping off systems with PCB concentrations only slightly above
50 ppm may result in lowering PCBs levels below 50 ppm without incurring
the costs of draining and refilling the entire system.
Disposalof contaminated fluid; Special high temperature
incineration of liquids contaminated with PCBs in excess of 500 ppm was
required by the PCB Disposal and Marking Regulations. The effect of the
PCB Ban Regulations is to extend this requirement to fluids containing
between 50 and 500 ppn PCBs. The most recent available price for this
incineration is $55 per 55 gallon drum (Rollins, 1978) plus drum costs of
perhaps $15 per drum, transportation of $.02 per pound, and drum disposal
costs of $30, or a total cost of $.22 per pound for contaminated hydraulic
*Armco, Inc. "Main Comments," received by EPA August 3, 1978.
**Letter from W. R. Johnson (General Motors Corporation) to EPA dated
August 7;, 1978.
***Letter from Hugh Thomas (Outboard Marine Corporation) to EPA dated
August 3, 1978.
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fluid. If all of the fluid in the calculated system capacity of 630,000
gallons required special disposal because of this change in the regulation,
increased disposal costs of (630,000 gallons x 10 Ib per gallon x $.22 per
pound = ) $1.4 million would be incurred. If the use of contaminated
reclaimed fluid has resulted in an increased number of systems contaminated
with PCBs in excess of 50 ppm, this disposal cost might increase by a
factor of 2 or 3 or more. The required retrofilling will generate a
quantity of liquid equal to the calculated system capacity, resulting in an
additional disposal cost of $1.4 million.
The regulations authorize the EPA Regional Administrators to
approve alternative incineration facilities for liquids such as
contaminated hydraulic fluids. It is possible that approval for the use of
high efficiency boilers might lower the disposal costs substantially, but
no estimate can be made of the resulting decreases in disposal costs.
Marking; The requirement that the special PCB label be applied
to systems found to contain from 50 to 500 ppm PCBs should not cost more
than $2 per machine. Even if (as an upper bound estimate) 2500 such
contaminated systems were found, total labeling costs would not exceed
$5,000.
All of the liquid that is removed from the hydraulic systems
during the retrofill and decontamination activities will also have to be
placed in labeled containers prior to being shipped for disposal. At a
cost of $2 per 55-gallon drum, labeling costs for disposal could total
(630,000 gallons x 2/55 gallons per drum x $2 per label = ) $46,000.
Special storage areas: Liquids contaminated with 50 to 500 ppm
PCBs will be allowed to be stored in drums in temporary storage areas prior
to disposal if a Spill Prevention, Control and Countermeasure Plan has been
prepared for the temporary storage area in accordance with 40 CFR 112.
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There is no information available in the record that would support an
estimate of the number of additional SPCC plans that would have to be
prepared under this requirement. However, it is assumed that perhaps one
third of the 585 firms that bought PC3 hydraulic fluid during the period
1970-1971 will be found to have contaminated hydraulic systems and that
some of the 200 firms will therefore have to prepare SPCC plans covering
temporary storage areas for PCB contaminated liquid.
Disposal of contaminated machines; It is not anticipated that
any of the machines will be scrapped before they are decontaminated to a
level below 50 ppm PCBs. Therefore, there should be no additional disposal
costs due to the PCB Ban Regulations.
Recycling of contaminated hydraulic fluid; New phosphate ester
based hydraulic fluid costs about $7.60 per gallon (Versar 1978, p. 68).
According to the comments of GM, the following treatment techniques have
been found to be incapable of reducing the concentration of PCBs to below
50 ppm: PAC carbon filter, Florsil filter column, and clay. Open air
distillation of contaminated phosphate ester fluid resulted in excess
oxidation of the fluid. Outboard Marine has described a vacuum distilla-
tion procedure which reduces the PCB content of the hydraulic fluid by 50%
at a cost of $3.75 to $4.00 per gallon*. Mr. Rober Damiani of RADCO
Industries in his oral comments at the August 25, 1978 hearings, described
in general terms a fractional distillation process that is "effective in
removing PCB. In fact, a number of runs were made in which PCB concentra-
tion was reduced to below 50 ppm." Mr. Damiani stated that RADCO has not
developed a process that will reliably reduce the level of PCBs to below 50
ppm and that their present process achieves a reduction to 100 ppm. He
stated that the result of a 50 ppm requirement will be to "decrease process
yield, and subsequent economics — 10 to 20 percent below that expected
with a 100 ppm specification."
If it is assumed that the total amount of contaminated fluid is
available for recycling once per year and that there is presently 725,000
*Oral testimony by Hugh Thomas (Outboard Marine Corp.) at the August 25,
1978 hearings on the proposed PCB Ban Regulation.
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gallons of such fluid in service, the successful development of a reclaim-
ing process might reduce costs for new fluid by $2.80 per gallon (based on
reclamation costs 20% higher than mentioned by Outboard .Marine Corp.) or b
a total of $350,000 to $1,700,000 per year. It is not known whether the
requirement that recycled fluid contain less than 50 ppm PCBs will
significantly affect the availabilty of such a reclamation service; the
total impact of the regulation therefore cannot be estimated.
10.4 PCBs Controlled by the Regulation
In section 10.1, it was estimated that hydraulic systems
contaminated with more than 50 ppm PCBs may contain from 630 to 3150 pounds
of PCBs. If the use of these systems were not regulated, all of this
material would be expected to leak out of the systems and eventually enter
the environment. The requirement that the contaminated systems be
retrofilled by the end of 1979 will reduce total losses to leaks prior to
the retrofilling. Since hydraulic systems often require make-up fluid
equal to their volume each year, the losses of PCBs prior to the
retrofilling may equal 25% of the PCBs present in the systems. The effect
of the regulation, therefore, is to prevent the loss to the environment of
.75 x (630 to 3150 Ibs = ) 470 to 2390 pounds of PCB.
10.5 Summary - Economic Impacts
Testing:
1979 $460,000 to 1,350,000
198G-1984 $1,000,000 total
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Retrofill: $10,800,000 to $17,600,000*
Disposal of fluid: $1,400,000*, **
'larking: $46,000
Special storage
areas of SPCC plans: Insufficient data available to estimate
Ban on recycling
contaminated hydrau-
lic fluid: Insufficient data available to estimate.
Maximum possible impact = $350,000 to
$1,700,000 per year for one or two years.
10.6 Cost Per Pound of PCBs Kept from the Environment
Cost per pound = ($460,000 to $1,350,000 + $1 million +
$10.8 to $17.6 million + $1.4 million +
$700,000 to $3.4 million)/470 to 2390 pounds =
$6,000 to $53,000 per pound PCBs
*May be significantly higher if the use of reclaimed hydraulic fluids has
contaminated hydraulic systems that never used PCB based fluids.
**May be somewhat reduced if EPA approves alternative incinerators for
hydraulic fluids.
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11.0 HEAT TRANSFER SYSTEMS
11.1 Present Use of PCBs in Heat Transfer Systems
In his letter to the EPA dated August 4, 1978, Mr. W.R. Corey
Monsanto estimated that there were 450 heat transfer systems using PCB
based fluid in 1972 when Monsanto discontinued sales of PCBs for those
systems. A review of a Monsanto customer list, however, indicated that
sales of PCB heat transfer fluids were made to 533 different companies
during the years 1970 and 1971 (Versar, 1978, p. 76). Mr. Corey estimati
that one half of the heat transfer systems had capacities between 50 and
500 gallons and that the other half had capacities averaging 2000 gallon;
This implies that the average system capacity was 1300 gallons, or about
15,000 pounds of PCB. The total Monsanto sales of heat transfer liquid
during 1970 and 1971 was 8.2 million pounds, or enough liquid to fill afcx
550 average systems. Total use of PCB heat transfer liquid in the Unitec
States since 1929 has been estimated at 21 million pounds, including botl
new installations and makeup fluid (Versar, 1978, p. 75).
Mr. Corey of Monsanto estimated that over 90% of the heat
transfer systems using PCBs were converted to alternative non-PCB fluids
1970-72 and that current system PCB levels in the industry range from
around 100 ppm to three percent. Mr. Jack Pulley of Dow Corning, in his
reply comment dated October 9, 1978, stated that Dow Corning replaced PC
fluids in their heat transfer systems about five years ago and that thes
systems still contain PCBs in concentrations from 1/2% to about 2% in th
new non-PCB heat transfer fluid. Data is also available for one other h
transfer system that contained 14,000 gallons of PCB based fluid.
Draining and flushing prior to replacement of the liquid reportedly redu
the concentration of PCBs to two percent (Versar 1978, p. 76). Monsanto
and Dow Corning agreed that it is technically infeasible to reduce the
concentration of PCBs in contaminated systems to below 50 ppm.
11.2 Requirements of the PCB Ban Regulation
All heat transfer systems that ever used PCB based fluids wil
be considered PCB articles because their surfaces are presently in conta
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with a liquid containing over 50 ppn PCBs. These systems will be allowed
to remain in service until July 1, 1984, subject to the following
conditions:
• Use; After October 1, 1979, no heat transfer system
containing a liquid with a PCS concentration above 50 ppn
may be used in the manufacture or processing of any food,
drug, or cosmetic.
• Testing; Required by July 1, 1979, for all heat transfer
systems that ever contained a PCB based heat transfer fluid.
Systems must be retested within three months after each time
the fluid is replaced to reduce the concentration of PCBs to
below 50 ppm. Records of all tests must be kept for five
years after the concentration of PCBs is reduced to 50 ppm.
• Retrofill; Within six months following any test that
indicates the presence of more than 50 ppm PCBs in heat
transfer fluid, the fluid must be drained and replaced with
fluid that contains less than 50 ppm PCBs. Topping off that
results in reduction of PCB concentration to less than 50
ppm is also allowed.
• Marking; Required for all systems found to have PCB concen-
trations in the fluid in excess of 50 ppm.
• Disposal of liquid containing over 50 ppm PCBs;
Por liquids with greater than 500 ppm PCSs, incineration is
required in an approved PCB incinerator. Liquids between 50
and 500 ppm PCBs can go to approved high efficiency boilers
or chemical waste landfills.
• Storage; Special storage facilities required for the
storage of PCB contaminated heat transfer fluid.
• Disposal of contaminated machine after liquid is drained;
High temperature incineration required in an approved PCB
incinerator or disposal of machine in an approved chemical
waste landfill.
11.3 Cost Impacts of the PCB Ban Regulation
Testing; The liquids used to replace the PCB based heat
transfer liquids may be analyzed for PCBs by a method similar to that used
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to analyze for PCBs in transformer oil. The cost of such an analysis
should be about the same as the price of $60 per sample previously quoted
by Versar for the transformer oil analysis (Versar 1973, p. 41). Samplin
and order handling costs might increase this cost to $100 per sample, or
total of $45,000 to $60,000 for the analysis required by July 1, 1979, on
the 450 to 600 contaminated systems presently in use. Additional testing
required within three months of each system retrofill is included below a
part of the retrofill costs.
Retrofill: The regulations require that the concentration of
PCBs in heat transfer systems be reduced to less than 50 ppm by July 1,
1984. Most of the systems now contain about two percent PCBs. Monsanto
stated that draining most heat transfer systems will remove at least 90% (
tiie fluid, and that new replacement heat transfer liquid will cost about '
per gallon.* Disposal of contaminated fluid containing over 500 ppm PCBs
in an approved PCB incinerator would cost from $1.20 per gallon (in tank
truck lots) to $2.10 per gallon (in 55 gallon drums) (Rollins, 1978).
Transportation would add about $.02 per pound or $.16 per gallon to this
cost (Versar, 1978). Since one-half of the systems have capacities of ov
2000 gallons, 80% of the liquid may be in these large systems which would
generate truckload lots of fluid when drained. The average disposal cost
would therefore be $1.54 per gallon, including transportation.
Incineration costs for liquids contaminated with less than 500 ppm PCBs
were quoted at about one-half the rate for the more contaminated liquids
(Rollins, 1978). This would be equal to a cost of $.81 per gallon,
including $.02 per pound transportation. If each system were drained eve
six months of 90% of the fluid and then refilled with new fluid that did
not contain PCBs, any PCBs that were adsorbed on the vessel walls or
absorbed into porous gasket material would have a chance to diffuse into
the liquid between retrofills. Each draining would therefore remove 90%
the PCBs from the system, progressively reducing the concentration from t
present 20,000 ppm (2%) to 2,000 ppm, then to 200 ppm, and finally to 20
*Letter from W. R. Corey (Monsanto) to EPA dated August 4, 1978.
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pan after the third retrofill. If the average system capacity is 1,300
gallons, the 450 to 600 contaminated systems presently contain (1300 x 450
to 600 gallons = ) 585,000 to 780,000 gallons. The cost to reduce the
concentration of PCBs from the present 2% to below 50 ppm will be $15
million to $20 million as calculated in Table 11.3-1.
Since each system must be analyzed within three months after
each retrofilling, a total of (450 to 600 x 3 = ) 1350 to 1800 additional
analyses will be required at a cost of $100 each, for a total additional
analytical cost of $135,000 to $180,000.
Marking: The marking of heat transfer systems containing
liquids contaminated at levels above 500 ppn PCBs is required by the
Disposal and Marking Regulations (EPA, 1978a). Since no systems are
expected to be contaminated at levels between 50 ppn to 500 ppm, the change
in the definition of PCB mixture from 500 ppm to 50 ppm in the Ban
Regulation is not expected to change the number of heat transfer systems
requiring the application of a special label.
The drums and trucks used to transport the contaminated liquid
to the incinerator for disposal will also require special labeling. Since
this is already required for liquids containing over 500 ppm PCBs, the
effect of the Ban Regulation will be to add this requirement to the
disposal of the liquid from the third retrofill. If four labels are
required per machine @ $2, total additional labeling costs will be (450 to
600 machines x 4 labels x $2 per label installed = ) $3600 to $4800.
Storage for Disposal; Since the required disposal areas will
have to be installed at each location that uses contaminated heat transfer
systems to meet the requirements of the Disposal and Marking Regulations,
no additional cost will result from the PCB Ban Regulations.
Disposal of Heat Transfer Systems; There is no information in
the record that will support any estimate of the number of heat transfer
systems that will be scrapped before they are decontaminated to PCB levels
below 50 ppm.
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Table 11.3-1
Cost of Retrofilling Heat Transfer Systems
to Meet 50 ppm Limit on PCS Concentration
Number of contaminated systems
x Average System Capacity
= Tbtal quantity of fluid
x Weight per gallon
x Concentration of PCBs
= Pounds of PCBs in fluid
First Retrofill
Total quantity of liquid
x Drainage efficiency
= Gallons to be disposed of and replaced
PCS Content @ 2%
Cost of replacement fluid @$8.00/gal
+ Cost of disposal @ $1.54/gal
+ Labor @ 16 hours/system @ $15/hour
= Total cost of first retrofill
Second Retrofill
PCB content § 2000 ppm
Total cost of second retrofill
450-600
1,300 gallons
585,000 to 780,000 gallons
8 Ibs per gallon
2% PCBs
93,600 to 124,800 Ibs PCBs
585,000 to 780,000 gallons
.9
526,500 to 702,000 gallons
84,200 to 112,300 Ibs PCBs
?4,212,000 to $5,616,000
$810,800 to $1,081,000
$108,000 to $144,000
$5,130,000 to $6,840,000
8,420 Ibs to 11,230 Ibs PCBs
$5,130,000 to $6,840,000
102
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Table 11.3-1 (Continued)
Ihird Retrofill
PCB content 9 200 ppn 842 Ib to 1,123 Ibs PCBs
Cost of replacement and labor $4,320,000 to $5,760,000
+ Cost of disposal a $.81/gal $426,000 to $569,000
- Ibta! cost of third retrofill $4,746,000 to $6,329,000
Tbtal cost to reach 50 ppm $15,000,000 to $20,000,000
Total Ibs PCBs removed 93,500 Ib to 124,700 Ibs PCBs
103
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However, since disposal of machines containing fluid with mor
than 500 ppm PCBs was required by the Disposal and Marking Regulations, ti
Ban Regulations only affect the disposal of those machines contaminated a
levels between 50 ppm and 500 ppm.
The previously established requirement that all heat transfer
systems contaminated at levels above 500 ppm be disposed of in approved
chemical waste landfills would have resulted in significant costs.
As a very rough estimate, the volume of each system using heat
transfer fluid might be ten times the volume of the fluid which it
contains. The total volume of material requiring disposal in approved
landfills might then be (450 to 600 systems x 1300 gallons/system x 10
gallons system volume/liquid volume 7.43 gallons/cubic foot = ) 800,000 to
1,000,000 cubic feet at a cost of $3 per cubic foot (Versar 1977, pp.
2-13). Because of the uncertainty in this estimate, actual disposal cost
might be considerably higher than this figure. All of these costs would
have been incurred, under the requirements of the Disposal and Marking
Regulations which defined PCS mixtures as those containing over 500 ppm
PCBs. The effect of the required decontamination will be to decrease the
eventual disposal costs by $2.4 million to $3 million.
11.4 PCBs Controlled by the Regulation
Monsanto claimed that leakage from heat transfer systems was
infrequent and would seldom exceed 5% of the capacity of the system in any
single incident. If retrofilling contaminated heat transfer systems were
not required, as much as 10% of the PCBs presently in the systems would be
spilled or leaked because of pump seal leaks and accidents. The remaining
amounts of PCBs would be incinerated as required by the Disposal and
Marking Regulations. If spill cleanup were 80% effective, the effect of
the regulation would be to reduce the amount of PCBs entering the
environment to 2% of the 93,600 to 124,800 pounds presently in the
machines, or by 1872 to 2496 pounds.
104
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11.5 Summary _- Economic Impacts
Testing:
Initial $45,000 to $60,000
Following retrofilling $135,000 to $180,000
Retrofill: $15,000,000 to $20,000,000
Disposal:
Cost savings because
systems are decontam-
inated $2,400,000 to $3,000,000
•total $12,780,000 to $17,240,000
11.6 Cost per Pound of PC3s Kept from the Environment
«•" ** *»* ' i&F^ * ^^ - «™ £T°7
(average = $6870/lb)
105
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12.0 COMPRESSORS
Prior to 1972, Monsanto marketed a PC3 based lubricant under the
trade name Turbinol® 153 for use in turbine type compressors. This liquid
was apparently used in a number of natural gas pipeline compressors (Versar
1978, p. 78). Although the liquid was flushed out and replaced with
non-PCB fluid in the early 1970s, residual levels of PC3s have been found
in at least a few of the machines.*
12.1 Requirements of the PCS Ban Regulation
Compressors containing a liquid contaminated with more than 50
ppm PCEs may be used until May 1, 1980, provided a PCS label is applied to
each contaminated machine. These compressors may not be used after January
1, 1980, unless they have been decontaminated to a level below 50 ppm PCBs.
12.2 Impacts of the PCS Ban Regulation
Versar previously estimated that there were perhaps ten
compressors that would be affected by the proposed PCB Ban Regulations and
stated that Columbia Gas and Texas Eastern had been contacted for
additional information on the number of contaminated compressors and the
cost and feasibility of decontamination (Versar 1978, p. 78).
In his letter to the EPA of August 4, 1978, Mr. Willard Young of
Texas .Eastern Transmission Corporation stated that Texas Eastern would be
able to reduce the level of PCBs in their compressors to below 50 ppm by
the end of 1978 "by another cycle of draining, flushing, and installing new
lubricants." He did not include any information on the cost of this
procedure or the number of compressors requiring decontamination.
In his letter to the EPA of August 4, 1978, Mr. Robert Welch,
Jr., of Columbia Gas System Service Corporation stated that forced shutdown
of compressors on January 1, 1979, could have a significant effect on the
*Letter from Willard T. Young (Texas Eastern Transmission Corporation) to
EPA dated August 4, 1978.
106
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delivery of natural gas, "depending on the number of units affected." Mr.
Welch also stated that the economic impact analysis of the proposed
regulations (Versar, 1978) was deficient because the cost of service
disruption was not estimated. However, Mr. Welch did not furnish any data
on die number of contaminated compressors operated by the industry or by
Columbia Gas, nor did he include any information on the difficulty, cost,
and time required to decontaninate such compressors. Therefore, it is
still not possible to estimate the total economic costs of the regulatory
requirements which ban the continued use of contaminated compressors.
Since Texas Eastern apparently will be able to meet these requirements,
total direct cost of the decontamination program should not exceed the
$200,000 previously estimated (Versar 1978, p. 79). The requirement that
the decontamination program be completed by the end of 1979 gives the
industry time to complete the program during the slack summer season, so
there should not be any costs caused by service disruptions.
12.3 PCBs Controlled by the Regulation
There is no information in the record that will support any
estimate of the amount of PCBs presently in use in compressors. Therefore,
no estimate can be made of the amount that will be controlled by the
regulation.
12.4 Summary — Economic Impacts
Decontamination costs — $200,000
107
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13.0 RECLAIMED OIL*
13.1 Present Status of PCBs in Reclaimed Oil
Approximately 1.3 billion gallons per year of used oil is
collected for use as road oil, fuel oil, re-refined hydraulic oil, and
re-refined lubricating oil. Much of the waste oil previously used in
applications other than automotive lubrication has been contaminated with
low levels of PCBs, and dissipative uses of this contaminated oil can
introduce PCBs directly into the environment.
A total of 2,376 million gallons of new oil were sold during
1975, the major commercial uses being automotive lubrication (50.8
percent); industrial and aviation lubrication (30.5 percent); and other
industrial uses primarily in materials processing (17.4 percent). The
amount available for collection and recycle was estimated to be 1,154
million gallons, or 48.6 percent of total sales. Data on U.S. use of new
(virgin) refined oil and availability of used oil for recycling are
presented for the year 1975 in Table 13.1-1.
Data generated by Recon Systems** for a 12-month period during
1970-71 indicate that, out of a total U.S. production of 2,480 million
gallons per year, approximately 901 million gallons, or about 36.3 percent
were actually collected for recycling or use as fuel. An additional 601
million gallons were estimated to be used on roads (application for dust
*This chapter is adapted from Chapter 13 of Versar, 1978. The SPA
promulgated the rules affecting the use of reclaimed oil with
essentially no changes from the proposed regulations.
**Vfeinstein, Norman J., (Recon Systems, Inc.), Waste Oil Recycling and
Disposal, SPA-670/2-74-052, Princeton, N.J.: August, 1974"(as cited in
Versar, 1978).
108
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Table 13.1-1
Type of Oil
Automotive Lube Oil
Industrial & Aviation
Lube Oils
Other Industrial Oils
Lube Oils Purchased
by U. S. Government
Outlet or Use
Service Stations
Commercial Engine
Fleets
New Car Dealers
Auto Fleet and Other
Lube Oil Uses
Retail Sales for
Commercial Eng:
Garages, Auto Supply
Stores
Discount Stores
Factory Fills G
Farm Equipment)
Subtotals
Hydraulic & (
lating Sysi
Metal Working Oils
Aviation & Other
Gas Engine Oils
Railroad Engine Oils
Subtotals
Electrical Oils
Process Oils
Refrigeration Oils
Subtotals
GRAND TOTALS
Oil Availability for Recycling :
is
jne
Other
i
>r
gines
lupply
Auto &
t)
Is
cu-
i Oils
ils
r
Oils
Is
ils
Is
LS
U. S. Sales
1975
(gal x I0"b)
239
225
103
151
95
90
250
54
1,207
314
145
147
60
58
724
62
340
11
413
32
2,376
Fraction
Available* *
for Recycle
.63
.50
.90
.50
.63
.63
.22
.90
.42
.70
.50
.90
.53
.90
.10
.50
.50
Used Oil
Available
for Recycling
150
112
93
75
60
57
55
49
132
101
73
54
31
391
56
34
6
96
16
1,154
*Weinstein, 1974 (as cited in Versar 1978, D. 81).
**Fraction available for recycling after losses in use and to enviromtent.
109
-------
control and possibly in asphalt) or as fuel oil; this used oil could
conceivably have been collected for recycle so that the maximum amount of
oil available for collection, based on the Recon Systems' estimates for
1970-71, may be as much as 60 percent of that produced.
A flow chart showing the distribution and utilization of waste
oil in the United States, based on the 1970-71 data of Pecon Systems, is
presented on Figure 13.1-1. Summary data for disposition and usage from
Figure 13.1-1 are as follows:*
Fate of Oil After Percentage of New
Primary Use Oil Production
Used as fuel 41.5
Dissipated to environment
and waste disposal
Applied to roads
Se-refined lube oil oroducts
The general distribution shown in Figure 13.1-1 is believed to
be valid at present, although the nragnitudes of the specific flows have
fluctuated as prices of virgin lube oil and fuel oil have varied. The
value of fuel oil has increased since 1970-71, and virgin lube oil was
scarce during the period of the Arab boycott and during a portion of the
period of price controls. One result of these factors has been increased
use of waste oil as fuel, either by the industrial concern generating the
waste oil or by processors.
The primary sources of waste oil available to collectors are
service stations and other automotive-related facilities. Industrial and
*Versar 1978, p. 83.
110
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%
m
*
-
§2
I
2|
o a
5
h.
•• «
i
00
CO
s i
II !
al*
"
t-i
(0
2
-H
U
*
111
-------
aviation facilities are also significant sources. A significantly larger
fraction of available oil is collected in urban areas than in suburban or
rural areas. According to studies in the Pittsburgh area, spills and oth
wastes from product pipelines are a locally significant source of waste o
for collection.
The use pattern of processed or re-refined waste oil is
extremely diffuse. Users include states and municipalities (road
application), industrial and commercial facilities (fuel, re-refined lube
oils, road oil), utilities (fuel), and the consuming public (re-refined
motor oil).
A small portion of the collection and processing of used
hydraulic oils does not follow the general pattern of scattered sources,
many reclaimers, and numerous users indicated for the waste lube oils.
Reclamation of used hydraulic oil, performed primarily by four companies,
results in a product which is marketed as hydraulic oil.
13.2 Requirements of the Proposed Regulations
Hie disposal of oil contaminated with PCEs in excess of 500 pp
was regulated by the PCB Marking and Disposal Regulations (EPA 1978a). Th
PCB Ban Regulations'- change the definition of PCB used in the Marking and
Disposal Regulations to include all mixtures containing more than 50 ppm
PCBs. Under the provisions of the ban regulations, oil contaminated with
PCBs in excess of 50 ppm must be identified, segregated for purposes of
disposal, and disposed of in accordance with one of the approved methods.
Oil containing measurable amounts of PCBs less than 50 ppm may be processe
for any use including fuel or reclaimed lubricating or hydraulic oil, but
it may not be used as road oil or as a constituent of any sealant, coating
or dust control agent.
112
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13.3 Sources and Amounts of Contaminated Waste Oil
Hydraulic Fluids; Oil is used as a low viscosity fluid in
hydraulic systems, and PCB based hydraulic fluids were widely used prior to
1972. The most expensive (and polluting) use was in die-casting machinery.
PCB based hydraulic fluids were also used in construction machinery, farm
machinery (a source of feed contamination),* and in deep mining equipment
where the use of PCBs resulted in greater fire safety.
Although hydraulic systems are nominally air-tight, leaks may
occur at dynamic seals, and major spills may occur due to hose rupture.
Normal leakage is collected in drip pans. Ihe rupture of a hose can spray
hydraulic fluid over a large area due to high operating pressures. It has
been estimated that 80% of phosphate ester hydraulic fluid losses occur
from leaks in the hydraulic system.** In certain industries, operators
state that it is more efficient to continually add hydraulic fluids to the
system rather than shut the system down, repair any leaks, and refill the
system. Leakage from these systems is often collected and reclaimed.
Monsanto manufactured almost all the PCB-based hydraulic
fluids. When Monsanto discontinued manufacturing PCB-based hydraulic
fluids in 1971, they did not recommend draining or flushing of hydraulic i
systems. They did recommend that replacement fluids be added to the
remaining PCB fluids in the system. As a result, hydraulic systems which
used PCBs in 1972 and prior years now contain replacement fluids
contaminated with 0.006 to 50% PCBs as discussed in Chapter 10. The total
amount of contamination is a function of the system leakage and dilution
during the past five years.
*U.S. Department of Agriculture Ad Hoc Group on PCBs. Agriculture's
Responsibility Concerning Polychlorinated Biphenyls (PCSs) Washington,
D.C. Office of Science and Education, U.S. Department of Agricultrue,
1972 (as cited in Versar 1978, p. 84).
**Lapp, T.W. (Midwest Resarch Institute), The Manufacture and Use of
Selected Aryl and Alkyl Aryl Phosphate Esters, EPA 560/6-76-OOS, Feb.
1976, p. 77 (as cited in Versar 1978, p. 84).
113
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A portion of tne available used industrial hydraulic oil is
refined and'sold for reuse as hydraulic oil. This specialized reclaiming
service is furnished by the following four companies which reclaim a total
of about 150,000 gallons of hydraulic fluid per year (Versar 1978, p. 35).
E. F. Houghton and Co., Philadelphia, Pennsylvania
Radco Corporation, LaFox, Illinois
Findett, Inc., St. Charles, Missouri
Wallover Corp., East Liverpool, Ohio
Automobile and Industrial Lubricating Oil; The amount of used
oil collected for reuse in 1970-71 was about 900 million gallons per year,
with an additional 600 million gallons used internally for fuel or dust
control on roads (Vfeinstein, 1974). Thus, about 60 percent of the amount
of new oil sold was reused. Major uses of this oil were as fuel (1028
million gallons), road oil (319 million gallons), and feedstock for
re-refined lubricating oil (138 million gallons) (Versar 1978, p. 85).
The extent of PCB contamination of this oil was studied on a
limited basis by the EPA National Enforcement Investigation Center (NEIC)
in Denver.* Samples of oil were taken from selected tank truck lots of
used oil that had been collected in Virginia, Maryland, and North Carolina.
This oil had been delivered to Continental Forest Industries in Hopewell,
Virginia, for use as supplemental fuel in a steam boiler of a paper mill.
The oil had t>een collected primarily from automobile service stations,
although it is possible that some industrial oil, including hydraulic oil,
had been included in some of the lots. PCBs were found in the samples of
*Testimony of Robert Magruder, (Continental Forest Industries) presented at
the U.S. EPA informal hearings on the PCB ban regulations at Washington,
D.C., July 15, 1977.
114
-------
oil at concentrations ranging from 3.2 pgn to 19.4 ppm. Although these oil
samples were collected from a restricted area, the extent of PCS
contamination is probably representative of waste oil collected throughout
the United States.
The PCS contamination of the waste oil could come from
contaminated industrial hydraulic oil or transformer oil or from PCB
additives used in lubricating oils prior to 1973. In applications such as
railroad car journal box oils, PCBs may have been used as lubricant
additives.* PCBs may also have been added to automobile transmission
fluids to control the swelling of oil seals.
It would not be expected that PCBs would be destroyed during
re-refining of waste oils. PCBs were reported to be present in
concentrations of several parts per million in reclaimed oil used to
lubricate whetstones.**
13.4 Compliance Costs
Collection of any waste oil likely to be contaminated with PCBs
for a controlled use would not be attractive financially unless the oil
were known to contain PCBs at levels below the control amount. Analytical
costs for determining low levels of PCBs will be considerably higher than
the costs quoted for transformer oil because naturally occurring sulfur and
chlorine compounds in petroleum oils cause interferences in the use of
electron capture gas chromatography at concentrations of 5 pan PCBs or
below.*** These interferences result in false positive indications of the
*Monsanto Chemical Company, Aroclors for , St. Louis, Mo.: undated (as
cited in Versar 1978).
**Weems, George, (United States Department of Interior, Denver, Colorado),
"Polychlorinated Biphenyls," File HLS 3-3-1Oh, June 13, 1977 (as cited
in Versar 1978).
***Hofstader, R. A. (Exxon Research and Engineering Co.); Lisk, D. J.,
Bache, C. A. (Cornell University), "Interference in the Electron-Capture
Technique for Determination of Polychlorinated Biphenyls by
Sulfur-Containing Compounds in Petroleum Products", Bulletin of
Environmental Contamination and Toxicology, Vol. 11, No. 2, 1974 (as
cited in Versar 1978).
115
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presence of PCEs. The PCB components can only be resolved through complex
clean-up procedures or the use of gas chromatography/inass spectrometry,
techniques that would cost up to several hundred dollars per sample.
Road Oiling; The most recent data indicates that road oiling
consumes 319 million gallons of waste oil per year (Figure 13.1-1). At an
application rate of 1/2 gallon per square yard, this is sufficient to oil
45,000 miles of roadway 24 feet wide (Versar, 1978, p. 87). The proposed
ban regulations would forbid the use of oil containing detectable amounts
of PCBs for dust control. Fluids from transformers are likely to have
detectable amounts and other industrial sources are at least somewhat
suspect. Currently these industrial oils are collected along with used
motor oil. Although virgin motor oil has no PCBs, used motor oil may have
PCBs fron previous recycling which included industrial oil sources among
the feedstocks or from old transmission oils which contained PCBs as an
additive. Nevertheless, used motor oil unmixed with industrial sources is
unlikely to contain as much as 10 pptn PCBs and may have PCB concentrations
that are undetectable without unusually elaborate and expensive analysis.
None of the reported analyses of waste oil for PCBs was based on used motor
oil without any possibility of industrial contamination. Presumably waste
oil solely from automotive sources would contain fewer PCBs. It is
doubtful that road oiling could stand the costs of even "simple" tests at
$70 per sample. Prospective road oilers therefore would be safer using
waste oil if they take precautions to ensure that it does not contain
industrial oils (and certainly no electrical oils).
Compliance with the requirements of the proposed regulations
could be achieved by either of the following strategies:
(1) Avoid all waste oil, and substitute virgin oil at
considerable monetary and energy cost where the customer is willing to pay
the increased price. At an average price of $.375 per gallon for #2 fuel
116
-------
oil vs S.08 per gallon collection costs for used crank case oil, the cost
of road oiling would increase (.375 - .08) x 139 million gallons = $94
million per year (Versar 1978, p. 37).
(2) Use synthetic road stabilization chemicals which both
reduce dust and provide surface stabilization. The increased cost of this
type of material is presently offset by lower road maintenance costs on
heavily traveled dirt roads at mines and other industrial facilities.
Savings in maintenance on lightly traveled roads would be less significant
and would only partially offset the increased material costs. A typical
synthetic material is Coherex®, manufactured by Witco Chemical Corporation.
This material is an organic resin in a water emulsion which is sold in
large quantities for $.40/gallon plus transportation, and is applied after
a 5 to 1 water dilution at a rate of one gallon per square yard.*
Increased costs incurred by the use of this material are summarized in
Table 13.4-1.
The use of synthetic road oiling materials such as Coherex® may
be more or less expensive than the use of used motor oil depending on the
local supply and price of the used oil. The present choice between the use
of used oil and synthetic materials apparently depends on local supply and
cost conditions. The total cost resulting from an effective ban on the use
of waste oil would certainly be no greater than S31.7 million per year, as
calculated in Table 13.4-1, and might even result in an overall cost
savings as claimed by Witco Chemical.
*Letter fron Victor Shepard (Witco Chemical Corp.) to EPA dated September
23, 1978.
117
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Table 13.4-1
Cost of Substituting COHESEX® for Used
Motor Oil in Road Oiling for Dust Control
Coherex*: Bulk Purchase Price
Transportation <§.02/lb.
(Versar 1977)
TOTAL
Material Cost for Coherex®: 1/6 gal./yd2
Minus: Used Oil: 1/2 gal./yd.2 @.QS to .30/gal.*
Equals: Increased Cost (Savings) per sq. yd.
x 14080 yd2 per mile of road, 24 ft. wide =
x 45,000 miles »
S.40/gal.
.17/gal.
5.57/gal.
.09
.04 to .15
$.05 (.06)
$704 (845)
$31,680,000/year
($38,025,000/year)
*Price range reported by Victor Shepard (Witco Chemical Corp.) for supplies
of used oil. Letter to EPA dated September 23, 1978.
118
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Users Other than Road Oilers; About 27 million gallons per
year of transformer oil will not be available to collectors. However, oil
diverted from road oiling may more than offset this loss of supply. Other
industrial oils may or may not be contaminated with PCBs; to be absolutely
safe, the recycling industry would avoid them. Individual industrial firms
can probably continue to use their own waste oil as fuel oil if they make
initial and occasional later spot check laboratory analyses to make sure
their oils continue to contain less than 50 ppm PCBs.
The impact on re-refiners (who make re-refined lube oil) and
external processors (who process waste oil for use as fuel oil) will depend
on what happens to road oiling. .\ strict enforcement policy with
occasional all-out efforts to find PC3s in waste oil could prevent its use
as road oil. Diversion of waste oil from this use would create a large
increase in supply for processors and re-refiners. Probably most of this
would originally go to fuel oil use since the capacity of re-refiners is
limited and the consumer acceptance of used motor oil is limited. Later, a
majority of the increase might go to re-refiners if the Frost and Sullivan
market projections of 23 percent growth per year until 1985 proves to be
even roughly accurate.* This would provide an extra use as lube oil while
retaining most of the heat value for later use.
Collectors; If collectors avoid transformer and industrial
oils, their total business will decrease. However, hauling contaminated
oils to chemical waste incinerators or high efficiency boilers will be
required and could offer new market opportunities to the collectors.
Processors: Waste oil for fuel use should become more
plentiful as use for road oiling is discouraged or made impossible by the
regulation. The effect of a larger supply of waste oil on the price to
processors theoretically would be to lower the price. Waste oil can be
*Maugh, T. W., "Re-refined Oil: An Option That Saves Oil, Minimizes
Pollution," Science, p. 1108-1110, September 17, 1976 (as cited in Versar
1978, p. 89).
119
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used as a supplemental fuel with coal. This use recovers the fuel value of
the oil and would destroy any PCBs that might be present in the oil. Since
PCB contaminated oils may be incinerated in large boilers, and since the
use of waste oil with coal in boilers is relatively troublefree, this use
^ is probably very elastic. If coal burning plants can absorb the increased
supply, which seems likely/ the price decrease should be negligible.
Hydraulic Oil Re-refiners; Information collected through
telephone interviews indicates that at least three of the companies which
re-refine hydraulic fluid receive hydraulic fluids which are contaminated
with PCBs. These fluids are sometimes contaminated to the extent of 6000
ppm (Chapter 10). In most cases, the reclaiming process removes no more
"""9- than 10% of these PCBs.* It is also reported that the concentration of
PCBs in some of the hydraulic fluid applications encountered by these
companies remains at approximately 2000 ppm despite repeated flushings and
drainings. The present status of PCB reduction technology is discussed in
Chapter 10.
Industrial Waste Oil Generators; Those industries whose waste
oil contains more than 50 ppm PCBs will have to incur disposal costs of up
to $.75 per gallon (see Chapter 6). Even industrial oil contaminated with
less than 50 ppm PCBs may be avoided by waste oil collectors. This may not
be a major problem for companies that have large high efficiency boilers.
Oil burning boilers can use a mixture of waste and virgin oil. Mr.
Magruder of Continental Forest Industries indicated that up to 14 percent
waste oil mixed with #6 residual oil is feasible.** The result may be the
development of a separate market for industrial oil with low levels of PCBs
for use as fuel. long term economic impacts should not be significant.
13.5 PCBs Controlled by the Regulation
Ihe provision of the regulation that prohibits the use of oil
containing any measurable amounts of PCBs as a coating or dust control
*Telephone conversion, Dwain Fowkes (RADCO Corp.) with L. Fourt (Versar),
September 19, 1977 (as cited in Versar 1978, p. 90).
**Testimony on Robert Magruder (Continental Forest Industries). Presented
at the U.S.E.P.A. informal hearings on the PCB Ban Regulations at
Washington, D. C., July 15, 1977.
120
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agent will affect only those waste oils that contain less than 50 ppm PCBs,
since the disposal of the oiore highly contaminated oils is controlled by
other provisions of the regulation. The only available data indicate that
waste oils are presently contaminated with PCBs to levels of 3.2 to 19.4
ppm (section 13.3). Mo information is available as to the sources of the
oils for which this data was obtained, and diversion of transformer oil and
contaminated industrial oils to high efficiency boilers might significantly
reduce the concentration of PCBs in the remaining waste oil. However, if
it is assumed that all of the oil affected by this provision of the
regulation is contaminated at levels of 11 ppn (average of 3 ppm and 19
ppm), then the PCB content of the used oil that is available for recycling
will be (11 ppm x 8 pounds per gallon x (651 million gallons automotive oil
+ 54 million gallons gas engine oils + 31 million gallons railroad engine
oils + 16 million gallons U. S. government lube oils*) = ) 66,176 pounds.
Approximately 12.9% of new lubricating and industrial oil
production has been applied to roads, 41.5% used as fuel, and 3.3%
re-refined as lube oil. Diversion of the 12.9% that has been used on roads
will control (.129 x 66,176 pounds PCBs = ) 8537 pounds of PCBs. If this
oil is used as fuel and re-refined as lube oil products in the same ratio
as above, (41.5/(41.5+3.3) = ) 93% will be used as fuel and 7% will be
re-refined. About one half of the re-refined oil will be lost to the
environment and the other half will be used as fuel, so the effect of the
regulation will be to divert about 96.5% of the 3537 pounds per year of
PCBs used on roads to fuel use. Since many of the boilers using this oil
may not meet the criteria established for high efficiency boilers, perhaps
2% of the PCBs in the waste oil will not be destroyed. Therefore, the
total amount of PCBs that will be destroyed in the boilers rather than
applied to roads will be (8537 pounds PCB per year x .965 diverted to fuel
use x .98 destruction efficiency = ) 8073 pounds PCBs per year. The actual
amount diverted to the environment may be lower if the controls on the
disposal of transformer oils and contaminated industrial oils decreases the
amount of PCBs in the remaining waste oil.
*Table 13.1-1.
121
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13.6 Sunrnary - Economic Impacts
Compliance Costs
Jtoad Oil - increased costs of
virgin or synthetic material
(first several years) $0 to 31.7 million/year
Road Oil - increased cost of
obtaining adequate supplies of
segregated used motor oil after
level of FCBs in used motor oil
drops below detectable limits. $0 to $6.4 million/year
13.7 Cost Per Pound of PQBs Kept from the Environment
Cost per pound »
0 to $31.7 million per year ...
8073 pounds/year
0 to $3925 per pound PCBs
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14.0 PCBS AS UNINTENTIONAL PRODUCT CONTAMINANTS
14.1 Current Production
There are a number of commercial chemical processes which
produce PC3s as an unintentional byproduct in concentrations over 50 ppm.
These include the production of two classes of pigments, a new aluminum
smelting process, and several other proprietary chemical processes.
Phthalocyanine pigments; Phthalocyanine blue and green
pigments are produced in two steps.* The first step is the production of
crude pigment using, in most cases, trichlorobenzene as a solvent.* In
this instance, a side reaction involving the trichlorobenzene is the source
of the PCBs. The crude is then further processed to produce a number of
different blue and green pigments. In 1976, production and imports of
Phthalocyanine blue and green pigments were 13,200,000 Ibs* with a value of
roughly $87.6 million. Testing indicates that the majority of this type of
pigment is contaminated with over 50 ppm PCBs, though there is considerable
doubt concerning the validity of the test method which was used.**
Currently, the only major domestic crude manufacturer which
does not use trichlorobenzene as a solvent is DuPont.*** They reportedly
use kerosene and have developed pigments based on the properties of the
crude they produce. In addition, Phthalchem uses a mixed solvent system
which has trichlorobenzene as one of the components. Testing indicates
that this crude may be contaminated below 50 ppm; again, however, the
analytical method has not been validated.
*"Main Comments of Dry Color Manufacturers Association ...." dated August
7, 1978, p. 16.
**Testimony of the Dry Color Manufacturers Association at the PCB
Manufacturing, Processing, Distribution in Commerce, and Use Bans
Hearings, Washington, D.C. August 30, 1978.
***0ral testimony of Arthur Hopmeier, (Phthalchem Inc.), at the PCB
Manufacturing, Processing, Distribution in Commerce, and Use Bans
Hearings, Washington, D.C., August 30, 1978.
123
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Imports of blue crude, primarily from Japan, supplied over 56%
of the U.S. market in 1976.* In addition, low-PCB crudes are currently
available in commercial quantities from at least one Japanese supplier.
This is a recent development, and any increase in demand for this product
:SMi could not be met for roughly a year.** Also, Mr. MacDonald Smith of Sun
Chemical testified that this low PCB crude was of inferior quality.***
Diarylide pigments; Diarylide yellow, orange, and red pigment:
are made by reaction of precursors which include dichlorobenzidine as an
essential component. A minor side reaction results in the decomposition c
the dichlorobenzidine to produce 3,3'- dichlorobiphenyl.****
.*«*< Sales of diarylide pigments in 1976 were about 9,760,000 pounds
with a value of $41 million.**** There are currently no substitutes for
the diarylide pigments, which are used in printing ink, textile ink,
plastics, and paints. In 1969, diarylide yellow (the diarylide with by f
the highest production) accounted for 84% of all yellow pigments produced
in the United States.****
Aluminum smelting; Alcoa has developed a new smelting process
which inadvertently produces over 50 ppm of decachlorobiphenyl.***** The
PCSs are produced in a preliminary step involving the production of
aluminum chloride through the reaction of alumina with chlorine in the
presence of coke. The PCBs and other contaminants are removed in the
second step, which is the electrolysis of the aluminum chloride to produce
metallic aluminum.
*0ral testimony of Arthur Hopmeier, (Phthalchem Inc.) at the PCB
Manufacturing, Processing, Distribution in Commerce and Use Bans
Hearings, Washington, D.C., August 30, 1978
**Letter to EPA from W. C. Parle, (Harmon Colors) July 11, 1978.
***Oral comments of Hugh MacDonald Smith (Sun Chemical Corporation) at
the PCB Manufacturing, Processing, Distribution in Commerce and Use
Bans Hearings, Washington, D.C., August 30, 1978, p.107.
****"Main Comments of Dry Color Manufacturers Association ..." dated
August 7, 1978, Table 3.
*****Information on this aluminum smelting process and the resulting PCBs
was taken from the letter from James 3. Boyt (Alcoa) to EPA dated
October 10, 1978.
124
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This process has several advantages over conventional aluminum
smelting. These benefits include elimination of fluoride emissions,
reduced energy consumption, and improved product purity. The energy
savings possible with this process are considerable. Conventional smelting
requires 8 KWH per pound of aluminum produced. This new process requires
4.5 KWH per pound, a savings of nearly 44%. Using these figures, a 300,000
ton per year smelter could save up to 1.95 million KWH per year.*
In addition, the production of the aluminum chloride in the above
process has a number of energy and process advantages compared to
conventional aluminum chloride production methods.
Other chemical processes; Phillips Petroleum and Dow Corning,
both have chemical processes that produce over 50 pan PC3s. The Phillips
process is still experimental and apparently involves the use of PCBs as a
chemical intermediate.** Dow Corning states that during the production of
a chemical intermediate, PCBs, apparently largely monochlorinated biphenyl,
are produced at levels between 50 and 500 ppm.*** Tennessee Eastman also
had a chemical process that produced over 50 ppm PCBs.**** However,
Tennessee Eastman subsequently advised EPA that it had modified its process
and "because of these modifications, the only time a concentration of PCB
in excess of 50 ppm occurs is after processing to concentrate and dispose
of the PCBs, as specifically contemplated at 43FR24805 ******
Polychlorinated terphenyls (PCTs) formerly produced by Monsanto
are known to have been contaminated with over 50 ppm of PCBs. The only
uses of PCTs discussed at the hearings were a number of applications in
microscopy. This use has been authorized. Similar applications involve the
use of certain Aroclors. These uses have also been authorized.
*Letter to EPA from James S. Boyt (ALCOA) dated October 10, 1978.
**Letter to EPA from Phillips Petroleum Co. dated August 4, 1978.
***Letter to EPA from Jack Pulley (Dow Corning Corporation) dated October
10, 1978.
****Letter from J. C. Edwards (Tennessee Eastman Companv) to EPA dated
August 7, 1978.
*****Letter from Elliott Stern (Tennessee Eastman Company) to EPA dated
December 21, 1978. (Letter in record of TSCA Exemption Docket No.
1)
125
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14.2 Requirements of the PCS Ban Regulations
It is assumed here that none of the operations described above
qualify as being "in a totally enclosed manner." Therefore, the
manufacture, processing, distribution in commerce, and use of any chemical
containing over 50 ppm PCBs (including phthalocyanin and diarylide pigment;
and the products of the Alcoa smelting process) are banned 30 days after
the date of promulgation of the PCB Ban Regulation except in those cases
specifically exempted by EPA.
14.3 Economic Impact
Pigment Manufacturers: The impact the ban regulations will hav<
on those manufacturers who produce products contaminated with low levels ol
PCBs will depend on the actions taken by the EPA in response to petitions
for exemption from the regulation. For the purposes of this analysis, an
upper bound economic impact will be estimated assuming that no exemptions
are granted before enforcement of the regulations begins. A lower bound
economic impact will be estimated assuming that all exemptions are granted
by the EPA. This second assumption also presumes that, where necessary,
exemptions for processing and distribution in commerce will be granted.
The Interim Procedural Rules for Polychlorinated Biphenyls (PCB's) Ban
Exemption (EPA, 1978d)*, state that only petitions from those affected by
the manufacturing ban will be considered. Therefore, separate petitions
will be required for processing, distribution in commerce, and use
exemptions.
*EPA. 1978d. "Part 750 - Procedures for Rulemaking Under Section 6 of th
Toxic Substances Control Act: Interim Procedural Rules for
Polychlorinated Biphenyls (PCB's) Ban Exemption." Federal Register,
November 1, 1978, pp. 50905-50907.
126
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The processes in use by Dow Corning, Alcoa, and Phillips
Petroleum must cease 30 days after the rule is promulgated unless EPA has
granted or is considering a petition for exemptions (EPA 1978d). The small
amount of economic data available are insufficient to support an estimate
of the impact this will have.
Upper Bound Estimate; There are three companies that manu-
facture crude phthalocyanine blue using trichlorobenzene as a solvent; they
are American Cyanamid, Chemtron, and Phthalchem.* Phthalchem uses a mixed
solvent system which has trichlorobenzene as one of the components; the
others use pure trichlorobenzene. Dupont uses kerosene; Hercules Powder
and Thomasett use a dry process. The crude produced by each of these
companies may contain over 50 ppm PCBs although Phthalchem pigment has
consistently shown less than 50 ppm PCBs.** In the absence of a valid
analytical method for determining PCB levels in this material, however,
this study will assume that all three companies must modify their processes
to comply with the regulations. Kerosene appears to be the most feasible
solvent to replace trichlorobenzene. Mr. Arthur Hopmeier of Phthalchem
testified that it would require 12 months and cost roughly $250,000 for him
to modify his plant.** Mr. Paul Malchick testified that the two Chemtron
plants could be converted to the use of kerosene solvent for a total cost
of $1,500,000 but that considering the age and condition of Chemtron's
*Letter from Arthur Hopmeier (Phthalchem Inc.) to EPA - August 4, 1978.
**Testimony of Arthur Hopmeier (Phthalchem Inc.) at the PCB Manufacturing,
Processing, Distribution in Commerce, and Use Bans Hearings,
Washington, D.C., August 30, 1978.
127
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equipment, it would be economically sounder for them to spend S5,QOO,OOC
construct a new plant.* They would also attempt to purchase low-PCB cru
from Japan in order to ;neet their needs during the 24-30 months necessar
to construct this plant.* Purchase of the required 3 million pounds of
<••** crude per year would cost roughly $4.5 million. ^ data were given by
American Cyanamid. Based on (1) a Chemtron estimate of $750,000 to conv<
each of their aged plants and (2) Mr. Hopmeier's estimate that Phthalche
plant would require less to convert than other plants,** the cost for
American Cyanamid is estimated at $500,000. The total cost for plant
conversion is:
$250,000 + $1,500,000 + $500,000 = $2,250,000
In addition, Harmon Colors produces either a special crude or
further processes purchased crude in trichlorobenzene to produce a
phythalocyanine pigment which contains 575 ppm of PCBs. This pigment is
used by the automotive industry and its manufacture has been authorized
the State of Michigan. It would cost Harmon Colors roughly $2 million to
construct a new plant capable of producing this pigment in an alternative
solvent.***
Four companies presented information which indicates that they
may be producing diarylide pigment with PCB levels in excess of 50 ppm.
They are: (1) Chemtron, (2) Pope, (3) Ridgeway Color and Chemical, and (4
Sun Chemical. It appears that the diarylide pigments could be produced
with less than 50 pan PCBs if some process modifications were made. The
are some estimates on the cost of adjusting the manufacturing process to
reduce the concentration of PCBs. Mr. Paul Maichick of Chemtron estimate
that it would cost $50,000 to modify their manufacturing and, because the
process modifications will put them out of compliance with their NPDES
*Testimony of Paul Malchick (Chemtron) at the PCB Manufacturing,
Processing, Distribution in Commerce, and Use Bans Hearings,
Washington, D.C., August 30, 1978.
**Testimony of Arthur Hopmeier (Phthalchem Inc.) at the PCB Manufacturing
Processing, Distribution in Commerce, and Use Bans Hearings,
Washington, D.C., August 30, 1978.
***Letter to EPA from W. C. Parle (Harmon Colors) dated July 11, 1978.
128
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permit, an additional $250,000 will be required.* Two other companies
estimate their cost for complying with a 50 ppn limit as follows:**
Company Initial Capital Cost Increased Annual Operating Expense
1 $750,000 $250,000
2 $200,000 $375,000-500,000
Three of the four companies listed would have an average
conversion cost of $333,000. If this average is used as the cost for the
fourth company, the total conversion cost could be $1.33 million.
Increased operating costs may amount to $345,000 per company.** Although
some types of diarylide pigments already contain less than 50 ppm PCBs, one
to two years will be required to reduce the level of PCBs to below 50 ppm
in all of these pigments.**
The manufacturing cost estimates for both types of pigments
include only those costs directly attributable to plant conversion and to
increases in operating costs. If the manufacturers are forced to cease
production of all pigments that contain over 50 ppm PCBs, there will be
additional costs associated with lost production and future loss of
customers who convert to substitutes or foreign suppliers. There may also
be costs associated with the disposal of contaminated pigments presently in
inventory. There is not enough data in the official record to support an
estimate of these costs, but the data which are present deserve attention
and seen to indicate that these additional costs could substantially exceed
the conversion costs.
*Testimony of Paul Maichick (Chemtron) at the PCS Manufacturing,
Processing, Distribution in Commerce, and Use Bans Hearings, Washington,
D.C., August 30, 1978, p. 126.
**Letter to EPA from Donald Morgan, (Dry Color Manufacturers Association)
dated August 7, 1978.
129
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In 1976, production and imports of phthalocyanine blue totaled
13,200,000 pounds* with a value, after processing into pigments, of roughly
$87.6 million. Imports of blue crude (not pigment), primarily from Japan
(85%), supplied over 56% of the U.S. market in 1976.** The majority of the
imports are high-PCB crude. low-PCB crude is being produced in Japan, but
an increase in demand could not be met for a year.***
Sales of diarylide pigments in 1976 were 9,760,000 pounds with a
value of $41 million. In addition, roughly 275,000 pounds were
imported.****
Sales for phthalocyanine and diarylide pigments in 1976 totaled
$131 million. Total sales of all organic pigments in 1976 were $261
million, compared with $200 million for inorganic pigments.**** Thus, the
two classes of pigments in question account for over 25% of the domestic
market.
The percentage of the industry that would be forced to cease
production in response to a manufacturing ban is not known, but it is
estimated to be closer to 50% than to 10%.***** This implies that up to
one quarter of the domestic organic pigment producing industry would have
to close down. In addition, a company that can no longer produce yellow
and/or blue pigments may lose other portions of its sales because
"customers demand a full line of colors."**** The minimum conversion time
given at the hearings was 12 months, so in the event an exemption is not
granted, domestic manufacturers would be affected for at least 6 months an
would not be back to full capacity for 18 months. The potential for sub-
stitution of different pigments types and the ease with which production o
low- or non-PCB pigment could be expanded are not known, but it does appea
*Letter to EPA from Arthur Hopmeier (Phthalchem) August 4, 1978.
**Testimony of Arthur Hopmeier at the PCS Manufacturing, Processing,
Distribution, and Use Bans Hearings, August 30, 1978.
***Letter to EPA from W. C. Parle (Harmon Colors) July 11, 1978.
****"Main Comments of Dry Color Manufacturers..." dated August 7, 1973.
*****Testimony of Donald "torgan (DCMA) at the PCS Manufacturing,
Processing, Distribution in Commerce, and Use Bans Hearings, August
30, 1978.
130
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that imports could not ironediately fill any shortages. However, the
available information indicates that extensive iak, dye, and paint
reformulation will be required, equipment may require modification or
replacement, and printing quality will suffer.
There could be additional costs once domestic manufacturers
begin producing low- or non-PCB pigments. In those cases where process
Ttodification rather than solvent substitution is used, it may be necessary
to test each batch of pigment for PC3s as it is produced. Chemtron states
that they have made process modifications that reduce the PCB concentration
to low apparent levels but that there .-nay be occasional batches with higher
concentrations due to mechanical failure or operator error.* In addition
to the testing, production of a batch with over 50 ppm would be illegal
production which could be subject to a possible fine. The lowering of the
permissible limit from 500 tp 50 ppm PCBs would result in the disposal of
additional batches of pigment.
Lower bound estimate; The lower bound estimate assumes that the
following eight "pigment" companies will individually apply for (and will
receive) exemptions:
American Cyanamid
Apollo Colors
Chemtron
Harmon Colors
Phthalchem
Pope
Ridgeway Color and Chemical
Sun Chemical
*Letter from Paul Mai chick (Chemtron) to EPA dated August 3, 1978.
131
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It is also assumed that each company will apply for two
exemptions: one for manufacturing and one for processing and distribution
in commerce.
Preparation of the required petition and attendance at the
hearing may require one man-week per company. Considering that, due to the
importance of the issue and the legal aspects involved, much of this work
is usually handled by lawyers and higher level company officials, a labor
rate of $200/day will be assumed. In addition, total travel expenses of
$600 for two people per company will be assumed. The total expense for the
eight companies listed using the above figures is $19,200.
If EPA grants the manufacturers an exemption from the
"manufacturing," "processing," and "distribution in commerce" bans, the
pigment that is manufactured could only be used to formulate inks, etc., if
the purchasers were in turn exempted from the "processing" and "distribu-
tion in commerce" bans. Further, since the inks will contain PCBs at
levels below 50 ppm because of dilution of material containing more than 50
ppm PCBs, all material containing the pigments will have to be labeled as
"PCBs," and the users will require exemptions from the "use" ban.
There is no information in the record that suggests whether EPA.
will consider class action petitions for exemptions, or that would suggest
how EPA may handle the labeling problem. Therefore, no estimate can be
made of the resulting economic impacts of these provisions of the
regulations.
Other chemicals: No information exists in the record to support
any estimate of the impact of the ban regulation on companies such as Alcoa
and Dow Corning that are inadvertently manufacturing PCBs in chemicals
other than dry pigments. These chemical processes will be subject to the
same ban provisions or, alternatively, the need to obtain exemptions from
the manufacturing, processing, distribution in commerce, and use ban
regulations as described above for dry pigments.
-------
14.4 PCBs Controlled by the Regulation
Pigments: Data reported by Sun Chemical Corp. suggests that the
average PCB concentration in diarylide pigments is 95 ppm and in
phthalocyanine pigments is 170 ppm.*
Tbtal annual sales of the phthalocyanine pigments are 13.2
million pounds of which 56% is imported (most from Japan).** The rest is
made in the U. S. by six manufacturers, three of which use trichlorobenzene
and presumably have problems with PCB contamination. If the six
manufacturers have equal market shares, the total PCBs in the production of
the three that use trichlorobenzene would be (13.2 million pounds pigment
per year x .44 U.S. market share x .5 share from companies with PCBs in
product x 170 ppm PCBs = ) 544 pounds PCBs per year.
Tbtal annual sales of dairylide pigments are 9,760,000 pounds,
all of which is contaminated with 3,3' - dichlorobiphenyl at an average
concentration of 95 ppm. Reduction of this concentration to 50 ppm by
required process changes would reduce the amount of PC3s entering the
environment by (9,760,000 pounds pigment x (95 ppn - 50 ppm) = ) 441 pounds
per year.
Other chemicals; No information is available to support any
estimate of the total production of PCBs in other chemical processes.
14.5 Summary - Economic Impacts
Upper Bound;
Increased Annual Additional
Conversion Cost Operating Costs Costs
Phthalocyanine pigments $4,250,000 No data No data
Diarylide pigments 1,330,000 345,000 No data
Aluminum smelting
Chemical manufacturing No data No data No data
*Appendix E to "Main Comments of Dry Color Manufacturers Association...."
dated August 7, 1978.
**Letter from Arthur Hocmeier (Phthalchem Inc.) to SPA dated August 4,
1978.
133
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Lower Bound;
Exemption applications $ 25,600
Aluminum smelting
Chemical manufacturinq No data No data No data
14.6 Cost Per Pound of PCBs Kept from the Environment
Phthalocyanine pigments
$425 000/*vear
544 pounds/year = $781
Diarylide pigments
$133,000* + $345,OOP/year
441 pounds/year
$108
poun
*Ten dollars as initial expense is equivalent to continuing annual cc
one dollar discounted at 10%.
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15.0 SPILL MATERIALS: 50 ppm TO 499 ppra PCSs
The change in the definition of "PCB" from 500 ppm to 50 ppm will
require that materials such as dirt that are contaminated with PCBs in this
concentration range will have to be picked up and buried in an approved PCB
landfill. There is no information in the record that can be used to
estimate the total additional volume of material that will be transported
to these landfills as the result of this change in the regulation.
Disposal of PCB contaminated material in approved landfills has been
reported to cost $3 per cubic foot (Versar 1977, p. 3-7) and transportation
to these facilities will cost an additional $2 per cubic foot (Versar 1977,
p. 3-19). If the spill material covered by this regulation is assumed to
be contaminated with 275 ppm PCBs, the cost of disposal will be ($5 per
cubic foot/(100 pounds per cubic foot of dirt x 275 ppm PCBs) = ) $182 per
pound of PCB. This figure could be lower in some cases if EPA approves
alternative disposal methods in response to specific petitions for
exemption from this portion of the disposal regulation.
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16.0 CAPACITOR MANUFACTURING
16.1 Present Use of PCBs
PCBs were used as the dielectric liquid in almost all
paper/foil and film/foil A.C. electric capacitors manufactured prior to
1976. The primary types and uses of PCB capacitors are listed in Table
16.1-1.
Substitutes for PCBs have been developed by the capacitor
manufacturers in anticipation of the ban on the manufacture and processing
of PCBs. Mo PCB power factor capacitors were manufactured after late 1977,
and there are no PCB capacitors of this type known to remain in
manufacturers' inventories (Versar 1978, p. 99). A survey of manufacturers
of industrial capacitors indicated that five companies (representing a 54%
share of the market in 1976) were planning in mid 1977 to continue using
PCBs into 1978 but to discontinue manufacturing PCB capacitors during 1978
(Versar, 1978, p. 103). Two of the manufacturers have provided additional
data on their use of PCBs during 1978 and on expected inventories of PCB
capacitors. Aerovox (24% market share) planned to stop using PCBs on
September 9, 1978, and expected an inventory on October 1 of less than
100,000 PCB capacitors.* Universal Manufacturing Co. (13% market share)
has estimated that its inventory of capacitors at the end of 1978 will be
approximately 800,000 items which cost about one million dollars to
manufacture. In addition, Universal will have an inventory at the end of
1978 of at least 500,000 completed ballasts which cost about $2,500,000 to
make.**
*Letter fron Clifford Tuttle (Aerovox Industries, Inc.) to EPA dated
August 15, 1978.
**0ral comments of N. Ray Clark (Universal Manufacturing Corporation) at
the August 29, 1978 hearing on the proposed PCB Ban Regulation.
136
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Table 16.1-1
Major Types and Uses of PC3 Capacitors
Power Factor Correction
Industrial Capacitors
Motor Control
Ballast
Electronic
Estimate
1976 Sales*
$54.5 million
$94.5 million
Use*
Used by electrical
utilities in high voltage
power distribution
systems.
Used as part of large
single phase A.C. motors
(air conditioners, etc.).
Used as a component of
ballasts for fluorescent
lights and high intensity
di scharge (i.e., mercury
arc and sodium arc)
fixtures.
As part of the circuitry in
some TV sets, microwave
ovens, computers, etc.
*Source: Versar, 1978, pp 97-98.
137
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16.2 Requirements of the PCB Ban Regulation
Manufacturing; The regulation bans the manufacture of PCB
capacitors.
Distribution in Commerce: PCB capacitors and new equipment
containing PCB capacitors may not be sold (i.e., distributed :
commerce) after July 1, 1979.
16.3 Cost Impacts of the PCB Ban Regulation
Manufacturing ban: The economic impact analysis of the
proposed PCB regulation estimated that non-PCB power factor capacitors
would cost 10% to 20% more than PCB capacitors having the same performance
characteristics and that the cost of industrial capacitors v*ould increase
15% to 20% because of the change from PCBs to other dielectric fluids,
(Versar, 1978). The only additional information that has since become
available is the testimony of Ray Clark who suggested that "perhaps in the
overall, simply based on the difference of dielectric constant (of the
non-PCB dielectric fluid) the non-PCB industrial capacitors should cost
more on the order of five to seven percent."* Based on 1976 industry sale
(Table 16.1-1), annual cost increases due to the banning of the manufactui
of PCB capacitors would be expected to be (10% to 20% of $54.5 million =
$5.5 million to $11 million for power factor correction capacitors and (7?
to 20% of $94.5 million = ) $6.6 million to $13.9 million for industrial
capacitors. These estimates should be increased by perhaps 15% to
compensate for inflation during 1977 and 1978. Since the use of small
capacitors is expected to grow rapidly over the next few years because of
federally mandated improvements in the electrical efficiency of appliances
the total demand for capacitors and the total increased costs resulting
from the ban on the use of PCBs may be greater than these estimates based
on historical sales data.
*Oral comments of N. Ray Clark (Universal Manufacturing Corporation) at ti
August 29, 1978 hearings.
138
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Ban on Distribution in Conroerce; The demand for PCS capacitors
remaining in manufactures's inventories at the end of 1978 is likely to be
extremely limited because the regulation bans the sale of these capacitors
or new equipment containing PCS capacitors after June 30, 1979. The
inventory losses incurred by the companies that use small capacitors in the
manufacture of appliances and equipment is discussed in detail in
Chapter 3.
The maximum inventory losses incurred by the manufacturers of
PCS capacitors would occur if all capacitors remaining in inventory at the
end of 1978 were scrapped. If all of the manufacturers who used PCBs in
1978 had the same expected inventory losses as that percentage of annual
sales anticipated by Universal, total inventory losses would be (.54 market
share for all affected capacitor manufacturers/.13 Universal market share)
x $1,000,000 Universal inventory loss = ) $4.15 million. However, the
actual loss will probably be much less than this because Universal was the
last company to phase out the use of PCBs and because some opportunities
may exist during the first six months of 1979 to dispose of this inventory.
Therefore a reasonable estimate of inventory losses may be in the range of
$1 to $2 million, all occuring during 1979.
16-4 PCBs Controlled by the Regulation
Total consumption of PCBs by the capacitor manufacturing
industry was 21 million pounds in 1975 of which 45% was used in large high
voltage power factor capacitors and 55% in industrial, lighting, and
appliance capacitors (Versar 1976a, p. 6).
Most large high voltage power factor capacitors do not rupture
upon failure, and only 20% to 25% of the PCBs escape to the environment
from those that do rupture. If it is assumed that 10% of the capacitors
rupture on failure, the total amount of PCBs entering the environment from
each year's production of large high voltage power factor capacitors would
be equal to (21 million pounds per year PCBs x 45% in power factor
capacitors x 1% rupture on failure x 15% PCBs lost on rupture = ) 14,200
pounds PCB per year.
139
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Only 0.4% of the small capacitors are assumed to rupture in us
(Chapter 3). If 15% of the PCBs leak out of these ruptured capacitors, th
total amount of PCBs entering the environment from each year's production
of small capacitors would be equal to (21 million pounds PCBs x 55% in
small capacitors x 0.4% ruptured in use x 15% leak out = ) 6930 pounds per
year. The rest of the PCBs would be disposed of in municipal landfills.
There is no information in the record to support an estimate of how
' i
much may leach out of the landfill, but it is expected to be low due to
the absorptive capacity of the surrounding material.
16.5 Summary - Economic Impacts
Increased cost of non-PCB power factor capacitors: $5.5
million to $1.1 million per year.
Increased cost of non-PCE industrial capacitors: $6.6 million
to $18.9 million per year.
Inventory losses incurred by manufacturers of PCB industrial
capacitors: $1 million to $2 million (1979 only).
16.6 Cost Per Pound of PCBs Kept from the Environment
Power factor capacitors
$5.5 million to $11 million per year
14,200 Ib/year = ?387 to $775 per
pound PCBs
Industrial capacitors
6 million to $18.9 million per year
6930 pounds per year = $950 to $2750 per pound
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17.0 BAN ON THE MANUFACTURE OF NEW PCB TRANSFORMERS*
Liquid filled transformers containing a PCB based liquid known
generically as "askarel" have been used for many years in those installa-
tions where the risk of fire justified the use of a fire resistant fluid.
Askarel transformers have been allowed in hazardous locations such as in-
side buildings without the requirement for a fireproof vault or fire
sprinklers. No substitute transformer liquids have yet been developed
which have fire resistant properties equal to the PCB based askarel.
17.1 Requirements of the Regulations
The regulations prohibit the manufacture of new PCB transformers
after December 31, 1978, but classify continued use of existing PCB trans-
formers, except those used in railroad locomotives, as use in a totally
enclosed manner. The regulations authorize certain minor maintenance of
existing transformers but prohibit major rebuilding of failed units. The
impacts of the regulation on the servicing and rebuilding of askarel trans-
formers is discussed in detail in Chapter 4. Disposal requirements for
failed askarel transformers are specified by the PCB Marking and Disposal
Regulations, and these requirements are not being changed by the PCB Ban
Regulations.
17.2 Industry Structure, Production, and Sales
Monsanto's customer list for PCBs in the early 1970s included
thirteen companies that used PCBs to manufacture askarel transformers.
These companies and the location of their transformer manufacturing plants
*This chapter is repeated with minor changes frcm Versar, 1978. The EPA
promulgated without change the proposed regulations that affect the
manufacture of new PCB transformers.
141
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are listed in Table 17.2-1. Production of askarel transformers averaged
500C units per year in the early 1970s (Versar 1978, p.109). tohen these
companies were contacted by Versar in September, 1977, only one manufac-
turer was still producing askarel transformers, and it planned to stop
production of this type of unit before the end of 1977 (Versar 1978,
p.109). All of these manufacturers produced both oil-filled and askarel
transformers in the same plants. Oil-filled transformers are interchange
able with askarel transformers in new applications provided the installa-
tion is properly engineered. Other substitutes for askarel transformers
are also available. Ihe 140,000 askarel transformers presently in servic
are only two percent of the total number of power and distribution
transformers in use (Versar 1978, p.111).
17.3 Substitutes for PCB jTransformers
The askarel transformers presently in service were specified
because this type of liquid-filled transformer offered advantages in size
reliability, and fire safety that were not available witn other types of
transformers. Alternatives to PCB transformers have always been availabL
although all of the other types of transformers have different design
characteristics and none are direct substitutes for the PCS units. There-
fore, eventual replacement of the existing PCB transformers will require
that each of the present installations be re-evaluated and that the
necessary engineering changes be made to allow use of the best available
replacement unit. New transformer installations will be designed to make
optium use of the available non-PCBs transformers. The choice among the
available alternative transformer types and materials depends on the re-
quirements of each specific applicaiton and the characteristics of the
available non-PCB units.
142
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Table 17.2-1
U.S. Transformer Manufacturers That Used PCBs After 1970
Company Name
Westinghouse Electric Corp.
General Electric Company
Research-Cottrel1
Niagara Transformer Co.
Standard Transformer Co.
Helena Corp.
Hevi-Duty Electric
Kuhlman Electric Co.
Electro Engineering works
Envirotech Buell
R.E. Uptegraff Mfg., Co.
H.K. Porter
Van Tran Electric Co.
Plant Location
South Boston, Va.
Sharon, Pa.
Rome, Ga.
Pittsfield, Mass.
Finderne, N.J.
Buffalo, N.Y.
Warren, Ohio
Medford, Oregon
Helena, Alabama
Goldsboro, N.C.
Crystal Springs, Mass.
San Leandro, Calif.
Lebanon, Pa.
Scottsdale, Pa.
Belmont, Calif.
Lynohburg, Va.
Vandalia, 111.
Waco, Texas
Source: Versar, 1976a.
-------
A number of alternatives to the use of PCBs in fire resistant
liquid-filled transformers and to the use of transformers that contain any
dielectric liquid have been developed and are commercially available.
These substitutes for PCB transformers differ in their performance charac-
teristi.cs, applicable fire code installation requirements, and cost. The
following sections discuss the major types of substitute units that are
available.
Non-PCB askarel transformers; Askarels are defined in the
National Electrical Code as non-flammable chlorinated hydrocarbon liquids.
Although all askarel liquids used in the past have been based on PCBs,
there is no requirement that PCBs be present. General Electric is pres-
ently testing a non-PCB askarel that is a combination of trichlorobenzene,
tetrachlorobenzene, and a hydrocarbon (either isopropyl biphenyl or ter-
phenyl). GE plans to market this material in 1979 under the trade name
Iralec*, if present transformer service tests are successful, and estimates
that the price will be about one-half that of silicone.*
If Iralec* does prove to be a direct substitute for PCB based
askarel, there may be no additional costs incurred by the banning of the
use of PCBs in new transformers.
High fire point liquid insulated transformers; The 1975
National Electric Code (NEC) and previous issues allowed only the use of
askarel and dry type transformers in hazardous locations without vault
protection. Askarel was essentially defined as a PCB based liquid. The
1978 NEC has added a specification (Article 450-23) for "high fire point
liquid insulated transformers" which can be used under these same condi-
tions (Versar 1978, p.111). The high fire point liquid must have a fire
point of at least 300°C, and must not propagate flames.
*Information presented by GE at a meeting with EPA Office of Toxic
Substances, June 21, 1978.
144
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Underwriters Laboratory presently lists three liquids as
meeting the high fire point property requirements for transformers op-
erating at voltages below 600v (Versar 1978, p.112):
Dow Corning 561
General Electric SF-97 (50)
SWS Silicones Corp. F-190
Factory Mutual Research has not yet conpleted developing formal
approval requirements and procedures for high fire point transformer
liquids. However, based on preliminary tests. Factory Mutual has'issued
interim guidelines to its field offices which allow six silicone liquids
and three hydrocarbon liquids at Factory Mutual insured locations without
special fire protection. The list of Factory Mutual accepted liquids
includes the following (Versar 1978, p.112):
Supplier
Designation
Type of Fluid
Dow Corning
Dow Corning
General Electric
Union Carbide
SWS Silicones
SWS Silicones
RTE Corporation
Gulf Oil Chemicals Co.
Uniroyal
DC 561
DC 200
SF-97
L-305
F-101
F-190
RTEmp
RF Dielectric
Fluid
PAO-20E
Silicone
Silicone
Silicone
Silicone
Silicone
Silicone
Hydrocarbon
Hydrocarbon
Hydrocarbon
145
-------
Mineral oil-filled transformers; If fire safety were not a
consideration, there would be no reason why oil-filled transformers could
not be used in all applications. In the past, PCB-filled transformers have
cost about 1.3 times as much as oil-filled units of the same capacity, and
thus most users preferred the oil type where possible (Versar 1978, p.112).
The oil-filled transformers are the same size as the askarel units and are
considerably lighter in weight. Also, mineral oil has somewhat better heat
transfer characteristics than askarel, and an electric arc in mineral oil
results in breakdown products that are non-corrosive.
The major disadvantage of mineral oil is flaramability; trans-
former mineral oil has a flash point of 145°C. If an arc occurs in the
transformer, the breakdown products will be hydrogen and methane, both of
which are flammable. Detailed records of such failures are maintained by
the electrical industry. Fire Underwriters does not approve of the use of
oils and other flammable liquids for indoor applications. Where oil-filled
transformers are not specifically prohibited as on-site replacements for
PCB-filled units, the National Electrical Code imposes certain restrictions
upon their node of installation.
Oil-filled transformers are used in almost all power transformer
applications and for most substation distribution applications where the
transmission line high voltage is reduced to 12.8 kv for local distribu-
tion. Most rural pole-mounted transformers that reduce the voltage to 220
volts are also oil-filled. The issue of flammability only becomes impor-
tant where the distribution transformer must be buried, as in many urban
applications, or located close to, within, or on the roof of the building
it serves. PCB-filled transformers have, in the past, been used in most
such applications. Oil-filled transformers can be used in these appli-
cations only if they are suitably isolated from flammable structures or if
these structures are suitably safeguarded against fires. When trans-
146
-------
formers are located outside the building they service, the low-voltage
power must be brought into the building via cables or insulated buses.
Additional energy losses are then caused by heating in the low-voltage
transmission lines from the transformer to the point of use.
Open air-cooled transformers; Transformers can be built without
the use of a liquid cooling medium. One type of dry transformer that is
quite successful, under limited conditions, is the open air-cooled trans-
former. In this design, cooling air is driven through the transformer by
either natural convection or forced circulation. In those sizes where
air-cooled transformers are available, they are about equal in price to
askarel-filled transformers of the same kVA rating. However, open air-
cooled transformers are limited in both heat capacity (which limits their
ability to operate under occasional overload conditions) and dielectric
strength (which limits the maximum voltage available).
The problem of electrical insulation is even more severe if the
open air-cooled transformer only operates intermittently. When the trans-
former is operating, the heat generated within the windings keeps the insu-
lation dry and maintains a high dielectric strength in the solid insulating
material. However, when the transformer is not operating, the coils cool
to ambient temperatures and the insulation can absorb moisture from the air
which reduces its dielectric strength. Open air-cooled transformers must
be thoroughly dried before being put into service after each cool period.
One other problem with air-cooled transformers is the tendency
of dust to be attracted fron the air to the coils by electrostatic forces.
Dust can build up in the coils and block the flow of air, or it can form
conductive paths and cause short circuits.
147
-------
Open air-cooled transformers are generally limited to dry,
clean locations where the load requirements are fairly even and constant
and where the maximum voltage does not exceed 30 kv. Such transformers an
being successfully used in large office buildings, particularly tall
'"*** buildings where the transformers are located every few floors. Even in
this application, though, conditions arise that exceed the capabilities of
the transformer. For instance, in the Sears Tower in Chicago, which is
over 1400 feet tall, the electric power is brought into the building and ui
to the distribution transformers at 128 kv, which is beyond the voltage
limitations of open air-cooled transformers (Versar 1978, p.115).
Closed gas-filled transformers*; Transformers can be built with
dry inert gas (usually at an elevated pressure) as a heat transfer medium.
These transformers avoid the maintenance problems caused by moisture and
dust in open air-cooled transformers, but they are similarly limited in
overload capacity because of reduced thermal inertia compared to liquid-
filled transformers.
Closed gas-filled transformers must be installed in pressure-
tight containers because of changes in gas pressure caused by changes in
temperature. However, the maximum voltage ratings of gas-filled trans-
formers can be equal to these of liquid-filled units.
A number of different gases have been used as heat transfer
media in closed gas-filled transformers. The most common gas used in the
U.S. is the fluorocarbon hexafluoroethane ^Fg). Nitrogen and sulfur
hexafluoride have also been used successfully in certain applications.
Helium has not been found to be a satisfactory gas for this application
because its low dielectric strength results in corona discharges within the
transformer. Hydrogen is unsatisfactory because any leak in the trans-
former would result in a severe fire hazard.
*This section is repeated from Versar 1978, pp.115-116.
148
-------
Because of the necessity for a pressure vessel container, gas-
cooled transformers are 30 to 40 percent heavier than PCB-filled trans-
formers and cost two-thirds more (and twice as much as oil-filled trans-
formers). In addition, the gas-filled transformers must be sized larger
than oil-filled units to allow for the expected heavy load peaks of power
cons unpt ion.
17.4 Relative Prices of Non-PCB Transformers
The relative prices of distribution transformers of the size and
type commonly installed in office buildings are summarized in Table 17.4-1.
If the RTEmp* high fire point liquid-filled transformer proves to be
acceptable for installation without auxiliary fire protection, there should
be no cost increases for new transformer installations resulting from the
ban on the manufacture of PCB transformers. The open dry type transformers
are also quite cost competitive with the PCB units for most applications.
Table 17.4-1*
Relative Transformer Prices
Type of Unit Price; 1000 kVA Unit Price; 2000 kVA Unit
Oil-filled $15,300 $23,300
PCB 19,900 30,300
Non-PCB askarel 19,000 29,000
KTEmp® 18,400 28,000
Silicone 22,300 34,500
Open air cooled 20,700 35,000
Sealed gas cooled 30,600 46,600
*Source: MGC Engineers, "Distribution Transformer Status - WTI Project."
Memorandum to U.S. General Services Administration, June 1, 1977, as cited
in Versar 1978, p.116.
149
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17.5 Compliance Costs
Clean-up costs; The only costs incurred by transformer manu-
facturers resulting from the ban on the use of PCBs will be clean-up and
disposal costs of flushing PCBs from storage and material handling equip-
ment before using this equipment to store high fire point liquids. This
equipment consists primarily of storage tanks, filters, pumps, and piping.
Clean-up costs, including disposal of contaminated solvents, should not
exceed $10,000 per plant, or a total one time cost impact of perhaps
$100,000 in 1977 and 1978 (Versar 1978, p.117).
Cost of substitutes; The high fire point liquid cooled trans-
formers and air-cooled transformers will cost about the same to 10% more
than askarel units depending on the acceptability of non-PCB askarels and
hydrocarbon base high fire point transformer liquids. Based on past sales
of 5000 askarel units per year at an average price of $20,000, a 10% cost
increase would increase sales and costs to the users by (5000 x $20,000 x
10% <• ) $10,000,000 per year. There should be no effect on the demand for
transformers for new installations, and there may be an increase in the
demand for replacement transformers of 1000 to 2000 units per year. This
additional demand should be easily supplied since the transformer manufac-
turing industry has recently been operating at only about 60% of capacity
(Versar 1978, p.117).
Market structure should not be significantly affected because
all of the former manufacturers of askarel transformers will have equal
access to the high fire point transformer liquid materials and technology.
Access to this market segment will open to those transformer manufcturers
who did not offer askarel as an alternative to oil. This will primarily
afford a marketing opportunity to RTE Corporation which has never supplied
askarel units but which has a strong market position in the high fire point
liquid transformer area. The increased sales by RTE will probably be less
than the total increase in transformer sales, so this small shift in
150
-------
market structure should not result in a net decrease in the sales by any of
the other manufacturers.
Increased fire losses; The presently installed PCB askarel
transformers were installed at a premium cost compared to oil-filled units
in order to achieve improved fire safety. Not all of the substitutes for
PCBs have as good fire resistance. In particular, the high fire point
transformer liquids can burn under certain conditions, including exposure
to an external fire, and can release flammable gases if an electrical arc
occurs within the transformer.
Various non-flammable substitutes for PCB askarel transformers
are available, including the various dry type units and non-PCB askarels.
Although these alternatives may cost more than the PCB units they replace,
they can achieve equal fire safety. Therefore, the banning of the manufac-
ture of PCB-filled transformers is not expected to result in significant
increased fire losses.
17.6 PCBs Controlled by the Regulation
There is no information in the record to support any estimate of
the probability that PCBs used in askarel transformers will enter the
environment from accidental spills and venting of transformers. Venting
results in the loss of no more than 2% of the total fluid in the
transformer. However, good clean-up of spills should limit the total
losses to perhaps 5% of the total liquid vented. Use of PCBs in
transformer manufacturing was about 12 million pounds per year in 1975
(Versar 1976a, p.6). The ban on use of PCBs in new transformers will
prevent the loss of (2% x 5% x 12 million pounds =) 12,000 pounds of PCBs
into the environment from each year's production of transformers.
151
-------
17.7 Summary - Economic Impacts
Transitional Costs:
Clean-up costs for manufacturers 5100,000 1978 only.
•Vtft
Long Term Costs;
Higher costs of non-PC3 transformers $0 to ?10 million
per year.
17.8 Cost Per Pound of PCBs Kept From the Environment
Cost per pound = $0 to $10 million per year =
12,000 pounds per year
$0 to $833 per pound PCBs
152
-------
13.0 S
iS.l Transitional Cost Impacts
Costs of decontaminating or scrapping existing equipment and the
ban on rebuilding of PCB transformers are all transitional costs. These
costs will end when the existing PCBs are finally removed from service.
The transitional cost impacts identified in this analysis of the impacts of
the PCB Ban Regulation (as distinct fron the previously promulgated PCB
Effluent Standard and the PCB Disposal and Marking Regulations) are
summarized in Table 18.1-1.
18.2 Long Term Cost Impacts
The costs resulting fron the ban on the manufacture of PCBs will
be continuing costs and will result in along term economic inpact. These
costs include the additional cost of non-PCB capacitors and transformers.
Tne long term costs identified as resulting from the PCB Ban Regulation are
summarized in Table 18.2-1.
18.3 Cost Per Pound of PCBs Kept from the Environment
The effectiveness of the regulation in preventing the entry of
PCBs into the environment was calculated for each industrial segment if
sufficient data was available. These costs are summarized in Table 18.3-1.
153
-------
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Transformers: (Chapter 17)
Increased Cost of Non-PCB Transformers $0 to 10 million/year
Increased Fire Losses
Capacitors: (Chapter 16)
Increased Cost of Non-PCB Power Factor
Capacitors
Increased Cost of Non-PCB Industrial
Capacitors
Diarylide Yellow Pigment (Chapter 14)
Increased Manufacturing Cost
Spill Materials (50 to 500 ppm PCBs)
(Chapter 15)
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$6.6 to 18.9 million/year
$345,000/year
No data
157
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-------
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-------
Page, William C.; Michaud, Terry (Dew Corning Corporation). 1977.
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T5.C.: Office of Science and Education, U.S. Department of Agriculture,
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Walsh, E.J.; Voytik, D.E.; Pearce , H.A. (Westinghouse Electric Corp.),
1977. Evaluation of Silicone Fluid for Replacement of PCS Coolants in
Railway Industry, Final Report, (Report No. DOT-TSC-1294). Cambridge,
MA.: Transportation Systems Center, U.S. DOT. December, 1977.
Weems, George. 1977. "Polychlorinated Biphenyls." Denver, Colorado:
U.S. Department of Interior, File HLS 3-3-lOh, June 13, 1977.
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Weinstein, Norman J. (Recon Systems, Inc.) 1974. Waste Oil Recycling and
Disposal, EPA-670/2-74-052. Princeton, N.J.: August, 1974.
Wood, David (Monsanto). 1975. "Chlorinated Biphenyl Dielectrics, Their
Utility and Potential Substitutes" in Conference Proceedings, National
Conference on Polychlorinated Biphenyls, November 19-21, 1975. Chicago,
Illionis"Washington, D.C.:Ofrice of Toxic Substances, U.S.
Environmental Protection Agency (Report No. EPA 560/6-75-004), pp.
317-322.
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••a*
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BIBLIOGRAPHIC DATA
SHEET
1. Report No.
EPA 230-03/79-001
3. Recipient's Accession No.
4. Tide mod Subtitle
PCS Manufacturing, Processing, Distribution in Commerce,
and Use Ban Regulation: Economic Inpact Analysis
5. Report D«ee
March 30, 1979
Westin, Bruce Woodcock
8. Performing Organization Kept.
No. 535-1
9. Performing Organization Name and Address
Versar Inc.
6621 Electronic Drive
Springfield, Virginia 22151
10. Project/Taak/Tork Unit No.
11. Contract/Grant No.
68-01-4771
13. Type of Report * Period
*• j
12. Sponsoring Organization Naae and Address
Office of Planning and Management
U. S. Environmental Protection Agency
Washington, D. C. 20460
Covered
Final Report
14.
15. Supplementary Notes
EPA Project Officer: Mr. Stephen Weil
16, Abstracts
This report summarizes the estimated economic impacts of FOB Ban Regulations which
implement the requirements of Sections 6(e) (2) and 6(e) (3) of the Toxic Substances
Control Act.
17. Key Torda and Document Analysis. • 17o. Descriptors
Polychlorinated Biphenyls
Toxic Substances Control Act
Liquid Waste Disposal
Economic Analysis
Public Utilities
Capacitors
Transformers
Coal Mining
Waste Oils
17h. Identirlers/Open-Ended Terms
17e. COSATI Field/Group
18. ATaUability Statement
Release Unlimited
9. security Class (This
Report)
Tnis
20. aeeuriry v.ia*s (T
'^CLASSIFIED
21. No. ai Pages
173
22. Price
m» NTIS-M i««v. lo-rii ENDORSED BY ANSI AND UNESCO.
THIS FORM MAY BE REPRODUCED
UJCOMM.OC
"US. GOVERNMENT PRINTING OFFICE: 1919 291-755'6H5 1-3
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United States
tnvirnomental Protection
Agencv
Official Business
Penalty for Private Use
$300
Special Fourth
Book
Postage and F
EPA
Permit No. G<
Washington DC 20460
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