PCB HEARING
SPECIAL MEETING OF
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION V - CHICAGO, ILLINOIS
July 19, 1977
10:00 a.m.
Pick Congress Hotel
Chicago, Illinois
iane H roofs*
Court Reporter
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PANEL MEMBERS:
GEORGE WIRTH, CHIEF, HEARING OFFICER
Regulations Development
Office of Toxic Substances
U.S. Environmental Protection Agency
Washington, D.C.
GARY J. BURIN, CHEMIST
U.S. Environmental Protection Agency
Washington, D.C.
DR. EMILIO STURINO, CHIEF
Organic Laboratory Section
Central Regional Laboratory
U.S. Environmental Protection Agency
1819 West Pershing Road
Chicago, Illinois
JAY GOLDSTEIN
Waste Management Branch
U.S. Environmental Protection Agency
230 South Dearborn Street
Chicago, Illinois
HAL SNYDER, HEAD
Toxics Strategy Implementation Unit
Office of Enforcement Division
Washington, D.C.
KARL E. BREMER
Toxic Substances Coordinator
U.S. Environmental Protection Agency
230 South Dearborn Street
Chicago, Illinois
ROBERT PEARSON, BIOLOGIST
Permit Branch, Enforcement Division
U.S. Environmental Protection Agency
230 South Dearborn Street
Chicago, Illinois
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GLENN D. PRATT, CHIEF
Permit Branch, Enforcement Division
U.S. Environmental Protection Agency
230 South Dearborn Street
Chicago, Illinois
PETER PRINCIPE
Environmental Engineer
Office of Toxic Substances
U.S. Environmental Protection Agency
Washington, D.C.
EDWIN SHYKIND, DIRECTOR
Office of Environmental Affairs
Interagency Work Group on PCBs
U.S. Environmental Protection Agency
Washington, D.C.
BRIAN DAVIS, ASSISTANT REGIONAL COUNSEL
Office of Regional Counsel
U.S. Environmental Protection Agency
230 South Dearborn Street
Chicago, Illinois
BLAKE BILES
Attorney of General Counsel
U.S. Environmental Protection Agency
Washington, D.C.
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SPEAKERS: PAGE
E. M. FREEGARD 13
Advance Transformer Company
E. M. WARNER 26
Joy Manufacturing Company
JOHN L. HESSE 71
Michigan Department of Natural
Resources
RICHARD ROLLINS 99
Electronic Industries Association
FREDERICK STEINBERG
Lawyer - Joy Manufacturing Company
HARRY ONISHI
PCB Task force
Edison Electric Company
WILLIAM CURTIS
Manager, Electronic Division
Northern States Power Company
JOHN WEIZEORICK
Association of Home Appliance
WILLIAM WARE
General Motors Corporation
WILLIAM PAGE
Dow Corning Corporation
VALDAS ADAMKUS
Deputy Regional Administrator
Chicago Region V
U.S. Environmental Protection Agency
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MR. BREMER: Good morning, I'm Karl Bremer.
X am the Toxic Substances Coordinator for the
Environmental Protection Agency in Chicago.
The meeting this morning will be
opened by Mr. Val Adamkus. Mr. Adamkus is the
Deputy Regional Administrator of the U.S.
Environmental Protection Agency in Chicago.
Mr. Adamkus has been active in overall
administration of Toxic Substances programs since
1970, starting with programs to haul mercury
contamination in on the Ohio Basin.
His continual persistence and attenta-
tiveness to PCB problems as well as other toxic
problems has enabled us to actively respond to
the Toxic Substances Control Act.
Mr. Adamkus.
MR. ADAMKUS: Good morning, ladies and gentlemen
I would like to take this opportunity to
welcome you here today.
We hope that today's meeting will be
extremely informative to all from industry,
citizen groups, the general public, and of course
to Environmental Protection Agency.
We consider this meeting a necessity
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in our rulemaking procedure to arrive at a balance
and objective viewpoint.
With a recent enactment of the Toxic
Substances Control Act, the first compounds of
concern are polychlorinated biphenyls.
In fact, the Act made special provisions
for PCBs requiring the Environmental Protection
Agency to issue labeling and disposal regulations
by July, 1977, to restrict use to close systems
by January of 1978, to prohibit all production by
January 1979, and to prohibit all distribution
of PCBs in commerce by July, '79.
Why then have PCBs received special
consideration?
To the unique physical and chemical
properties of PCBs include low vapor pressure at
ambient temperatures, resistance to combustion,
remarkable chemical stability, high dielectric
constant, and high specific electrical stability
and flow water solubility.
At the same time, PCBs are liquid
solubles, and hence the potentials for absorption
into fatty tissue and into the liver is high.
Thus once ingested, PCBs are retained
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by most organisms rather than excreted.
The qualities of resistance which
made PCBs useful for industrial purposes greatly
aggravate their potential for harm in the eco
system.
The principal uses for PCBs today arts
enclosed electrical systems. PCBs have been
used over the years resulting in great and greater
direct contamination of the environment.
These uses includes an additive in
investment casting waxes, lubricant additivesr
hydraulic and compressor fluids, carbonless paper,
plasticizers, paints, heat exchange fluids,
certain types of paper and sealants.
Most of these uses have been substantially
curtailed by the PCBs which have entered the
environment, will be here for many years.
Water and sediments seem to be the
final major thing for PCBs when they are supported
by contributory streams, municipal and industrial
outfalls or transported by the atmosphere.
Because PCBs are extremely persistent,
we may expect to deal with this problem over a
long period of time.
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In today's presentations, and during
each question period* we are asking for objec-
tive facts, facts which will give the Environ-
mental Protection Agency adequate input prior
to proposing PCBs ban regulations under the
Toxic Substance Control Act*
I an positive that your contribution
will be of great significance.
At this tine I would like to introduce
to you Mr. George Wirth.
Mr. Wirth is the Chairman of our PCB
Board group in Washington and has been actively
involved in PCBs in EPA's Office of Toxic
Substances.
Mr. Wirth will chair today's meeting and
will explain the meeting's objectives, procedures,
and the rules.
Mr. Wirth?
HEARING OFFICER WIRTH: Thank you.
Good morning*ladies and gentlemen.
As Mr. Adamkus pointed out, the meeting
this morning concerns PCBs and specifically it
concerns the development of regulations surrounding
the various bans on manufacturing, processing,
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diatribution and commerce and use proposed
•tarting January 1st, 1978, and the final
distribution commerce ban that will take effect
July 1st, 1979.
The Environmental Protection Agency
has recently proposed rules on the labeling and
disposal requirements for PCBs as a requirement
of the Toxic Substance Control Act/ and we have
also completed the Informal Hearing requirement
specified by the Toxic Substance Control Act
in the end of June of last month.
Those regulations now are in final
consideration and comment period, and we anticipate
that we will promulgate such regulations sometime
toward the end of August or September.
So basically we have progressed to
the point that we just about have regulations
on labeling and disposal and this general meeting
is to discuss the future bans on manufacturing
and use and other activities.
The panel this morning consists of
representatives from Region v, the Chicago Region '
that have been involved in the PCBs in the
Environmental Protection Agency, and represents
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tives from Washington who form the major core
of the Work Group involving this regulation.
This Work Group has probably 25 members
strong and roughly a third of that Work Group
here with us appear today to hear your points.
This meeting is an informal meeting,
public participation meeting. It is not the
Informal Hearing required by the Toxic Substance
Act.
So generally this meeting will be less
formal in nature than that meeting, and it is
a meeting intended for the public to have input
to the agency before we go actively propose a
regulation or consider how a regulation should
be constructed.
This is the sixth such meeting we have
had in the Toxic Substance Control area. This
will be the fourth one on PCBs, the second one
on manufacture.
There was one last Friday in Washington
on this same subject/ and we have had two
previously on chloroflourocarbons, banning of use
on chloroflourocarbons, and aersol sprays.
The general procedures that we will
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follow for today is that the people that have
previously signed up to make a presentation
at this meeting will be called in the order of
their sign up, and be allowed to make whatever
general statement they would like.
When they complete that statement, wo
will go down the panel to ask various questions
concerning our testimony, and concerning our
interest, and when we complete that, we will b*
happy, as time allows, to ask any question of
the witness from the general audience so that
during the individual's presentation or during
his questioning by the panel, we invite the
audience to formulate whatever question they
would like to ask, and raise their hand at
some point that is opportune and it will be
brought to the panel to be asked of the witneso.
When we complete all witnesses, if
time allows, we will be happy to have any
general statement or additional question or any
comment that anyone would like to make from
the audience for the record.
Concerning the rules on or procedure
on calling individual witnesses, we will call
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you and we essentially allow four options on
your request to take the podium.
You may, of course, speak. You may
yield your time to anyone else that you wish.
You may cancel your time or you nay pass if you
wish for whatever reason you may have.
If anyone passes, he will be recalled
after we have gone through the entire witness
list, and we will keep calling the passes in
the order in which they pass until everyone
either passes or cancels and then we will end
the testimony for today.
It is very similar to a Midwestern
poker game called 7/27. Those types of rules
I am sure many of you out there understand ~-
and having grown-up in this part of the country
myself.
If there are no general questions
on today's procedures, I think we are prepared
to call the first witness and proceed with
this meeting.
Yes, I am sorry, thank you, Karl.
I forgot the procedure of this myself
-- and that is to introduce the panel —
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essentially tell you what their interest is
in this particular regulatory activity.
Starting at my extreme right,
I have Mr. Gary Burin who is out of the Office
of Toxic Substance, and is assigned to work
on the PCS manufacturing and banning regulations.
He is an engineer and scientist, and
background in public health administration.
Next to Mr. Burin is Dr. Emilio Sturino
who is out of the Chicago Central Regional Lab
of EPA from the Organic Section and background
in doing analytical work on finding PCBs and
determining levels of PCBs.
Next to him is Mr. Jay Goldstein of
the Solid Waste Program in Chicago Region.
Next to him Mr. Hal Snyder out of the
Office of Enforcement in Washington, D.C.
Formerly out of the Office of Toxic
Substance and basically the author of the
labeling and disposal regulations, if we have
a single author.
To my immediate right is Mr. Karl
Bremer, the Toxic Substance Coordinator for
Region V in Chicago, and he also is a member of
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our PCB Work Group/ and the Regional representa-
tive on that work.
On my immediate left is Mr. Blake Biles
from the Office of General Counsel who has been
involved with PCBs for quite a number of years
and is also a member of the Work Group on PCBs.
Next to him is Mr. Brian Davis, the
Regional Counsel's Office in Chicago.
Next to him is Mr. Edwin Shykind,
Director of Environmental Affairs and Bureau
of Domestic Commerce in the Department of Commerce.
He is one of the representatives to
the PCB Work Group and he is also a member of
the Chloroflourocarbon Work Group and was
involved in the regulatory activity.
Next to him is Mr. Peter Principe,
Environmental Engineer out of the Office of
Toxic Substance, primary responsibility in my
office for writing second phase PCBs, to
regulations.
Next to Mr. Principe is Mr. Glenn
Pratt who is out of the Enforcement Division
in the Chicago Regional Office. And he is
Chief of the National pollution discharge elimination
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system in Chicago — the water pollution control
permits.
And next to him, Mr. Pratt, is Mr.
Robert Pearson out of the Office of Enforcement
in Chicago Region.
With that, then, we call the first
witness, Mr. E. M. Freegard of the Advance
Transformer Company of Chicago, Illinois.
Is he here? Mr. Freegard, feel free,
as all witnesses, to bring whoever you like with
you to the podium for whatever reason you like .
MR. FREEGARD: Good morning, ladies and
gentlemen.
I am Ernest Freegard, and these
comments are presented by the Advance Transformer
Company of Chicago, Illinois.
We are a company of the North American
Philips Corporation which is a corporation of
Delaware.
The Advance Transformer Company is
one of the largest consumers of small oil-filled
capacitors for AC application in the lighting
industry.
And we are directly affected by any
rulemaking regarding polychlorinated biphenyls*
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Thia testimony pertains to informa-
tion regarding PCBs printed in the Federal
Register Volume 42, Number 123, dated Monday,
June 27thf 1977 — Page 32555.
This document indicates that Section 6(e)
of the Toxic Substances Control Act provides
that after January I, 1978, PCBs may not be
manufactured, processed, distributed in commerce
or used in other than a totally enclosed manner.
No PCBs may be manufactured after
January 1, 1979, and PCBs may not be processed
or distributed in commerce after July 1, 1979.
Since the small AC capacitors utilized
by the lighting industry are hermetically sealed,
I assume that these are considered to utilize
PCBa in a quote totally enclosed manner unquote.
If there is no disagreement on this,
then I assume the proposed January 1, 1978 ban
does not affect the distribution in commerce
of capacitors used in the lighting industry.
I am, however, concerned regarding
the intention of the Act with respect to the
January 1 and July 1, 1979 bans.
Let me take a minute to explain
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just how discharged lamp lighting fixtures
work* their way through the manufacturing and
distribution chain before they finally reach
the user.
First, the capacitor industry manu-
factures the hermetically sealed small AC
capacitors and sells them to the many companies
who are in the business of manufacturing and
selling discharge lamp ballasts.
The Advance Transformer Company is
one of more than a dozen companies who make
ballasts.
Second, the ballast industry makes
ballasts, utilising these capacitors and selln
them to about 500 lighting fixture companies
who build the ballasts into their lines of
lighting fixtures.
Third, the lighting fixture industry
produces a nearly endless variety of lighting
fixtures which are typically sold to about 4,000
electrical distributors located throughout all
of the 50 states.
And last, the electrical distributor
sells the lighting fixtures to thousands of
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•lectrioal contractor* who subsequently install
the lighting system for the user.
There are, then, in this manufacturing
and distribution chain, no lees than five
separate industries involving thousands of
business enterprises.
Obviously, this pipeline is long and
involved at each step are product inventories.
As a ballast manufacturer, I can say
that we have ballasts with PCS capacitors in
stock which will not be sold to the fixture
industry for several years.
Likewise, the fixture industry builds
for stock and many items will remain in their
t,
inventory for some time.
x The electrical distributor also stocks
lighting fixtures, and many of these will be
in a slow-moving category. I believe that this
illustrates why I am concerned about what is
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intended in the Act.
Z would hope that the Agency would
agree that the important ban involved here is
the one affecting future production processing
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It cannot be stopped, and restarted
without a devasting effect on the several
industries involved.
Referring now to Section 4, Resale of
PCBs, under General Issue on Page 32556 of the
Register/ it appears to me that this issue
is made difficult by our use of the letters "PCB".
Some of the earlier documents which we
have studied introduced more restrictive terms
such as "PCB Articles" and "PCB Equipment".
I believe we might achieve better
understanding if we make use of these more
restrictive terms.
As a manufacturer of discharge lamp
ballasts, fluorescent as well as HID, we purchased
PCB articles, that is capacitors, and we sell
PCB equipment, those are ballasts.
Likewise, the fixture manufacturer,
the electrical distributor, and the electrical
contractor all deal with PCB equipment — at
least this would be my understanding of the
definition of these terms.
Certainly lighting fixtures are sold
more than once.
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They are sold to the electrical
distributor, to the contractor, and to the
user.
Since the ballast is included in the
lighting fixture, it also is sold more than
once.
But both ballasts and fixtures are
PCB equipment/ and there should be no ban on
distribution in commerce of such equipment.
It is this very process of buying and
reselling wich can take years to accomplish
and makes any date limiting distribution in
commerce of PCB equipment unworkable in my view.
I suggest to the Agency that if we
have bans on the manufacture and distribution
in commerce of PCB fluid and PCB articles that
will be affective as far as the lighting industry
is concerned/ additional bans affecting use
or distribution in commerce of PCB equipment
such as ballasts or lighting fixtures will
provide no additional safeguards and will be
extremely disruptive and costly to the lighting
industry and ultimately to the consumer.
This concludes my prepared remarks
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and Z thank you for the opportunity to present
than today.
HEARING OFFICER WIRTH: Thank you.
Thank you, Mr. Freegard.
Okay, let's begin with questions
starting on the left end of the table down here
at my left with Mr. Pearson*
Do you have any questions?
MR. PEARSON: No.
HEARING OFFICER WIRTH: Mr. Shykind?
MR. SHYKIND: I would just like to know
if you estimated any costs versus the January
versus July bans on these articles. Do you have
any idea what the construction would be economically?
MR. FREEGARD: Well, if — if the rule
finally became that PCS equipment could not be
distributed in commerce after July 1, 1979,
it would be extremely difficult for me to estimate.
But this — this would involve not only the
ballast industry but, as I mentioned the lighting
fixture industry, some 500 companies, electrical
distributors, even contractors who would have
their inventories frozen, if you will, and this
equipment would either have to be modified or
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•crapped.
Certainly if it ia scrapped we don't
get away from the disposal problem of the PCB
article which is inside.
Z have — I have not attempted to make
any estimate of total cost of such a ban at that
time, but it would be very, very high.
MR. PRINCIPE: I would like to ask a
question.
Does Advance Transformer make capacitors?
MR. FREBGARD: No, we do not.
MR. PRINCIPE: You buy capacitors?
MR. FREEGARD: We purchase capacitors.
MR. PRINCIPE: Do you — if you purchase
capacitors, you could make an estimate of the
cost impact for your own company given different
possible regulatory approaches, couldn't you?
MR. FREEGARD: I made an estimate which
I presented on June 27th, I believe, in Washington.
Assuming that I would have to go into
our inventory, and now this would not be to
remove capacitors, this was simply on the basiti
of having to label them.
I reckoned the cost to my company of
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soraething in the neighborhood of $150,000.
Now, that number would not be applicable
in this instance because in this case we would
have to replace the capacitors and purchase
new ones to replace them and handle the disposal
problem of the old ones. It would be much,
much higher.
MR. PRINCIPE: How many capacitors do you
have in inventory right now, do you know?
MR. FREEGARDj I really couldn't tell you.
MR. PRINCIPE: Could you give me any idea
of the dollar — I don't know if this is practical,
but do you know what the dollar value is?
MR. FREEGARDs if I had the number, I would
consider it to be proprietary.
MR. PRINCIPE: Has Advance Transformer
made any efforts to purchase capacitors that
do not contain PCBs?
MR. FREEGARD: We do purchase some that do
not contain PCBs.
MR. PRINCIPE: How long would it take you
to change over to purchase all of your capacitors?
MR. FREEGARDi Non-PCB capacitors are not
necessarily generally available to the extent
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that they are needed by the industry.
In other words, they are in short supply.
They also cost more.
MR. PRINCIPE: Okay.
BEARING OFFICER WIRTH: Along that same line,
Mr. Freegard, could you give us any idea of
how much of the ballast industry or what percentage
of the market your company represents, roughly?
Is it 57, 5, 30, 10?
MR. FREEGARD: No, I know that number.
but I couldn't give it to you.
HEARING OFFICER WIRTH: You wouldn't care
to give a range at all?
MR. FREEGARO: We are one — we are one of
the largest.
HEARING OFFICER WIRTH: One of the largest?
Okay.
HEARING OFFICER WIRTH: Do you have any more?
MR. SHYKINDt No more.
HEARING OFFICER WIRTH: Okay.
Mr. Davis? No?
MR. DAVIS: No.
HEARING OFFICER WIRTH: Mr. Biles?
MR. BILES: In manufacturing ballasts for
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fixtures, and so forth, is there any contact
with the liquid PCB mixtures in the — chemical
substances themselves?
MR. FREEGARDt No.
MR. BILESs Do you have any economic use
for those that are leaking other than —
other than disposing of them?
MR. PREEGARD: No.
MR. BILES: Is there anything you — in which
you can do in which there is liquid PCB coning out
of it?
MR. PREEGARD: No, no.
MR. BILES: Do you think it would be possible
for a company such as your own to sell all of
your ballasts prior to July, 1979, have contracts
and make the sale of them?
MR. FREECARD: No.
MR. BILES: Approximately how long do you
think it would take given your current inventories
and your projection of sales before you think
you could have contracted the last sales?
MR. FREEGARDr I really —•
MR. BILES: Or would that be possible to
come up with some information?
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HR. FREEGARD: It would be — it would be
— any answer I would give you would be rather
speculative.
I can say that we have ballasts in
stock that we have had for five years.
MR. BILESi Okay.
MR. FREEGARD: If that is any indication
of what might happen in the future, I don't know,
That is about as good as I could do.
MR. BILESt As far as you know, are any of
the ballasts that you sell resold as ballasts
as opposed to being resold after they have been
incorporated into a fixture?
Do you think — in terms of the
industry you are talking about?
MR. FREEGARD: There is — a very small
segment of the market that deals with replace-
ments in existing lighting fixtures.
MR. BILES: Okay.
MR. FREEGARD: Now those products moved to
their final application directly from us to
electrical distributors to either the user or
to a contractor who is going to replace the
product.
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That is a rather small segment.
MR. BILES: So by and large, when you sell
them, you sell then?
MR. FREEGARD: To lighting fixture manufacturers
MR. BILES: Who then puts them in their
fixtures and resells them to distributors?
MR. FREEGARD: Right.
MR. BILES: All right, thank you.
HEARING OFFICER WIRTH: Karl?
MR. BREMER: I have nothing.
HEARING OFFICER WIRTH: Tom, questions?
None? Okay.
Questions from the audience, anyone?
Excuse me one second.
All right, if there is no further
questions, thank you very much.
MR. FREEGARD: Thank you.
HEARING OFFICER WIRTH: The next witness
is Mr. E. M. Warner of the Joy Manufacturing
Company of Franklin, Pennsylvania.
MR. WARNER: Good morning, ladies and
gentlemen.
HEARING OFFICER WIRTH: Excuse me, sir,
we have a question here.
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Is Mr. Steinberg to speak with you?
MR. STEINBERG: I am signed up to --•
I think fourth or fifth this morning.
HEARING OFFICER WIRTH: Yes, that's
correct.
Do you want to speak with Mr. Warner?
I have a note on the card here,
Frederick W. Steinberg to speak with E. M.,
Warner of Joy Manufacturing.
MR. STEINBERG: I am going to hold my
position as fifth.
HEARING OFFICER WIRTH: That is fine,
that is fine.
Mr. Warner, would you state and
spell your name and your association?
MR. WARNER: My name is Edward Warner,
E. M. Warner. I am with the Joy Manufac-
turing Company, Mining Machinery Division.
I am the Director of Engineering.
We are a leading manufacturer of
underground mining machinery.
Our company has only one use for
PCBs. It is used as a coolant internally
in electrical motors.
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While new machinery has not been
produced using PCB motors since 1973,
hundreds of motors are still in operation
in underground coal mines.
It is the continued utilization
of the equipment using these PCB-filled
motors that concerns Joy and our customers.
We believe that EPA should be
informed as to the economic impact and the
production and dislocations in the coal
industry that could occur if total ban
were being placed on PCBs beginning in 1978.
As long ago as March, 1972, our
company advised our customers of the need
for special care in handling and disposal
of PCBs.
Joy first used petroleum hydraulic
oil as a cooling fluid internally in motors
in 1960. But the flammability of the oil
concerned mine safety authorities.
Even though these mine motors
were explosion tested and could not emit
sparks or flame to the mine atmosphere, it
was decided that a flame-resistant coolant
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was required.
After exhaustive testing, Monsanto
Aroclor 1242, the PCB fluid was chosen.
May I have the first slide?
Ultimately PCB fluid was used in
three different motors.
Because of the great heat transfer •
HEARING OFFICER WIRTH: Excuse me one
second, can the panel see this? If not,
why don't we take one second?
MR. WARNER: It is difficult to see,
I know, in this area.
HEARING OFFICER WIRTH: Just take chairs
out here if you like.
MR. WARNER: Surely.
I have about nine slides.
Because of the greatly superior
heat transfer qualities of PCB liquid as
compared to air, it was possible to dramati-
cally reduce the physical size of motors.
This illustration shows one com-
parison of two, 100 horsepower motors, one
PCB-filled and the other of conventional
air-filled construction.
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The first application was on a
continuous mining machine known as a CU-4.J.
Fifteen of these continuous miners
were built over a four-year period beginning
in 1963.
The approximate selling price
of this machine was $105,000.
Three motors were used on each
machine.
Due to the motor's location and
size constraints, it was not possible to
build these miners using conventional motor
construction.
Seven of these machines remained
in operation as of this time mining coal
in two small coal companies in West Virginia
and Pennsylvania.
The second application of PCB-filled
motors was made in 1963 — excuse me — 1?65.
In this design two motors were
used to provide traction power for a coal
loading machine. The approximate selling
price of these loaders was $60,000.
The size of the motors was not
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reduced because of the very high operating
temperatures experienced with this motor.
PCB was added internally to the
motors to greatly reduce the operating
temperature.
One thousand and twenty-eight of
these motors were used on loaders shipped
between 1965 and 1973 to 88 different
companies.
Many of these users are small coal
operators. In fact/ 36 companies own only
one machine.
Sixty companies own one, two, or
three machines.
Because of the wide distribution
of these loaders, rulings affecting the
distribution and use of PCB would have a
substantial effect on small coal operators.
The third application of PCB-fillecl
motors was on another continuous miner
called the 9 CM.
These miners sold for approximately
$120,000.
In this design, two cutter-head
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motors were completely hidden inside the
cutting element at the front of the machine.
The third PCB motor was used as
a hydraulic pump motor.
As with the CU-43 shown previously,
the motor size was shrunk in order to locate
it in its position.
From 1967 until 1970, 64 of these
miners were constructed. It is estimated
that 30 of these machines are still in
operation.
Beginning in 1974, Joy provided a
conversion kit to our service centers to
change PCB loader motors to conventional
construction.
It was recognized that regulations
were forthcoming to prohibit the use of
PCBs.
To date, 353 motors have been
converted or approximately one-third of
the total.
Loader users have not been receptive
to this change because the conventional
motors run much hotter and the service life
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is shorter.
There is no conversion possible
for either the CU-43 or the 9 CM motors.
Conventional motors of adequate
horsepower cannot be installed on these
machines because of their increased size.
Beginning in 1972, Joy Manufacturing
and our motor supplier, Reliance Electric
Company, in Cleveland, began a search for a
substitute for a Aroclor 1242.
Nineteen different chemical companies
were contacted and 21 fluids were evaluated
in the search for replacement.
The cost of this program was
approximately $60,000.
Heat stability and compatibility
with electrical insulation were primary
requirements.
Only one fluid was found to meet
the test, but unfortunately it gave a very
pungent odor while operating, while under
operating conditions. And consequently,
it was abandoned.
We are convinced that a suitable
-------
-34-
substitute does not exist for our require-
ments . We are continuing to evaluate
possibilities as they become available.
Our company believes that continued
use of PCS fluid in mining motors constitutes
a minimal risk to the environment.
Although PCB-filled mine motors
cannot be classed as totally enclosed,
great efforts have been expended to assure
low loss of PCB from the motors.
The liquid is contained within
an explosion-tested enclosure under a pressure
of 20 pounds per square inch.
Under very extreme conditions,
such as a motor-winding failure, PCB vapor
may be emitted from a pressure relief valve.
The only other possible leakage
point is around the motor shaft seal.
If the seal becomes badly worn,
PCB can leak, but it would go into a gear
reducer to which the motor ia connected.
In normal operation, the loss of
PCB from the motor is zero.
Joy sells PCB in one-gallon
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-35-
containers to customers who need small
amounts to replenish losses from motors.
The primary risk of environmental
contamination is during motor repair,
PCB handling and disposal at Joy's
service center In Bluefield, West Virginia,
Is being done in accordance with suggestions
from EPA.
This is the facility that repairs
motors.
This facility has been examined
twice by EPA and has not been cited for any
misuse or contamination of the environment.
Used PCB is accumulated and returned
to the Monsanto Company for incinceration.
Additional detailed safeguards
have been adopted as a result of visits
by EPA personnel.
The quantity of PCB used in each
motor is small averaging about four gallons.
Handling is restricted to a few
people who are carefully instructed and
supervised.
At the present time our company
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-36-
is repairing PCB motors at three different
locations, but .it has proposed to consoli-
date all repairs of service center.
As a final consideration, we would
like EPA to be aware of the impact on the
coal industry -- if an outright ban on the
use of PCB for mine motors were to be imple-
mented, underground coal mining Is a sequential
process. It Is accomplished by the use or
the machines to do certain jobs in sequence.
One system known as conventional
mining uses a group of six machines, the
cutting, machine, a face drill, a loader, two
coal haulage vehicles known as shuttle cars,
and a roof bolter.
It is obvious that when any single
machine becomes inoperative, the mining of
coal stops .
In additions to the loss of produc-
tivity, five other machines must cease operation
-- with no consequent return on their capital
Investment.
The cost of downtime varies. However,
an average production loss might well be 500 tons
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-37-
of coal in a single working shift.
Which at today's prices would be
worth at least $10,000.
The value of the group of machine*
involved would total $300,000 to $450,000
depending on their age and condition.
In continuous mining, the mining
sequence is simpler, and only four machines
are used.
One continuous miner, two shuttle
cars, and a roof bolter.
Again, loss of operation of any
machine stops the mining process.
Loss of coal production is comparable
to that in conventional mining.
The capital investment would only
be slightly less than that for conventional
machines.
It is for these economic reasons
that coal mine operators exert maximum effort
to keep all machines in operation simultaneously
Taking mining machines out of
operation to make conversions obviously would
be a costly procedure.
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-38-
In conclusion, Joy Manufacturing
proposes that use authorization be granted
by EPA to us and our customers for three
years beyond January 1st, 1978.
This authorization would be con-
tingent upon the following:
One, no additional PCBs to be imported
by Joy Manufacturing.
We have been importing PCBs in the
past.
Two, if recommended by EPA, Joy
could sell part of our present inventory of
PCBs to our customers before January 1st,
1978.
This would eliminate future need
to transport PCB.
Three, Joy would handle all future
motor repairs at a single service center
operating under rules prescribed by EPA.
Pour, conversion of loader traction
motors would continue at a rate to complete
the remaining 675 motors by January 1st, 1981.
The program would be planned to make
conversions as motors fail and not to convert
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-3')-
the good PCS motors while they are still
in operation.
Five, coal operators using CU-43
or 9 CM continuous miners with PCB-filled
motors would be advised to phase out this
equipment by 1981.
In case of the 9 CM, a conversion
kit could be designed for a new cutter head
at approximate cost of $80,000 to $100,000.
We thank you for this opportunity
to present our views on this important
subject, thank you.
HEARING OFFICER WIRTH: Thank you,
Mr. Warner.
Questions, starting on my right,
Gary?
MR. BURIN: I have two questions.
One is who owns the 9 CM machines?
Are those also the small operators' or are
those —
MR. WARNER: The 9 CM miners.
This is -- thescj are owned by
actually a number of larger customers.
The distribution of continuous miners
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-40-
quite frequently go to the larger coal
operators.
I am sorry I don't have a statistical
count who has the 9 CM continuous miners,
but we could provide EPA with such information.
MR. BURINt Okay.
And how often are loaders routinely
repaired?
MR. WARNER: This varies depending upon
the application that is involved.
In the case of a loading machine,
which is the application in which we have
the largest numbers, the average life as
defined by when 50 percent failures would
take place would be somewhere between 18 and 24
months.
The life of the motors on the 9 CM
and the CU-43 is somewhat shorter.
I am not sure of the figure on this,
but I would guess it was probably closer to
one year.
MR. BURIN: And it would be in the
course of this repair that the conversions
would take place?
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-41-
MR. WARNER: The conversion is possibla
only with the loading machine motor.
It is not possible to convert the
continuous miner motor, but referred to as
CU-43 or 9 CM no conversion is possible
on those motors.
It is an engineering problem in
which the motor has been located on the
machine in such a way and shrunk to such a
size that if you attempt to substitute a
conventional motor, this space is not
available.
MR. BURIN: Thank you.
DR. STURINOt What is the total amount
of PCB in any of those machines?
MR. WARNER: The total amount in any
one machine?
DR. STURINO: Total in any one operation
— are we talking about 5,000 gallons a year?
Are we talking about millions a year?
MR. WARNER: I don't think I can give
you a direct answer to that because it i«
not calculated.
I can tell you that our present
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-42-
inventory of Aroclor is approximately 9,000
gallons.
There are four gallons used in
each motor on the average, and since we are
talking 30 machines in the — say 37 machines
on the continuous miners, we could take 37
times 4 and end up with the approximate
amount of PCB in use on the continuous miners.
All or nearly all of the loading
machines are in operation and this would be
514 machines.
So we could, in that case/ average
it out by saying 514 machines times 2 --
there are two motors, multiply that by four
gallons each and that would be the amount
that is presently in use in underground mines.
I am not sure what that figure would
be --
DR. STURINO: All right, thank you.
MR. SNYDER: My questions are oriented
towards the kinds of environmental exposures
that might occur from the use of the motor
in mining.
You have indicated that the motor
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-43-
shaft seal problem and the vapor pressure
relief point, pressure relief valve, are ycu
aware of any cases where there has been
what I would call a rather catastrophic
failure or some rupture of the case, something
of that nature, where one of these motors
and if so what was referred to — where do the
PCBs go or where would they go?
MR. WARNER: I am aware of the catastrophic
failures when we had hydraulic motors, yes,
I am aware of this.
This is one of the things that really
concerns us and one of the reasons why mine-
safety authorities wanted a fire-resistant
fluid in the motor.
This did occur in the early days
of the CU-1J3.
MR. SNYDER: And those motors caught fire?
MR. WARNER: Pardon?
MR. SNYDER: Did those motors catch fire?
Was there oil-filled motors —
MR. WARNER: No, to my — to the best
of my knowledge, there was no actual fire
resulting from this, but there was a rupture
-------
-UH-
of the enclosure.
MR. SNYDER: Okay.
And you are not aware of any --
with any of the PCB motors?
MR. WARNER: I am not aware of any
catastrophic failure on the PCB motor.
MR. SNYDER: You have indicated two
sources, one the pressure relief valve and
then a motor shaft seal failure?
MR. WARNER: Right.
MY. SNYDER: Are you aware of any other
kinds of failures when motors were in service
to cause PCBs to go out of the motor either
into some other part of the machine or on
the floor around?
MR. WARNER: There are check level plugs
in the motors, and I feel sure that at some
point in time, mine maintenance people could
possibly overfill the motor. In which case,
if it does, it could expel that much to get
down to the proper level.
It would be difficult to say how
many cases like that took place. It is like
the man perhaps overfilling your radiator.
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-45-
It does happen once in a while.
And under those circumstances,
the excess could be expelled to the pressure
relief valve.
MR. SNYDER: What kind of programs do
you have relative to educating and informing
the users when they are involved in some sort
of a topping-off process?
You have indicated you sold one-
gallon quantities of PCBs to various users
and the presumption is for them to fill
motors overheated and whatever.
Is there any kind of program that
you have undertaken to improve the level of
environmental control, reduce burn procedures
— that sort of thing?
MR. WARNER: No, we have no actual
training program to train mining people In
such an endeavor.
This could be accomplished, however,
through the simple procedure including it
in our company sponsored training schools.
We have treatment activity wher^
we bring our customers into our plant and
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-46-
train them for maintenance and operating
people.
And this could be included in such
a program.
I might add, though, going back
to the early days, we did spell out in
considerable detail the type of advice that
we offer to our customers.
I believe it was in 1972 on a
precautionary measures in handling and
disposal.
For instance, if there was a need
to dispose of it to -~ going back or to ship it
back to our shipment center. Consequent
return for consideration.
If EPA does not have a .copy of that
document, we would be glad to supply this.
I believe it was dated 1972.
MR. SNYDER: Well, the purpose of my
questioning is -- is oriented towards your
request, suggestion, that some extended
period of time, several years, what have you,
be allowed for further use of the motors.
And ray thought is what -- what kind of a
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-47-
program could be developed, in a cooperative
way, perhaps, in cooperation with the Agency
or the Agency serving some sort of advisor
role/ critique what you may have done to
enhance the degree of environmental safety
that might be possible in actual use situations.
And so — it sounds like you are
leaning towards that and just expanding a bit
on my question, would that be the kind of
thing that you would consider to be a reason-
able venture in any decision by the Agency
that would extend the use of the motor?
MR. WARNER: Yes, Mr. Sayder, I am sure
this could be done.
As a matter of fact, at the present
time, when we have our training schools
for customers, we already have participation
by Department of the Interior, MESA, the
Bureau of Mines, and other people in offering
to nine maintenance and operating people/
special precautionary and safety measures
that would be practiced in underground mines.
It would be a reasonably simple
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-48-
procedure to set up in conjunction with EPA,
a suitable training program for mine people
that were directly involved in maintaining
this equipment about proper handling and
disposal procedures.
MR. SNYDER: I have no further questions.
MR. BREMER: Two short ones — this is
Karl Bremer.
Primarily, which Aroclor is used?
MR. WARNER: Sir?
MR. BREMER: Which Aroclor are you using?
MR. WARNER: Aroclor? 1242.
MR. BREMER: Okay, 1242?
You don't use any 1016, then?
MR. WARNER: I am sorry — I apologize
— I have a hearing problem.
MR. BREMER: Okay.
It is just an Aroclor 1242?
MR. WARNER: Just.
MR. BREMER: No other, 1016 or any other?
MR. WARNER: I should, I should qualify
that to the extent that we did import PCBs
as EPA knows, and of course when we imported,
it was to our knowledge, a direct substitute
-------
chemically for Aroclor 12*12.
I believe -- this one case, it was
— I had a trade name of Pyrolene or
something of this nature.
But when we used an Aroclor fluid
purchased in the U.S.A., it was Aroclor
MonstantO's 1242.
MR. BREMER: Uh-huh.
And offhand, are there -- can you
name any of the substitutes which you have
attempted to evaluate?
MR. WARNER: I could specifically pinpoint
for you the substitute which we say they tried
and was not successful.
This was TCB, trichlorobenzene,
and we found that this would have been
acceptable in all respects except for this
very pungent odor.
For this reason, we did abandon
that one.
We also evaluated a number of
silicone oils, for example, and unfortunately
the silicone oil will not pass the flame-
resistant properties reauired by -- the
-------
-50-
Mining Enforcement and Safety Administration.
And the other problems were mostly
with regard to the compatibilities of the
fluid with the insulation system in the motor.
MR. BREMER: So this mine safety organi-
zation has tested the silicone oils and they
don't come up to snuff?
MR. WARNER: That is my best recollection,
Mr. Bremer, that is my best recollection.
MR. BREMER: Because we would be interested
in seeing those documents, if they are
available. Okay?
I have no further questions.
HEARING OFFICER WIRTH: Okay, Mr. Biles?
MR. WARNER: Perhaps I should say this way
— I can't categorically state that MESA tested
silicone oil and said that it was not flame-
resistant .
This could have been a matter of
compatibility with the insulation.
I am really not prepared, at the
moment, to speak in detail on those fluids
which were tested and the results.
However, we would be very willing
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51-
to provide EPA with any listing of the
fluids that were tested and the exact
reasons why they were not utilized.
MR. BILES: First couple of questions,,
to understand what you said/ it is my under-
standing that several hundred of the loaders
have been converted.
Does that mean that they no longer
use PCBs?
MR. WARNER: That's right.
MR. BILES: Okay.
And do you know how many companies
use the 9 CM miners?
MR. WARNER: The 9 CM miners, we do not
have an exact count.
As close as we can tell, there are
30 — approximately 30 of these machines
still in operation.
MR. BILES: Okay.
And how many motors are there on
each one of the loaders?
MR. WARNER: On the 9 CM?
MR. BILES: No, on the loaders?
MR. WARNER: On the loading machine?
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-52-
MR. BILES: Yes?
MR. WARNER: There are two traction
motors each.
On each of the two continuous
miners, there were three motors each.
MR. BILES: Okay.
How, it is ray understanding that,
you know, you are not currently, you -- are
not currently processing the machines and
you have no anticipated future production
of them?
MR. WARNER: No, sir, we are not producing
any new equipment or shipping any motors.
MR. BILES: To your knowledge, I know
we can ask Reliance, but as far as you know,
are they continuing to make the motors or
have they ceased production, too?
MR. WARNER: Oh, Reliance?
MR. BILES: Reliance?
MR. WARNER: No, they are making no
motors with PCBs in them.
MR. BILES: Okay.
When I took the figures that you
have suggested on how many gallons per machines,
-------
-53-
it sounded like If you take away the loader,
which you maintain the conversion kit for
and I guess it is mainly a matter of economics?
MR. WARNER: Excuse me?
MR. BILES: That that leaves approximately
450 gallons being used in the continuous
miners.
That the overwhelming amount of PCBs
being used right now is used in loaders which
you say there is a conversion kit available
which --
MR. WARNER: And we are converting
these currently.
MR. BILES: Okay.
What — could you talk a little bit
about what you mean when you said that you
recognized that this is not a totally enclosed
use?
Did you mean by that that — 1
recognize you said there were ? or 3 meams of
escaping PCBs but it sounded like you said
that under normal operating -- operations,
there were no PCBs getting out?
MR. WARNER: Mr. Steinberg asked the
same question.
-------
The reason that I made my statement
that -- the mine motor could not be classed
as a totally enclosed application for PCBs
is simply because I read the article, in
the Federal Register that the EPA had already
concluded that it was not.
And I was simply accepting what
I believed to be your definition to be
totally enclosed.
MR. BILES: Okay.
Part of this hearing and the rule-
making is to define that term.
MR. WARNER: I see.
MR. BILES: Actually what we are trying
to define is what is significant exposure.
So, what I am asking in that
practical application of these machines,
what kind of exposure is there of PCBs beyond
the fact that they might get out through
vapors or as through the leaking through
the motor shafts? Does that -- PCBs escaping
in that manner go anywhere other than first
of all the leaking?
You seemed to indicate that those
-------
-55-
may be caught somehow -- the ones that were
leaking through the motor shaft?
MR. WARNER: Well, the ones that were
leaking through the motor shaft —
MR. BILES: Yes?
MR. WARNER: This leaks into the gear
case — the gear — a gear box -- that is
located directly in front of the motor, in
each case. That is true for all applications.
MR. BILES: Then where does it go?
Does it just stay there?
MR. WARNER: It goes into the lubrication
systems for the machine and that is a gear
case in which lubricants are periodically
added.
It is not usual mine procedure
ever to drain lubricants out purposely.
The mine people normally just
keep adding to the lubricant.
MR. BILES: Okay.
Then, under what conditions would
you see the vapor escape?
Is that normal or is that --
MR. WARNER: With the number one assumption
-------
-56-
that the motor is not overfilled,
MR. BILES: Yes?
MR. WARNER: If the motor is properly
filled, there is an expansion provision
provided for the PCB.
And under those circumstances,
the only expelling would be under a severe
condition such as a winding failure.
Now, even that can be qualified
because it has to be a sustained electrical
fault inside the motor.
Normally, normally the electrical
protection on the machine will isolate that
motor very quickly.
But mining machine maintenance
being such as it is, you can't be 100 percent
sure that that protection is there and
operable.
MR. BILES: To your knowledge, have
either state officials or federal officials,
employees, labor unions, any of those kinds
of groups expressed any concern to you about
PCBs associated with the use of machines?
MR. WARNER: I am sorry, I didn't hear.
-------
— 5 7~
Something about expressing concern?
MR. BILESj Yes, have unions or state:
officials --
MR. WARNER: Unions.
MR. BILES: Or other officials expressed
any concern to you or to your knowledge to
the companies using these machines about
any possible risks associated with PCBs as
far as you are -~
MR. WARNER: No, sir, not as far as I
am aware in our engineering department.
MR. BILES: Okay.
The last question goes to -- the
three year phase-out that you proposed.
Prom what I gather/ your main
argument for needing the phase-out is an
economic one.
That if you were required to do it
— in other words/ you are not going to be
producing these machines any more in the
future even whether or not you have a substitute
right now, that you want to have a phase-out
over a period of time so mainly the economic
impact will not be as great as if today you —
-------
-58-
were forced to say, "No more machines,"
and the companies out there couldn't use
them.
Is that the main reason that you
think the phase-out is needed over a three
year period?
MR. WARNER: Yes.
The reason for displaying the
sequential slides there was to indicate
that It is highly necessary to keep all this
equipment operating simultaneously.
Now, even though a conversion is
available, for example --
MR. BILES: Right.
MR. WARNER: In the case of a loading
machine, if you didn't make this conversion
at the time that the motor failed, for some
other reason, this would be additional down-
time -- additional time that the equipment
would be out of operation.
Therefore, our proposal is to
convert the motor at the time that it electrically
fails.
It was goinp; to be out of operation
-------
-59-
anyway.
MR. BILES: If EPA granted you a use
operation as you propose and three years
from now there wasn't a substitute for the
continuous miners, what — then what do you
think would or should happen?
MR. WARNER: Well, we have taken the
position that -~ at the end of three years
it will be necessary to advise those customers
that those machines can no longer be used.
MR, BILES: Okay, fine, thank you
very much.
HEARING OFFICER WIRTH: Mr. Davis?
Mr. Principe?
MR, PRINCIPE: What is the useful life
of a loader -- approximately in years?
MR. WARNER: I am sorry -~ again, I am
having trouble.
The useful life of —
HEARING OFFICER WIRTH: A little louder,
please.
MR. PRINCIPE: What is the useful life
of the loaders?
MR. WARNER: Of the loading machine?
-------
-60-
MR. PRINCIPE: Yes?
MR. WARNER: Are you referring now to
the loading machine itself or the motor on
the loading machine?
MR. PRINCIPE: The machine itself?
MR. WARNER: The machine itself —
we have to answer that question in the context
of how many times it is rebuilt.
It is common practice in coal mines
to rebuild such specific machinery.
A loading machine, such as the one
here that uses PCBs, motors, might well load
a million tons of coal before the machine
was brought out for a rebuild.
That may take a year or two.
The criteria really can be expressed
in another way and that is to say that we
have many machines out.
They are still operating -- still
being rebuilt. They are 20 and 25 years old.
In fact, in some of the cutting
machine lines, there is equipment in operating
— in underground coal mines that is probably
more than 30 years old.
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-61-
MR, PRINCIPE: Okay.
What is the useful life of the
miners — continuous miners -- like the
9 CM?
MR. WARNER: The 9 CM?
MR. PRINCIPE: And the CU-43? What is
their useful life?
MR. WARNER: Continuous miners -- tend
to be taken out of operation more frequently
than something like a loading machine --
simply because the technology and the develop-
ment of continuous miners is such — that what
you — the coal operator very often finds is
that he must dispose of that machine and
buy a higher productivity machine.
One of the reasons that we state
that it is probably reasonable to assume
phasing-out of these machines by 1981 is
there are much more powerful, more highly
productive continuous miners available so
that in the case of asking the age of the
continuous miner, as far as their actual
utilization is concerned, I am sure they are
good for many more years.
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-62-
Again, in the case of continuous
miners are continuous miners that have been
in operation for 10, 15 or 20 years. But
coal operations tend to obsolete these
machines themselves simply because they can
buy higher productivity machines.
MR. PRINCIPE: And you think that by
1981 that point would be reached for those
PCBs?
MR. WARNER: There are already machines
available at much higher productivity --
machines either the CU-43 or the 9 CM, they
are already available today.
MR. PRINCIPE: Is there a secondhand
market available for these machines, like
could a coal miner resell it to a --
MR. WARNER: Yes, yes, there is quite
an active used machine market for machines
and very often the small operator will tend
to buy a -- secondhand machinery.
MR. PRINCIPE: All right.
How long does it take to use the
kit or to — when the loader motor, traction
motor dies, and it's got to be rebuilt, how
-------
-63-
long does it take to do that problem?
MR. WARNER: To rebuild it?
MR. PRINCIPE: Yes -- using — using
the conversion time?
MR. WARNER: It would depend a great
deal, at one — any one time, what happens
at the service center as to what their backlog
and repair were.
But, I would say that — from the
time a motor was taken off the machine,
shipped back to a service center, repair,
return and install the machine, it would be
fair to say that — at best, a week would
take place.
It could be longer, but I would
say that a week would be a reasonable period
of time.
MR. PRINCIPE: So all three rebuilding
of these motors is done at your facility?
MR. WARNER: Yes.
We have three facilities, actually,
now,that — are rebuilding and we are pro-
posing consolidating this rebuilding in a
single facility.
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-64-
MR. PRINCIPE: Does it take longer
to convert the engine or is it -- does it
take longer to convert the engine bark to
air than to do the normal rebuild that you do?
MR. WARNER: No, actually the rebuild
or the conversion to the conventional con-
struction is such that you supply a lot of
new parts for the motor internally.
So that I would say there is not
a great deal of difference between the time
that it would take to restore it to its
original PC built construction or whether
you would actually convert it.
MR. PRINCIPE: Well the miner is out
of use for the week that it is dead, aside
waiting for another engine, another motor,
I assume there are additional loaders or
shuttle cars available to take its place
in the mines, is that correct?
MR. WARNER: In some instances -- for
a large coal producer, you could have expected
him to have possibly a stand-by machine,
and if not, possibly a spare motor or two.
Now, for those people who have
-------
-65-
that investment, and have that capability,,
obviously they don't get hurt from the time
point of view.
But, my point in outlining the
profile of a smaller customer was to indicate
that we had 36 customers that had only one
machine.
You can be quite sure they don't
have any backup.
MR. BILES: During the rebuilding opera~
tion, is there a significant exposure to be
— not exposure to the workers, that is not
our concern, I guess, but is there a loss
of PCB at any point during the rebuilding
process — a conversion process?
MR. WARNER: In the rebuilding process,
this is something that has been discussed
in quite considerable detail between our
service center personnel and EPA personnel.
As I have said, we have had two
visits from EPA and they have made a number
of suggestions which we have adopted.
These are such things as concentra-
ting the area — restricting the area during to
-------
-66-
which the repair work is confined and to
also confining the number of personnel that
are actually involved in the procedures.
They have screened such things as
our activity to return for insertion
and also the disposal methods that are
presently used on the solid waste that is
hooked up that may have PCB contaminated
in it.
But all of these things have been
reviewed by EPA and to the best of my know-
ledge is in accordance with your recommenda-
tions .
MR. PRINCIPE: Is it within the scope
of your company to rebuild all of the loaders
in the space of one year -- if that was
required?
MR. WARNER: There have been in the
past -- a small number of competitive facilities
that have attempted to repair these motors.
But they are handicapped two ways,
One is they don't know the technology
of the compatibility between the fluid and
the insulation system and customers who
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have tried these competitive repairs find
that the life is so short that not many
of them have stayed in business.
The other thing is, of course,
the difficulty of these people getting PCEi
to replenish the rebuilt motor.
MR. PRINCIPE: My question is is that —
if we required that all of the loader motors
be converted within the space of one year,
could your company do that? In other words,
do you have the facilities to convert all
of the PCB loader motors to non-PCB loader
motors in the space of one year?
MR. WARNER: Here I am attempting to
speak to our service center facility.
We are presently doing this in
three service centers now.
So, if you concentrate it in a
single facility, it becomes more difficult.
The other thing is that the rate
-- we -- this is obviously only one motor
that we convert or excuse roe, rebuild.
We rebuild all of the various
motors on Joy mining equipment so the PCB
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-6R-
motors only represent a small part of what
is done.
Your question is could we do
this in a single year period -- I assume
at a single facility.
The answer to this might be yes,
but it would be highly dependent, I am sure,
on expanding the present facility that we have
-- because at the present time, we don't
have capability to do it all in one year.
MR. PRINCIPE: Okay.
Suppose that at the end of three
years we said that you couldn't use continuous
miners any more, and they would have to be,
you know, removed from the mines — do you
have any idea of what would happen to those
miners if they just were left off to the
side to rust or what does a mining company
normally do with old equipment?
MR. WARNER: I am not sure I could teli
you the answer to that.
When machines are taken out of
operation, they are very often brought
outside the mine.
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D y
I suppose all ultimately dismantled
for scrap -- that's usually what happens
to a -- to a used piece of machinery that
is no longer in operation.
MR. PRINCIPE: Okay, one more question.
Did the 9 CM cutters have the --
redesigned cutter head?
You suggest it is possible to use
a non-PCB motor head that cost $80,000 to
$100,000 -- it feels much more reasonable
to buy a new machine, wouldn't it?
MR. WARNER: Yes, obviously the 9 CM
originally sold for $120,000.
And the figure I gave you on a
conversion just for the cutter head was
$80,000 to $100,000.
He would have to ~- want it pretty
bad to convert that machine in order to
make that kind of investment.
MR. PRINCIPE: That you.
MR. WARNER: In other words, it is
really not a practical conversion from a
dollar point of view.
MR. PRINCIPE: Thank you.
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HEARING OFFICER WIRTH: Mr. Pratt?
Mr. Pearson?
I just have one question, Mr. Warner.
In calculating on the numbers you gave
for the number of motors -- there are roughly
3,000 gallons in the machines that are in
current use that is the miners and the loaders.
If I understand you correctly,
you said your current inventory was 9,000
gallons?
MR. WARNER: Yes, sir.
HEARING OFFICER WIRTH: How long would
it take to go through that 9,000 gallons --
in let's say current rates on rebuilds?
Do you have any idea on that?
MR. WARNER: Again, I am afraid I would
have to go to some arithmetic, Mr. wirth,
to answer your question.
I do know this, that when we
looked at our inventory, we felt quite sure
that the 9,000 gallons was far more than
adequate to complete our program on the
basis proposed.
Because obviously, as you convert
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motora, the use both in the service center
and the small amount used by a customer
is declining. So there is no question in
our mind whatsoever that the 9,000 gallons
is completely adequate -- in fact, we end
up with, I am sure, with a surplus.
HEARING OFFICER WIRTH: You in fact
end up with a surplus?
MR. WARNER: Oh, sure.
HEARING OFFICER WIRTH: Have you in fact
heard of miners -- I take it you would not
then be importing any PCBs or --
MR. WARNER: I am sure we will be
importing no more.
HEARING OFFICER WIRTH: Okay.
Is there any question from the
audience?
Okay, thank you very much.
The next witness is Mr. John Hesse,
the Michigan Department of Natural Resources.
MR. HESSE: My name is John Hesse
with the Michigan Department of Natural
Resources.
I think most of the panelists
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~ 7 2 —
are aware that Michigan has in effect now
legislation already banning PCBs for many
uses and we have talked to you many tines
about this.
I'll address or have a few c6mments
regarding the announcement in the Federal
Register of this meeting.
I will take the general issues
pretty much in the order in which they
were outlined.
First, the totally enclosed manner
or issue over significant versus insignificant
exposures.
We don't believe that there is
adequate information to determine that
there is some type or level of exposure to
PCBs which could be called insignificant.
For an example, fish in Lake
Superior are accumulating PCBs up to 60 parts
per million and their tissue has been
exposed to less than one part per trillion
in the water.
This type of biomagnification
potential for PCBs alone negates the
probability of insignificant exposure.
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To my knowledge, also, Dr. James
Allen from the University of Wisconsin has
not yet determined a no-affect level in
his rhesus monkeys exposed to PCBs in
their diet and also supports the conclusion
that we simply do not know enough about
the effects to deem any exposure insignificant
From language in 6(e)(2)(a) of the
Act, it appears clear to us that exposure
during manufacturing processes was intended
also to be relevant to the definition of
the totally enclosed manner.
And we questioned whether the
manufacturing industry has the capability
to eliminate all environmental losses or
employee exposure so as to qualify under
the definition.
If not, then it seems that the
one year and the two year phase-out dates
of the ban are sort of redundant.
But Michigan can't speak to this
with authority because we haven't had to
address this question because we don't
have any PCB manufacturers in our state.
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74-
Under the Category 2, 1978, of
exemptions in Michigan, we have limited
our definition of PCB use enclosed systems --
says that in electrical transformers and
capacitors and therefore allow for the
continued use of PCBs for these applications.
Although we recognized that environ-
mental losses can occur through accidental
rupture or leakage from these devices, or
through incorrect disposal practices, we
have chosen to allow these uses but apply
strict control in reporting requirements
upon the user thereby minimizing environmental
losses.
These requirements in our program
require that -- include the filing of pollution
incident prevention plans covering such
actions as diking around transformers or
relocation of capacitors away from drains
or water courses and also the development
of cleanup and disposal procedures.
From past experience, we do not
think other or any other categories of PCB
use can be similarly controlled and we
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strongly encourage that no other use exemptions
be allowed.
Hydraulic fluid applications and
heat transfer system uses were among the
most commonly detected sources of PCB losses
in Michigan surveys and especially should
not be considered.
But to allow for continued use of
PCB-filled transformers, we feel special
provisions need to be made for transformer
service companies who provide routine maintenance
for such units.
Without servicing, we would expect
that the life span of the units would be
shortened drastically and unnecessary
fires may result.
Yet we still believe that a high
risk of exposure and environmental losses
likely exist in such facilities.
We will be interested in hearing
additional testimony on this subject and
encourage JSPA to require strict spill control
measures and disposal requirements if
this activity is allowed.
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Under the 1979 exemption category
or issue, the 1979 ban against manufacturing,
it appears that it may be academic since
Monsanto plans to phase out the manufacturing
of PCBs by this fall.
The ban against distribution would
still seem to be pertinent, though, in
order to limit importation.
With regard to existing stacks,
we feel they should be used for servicing
of transformers only.
And that any excess that would
be left over from that should be destroyed
by incineration.
Under category 4 or Item 4, the
resale of PCBs, it appears that the phrase,
"sold for purposes other than resale",
should be interpreted to allow transformer
servicing companies and individual industries
who buy stockpiles of PCB fluids for
servicing of transformers to use these
fluids following the July 1979 deadline
on distribution.
Strict control over the storage
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— 7 7 —
areas, though, must be a prerequisite.
In addition to our comments on
these specific issues, we feel some provision
needs to be made for residuals of PCBs
remaining and retrofitted equipment such as
heat transfer systems, hydraulic systems
and transformers.
It is important to remove -- no,
it is impossible to remove all PCBs in
these systems.
Michigan's experience indicates
that with the conscientious effort toward
repeated flushings of hydraulic systems,
the residual can be reduced below the 500
parts per million cutoff selected by EPA
in its proposed disposal and labeling
regulations.
We have a number of them that --
a number of industries that have reported
concentrations in these transformed hydraulic
systems that range between 100 and 300 parts
per million.
Records on one heat transfer system
in a Michigan industry show a PCB residual
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-78-
after flushing of 3,750 parts per million.
Retrofitted transformers are
likely to have a residual of one to two
percent PCBs.
Michigan has exempted some of
these systems and allowed their continued
use, but these are not exempt from our
labeling requirements and the retrofitted
fluid containing the PCB quantity must be
ultimately disposed of as if it were a PCB.
In Michigan our law automatically
allows for use of products containing 100
parts per million or less.
Through the implementation of
our PCB Control Act which went into effect
in April, 1977, we will soon be able to
supply EPA with a breakdown of total PCB
quantities being used in capacitors con-
taining more than 3,000 PCBs in Michigan
and transformers, their average size and
the number of industries reporting use of
each.
Our questionnaire booklets were
mailed to about 15,000 facilities in
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-79
Michigan and through a single follow-up
letter, to those non-respondents who have
received an extremely high percentage
return.
When available, and we expect
this might be available within a couple
of weeks, we can provide you with a
statistical summary of this information.
And that is the end of my prepared
comments.
HEARING OFFICER WXRTHt Okay, thank
you very much, Mr. Hesse.
Questions, Gary?
Questions? Mr. Biles has a question
MR. BILES: Do you have any regulations
right now concerning maintenance operations
and how it is to be performed?
MR. HESSE: Servicing of transformers?
MR. BILES: Yes?
Do your regulations say how it
should take place?
MR. HESSE: Not specifically addressing
the servicing.
This is something that we did not
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-80-
take into consideration in terms of our law
that -- where we realize we are allowing
the continued use of PCBs in those closed
systems, but we have not made provisions
for the servicing. So we have considered
that we were going to have to make exceptions
for the transformer servicing industry.
Our only regulations would be those
involving the filing of a pollution incident
prevention plan at each of those facilities
and also the disposal of the materials from
the operation.
MR. BILES: Do you think it is practical
for the federal government to try to
specify some minimal procedures to be
followed?
MR. HESSE: I would hope so, yes.
MR. BILES: Michigan and several other
states in this area have enacted laws or
have enacted regulations on PCBs.
I think that was partly the fact
that there was no official regulation in
this area.
Do you have any feel for what the
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_ Q 1
O J. '
state's attitude is going to be now if EPA
or when EPA promulgates its regulations as
to whether yours should continue in effect,
whether you are going to want some exemption
to continue yours in effect?
I am not asking you to go through
your regulation and tell us reg by reg or
just your general feeling about the federal
government's role as compared to the state's?
MR. HESSE: Well, I think Michigan's Act
is every bit as — I was going to say every
bit as restrictive as the Federal regulations
appear to be going, but we will have some
areas of conflict.
In terms of the lower limit that
we allow, at 100 parts per million rather
than 500, I think we will go ahead and
adopt the 100 parts per million.
In terms of the labeling, it
appears that our label will not be in conformance
with Federal regs.
We would probably choose to adopt
the Federal label in that case because we
want to be, right from the start, we want
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-82-
to be in conformity on a national basis
with that.
MR. BILES: With regard to hydraulic
fluids, if we prescribed any kind of
requirements on systems that previously
had PCB containing hydraulic fluids, if
we did anything, should we do anything
beyond prescribing some kind of flushing
procedures?
I know that there are some companies
in this area that have some kind of distilla-
tion processes for systems.
MR. HESSE: I don't know, it is bothering
some that we know of continued losses ~-
it is hard to decide what is continued losses
from the new, from the residual of the left
and the new fluids from what it might be
losses from the existing discharge lines
and so on.
We do note, in some of these
discharges, from plants where the hydraulic
systems are used to have PCBs -- we still
see PCBs coming out in the discharge.
And I don't know what the solution
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-83-
to that is.
They would not be meeting the
zero discharge limitation of the federal -•-
or the -- the effluence guidelines if they
were divided across the board to all industries
MR. BILES: Do you think that EPA
should continue -- should authorize to
continue the manufacture of transformer
capacitors during '78?
MR. HESSE: The manufacture?
MR. BILES: of the capacitors and of
the transformers?
I recognize that there are none
of those operations in your state?
MR. HESSE: Yes.
I don't know how effective the
controls can be within these manufacturing
facilities.
Just judging from what we have
read about the Hudson Falls plants in
New York/ we have quantities of PCBs that
were being lost there.
It just didn't seem reasonable
that you could interpret those as being in
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-84
totally enclosed operations.
Now the manufacturing operation ~-
so we see that there is some conflict there
appearing in the 1978 phase, in step.
But I don't know for sure what
you ought to do.
I — Just supply the best control
as possible if you do allow it.
MR. BILES: Okay, and the last question,
have you expressed any of the waste problems
or sludge problems and what do you suggest
we do, if anything, in those areas?
MR. HESSE: Back in about 1971 or 1972,
I expect that we had, prior to looking, we
probably had concentrations of PCBs in some
of the municipal sludges in the neighborhood
of a thousand parts per million.
But in 1973, when we first made
a general survey of municipal sludges, the
highest we have found was 350 parts per
million, and we had already instituted a
control on the industry that was contributing
greatest to that source.
Since that time, the level in
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-85-
that plant, and all the other plants
have decreased to in the neighborhood of
one to five parts per million, maximum,
in municipal sledges.
And so we don't view this as a
real critical situation, in Michigan, right
now.
We have no existing guidelines
on the use of sludges in terms of the maximum
value of PCBs in them.
I have heard some statements that
10 parts per million is being considered as
maximum level.
I don't think we would see that very
often.
What was your other question?
MR. BILES: Waste Oils?
MR. HESSE: The waste oil — we have
made a survey of the concentrations of PCBs
in waste oil in Michigan, and it appears
that the general level is very commonly in
the range of 1 to 20 parts per million.
This falls below the 100 parts
per million maximum in our law, and, there-
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-86-
fore, we don't know that we can legally
go after that unless we consider it a secondary
contamination that was caused by the
particular industry owning the oil at that
time.
Then we would have some authority
over itr and we do plan on implementing
that authority where it is practical.
So that that oil is used in the
— in a manner so as to minimize the environ-
mental losses from it.
Where a waste oil is received
by another industry that was not responsible
for the inclusion of PCBs, I think our
position would be, at this point/ to exempt
them through our incidental PCB contamination
clause in our Act.
MR. BILES: Thank you.
HEARING OFFICER WIRTH: I want to ask
a question along the same line.
Are you aware of any other products
that have contaminants — in your surveys
at work -- what products have contaminants
of PCBs which are within the a hundred to
100 and 500 parts per million level?
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When you move from 500 to 100,
what things would you include as a definition
of a PCB?
MR. HESSE: Well, I think the trans —
the hydraulic systems have been converted,
they do fall between 100 and 500 in some cases.
So they would be affected by our Act and not
yours.
Another one, there is a foreign-
made compound used by some industries in
the United States that we have not investigated
very extensively, but it has come to our
attention that in some cases it has PCBs
entered as a contaminant. And this is
diphenylacetylene, dial, I am not sure how
it is pronounced.
This appears addicting. The con-
centrations range anywhere from 200 to 1,500
parts per million of the lower chlorinated
forms of PCBs.
HEARING OFFICER WIRTH: How about
hexachlorobenzene?
MR. HESSE: I was unaware that hexa-
chlorobenzene had PCB contaminants in it
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-88-
until just recently. And I think I did read
somewhere, but I have no personal knowledge
of it.
HEARING OFFICER WIRTH: And you say
most of your sludges with a pre-treatment
program of some type or a control on indus-
trial discharges to it — now all less than
five parts per million?
MR. HESSE: Yes.
HEARING OFFICER WIRTH: In all cases,
to bring them down to that level, it was a
point source of discharge in your municipal
systems that you had to go against runoff.
MR. HESSE: That's right.
In our -- in the plants that had
the highest levels, we went into the distribution
systems, the interceptor system with treat-
ment facilities, and were able to trace back
to the originating source and apply controls
at that point.
And apparently it's been effective.
HEARING OFFICER WIRTH: Any Other
questions? Mr. Pratt?
MR. PRATT: Yes, I have a couple, I have
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-89-
a couple of questions, John.
In Michigan's problem — two
questions in part.
In following-up on industries,
the automotive industry and some of the
others, who are tremendous purchasers of
PCBs and with millions of pounds of PCBs
were lost in the Great Lakes or Great Lakes
environment, there has been substitutes
that have been instituted for these.
What work has the State of Michigan
done, one in following-up the specific plans
with the substitutes and what potential
it does have and two, in the manufacture
within the state of Michigan who are pro-
ducing substitutes as to potential effect
of these?
MR. HESSE: Well, the primary substitute
for the hydraulic fluids appears to be the
phosphate esters -- the ones that we are
aware of, anyhow, that have converted.
And we have not done any environ-
mental sampling for the triorial phosphates
that these belong to.
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-90
And we are — have been communi-
cating with the federal government frequently
on this subject and we will be glad to
participate in any kind of a study that
EPA might want to do.
And we are aware that there is
apparently contracts have been let to study
phosphate esters.
In terms of the substitutes by
manufacturers in Michigan, I assume you
are talking about the silicone fluids and
the Dow products for capacitors.
We haven't done any environmental
testing on those substitutes.
MR. PRATT: As far as on the disposal
of sludge/ back when you found that some of
the sludge contained 350 or 1,000 milligrams
per liter of PCBs, what has been the
ultimate disposal of the sludge and what
steps has the state taken in this?
MR. HESSE: Likely, I don't believe
any of the high contaminated sludges was
used for agricultural purposes.
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-91-
The worst situation that we had,
the sludge was being incinerated in the
municipal incinerator and probably not
satisfactorily to completely destroy the
PCBs .
But I imagine if a percentage
was destroyed, the rest went into the
atmosphere was redistributed.
We are in the developmental
stages of sludge disposal guidelines at
this point. And we find it very difficult
to adjust the PCB issue from lack of guidance
in terms of what is significant being applied
in various applications.
MR. PRATT: Looking at the Great Lakes
at some data from some other people, where
there has not been a particular decline in
the Great Lakes, like DOT which is quite
similar biologically to this, it has dropped
off quite rapidly.
It appears that there are still
major sources of PCBs getting into the Great
Lakes.
And since, shall we say the auto-
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-92-
motive industry and others have not used it
for several years, would you attribute this
in large part to things like incineration
of sludge to PCBs in waste oil to the
incineration of electrical appliances, to
all of these various sources or what ideas
do you have on this as far as controls of
PCBs?
MR. HESSE: Well, it appears through
the various math balance studies of two or
three firms have come up with, that the point
source losses that we were finding in your
surveys directly to water were very insigni-
ficant contributions to the Great Lakes
environment in terms of total PCB input.
That the majority of the input
was coming from atmospheric deposition.
And this atmospheric contamination
undoubtedly was the composite of all types
of sources such as those you mentioned.
This is why we felt that the ban
on the usage was entirely necessary to
bring the Great Lakes contamination problem
under control. And that it had to be more
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-93-
than on a single state basis that it had
to be on either at least a regional basis
or a national basis and finally we do
have it on that basis.
So we are hopeful that now, when
this Act goes into effect, we will start
seeing the same decline that we did for DDT.
But I don't think we have had
complete control on PCBs up to this point
that we had with DDT in 1969 and '71.
MR. PRATT: On the level of PCBs and
waste oils and other materials, you initially
said that as far as like Lake Superior is
shown that you needed to get as near as
possible -- wouldn't, therefore, these levels
residuals of 500 or even 100 parts per million
of waste oils released still be a significant
source both as far as to the Great Lakes or
other water waste contributing to the whole
atmosphere of the earth as well as possible
worker impairment?
MR. HESSE: Well, we haven't aeen any
as high as 100 or 500 in waste oils.
I think 20 is the maximum -- 20 parts
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-94
per million.
It's been very difficult to
evaluate what kind of environmental impact
that 20 parts per million has.
In terms of the Great Lakes environ-
ment or any other portion of the environment
— I just can't put it in terms that I can
easily grasp.
I think we figured out that 20 parts
per million — in Michigan's waste oil
stream, if we use that as a maximum or an
average, even, that this would only amount
to 100 pounds or so of PCBs which is equiva-
lent to maybe one transformer.
Spread out over the entire Great
Lakes area, I don't know how significant
that is.
I am sure it adds to the problem,
but I don't know whether we can -- we can
really do anything about it at this point
other than make sure that no additional
disposal of PCBs is made so that it gets
into the waste oil stream ~- attack it at
its source rather than the already contaminated
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-95-
oils.
MR. PRATT: We found in a couple of
the Great Lakes states such as Ohio/ where
they have commonly had 500 million grams
per liter and why it is almost in a deliberate
combination of the transformer fluid or
other materials into the waste oils, to lend
them down to quote acceptable levels, as they
saw it, how much have you seen of this in
Michigan of the potential problem?
MR. HESSE: I suspect that the purpose-
ful addition of PCBs to waste oils was very
common in the past, before the high level
of concern became apparent or well publicized.
I have not seen any evidence that
people are intentionally diluting it down
into waste oils now to get under the maximum
limits of our law.
This could be going on, but this
is not an acceptable way of disposal of
PCBs even if they are diluting it down to
less than 100 parts per million, our law
forbids such an application, and I Just
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_Q C. _
y v
don't have any records that it is being
done — I hope that it isn't.
But I assume that waste oils
were probably much higher in PCBs in the 1960's
than they are now with all the publicity.
It may have contributed very much
to our atmospheric loading of PCBs, I feel.
MR. PRATT: Does Michigan, this is
the last question —
Does Michigan have a program, and
I should be more familiar with it than I
am, but in Michigan, what controlling do you
have over waste oils that come across state
lines that come into the state of Michigan?
In other words, do you require
any type of certification on these?
MR. HESSE: No, I am not aware of any.
MR. PRATT: As we know in this last
fuel crisis we had last winter where we had
waste oils that were shipped from Ohio to
Minnesota to Arkansas that contains PCBs,
hexa wastes, and a number of other highly
toxic material.
You have no program for evaluating
-------
-97-
this as they come into Michigan?
MR. HESSE: No.
MR. PRATT: Thank you.
HEARING OFFICER WIRTH: Mr. Pearson?
MR. PEARSON: Yes, I have one.
HEARING OFFICER WIRTH: Okay.
MR. PEARSON: You mentioned that you
have -- advocate allowing the service centers
to continue to use them for stockpiles of
PCB fluids in servicing transformers, is
that correct?
MR. HESSE: I felt that that was a
reasonable action — if we are going to allow
the continued use of transformers, we have
got to allow some servicing other than —
it seems like the two decisions go hand in
hand.
We could go -- say — okay, let's
say we will take all of the transformers out
of use right now or -- let's let them be
used throughout their entire lifespan, and
if we go one way, we might as well go, all
the way and allow them to be serviced, but
apply appropriate controls on that servicing.
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MR. PEARSON: But that use extends to
used transformer fluids that have been
reconditioned.
Have you thought about that?
MR. HESSE: As long as the reconditioned
fluids were going back into transformers,
I see no difference there.
We are aware of at least one
situation where transformer oil has been
taken out of transformers, and put into
another application/ and we very much
oppose the use of transformer oils in open-
ended systems such as the one we have found.
MR. PEARSON: Had you considered the
possibility that it may be advisable to
continue manufacture of PCB fluids in order
to service these transformers?
MR. HESSE: No, I think at that point,
we have got to draw a line and as soon as
the existing stocks of PCB fluids are depleted,
then let's don't/ let's stop the use of
those transformers, let's let that be
their natural lifespan at that point.
MR. PEARSON: Okay, that is it.
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-99-
HEARING OFFICER WIRTH: Okay, is
that all, Mr. Pearson?
MR. PEARSON: Yes.
HEARING OFFICER WIRTH: Any questions
from the audience?
Thank you, Mr. Hesse.
We will take one more witness
before we adjourn for lunch to get everyone
in today.
Mr. Richard Rollins of the
Electronic Industries Association or Richard --
MR. ROLLIHS: No, Mr. Tylenoa (phonetic)
will not be here.
HEARING OFFICER WIRTH: Okay.
MR. ROLLINS: My name is Richard Rollins,
and I am speaking today on behalf of the
Electronics Industries Association and its
committee on the PCS, yes.
Today, we would like to offer
comments on two issues that were contemplated
in your subject request.
One is the intended meaning of
"totally enclosed manner", and two, the
intended meaning of, "for purposes other
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-100-
than resale".
Number one, the question on the
first issue, does totally enclosed manner
refer to exposure resulting from the manu-
facture of PCBs or articles containing
PCBs?
It is our contention that the
legislative record is clear and eliminates
this question ambiguity.
Senator Nelson, for example, when
introducing his PCB amendment in the daily
edition of the Congresional Record in the
Senate, March 26th, 1976, indicated that the
use of non-enclosed PCBs such as carbonless
paper, paints, coatings, soaps, and coffee
and ink toners quote would be banned in one
year after enactment comma while end of quote.
"AllPCBs used comma including closed uses
such as electrical capacitors and transformers
would be banned in two and a half years
after enactment".
Senator Tony (phonetic), in the
above-referenced to the Congressional Record,
also understood that the amendment phases
-------
-101-
PCBs out by eliminating non-closed systems.
Non-closed systems uses, within
one year, and eliminated PCBs altogether
within two years.
Further clarification is shown
by Representative Dingle's (phonetic)
comments.
Upon introducing his PCS amendment
in the daily edition of the Congressional
Record, August 9, 1976, where he indicated
quote "This proposal would prohibit any
person from manufacturing, processing or
distributing in commerce any PCS for any
use other than a use in a totally enclosed
manner" end of quote.
In the Joint Conference between
the House and the Senate on the PCB Amendment
to the Toxic Substances Control Act, no
disagreement existed in the fine language,
and it is thus apparent that only cosmetic
changes occurred there with no attempt to
alter the meaning from the original versions.
We, therefore, conclude and suggest
to the EPA that the words, "totally enclosed
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-102-
manner", were intended by Congress to refer
only to the product uses and not to the
manufacture of the product.
Point two. The intent of the
Congress as to the meaning of the phrase,
"for purposes other than resale", is made
clear by examining the Representative Goode's
(phonetic) supporting arguments for
Representative Dingle's PCB amendment and
I quote, "As my colleague, the gentleman
from Michigan, Mr. Dingle, has pointed out,
this amendment does not specify replacement
of PCBs in existing equipment or the equip-
ment itself."
New language that we have added
to the Amendment makes it clear that the
distribution as well as the resale of PCB
containing equipment manufactured prior
to the ban is not prohibited.
This would apply to such everyday
products as air conditioners.
Subpoint, the PCB ad hoc committee
of the EIA further urges that the EPA classify
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-103-
distributors of replacement capacitors in
the category of purposes other than resale
for the following reasons: One. Distributors
of replacement components such as capacitors
provide a valuable service to the consumer
by facilitating care in installing equipment.
Without this service, the consumer
cost of the function equipment could increase
significantly due to premature purchasing
of replacement equipment as the manufacturers
could not supply the distributors.
Minimum inventories of a wide range
of capacitor ratings roust be available at
the distributor's in order to service his
account.
Two, between January, 1978, and
July, 1979, only one full selling season
for distributors will have occurred.
Thus, much of the present inventory
at the distributor level will exist in mid-'79
As there are many distributors,
the potential exists for quantities of
capacitors containing PCBs to be improperly
disposed if their inventories are not
-------
-104-
cocunitted to diminish by attrition.
Three. Further, not permitting
the gradual reduction of inventories, may
cause a retrofit problem since the PCB
substitute capacitors will be too large
to be installed in some applications,
again hastening the discarding of equipment.
Four. Finally the impracticality
of enforcing the ban at this level suggests
the allowance of a more appropriate alterna-
tive.
This concludes my remarks and I
thank you for your attention.
HEARING OFFICER WIRTH: Thank you very
much.
Any questions -- Gary?
MR. BURIN: No.
HEARING OFFICER WIRTH: Dr. Sturino?
DR. STURINO: No.
HEARING OFFICER WIRTH: Mr. Snyder?
Blake?
MR. BILES: On your discussion of "totally
enclosed manner", the -- obviously you
have hold, as we have with legislative
-------
-105-
history, you are trying to get some feel
for what Congress intended for us to even
reach these regulations are.
The language before the -- is
quite different than that that appeared
in the final Bill.
The House and the Senate Bills both
said that totally enclosed manner, any
manner which insures any leakage from any
closure is significant.
And, as you know, the final Bill
said, "any manner in which exposure of
human beings or the environment is insignifi-
cant".
Now, our question is — is a lot
of the issues that EPA over the last two
years has faced dealing with PCBs have
been associated not only with the fact of
you all putting PCBs in a sealed components
-- in fact I doubt that you have seen EPA
trying to build a strong argument that once
in a capacitor it represents a great risk
during the time the capacitor is being
used -- obviously we feel that the disposal
-------
-10 6 -
problems are significant.
A lot of the problems we have
faced have dealt with the facilities and
the surrounding contamination of the
environment itself.
And my question is is it your
position that Congress did not intend to
— TSCA to be directed towards the problems
associated with your facilities?
MR. ROLLINS: That's correct.
MR. BILES: So that your position
would be that during 1978 as long as some-
body is making capacitors or transformers,
TSCA doesn't even apply?
MR. ROLLINS: That's correct.
We would like to add that we, as
manufacturers, had taken many steps and you
are aware of them to control the effluence
containing of these PCBs both air and water
and we are all voluntarily living with the
guidelines as reported out of the American
National Standards Institute back in 1974,
and we believe that no useful purpose is
going to be served by going further on
-------
-107-
the manufacturing operation in this particular
time span of January of '78 through January
of '79.
MR. BILES: What do you think Congress
was addressing when it changed the language
from "no leakage from an enclosure to no
significant exposure to humans or the
environment"?
That certainly is a change in the
language.
And the first specifically addresses
leakage from a discreet component of this
oil — I think.
And the second, of exposure to
humans and the environment?
MR. ROLLINS: We believe it waa more
of a cosmetic change rather than the intent
to change the meaning of the two versions
that were in the House and the Senate.
If we go back to the record, both
in the House and the Senate, we see that —
the attention seems to be the same, and to
make a modification there, a conference
without having a report out as to why that
-------
-108-
change occurred, seems to imply that the
intention was not changed.
MR. BILES: Although both versions had
— both versions were changed in conference,
do you think that that was a cosmetic
change?
MR. ROLLINS: Yes, we do.
MR. BILES: There was no intent to
make any change?
MR. ROLLINS: No, we did not believe
there was.
MR. BILES: If EPA took the position
that states from your facilities, associated
with manufacturing, are covered by this Act,
that does not mean that EPA is saying you
therefore cannot manufacture capacitors?
MR. ROLLINS: Yes.
MR. BILES: We had discussed those
situations.
If EPA took that position, how
long do you think it would take for either
your company or, I guess representing
capacitors' manufacturers, how long would
it take the industry to use up the liquid
-------
-109-
PCBs that are in stock either as of now,
or as of the beginning of next year,
putting them in the capacitors?
MR. ROLLINS: Within a year.
MR. BILES: Do you believe that it
will take you —
MR. ROLLINS: The maximum of one year.
MR. BILES: Do you think that it will
take less time?
MR. ROLLINS: Yes.
MR. BILES: Do you have any idea how
long?
MR. ROLLINS: That will be an individual
company's decision, but it will be less
than one year, probably significant.
MR. BILES: Okay.
The last question goes to your
issue of people that are handling capacitors.
To understand what you are saying,
are you saying that if somebody purchases
capacitors prior to the middle of '79 and
then uses those capacitors to repair the
equipment of some sort, and in that second
transaction there is some kind of, you know,
-------
-110 -
money exchange, you know somebody is paying
for that service, that that person is not
reselling a capacitor?
MR. ROLLINS: We are asking you to
review that language under that guideline
because we believe it would cause more
disruption than would provide any benefits
to the environment.
MR. BILES: Okay, thank you.
HEARING OFFICER WIRTH: Mr. Shykind?
MR. SHYKIND: I have a question.
One point which disturbs me greatly
is the -- the secondary market for replace-
ment to capacitors.
We have, in this room, that elegant:
TV set they are taking our pictures with,
and the last 10 or 15 years we have been
making most of the electronic component:)
for commercial specifications or industrial
specs as well as with PCB capacitors with
reason.
If we cut off the manufacture,
is it possible to develop in terras of
electrical capacity, safety,, exact replace-
-------
-111-
ments for January inspection, multi-inspection,
capacitors that will fill the replacement
of secondary --
MR. ROLLINS: The question is a matter
of tine rather than whether it is a functional
situation.
We have heard this morning, we
have mentioned many times before, that the
polychlorinated biphenyl has a special
characteristic in its unflammability and
the substitutes will not have that. It is the
requirement upon the manufacturers to insure
that the capacitor enclosure does not allow
this fluid to get out in the environment
and cause potential fires.
And this is a major concern of the
capacitor manufacturers.
We are in the evaluation stages
at this moment, and there are some people
who have the — a substitute available, but
there are many others who are not yet ready
with their substitute.
The question of, if you were to
stop today, would you have an adequate
-------
-112-
supply, the answer is absolutely not.
MR. SHYKIND: What happens to the
multimillion or multibillion dollar
secondary business in surplus electronics
either in the government or some manufacturer's
overrun?
They are companies that specialize
in capacitors and transformers.
Would they then be out of business
in July of '79?
MR. ROLLINS: We believe that there --
as John Hesse from Michigan has indicated,
that there is --• there should be controls
on the addition of equipment containing PCBs
into new applications, even if it is on a
resale basis.
But on a small capacitor, we believe
that the — to allow distributors to buy
attrition to get rid of their product is
probably the best way on an environmental
basis.
We feel that to try to indoctrinate
the people at the distributor level on what
is the proper way of disposal, is an endless
-------
-113-
task, and in that short, span of time to
get r:.d of this product probably is not
going to be terribly beneficial.
MR. SHYKIND: Would you favor some sort
of, perhaps adhesive label to be slapped on
the small power supply capacitors, that
sort of thing, this would accommodate that
to say, "dispose of this environmentally
safely"?
MR. ROLLINS: We, in the capacitor
industry, under the American National Standards
Institute, are beginning to identify the
product that contains PCBs, in accordance
with the State of Michigan rules and will
eventually honor marketing disposal require-
ments, adhere to whatever policy as it is set.
So, the product will be identified,
yes, sir.
MR. SHYKIND: That would include the
many miles of relatively large capacitors
with power supplies and things like that
that are in surplus?
MR. ROLLINS: Well, you indicate large
capacitors and cost-wise, there are large
-------
-114-
capacitors used in the corrective action.
Those have been labeled for
some time, ever since the American National
Standards Institute got its guidelines
back in 1974,
The smaller the capacitors with
the advocation essentially encloses the
capacitor — there are no identifications
shown in that capacitor or on that piece of
equipment as it now stands.
MR. SHYKIND: Thank you.
HEARING OFFICER WIRTH: Okay, Mr. Pearson?
Anyone on this side?
Mr. Biles, you have another question?
MR. BILES: Assuming we take the
position you advocate on what is "totally
enclosed matter"? There are still a number of
other industries that we are talking about
so -- something affected by these regula-
tions .
Your industry is certainly as
much as any industry is affected by EPA
and other federal agencies related by PCBs,
Do you have any idea what the
-------
-115-
exposure should be for somebody else?
In other words, how do you think
it is possible to regulate the different
media of release with the type of manufac-
turing operation you are talking about?
Because even if we took the
position with regard to your industry, EPA
in itH rulemaking, I believe, cannot escape
the requirements that it comes up with some
definition of the significance of exposure?
MR. ROLLINS: I really can't give you
a good answer to that — not being knowledge-
able in the area of the identifying airborne
contaminants and what levels, I not being a
tpxicologist, is what level is not harmful.
I really couldn't give you a good
answer.
MR. BILES: Okay, thank you.
.HEARING OFFICER WIRTH: I have a few
questions, Mr. Rollins,
The firat one is basically how
well stocked is the industry, your industry,
with PCBs?
My question is that should we follow
-------
-116-
your argument that manufacture or processing
the PCB capacitors was not meant to be
restricted in '78, not until '79, was that
being cut off? That if with the regulation,
would your industry have sufficient PCBs
to operate through '78 to make or really
transfer over to the substitutes — would
we have sufficient PCBs in current stock?
My question is would they be importing PCBs?
MR. ROLLINS: The Monsanto Company/
as you know, it will cease shipping the
product on the last day of October of this
year.
Each company has -- set up its own
plans on this, but I think you will find
that the concensus is that they will have
enough material on hand from Monsanto to
finish off the use of PCBs in the capacitors
and, therefore, that the attrition of the
PCB-type capacitor will continue very quickly
after the mid-'78.
HEARING OFFICER WIRTH: Would you
anticipate of any cutoff of PCBs in the
United States on the market?
-------
-117-
MR. ROLLINS: I do not.
It appears to be rather orderly
at the.- moment, in its transition.
HEARING OFFICER WIRTH: Okay.
The bottom question I have is
/ou made a reference to the fact that the
manufacturing process now, which would be
subject to the toxic effluent guideline
as of next February, that the industry was
confirming to have standards of emissions.
You mentioned the ANSI standard.
Would you elaborate a little bit
on that and explain certainly what air
emissions -- my question is air emission
standards are self-imposed or federally
imposed standards that you mentioned?
IMR. ROLLINS: OSHA, in its Act, has
put ia a requirement over air emissions over
work stations of one milligram per cubic
meter.
The maximum concentration on an
eight hour average exposure.
And there has been no violations
at any of the vaster operations that we are
-------
-118-
familiar with on this particular point.
The effluent guidelines, both.
capacitor companies and the EPA are very
familiar with what is being done there.
HEARING OFFICER WIRTHi Yes.
So the companies are conforming
to the OSHA work place standard of guidelines.
Have there been, to your knowledge,
any air emission standards imposed on any
of your manufacturers through state implementa-
tion?
MR. ROLLINS: Yes. The answer is yes,
some states have had that -- the state of
New Jersey/ for instance, and there have
been some measurements, and the measurements
have been found to be negligible, insignifi-
cant to the point of no measurement detected
— no level detected.
HEARING OFFICER WIRTH: There is no —
no levels detected emitting from the plant
site?
MR. ROLLINS: That's right.
HEARING OFFICER WIRTH: Are you familiar
with any place at any time when detectable
-------
-119-
levels of PCBs were —
MR. ROLLINS: I have no record other
than that one particular incident reported
to me .
So I can't tell you whether other
plans have been—-
MR. BILES: If we/ again, assume the
particular position, do you anticipate
you would be asking for an exception in '79?
MR. ROLLINS: No.
MR. BILES: So you think your position
is now that if federal government did not
put out regulations regarding the purchase
of transformers in '78, that is all that is
needed — that there would be no need
afterwards to make them with PCBs, I am
specifically referring to —
MR. ROLLINS: Capacitors, because on
transformers I can't, sir.
But the answer is January of '78
I would anticipate every capacitor company
in th« United States would be out of the
use of PCBs.
MR. BILES: Okay, fine, thank you.
-------
-120'
HEARING OFFICER WIRTH; Are there any
more? Do you have one question?
MR. PRATT: If I could adjust one thing
that there were several areas in -- where
we found air emissions from capacitor plants
and you said you had not found any -~ to
our knowledge, there are several within the
six states where there has been a emission.
MR. ROLLINS: I only indicated that I
knew of none.
MR. SNYDER: My question relates to
the toxic effluent standards that become
applicable in February for capacitors and
transformer manufacture facilities that
discharge directly in the stream.
For those plants that discharge
to municipal systems, what do you think
the impact would be if those standards/
through some mechanism, were made applicable
on capacitor manufacturers who were discharging
to municipal systems?
MR, ROLLINS: As you know, the 307-A
is in appeal by our group, by our committee,
and we, therefore, are not sure what the
-------
-121-
£inal outcome is.
But, on the — if the 307-B that is
the discharge to the treatment facilities,
is the same as those, as presently proposed
by 307-A, there would be requirements in
some cases for additional treatments.
MR. SNYDER: Your comment that it is
under appeal making the assumption that you
would have to comply with those standards
by February or direct discharges, were you
not discharging into municipal system?
If you may --- if you are going to
make some assumption, I perhaps X shouldn't,
that your industry will be able to do that
at le.ast physically from an engineering point
of viow, would you be able to do the same
thing with those operations in your discharging
to municipal systems?
MR. ROLLINS; If the — if we are forced
to say, if we are forced to live with a
standard that says, "No detectable levels
can exist", even after being through passive
treatment, it is going to be an extremely
difficult task.
-------
-122-
MR. SNYDER: Do you see both problems,
both conditions essentially similar?
MR. ROLLINS: Yes.
MR. SNYDER: In their difficulty and
also ability to meet, be very similar?
MR. ROLLINS: Absolutely.
MR. SNYDER: All right.
HEARING OFFICER WIRTH: Okay.
Are there any questions from the
audience?
Okay, thank you very much, Mr.
Rollins.
And with that we will adjourn for
lunch and we convene promptly at 1:30.
(WHEREUPON, a luncheon
recess was had until
1:30 p.m.)
-------
PRESENTATION TO ENVIRONMENTAL PROTECTION AGENCY1
PUBLIC MEETING -JULY 19, 1977
My name is Ed Warner* I am Director of Engineering for the
Mining Machinery Division of Joy Manufacturing Company. We are a
leading manufacturer of underground mining machinery.
Our company has only one use for PCB's. it is used as a
coolant internally in electrical motors. While new machinery has
not been produced using PCS motors, since 1973, hundreds of motors
are still in operation in underground coal mines, it is the con~
tinued utilization of the equipment using these PCB filled motors
that concerns Joy and our customers.
We believe that EPA should be informed as to the economic
impact and production dislocations in the coal industry that couJd
occur, if a total ban were to be placed on PCB's beginning in 1978.
•i
As long ago as March, 1972, our company advised our customers of tho
need for special care in handling and disposal of PCB's.
Applications
Joy first used petroleum hydraulic oil as a cooling fluid
internally in motors in 1960, but the flammability of the oil con-
cerned mine safety authorities. Even though these mine motors were
eacplosion tested and could not emit sparks or flames to the mine
-------
2.
atmosphere, it was decided that a flame resistant coolant was re-
quired. After exhaustive testing Monsanto Aroclor 1242, a PCB
fluid was chosen. Ultimately, PCB fluid was used in three differ-
ent motors designs. Because of the greatly superior heat transfer
qualities of PCB liquid as compared to air, it was possible to
dramatically reduce the physical size of the motors. This illus-
tration shows one comparison of two 100 H.P. motors - one PCB fillec
and the'other of conventional air filled construction. The first
application was on a continuous mining machine known as the CU43.
Fifteen of these continuous miners were built over a four year
period beginning in 1963. The approximate selling price of this
machine was $105,000. Three motors were used on each machine.
Due to the motor's location and size constraints, it was not possi-
ble to build these miners using conventional motor construction.
Seven of these machines remain in operation as of this time, mining
coal at two small coal companies in west Virginia and Pennsylvania.
4
The second application of PCB filled motors was made in
1965. The approximate selling price of these loaders was $60,000.
In this design, two motors were used to provide traction power for
a coal loading machine. The size of the motors was not reduced
because of the very high operating temperatures experienced with
this motor. PCB was added internally to the motors to greatly
reduce operating temperature. 1,028 of these motors were used
on loaders shipped between 1965 and 1973, to 88 different customers,
-------
3.
Many of these users are small coal operators. In fact, 36
companies own only one machine. Sixty companies own one, two,
or three machines. Because of the wide distribution of these
loaders, rulings affecting the distribution and use of PCB in
mines would have a substantial effect on small coal operators.
The third application of PCB filled motors was on another
continuous miner called the 9CM. These miners sold for approx-
imately $120,000 each. In this design, two cutter head motors were
completely hidden inside the cutting element at the front of the
machine. A third PCB filled motor was used as a hydraulic pump
motor. AS with the CU43, the motor size was shrunk in order to
locate it in these positions. From 1967 until 1970, sixty-four
of these miners were constructed. It is estimated that 30 of these
machines are still in operation.
Conversion Program
Beginning in 1974, Joy provided a conversion kit to our
Service Centers to change PCB filled loader motors to conventional
construction. It was recognized that regulations were forth-
coming to prohibit the use of PCB's. To date, 353 motors have
been converted, or approximately one third of the total. Loader
users have not been receptive to this change because the con-
ventional motors run much hotter, and the service life is shorter.
-------
4.
There is no conversion possible for either the CU43 or
9CM miner motors. Conventional motors of adequate H.P. cannot
be installed on these machines, because of their increased size.
Beginning in 1972, Joy Manufacturing and our motor supplier.
Reliance Electric Company, began a search for a substitute for Arocli
1242 (PCB). Nineteen different chemical companies were contacted an<
twenty-one fluids were evaluated in the search for a replacement. Tl
cost of this program was approximately $60,000. Heat stability and
compatibility with electrical insulation were primary requirements.
Only one fluid was found to meet the test, but unfortunately it
gave a very pungent odor under operating conditions, so it was
abandoned.
We are convinced that a suitable substitute does not exist
for our requirements. We are continuing to evaluate possibilities
as -they become available.
Minimal Risk
Our company believes that continued use of PCB fluid in
mine motors constitutes a minimal risk to the environment. Although
PCB filled mine motors cannot be classed as totally enclosed, great
efforts have been expended to assure low loss of PCB from the motors
The liquid is contained within an explosion tested enclosure, under
a pressure of 20 pounds per square inch, under very extreme condi-
-------
tions, such as a motor winding failure, PCB vapor may be emitted
from a pressure relief valve. The only 6ther possible leakage point
is around the motor shaft seal. If this seal becomes badly worn,
PCB can leak but it would go into a gear reducer to which the motor
is connected, in normal operation, the loss of PCB from the motor
is zero. Joy sells PCB in one gallon containers to customers who
need small amounts replenish losses from the motors.
The primary risk of environmental contamination is during
motor repair. PCB handling and disposal at Joy's Service Center in
Bluefield, West Virginia is being done in accordance with suggestions
from EPA. This facility has been examined twice by EPA and has
not been cited for any misuse or contamination of the environment.
Used PCB is accumulated and returned to the Monsanto company for
incineration. Additional detailed safeguards have been adopted
•
as the result of the visits by EPA personnel. The quantity of PCB
used on each motor is small, averaging about four gallons. Handling
is restricted to a few people who are carefully instructed and
supervised.
At the present time, our company is repairing PCB motors at
three different locations, but it is proposed to consolidate all
repairs at a single Service Center.
-------
Consequences of PCS Ban
As a final consideration, we would like EPA to be aware of
the impact on the coal industry, if an outright ban on use of PCB
for mine motors were to be implemented. Underground coal mining
is a sequential process. It is accomplished by the use of a group
of machines to do certain jobs in sequence. One system, known as
"conventional mining" uses a group of six machines: A cutting
machine, a face drill, a loader, two coal haulage vehicles
known as shuttle cars, and a roof bolter. It is obvious that
when any single machine becomes inoperative, the mining of coal
stops. In addition to the loss of productivity, five other
machines must cease operation, with no consequent return on their
capital investment. The cost of down time varies, however an
average production loss might well be 500 tons of coal in a
siijgle working shift, which at today's prices would be at least
$10,000. The value of the group of machines involved would total
$300,000 to $450,000, depending upon age and condition.
In continuous mining, the mining sequence is simpler,
and only four machines are used: One continuous miner, two
shuttle cars, and a roof bolter. Again, loss of operation of any
machine stops the mining procedure. Loss of coal production is
comparable to that in conventional mining. The capital invest-
ment would be only slightly less than for conventional machines.
-------
7.
It is for these economic reasons that coal mine operators
exert maximum effort to keep all machines in operation simultaneously.
Taking mining machines out of operation to make conversions obviously
would be a costly procedure.
Conclusion
Joy Manufacturing Company proposes that "use authorization"
be granted by EPA to us, and our customers for three years beyond
January 1, 1978. This authorization would be contingent upon the
following:
1. No additional PCB to be imported by Joy Manufacturing.
2. If recommended by EPA, Joy could sell part of our present inventory
bf PCB to our customers before January, 1, 1978. This would
eliminate future needs to transport PCB.
3. Joy would handle all future motor repairs at a single Service
Center operating under rules prescribed by EPA.
4. Conversion of loader traction motors would continue at a
rate to complete the remaining 675 motors by January 1, 1981.
The program would be planned to make conversions as motors fail,
and not to convert good PCB motors while still in operation.
-------
8.
5. Coal operators using CU43 or 9CM continuous miners with PCB
filled motors would be advised to phase out this equipment by
1981. In case of the 9CM, a conversion kit could be designed
i
for a new cutter head at an approximate cost of $80,000 to
$100,000.
We thank you for this opportunity to present our views on
this important subject.
-------
Environmental Activities Staff
General Motors Corporation
General Motors Technical Center
Warren, Michigan 48090
July 18, 1977
U. S. Environmental Protection Agency
Office of Toxic Substances
401 M Street, S. W.
Washington, DC 20460
Gentlemen:
Re: Polychlorinated Biphenyls (PCB's)
In response to the solicitation of comments published in 42 FR 32555,
June 27, 1977, General Motors Corporation requests that the following
comments be placed in the record for consideration of proposed 40 CFR,
Part 761.
COMMENTS
General Issues
1. Is any type or level of exposure to PCB's "insignificant"?
Surveying the data in the EPA's "Criteria Document on PCB's"
(EPA 440/9-76-021), most toxicological information seems to
have been developed on short-term, high-dose exposure to PCB's.
There appears to be relatively little information on long-term,
low-dose exposures. Thus, it seems impossible to state that
a specific exposure level is "insignificant. " It appears concen-
trations on the order of 10 to 20 parts per million (ppm) may give
certain long-term deleterious effects in various mammalian species.
However, the general population has been exposed to levels in the
low parts per billion (10~^ parts per million) for periods of at
least 10 to 15 years with no apparent adverse effects. At least
there are no data at present which would indicate adverse effects
in humans at the low parts per billion exposure level. Therefore,
an "insignificant" human exposure level might be in the low parts
per billion range.
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U.S. EPA
Offioo of Toxir Substances -2- July 1H, I (>77
We presume that any discxission of exposure includes exposure
of all portions of the environment. Thus, establishing a single,
no effect exposure level becomes very difficult. It is well known
that different organisms react differently to PCB's. An "insignificant"
exposure level for a clam could be very different than that for a
human. Therefore, in our opinion, "insignificant" exposure levels
should be related to the specific organism (i. e. , plants, worms,
clams, birds, man, etc.) most likely to be exposed.
2. Does "totally enclosed manner" refer to exposure resulting from
the manufacture of PCB's; e.g., escape of PCB's from manufacturing
processes, or only the end use of PCB's?
The term "totally enclosed manner" is used in Section 6(e) of the
Act in relation to "manufacture, " "processing, " "distribution, "
and "use. M Therefore, the statute contemplates that all of those
activities can occur in a totally enclosed manner and regulations
should be drafted accordingly. It is, of course, possible that the
term "totally enclosed manner" could be defined differently depending
on which of the four classes of activities the term is applied to.
GM does not manufacture or process PCB's. Therefore, these
comments do not address the question of how "totally enclosed
manner" should be defined in relation to "manufacture" or "pro-
cessing. " However, GM does "\ise" PCB's in electrical capacitors
and transformers, which are closed and sealed units. We recommend
that such units be defined as "totally enclosed" even though they
are physically capable of being opened by some means. Likewise,
we recommend that electrical devices which contain PCB's and
are factory-sealed at the time of manufacture also be classified
as totally enclosed when used with their original seals intact.
An additional consideration in defining "totally enclosed" is the
incidental contamination by PCB's of certain fluids used in heat
transfer and hydraulic systems. Specifically, until 1972, PCB's
were widely used as fire resistant hydraulic fluids. When the
environmental risks associated with PCB's became known, GM
ceased using PCB hydraulic fluids. Typically, PCB-containing
hydraulic systems were drained, flushed, and refilled with non-
PCB fluids. After nearly five years, we still find PCB contamina-
tion present in many hydraulic systems at the parts per million
level. Hydraulic systems are, by nature, not permanently scaled.
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U.S. EPA
Office of Toxic Substances -3- July 1 8, 1«)77
However, they are sealed when in normal operation. The same
is true of heat transfer systems used in some GM operations.
Heat transfer systems are less susceptible to leakage because they
are not subject to the pressures present in hydraulic systems.
We, therefore, request the EPA to establish a PCB concentration
of 500 ppm or less as being considered incidental contamination,
and exempt such situations from the "totally enclosed manner"
limitation.
1978 Exemptions
As stated above, an exemption should be granted for any type of incidentally
contaminated system. The EPA has recognized, in the proposed PCB
disposal regulations (40 CFR 761.4, proposed on May 24, 1977), that
incidental contamination of various systems has occurred. A cutoff
of 500 ppm is proposed in the definition of "PCB Mixture" for disposal
purposes. This definition should also pertain to all exemptions authorized
under Section 6(e) of the Act.
A hydraulic system containing residual PCB concentrations of less than
500 ppm does not pose an unreasonable risk to health or the environment.
The system is enclosed, and, therefore, workers are shielded. Water-
borne discharges from the system are controlled under the provisions
of the NPDES permit program and other discharge regulations. We
expect that systems which once held mixtures containing 60 percent to
90 percent PCB's will continue to show low levels of residual contamina-
tion for many years, even after being cleaned.
It is unreasonable, in our opinion, to require industry to reclean hydraulic
* or other fluid systems presently containing less than 500 ppm PCB.
The incremental reductions in PCB content gained by successive draining
of a system below about one percent residual PCB are small (on the order
of 25 percent reduction with each clean out).
The material costs of cleaning a system are about $2. 45/litre (L) of
fluid replaced. In a facility having 500, 000 L of hydraulic fluid, the
materials cost alone would be over $1 million. (This cost is based on
new hydraulic fluid at $2. 00/L, flushing fluid at $0. 30/L, and disposal
at $0. 15/L.) Labor and parts replacement would be additional costs.
It is apparent that the costs of removing residual PCB concentrations
are very high and the expected benefits are minimal. In our opinion,
residually contaminated fluid systems containing less than 500 ppm
PCB should be exempted from the provisions of Section 6(e).
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U.S. EPA
Office of Toxic Substances -4- July 18, 1977
Resale of PCB's
As a general position, GM believes PCB's should not be recycled.
Once a PCB-containing system reaches the end of its useful service
life, it should be properly discarded. However, there should be a
small stockpile of PCB dielectric fluid available for routine maintenance
of transformers. This would help avoid costly, premature scrapping
of transformers due to the unavailability of dielectric fhiids.
Specific PCB Activities and Uses
Existing Transformers
Transformers require different types of scheduled maintenance. Some
units require no maintenance over their service lives, while for others
the maintenance schedule varies with the unit type and use conditions.
Some require annual checking; others may go five years between service
checks.
During maintenance, one to two gallons of dielectric arc rrmovod,
tested, and discarded. The scrap fluid is normally incinerated. If
the technician performing the test exercises normal precautions to
prevent spillage, the risks of PCB loss are minimal. The precautions
include:
testing to be performed only by trained, qualified individuals,
use of an absorbent blanket to catch any drippage, and
scrap fluid and the absorbent blanket to be placed in labeled
containers for proper disposal.
Dielectric testing is required to maintain the proper characteristics
of the fluid so that the transformer will continue to function. There
are commercial techniques for filtering the fluid to remove suspended
solids and other contaminants. The dielectric constant is checked to
see if it is adequate to prevent arcing within the transformer (arcing
or short circuiting can cause the transformer to explode). Thus, fluid
testing according to manufacturer's specification is absolutely necessary
to protect the transformer.
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U.S. EPA
Office of Toxic Substances -5- July 18, 1977
The release of PCB's resulting from transformer maintenance is negli-
gible. As stated earlier, if proper, common sense care is exercised
during maintenance, there is no reason to expect any uncontrolled
release of PCB's. Consequently, the health and environmental impacts
of transformer maintenance are also negligible. If routine maintenance
is prohibited, the rate of transformer failures could increase significantly.
A certain percentage of the failures could result in rupture of a trans-
former and release of PCB's to the environment. Therefore, trans-
former maintenance must be allowed as long as PCB transformers are
in service. Common sense precautions to prevent spillage should be
exercised. Disposal of scrap fluid and other contaminated articles
should conform to EPA's rules on PCB disposal.
Existing Stockpiles
As stated earlier, some amount of PCB should be available only to
supply the maintenance needs of existing transformers.
Locomotives
GM produces diesel-electric locomotives. There are several small
capacitors used in the locomotives which have contained PCB's. Those
capacitors contain paper impregnated with approximately 0. 2 kilograms
(kg) of liquid PCB. The capacitors are obtained from outside suppliers
who are in the process of converting to non-PCB dielectric materials.
GM has initiated a program to completely phase out all use of PCB-
containing capacitors in diesel-electric locomotives by January 1, 1979.
Thus, there does not presently appear to be a need for GM to seek an
exemption from the July 1, 1979, ban on distribution of PCB's.
•I
The main reason for using PCB's in locomotives is fire protection.
Railroads are concerned over the possibilities of an electrical fire
igniting dies el fuel while a locomotive is in a crowded train station or
going through a tunnel. It has been our experience that electrical fires
in locomotives are rare.
At this time, GM sees no compelling need to use PCB's in diesel-electric
locomotives, but neither do we see a compelling need to retrofit locomo-
tives presently in service with non-PCB capacitors. Electrical gear
in locomotives should be allowed to remain in use until the end of its
normal service life and be replaced with non-PCB gear at that time.
The amount of PCB's in a diesel-electric locomotive is small (a total
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U.S. EPA
Office of Toxic Substances -6- July 18, 1977
of about 1 kg PCB per locomotive) and is well protected. Allowing
continued use of PCB-containing electrical components in locomotives
does not present any unreasonable risk to health or the environment.
By allowing conversion to non-PCB components on a scheduled main-
tenance basis (rather than retrofit), unnecessary costs and rail service
disruption can be avoided.
Other PCB Activities
The apparent intent of this inquiry is to determine if PCB-contaminatecl
articles should be removed from service. It is unreasonable to expect
industry to literally tear down a manufacturing facility which may contain
pipes, pumps, concrete, etc. -incidentally contaminated with small
amounts of PCB. The economic and environmental costs of demolishing
a building to remove a few kilograms of PCB are totally unreasonable.
Manufacturing buildings cost millions of dollars to construct. Chemical
landfills simply could not handle the quantities of construction rubble
which would result from wholesale demolition of incidentally contaminated
structures.
Disposal of PCB contaminated solid waste is covered by other EPA
regulations (40 CFR 761.4, proposed on May 24, 1977). It is obvious
that building materials secondarily or incidentally contaminated with
PCB's must be exempted if the material does not qualify as a "PCB
Mixture" under EPA's proposed disposal regulations. Therefore, we
recommend that EPA abide by its proposed definition of "PCB Mixture"
and specifically exempt any material containing less than 500 pprn
PCB from the provisions of TSCA Section 6(e).
' We hope these comments will be considered by EPA during formulation
of regulations affecting the ban on PCB's required by TSCA.
Very truly yours,
'.0
i
W. R. Johnson, Director
Plant Environment
pm
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PCB HEARING
SPECIAL MEETItTG OP
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION V - CHICAGO, ILLINOIS
July 19, 197?
1: 3 0 o. ra.
Pick Congress Hotel
Chicago, Illinois
A, Dime
Court Reporter
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PANEL MEMBERS:
GEORGE WIRTH, CHIEF, HEARING OFFICER
Regulations Development
Office of Toxic Substances
U.S. Environmental Protection Agency
Washington, D.C.
GARY J. BURIN, CHEMIST
U.S. Environmental Protection Agency
Washington, D.C.
DR. EMILIO STURINO, CHIEF
Organic Laboratory Section
Central Regional Laboratory
U.S. Environmental Protection Agency
1819 West Pershing Road
Chicago, Illinois
JAY GOLDSTEIN
Waste Management Branch
U.S. Environmental Protection Agency
230 South Dearborn Street
Chicago, Illinois
HAL SNYDER, HEAD
Toxics Strategy Implementation Unit
Office of Enforcement Division
Washington, D.C.
KARL E. 3REMER
Toxic Substances Coordinator
U.S. Environmental Protection Agency
230 South Dearborn Street
Chicago, Illinois
ROBERT PEARSON, BIOLOGIST
Permit Branch, Enforcement Division
U.S. Environmental Protection Agency
230 South Dearborn Street
Chicago, Illinois
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1.2',
GLEHN D. PRATT, CHIEF
Permit Branch, Enforcement Division
U.S. Environmental Protection Agency
230 South Dearborn Street
Chicago, Illinois
PETER PRINCIPE
Environmental Engineer
Office of Toxic Substances
U.S. Environmental Protection Agency
Washington/ D.C.
EDWIN SHYKIND, DIRECTOR
Office of Environmental Affairs
Interagency Work Group on PCBs
U.S. Environmental Protection Agency
Washington, D.C.
BRIAN DAVIS, ASSISTANT REGIONAL COUNSEL
Office of Regional Counsel
U.S. Environmental Protection Agency
230 South Dearborn Street
Chicago, Illinois
BLAKE BILES
Attorney of General Counsel
U.S. Environmental Protection Agency
Washington, D.C.
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MR. WIRTH: Let's get started, gentlemen.
Good afternoon,, ladies
and gentlemen, we vll reconvene this session
on the polyehlorinated biphenyl marketing and
— excuse me, manufacturing ban regulation.
We finished with the marketing and disposal
ban.
If there is no procedural
question or announcements we will proceed with
the next witness.
The next witness then in
Fredrick w. Steinberg, a lawyer. Is he here?
Would you state your name
and would you spell your last name for the
clerk and your association, sir?
MR. STEINBURGi My name is Fredrick W.
Steinburg, S-t-e-i-n~b-u-r-g. I am associated
with the law firm of Rose, Schmidt, Dixon, Hasley
and White from Pittsburg, Pennsylvania, the
law firm of which represents Joy Manufacturing
Company who was represented earlier this morning by
Mr. E. M. Warner, the Director of Engineering.
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I am going to restrict
my comments which will be very brief to a
couple of the questions that Mr. Warner was
asked by members of the panel.
I believe it was Mr.
Burin who inquired about the identities of
the owners of the 9 CM, Continuous mining
machines and Mr. Warner did not have with
him at that time a copy of the Joy Manufacturing
Company's submittal to the EPA, dated
September 22, 1975, which is a fairly thick
document/ but it was submitted to the EPA and
I would direct Mr. Burin to documents seven
and nine in that compilation which does state
— which do state the identity of those
customers.
I think it was Mr. Breraer
who inquired about the types of fluids that
were evaluated by Reliance Electric Company
who is working in conjunction with Joy
Manufacturing Company in attempting to locate
a suitable substitute for PCBs in the mining
machinery category.
I have two volumes which
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were prepared by Reliance Electric Company
which essentially reflect that work. And I
would be happy to share it with anybody at tha
EPA who would wish to look into this matter
further.
It is my understanding
that the EPA is continuing attempts to identify
potential substitutes of PCBs in almost every
application imaginable. So, I don't think
Reliance Electric would have any objection to
our supplying them to you.
A point that Mr. Warner
mentioned this morning was that Joy Manufacturing
Company would be happy if the EPA deemed it
desirable to consolidate its loader motor
conversion program at a single facility rathor
than the three facilities that are now being
used or have been used in the past.
I think that such a
consolidation of activities would probably
involve a trade-off that the EPA would be
concerned about. By restricting the conversion
activities to a single facility I think it is
safe to assume that unless Joy was required to
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dedicate a very large amount of their re-
sources of that Bluefield facility strictly
to that conversation program that ultimately
the conversion program would be slower than
if three facilities were utilized.
The counter-balance factor
that the EPA may wish to think about here is
that if a single facility is involved, it is
quite likely that the number of Joy employees
who would be participating in the conversion
would be reduced. I don't think that Joy
itself has a preference. But, this is something
that I simply offer for the EPA's consideration
at this time.
Similarly the offer that
Mr. Warner made this morning with respect to
the willingness of tho company to conclude its
direct sales of PCBs to customers in one-gallon
containers which are now used to top off
motors in operation also involves a trade-off
perhaps. In making the offer Joy in no way
means to attempt to end one round of any <••>*
tha deadlines contained in the act, but direct
sales if concluded before the statutoru deadlines
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j. 3.1
ir.ay simplify transportation of the fluids
which presumably will also b© in areas regulated
In talkJnq with Mr. Warner
at lunch in connection with the company's
willingness to divise an instructional program
for customers, Mr. Warner or other appropriate
associates at Joy will be happy to discuss
with officials of the EPA at any time the
contents of such a program, how it might best
be implemented.
Those are the* only remarks
I have. I'd be happy to address myself to
any questions that a lawyer is competent to
answer in this field if there ar& any.
MR. WIRTHt Okay.
Thank you very much.
Professional competency
is not a question here. The questions here
are that we have a lot of problems in this
entire work.
Okay questions?
No questions -- any
questions?
I guess there are no
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questions. I guess we exhausted Mr. Warner
this morning on the subject.
Of course, we won't
respond at this time. We will not respond
on any of these particular comments, at this
time we are not prepared to, I think the main
issue here is for us to understand what your
capabilities are; what Joy's capabilities are
and what substitutes are available and write
the regulations accordingly relative to the
environmental risks associated with the operation
and use of PCBs.
I have one question, I
guess it concerns the three facilities versus
one.
Is there any comment you
would care to make about the relative
environmental risk of three facilities versus
one? Do you consider one environmentally
safer, easier to operate or control than three?
MR. STEINBERG: Let me begin by saying
that I have not personally visited any of
the three facilities that have participated
in the conversion program.
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13?
Mr. Warner stated this
morning that EPA officials have visited the
Bluefield, West Virginia facility on two
prior occasions in the very recent past.
It is my understanding
from hearing summaries of those visits that
they were essentially satisfied with the
handling procedures at that facility. There
were some recommendations made and it is my
understanding that they are now being im-
plemented.
Except to say that -- as
I previously indicated that if you can limit
the number of persons participating in that
kind of a conversion program I think it may
be safe to conclude that those relatively
small numbers of people will be more impressed
with the hazards involved in handling PCBa.
I don't know that the
physical facilities of those three plants
vary to such an extent that the physical
plant would make one more properly a
subject of that kind of activity.
MR. WIRTH: Do we know where the other
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— where all three facilities are? One is
Bluefield --
MR. STEINBURG: One is Bluefield, Weat
Virginia, the second is the Headowlanes facility,
I believe, in Cannonsburg, Pennsylvannia, and
the third is the Mount Vernon facility which
is here in Illinois.
MR. WIRTHi Okay* Thank you* Any
questions?
Okay.
We will call our next
witness, Mr. Haryy Onishi, from the PCB Task
Force of the Edison Electric Institute.
MR. ONISHI: Good afternoon. My name is
Harry Onishi, O-N-I-S-H-I, and I am Manager of
Transmission Engineering for Commonwealth Edison.
I am appearing today as a member of the Edison
Electric Institute.
And this task force is
somewhat unique. It is comprised of representa-
tives from investor-owned and municipal-owned
utilities as well as TVA, BPA and REA.
The task force has had
several meetings with BPA concerning the
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problems of handling and disposal of PCBs ,
I guess this goes back to early 1976.
At that time we proposed
that an affective control program encompass
the following basic considerations: number
one wan that existing "closed system" 11335
such as transformers and power capacitors
remain in service for the remainder of their
useful life and that the PCS control efforts
be directed towards maintaining adequate records
of in-service equipment and establishing
procedures and methods for the handling, con~
taining, clean up and disposal of PCBs in an
environmentally acceptable manner.
We believe this recommended
course of action is appropriate and consistent
with the Toxic Substances Control Act. ftnd
accordingly we have stated in the hearings on
the promulgation of regulations covering the
labelling and disposal of PCSs and PCB articles.
We also recognize that
there ar« additional requirements associated
with the promulgation of reqv.lations concerning
the manufacture, proctsssinc and distribution
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of PCBs in commerce.
I think we have a few
comments in this area. We do recommend
that the exemption for closed-system uses
continue. I think that has been fairly
clear that the intent ia there.
Our past experiences
show that the transformers and capacitors
are extremely reliable. The failure rates?
are very low. The releases to the environment
because of inadvortant catastrophic failure is
very small. This finding is supported by the
Versor study. And I think it has been
stated that probably the safest place for PCBs
in any instances is 5.n transformers or
capacitors that are in normal operating
conditions.
The ban on the manufacture, processing
and distribution of PCBs will have some impact
on utility operations. And it already has
some impact. For example, on capacitors now
most suppliers, to my knowledge, have in-
dicated that they wil3 not supply PCB-filled
capacitors. So, we are purchasing non-PCB
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power capacitors and transformers. I think
there may be one or two suppliers that will
still supply an askarel-filled transformer,
but most companies are changing. And I would
think the ordering of new askarel-filled
transformers is very rare.
The unavailability of
PCS does not directly affect power capacitors.
As you know these units are hermetically
sealed and there are no make-up fluid require-
ments. It does require that non PCS
capacitors be available and they apparently
are. I think we — to my knowledge they are
in service. We have not had time to effectively
evaluate their in-service operation and we will
be doing this over the period of years.
For PC3-filled transformers/
however, there ar^ nominal make-up fluid
requirements. I think thf? industry intends
to provide these make-up requirements by
using in-stoc^c PCBs initially and ultimately
as we go loo); down the road, v/e figure it will
have to be done by reclaiming PCBs from
existing transformers that are removed fron
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A O .
service.
So, with this in raind
we would recommend that the proposed
regulations provide for the use of PCBs
both from an inventory initially and then
allow reclamation of PCBs from all transformers
for future use. And these uses can be
accomplished in an environmentally acceptable
manner.
I think that is the
extent of my comments. I'd be happy to answer
any questions.
MR. V7IRTH: Thank you very much.
~ary, do you have any
questions?
MR, BURIN: NO.
DR. STURIHO: My only question is does
any of the companies you deal with have any
programs where they do recycle the PCBs or
are they sent directly to scone other proper
disposal facility at this time?
MR. ONISHI: Well, for disposal I think
most companies are sending them to a suitable
disposal facility, whether it be Rollins or
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133
whether it be Monsanto for recycling or
reclamation of PCBs. There is equipment
available to do that.
I think some companies,
maybe the large utilities can do that.
Certainly large transformer manufacturers
can recycle.
DR. STORING: Is anybody doing it at
this time?
HR. O1IISHI: I would imagine they are,
yes.
MR. SNYDER: You commented earlier about
the make-up procedures for transformers.
There seen to be some question at some point
down the road we won't have enough PC3s to
satisfy this make-up requirement.
In what ways do PCBs
escape from a transformer in a normal use
situation such that make-up fill would be
required?
MR. ON1SIII: Well, many utilities
will sample periodically the Dielectric
fluid to nake sure it is maintaining its
properties. 'This would be a small quantity
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13J
but over the period of time this could have
some impact.
In many other cases you
may have oh, a loose gasket or something of
this sort where moisture would enter into a
transformer and you would then have to recycle
that fluid, or perhaps even drain it and
replace it with additional PCB fluid.
So, there are different
ways in which you could have some loss of
fluid or have need for added fluid.
MR. SNYDER: Do you feel that any of the
practices present have perhaps been more on
the side of why not go ahead and change
because there is an adequate supply of FCBs
to undertake such a change versus future
situation where supplies would be limited for
all reasons that we have di«cussed here today,
and by virtue of this limitation that one
night find that they cion't have to undergo
the change of Dielectric fluids that they
iri=-iy have undergone before; meaning that you
sort of decide maybe life is getting a little
tougher, raaybc w»2 don't; have to fiddle around
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so much with these fluids.
Is there any basis for
that kind of a thought?
MR. ONISHI: I dcn't know. I think it
is possible that some -- in some instances
we might consider replacement of the trans-
former rather than say changing the fluid or
something of this sort. I think most utilities
would intend to continue their program of
periodic saiaple of the fluid just to make
sure that the Dielectric is adequate and thers
is no contaminants in this sort thing,
because it is far more economical in most
cases to keep a transformer serviced that it
is to replace it.
MR. SNYDER: What are some of the
consequences of PCBs becoming contaminated,
whether it is moisture -- or perhaps ~- you
have mentioned moisture as a contaminantr
what other kinds o' contarain«2nts would you
describe and for those contaminants what
kind of ill effects would ociur if they were
not corrected?
MR. ONISHI: Well, it would lead to
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141
failure of the transformer, and the failure
would bo ralated to the level of contaminents
and location of those contaminents, it could
be rather quick and it could stretch over
some period of time.
But the emphasis on
insuring the Dielectric strength would be
to maintain the life of the transformer and
prevent any equipment failure.
MR. SNYDER: Can you mention any other
contaminents other than moisture at this time
that you would expect to find?
MR. ONISHIj There undoubtedly are but
I am not aware of them.
MR. SNYDER: Are you aware of any way
in which -*• well, my understanding is that
you can lose some PCBs from a transformer,
this would contribute both t:o an environmental
release and also a lowering of the level whicn
•nay require nake-up, that there is an off
aspect of the transformer, :'lt becomes overheated,
for whatever reason •-•-
MR. ONISHI: You moan to an operation of
a pressure relief device or something ot this
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sort.
Normally, I should say
on most transformers from the distribution
Icsvel that have pressure relief devices.
However, on the askarel
type transformers, network type transformers
generally this pressure relief device is a
frangible diaphragm. It is sealed, it does
not release unless you have -- generally it
is a failure that will crack or rupture that
Device, it is not a breathing device.
MH. SNYDER: If in the course of
developing these ban regulations we were to
develop essentially spill-protection regulations
which might involve things such a.s secondary
contciinnent meaning diking or curbing or
something of that nature around transformers,
a• whit would be your thoughts on the use-
fulness of that and b- the practicality and
c- in a sonawhat related way, wh.'it some of
the cost impact ^.\y ;>c?
MR. ONISHI: '-Tali, I tV.ink -'.he usefulness
of sonio sort o" s^ill prevention -- most
utilities I think ^re very actively looking
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143
in that area.
Vie do have a problem,
many of our transformers are located in sub-
surface locations, and many of them have either
sumpumps or direct connections to the drain
systems.
There is a lot of
investigation going on on how you are going
to seal those. Some companies are looking at
standpipes.
When you are in a sub-
surface condition diking is not effective
because you can have water levels.
1 think it ir probable
in our opinion it is necessary to do that.
When you're in an
above inside building vault location, most of
these either the drains -- if there are drains
they can be plugged, ar.d in many of the newer
vaults there are no drain facilities so that
if you would have a leak or a spill they
would be contained within tJat area.
What is your third part
of the question?
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MR. SNYDER: The cost impact of this
sort of program in relation to current
practices?
MR. ONISHI: The cost impact of adding
invirob to this sort of a thing I think is
relatively nominal.
If you have to go into
the redesigning of vaults and that sort of
thing then it gets rather astronomical and
we are trying to avoid, that.
MR. SNYDER: Are you aware of any way
to improve this accident or stroke of any
potential other than secondary containment
such as diking?
MR. OillSHI: Well, let me say first
t;ae typa of occurrance or failure, where you
would have a tank rapture or something is
extremely rare.
The way of improving
that, of courso, is if. you do have a failure
to have your protective equipment, remove that
oquipment from aarvice rapidly.
I think most utilities
do have equipment that operates in a matter
-------
of seconds. And that does not preclude the
possibility of having a catztstrophic rupture
under certain conditions. And in most cases
I think you have to rely on the secondary
containment.
MR. SNYDER: Are you aware of any
canes where utilities, or users for that
matter, that may not be utilities to the
extent you are familiar in that area, where
a transformer -- PCB transformer, for whatever
reason they decide they won't go into setrvice,
in examining the cost of disposal or in-
convenience or whatever, eloct really to
bypass that unit, tako it out of service
electrically but allow it to remain in place,
assuming that it's cheaper than haggling with
the unit, are you aware of that kind of
practice?
MR. ONISHI: >Jo, T am not aware of it.
Personally I could force the situations under
which that might occur.
MR. SNYOBR: Would you consider it
unreasonable if we had requirements tha': would
preclude t*fet sort Qf practice, in othe£ wordg
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143
truly define the useful life of the transformer
as one that somehow relates to its useful life
in its electrical system or as time passes
properly removing the iten from service on
the assumption that it has become some greater
risk whether it is corrosion or damage,
incidental damage or something like that that
might resxilt in a leafc?
MR. ONISHT: Well, I would think — I
would think it would probably be -- we would
think it would be unreasonable to take that out.,
I think if you have that
equipment on a standby basis, standiarr there
idle, we would thir.!c that it woxild be perfectly
secure as far as environmenta1 releases to the
environment. And 7 don't think it would be
necessary to pull that out and dispose of it.
;•'?.. SMYDE^r ..y "standby" are you «?u
that it could be back into service until eu<
time as it has no further useful service 3 ifa?
MH. ONISHI: Well, if 'It has no further
aseful lifs I thinV. il: should be disposed of.
MP.. 3TXEMER: Mr. Oniohi , you indicated
that 3> good majority of comparie-; ar» not
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147
ordering PCBs or askarel-filled transformers
and capacitors at this time?
MR. OWISHI: That is correct. Most of
our capacitors — power capacitor suppliers
have indicated that PCB-filled legal supply,
only non-PCB capacitors and this has been in
effect for some time.
Many of the transformer
manufacturers have indicated that they will
no longer supply PCB-filled transformers.
MR. BREMER: What replacement is either
Commonwealth Edison using or is the Edison
liloctric Institute recommending at this tine
for both transformers and capacitors?
MR. ONISHI: For capacitors Edison
Electric Institute is not recommending any-
thing. They are relying on the manufacturers
of power capacitors and raany of the manufacturers
have come out with substitute fluid, General
Electric/ KcGraw Edison/ Westinghouse --
MR. BR3MER: They're letting the actual
manufacturers wake their owr; recommendations
then?
?1H. OiJIC:.II: That is correct.
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V.'
14Q
MR. BREMER: They haven't selector! any?
MR. ONXSHZ: *lO .
MR. BREWER: I thought that the Institut«3
as going to select, in fact they had some
tyoe of a survey going, to evaluate replacement
substitutes?
MR. ONISHI: Well, I think we will monitor
the performance of the substitute fluids arul
just to determine whether or not their
reliability or whether or not there are other
hazards.
I don't think it's the
Institute's position to dictate the type of
substitute fluid that should be used.
As far as transformers
ic concerned, again this would bp a similar
situation and there £.re several substitx'.te
fluids, most proirirent being silicone, that
har been a replacement: fluid for askorcls.
MR. BRF.MF.R: OV.ay.
Let's say foz example
Cotimonvealth Edicon has to replace a trans-
former in the city of Chicago in a public
building that, was required by electrical
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• 149
code to have an askarel-filled transformer
in a particular situation you would use a
silicons base fluid transformer oil at this
time or would you use an askarel?
MR. ONZSHX: Well, it would depend on
circumstances. In many of the locations where
we have askarel-filled transformers we do
have -- they are installed in class A fire-
proof vaults, ao we could be ready to substitute
an oil-filled transformer there.
MR. BREMEN: Let's say for example on a
new building, what would you put in now?
MR. ONISHXi In a new building we would
probably go to oil and in some cases we are
trying out some silicons transformers.
MR. BREMEKs So, the Electrical Code
doesn't keep you from using say mineral oil
inside a building?
MR. ONISH1: No, I dees not.
MR. BREM3R: Maybe seme of us were
confused because when the --
MR. ONISHI: It does require —
MR. BREMER: — NC Guideline was being
developed they indicated that there were
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160
specific places, public places where a number
of people would be exposed to, you know, let's
say fire from a transformer that they were
required to xise an askarel -filled transformer.
MR. ONISH1: That is correct.
MR, BREMER: But, now you are saying that
you can go to oil-filled?
MR. ONIfiHI: Well, in our locations KG
do have the transformers in stall ad in a fire--
proof vault. In many locations the transfornera
are not installed in a fire-proof! vault, whic:h
means that it does have to be a non-flammablo
or firs-resistant l:ype tramsf orm-ar, In thoso
cases you would have to go J-o aa>.arel or sili.cone
or something that is approved from an electrj.cal
code standpoint.
MR. BREMER: Is the silicons-filled
acceptable at this tinno?
M.R, ONISHI: My understanding is that
the National Electrical Codti -- at least the
proposed regulations indicate that it will
be. accepted.
MR. BREMER: It will, but i^ isn't at
this time?
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* - 151
MR. ONZSHX: I don't think it has been
formalized, but indications are that it will
be.
MR. BRKME3: Thank you.
MR. BILES: If we are going to accommodate
transformers, it's certainly being urged upon
us as a policy matter, we are going to try to
fit this within what; six (e)allows us to do.
And there are two or three
questions that I want to aee how ypu can help
us interpret this.
One t«rm that this act
uses throughout, not only in sixty is the
term due process, not fron a legal standpoint,
but just front a standpoint of how people
actually use transformers, do you consider the
repair of the transformer to be the processing
of the PCB liquid it.oelf?
MR. ONZSHIs What was that question again?
MR. BILES: Do you consider the handling
of liquids and putting thorn in a transformer
to repair and maintain a transformer, is that
processing of the 15.quid. Do you think it is
reasonable or not reasonable to say that that
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152
activity is processing?
MR. ONI3HI: I think if you are in
an extensive repair, where, say you are in
a rewind operation or something of this sort,
major repair, refilling th« fluid, that
would be part of the processing.
MR. BILES: Okay.
That leads into ray next
question. I am assuming that there are various
kinds of activities that people would call
servicing or maintenance, some of which may
involve essentially building a new transformer,
others of which may involve kind of routine
maintenance, whatever that means.
Do you think we are
going to have — how difficult it is going to
b« for this agency to try to distinguish
between what is necessary for routine
maintenance to keep things for their current
life and the activity necessary and associated
with really building n«w transformers. la
that going to be a hard lin« for us to draw
in your opinion?
MR. ONISHI: I don't think so. I think
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C O
J o
on routine maintenance and servicing would
be an analysis of the fluid, perhaps a bushing
change, something like that.
I think whenever you have
to open a transformer and get into the
internals and start doing repairs within
the windings and something like that, that
would be a major repair and could be differen-
tiated between service and maintenance!.
MR. BILES: Do you think that second
activity is also the kind of activity that
should be authorized for the next ten, twenty,
thirty years, or are you directing your
comments to the first kind of activity?
MR. O3IXSHI: I ara directing my comments
to the first activity. The repair facility
or operation is generally not part of the
utility operations and our position r;.ght now
would be it is going to ba pretty much on an
economic decision wlnather you can have a
transformer repaired or whether you purchase
a new one.
MR. BILES; If we attempt to wri^ie soire
regulations that account, for repair, however
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* 154
we define that terra, another Issue that we
have got to face ia how we project the amount
of PCBs needed if they refer to the fact that.
you thought reclamation might be one source
of the liquid?
How reasonable is it for
EPA to try to project for the amount of
transformers that are out there and we think
may be out there for the next thirty to forty
years to try to project the amount of liquids
that could be needed and promulgate the
regulations as opposed to being silent on th^
issue and just assume that you can't make
any new ones, you can't import, so it has to
come from reclamation/ that is one of the issues
that we have to allow the import to let people
build up stock specifically for that purpose,
MR. ONISHI: Well, I think it would be
very difficult to project what the requirements
are going to be. And I think most companies
have some difficulty with the situation
since Monsanto went out of business they
certainly don't intend to stockpile adequate
amounts of PCBs to handle their needs for
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155
the next thirty yearn.
MR. BILES: One of the things I have
coma to understand In that a lot of reclamation
processes may be a source of a lot of sloppy
handling of. PCB, I am not saying that is
true of some of the major companies who do
that, but a lot of the stuff we have heard
had indicated to us "n the past that might
be where a lot of PCBs are getting into the
environment, not by the large companies that
have their repair sho s.
:c am just wondering if
you took all the recommendations of the
source of the liquid and effectively stay
you can't make any now ones or import any
pure onea, to what extent we are buying a
bigger problem in tvunty years or ten years.
Leave that to the market.
MR. ONISIII: I ihink we le-ive it to
the market, but I do.-j" t think it is going
to be a real problem. Tha requirements or
restraints on handling FC3s are so restrictive
that I think repair of transformer facilities
is going to be fairly costly.
-------
MR. BILES: The other provision we have
to deal with and people have commented on is
the provision on resale. I think it is
obvious that one of the things it was in-
tended to cover in the maintenance of the
transformers.
The Act says that you
can distribute in commerce the liquids if
in effect they were sold prior to the middle
of '79 and are for purposes other than re-
sale.
How possible is it fox
industry now to essentially get in stock
the PCBs it is going to nesi because otherwise
we face the problem of having to grant some
kind of real exemptions for people who buy
PCBs later and reduce them in granting the
1979 type of exemption time is difficult.
What I am here to say
is that on hand all the things ~~ getting
sold in the hands of repairers all the liquid
they are going to need by the end of '79
doesn't make sense.
MR. OIIISHI: I am not sure I understood
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• 157
the question, bat T would say that few, if.
not any of the utilities I know of, intand to
try to stockpile adequate amounts of PCBs for
any repairs or reclamation they way anticipate
in the future.
MR. BILES: What I am referring to is
that the legislation says you cannot dis-
tribute into commerce any PCBs after July 1st,
'79 unless they wero sold prior to that date
for purpose of resaLa,
It sounds like you are
going to have PCBs being sold after July 1
of '79, which in itself c.an —
MR. OMISHI: Wa.lt a minute, I don't
quite follow you.
MR. BILES: You are talking about
reclamation then in selling -~
MR. OHTSHI: I am not talking about
reclaiming and selling, 1 am just talking
about reclaiming an3 reusing.
MR. BILES: Just one ™- the one repair1
so you are not different entities?
MR. ONISKI: No.,
MR. BILE£: Thank you.
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158
MR. PRINCIPE: On the maintenance of
transformers, it is ray understanding that
when they take a sample of liquid to test,
that it is approximately a pint. DO you know
if that is some magic amount or would it
be possible to reduce that amount?
MR. OMISHI: I think I understand
our sample quantities to ba a half a pint*
But, I think you would have to have an
adequate sample to make the analysis. But,
I wouldn't see too much benefit to be gained
by having to reduce that amount further.
MR. PRINCIPE; I have read something
about trichlorobenaene to dilute PCBs in
transformers to the point whore you have
approximately 60 percent TOD solution to
40 percent PCB. Is it possible that Instead
of using TCB to replace PCJJis you take out to
test, let me say the Dielectric fluid you take
out to test instead of replacing that with
PCBs you replace it with trichlorobenzene,
arid then over the life of the equipment it
wouldn't really iaa.ke much
-------
MR. ONISHI: You are correct,
trichlorobenzene is added to PCB and PCB
fluids, but it is a mixture at present. We
have been looking at the use of trichlorobenzene
as an additive rathe): than PCBs. Certainly if
it is feasible we intend to do it.
There are some supply
problems with trichl.orobenzene and a fe"
other properties that they have some
dif£iculties with, at least in ray last, review
of this literature it indicated that they
had some difficulties.
MR. PRINCIPE: Could you elaborate- what
the difficulties wera; are they safety?
MR. ONISHI: Safety, I think there was
a pour problem, tenparature and a few problems
of that nature, cheriical problems.
MR. PRINCIPE: Do you have any iflea
what stockpile in a nornal utility woald
have today of .PCBs, that is what quantity?
HIl. OS I SHI: No, I think you would find
considerable variations, but it would
probably range froit. a few gallons to maybe
a couple of thousand gallons.
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- 160
MR. PRINCIPE-; Thank you.
KR. PEARSON: This may be a little
repetitive, but have you looked into the
possibility of th« difficulties that smaller
electrical utilities and cooperatives and
municipal electrical companies are going to
have with this?
MR. ONZSHI: Most of the smaller utilities
have a very limited number of transformers.
Almost all utilities uae capacitors and
capacitors are primarily a replacement and
the new product would not be PCB problems, you
would not have ma>;a~up fluids in this sort
of thing.
AB lon
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* 161
formers it would still be important.
MR. ONlSHIs Well, that is correct,,
MR. PEARSOHs Would they have had to —
would you foresee them having a great deal of
difficulty having the* transformers serviced
or replacing PCBs in them in the future?
MR. ONISHI: Ho, I would think that the
small utilities would have very little in
number, they would he in ;i position to phase
out their transformers more quickly.
MR. WIRTH: Okay/ thank you.
Any more question*!?
Any questions from -the audience?
MR. RICE: Dan :i*ice, R-i~c-a, from the
Illuminating Company, Clearwater, Ohio, and
I address the question we had on repair here
for transformers, because I think when we're
talking about the larger power transformers
most of them go back to the manufacturer or
the rupair shop.
At least in some companies
what we might call minor repairs is daing it
in a shop within the facility of the utility
and minor repairs might be replacing bushings,
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"• 162
repainting the case to make it laat longer and
in general just refurbishing the transformer,,
putting in new oil if that is what is required.
I am not sure if you're
trying to find an interpretation of what
repair actually is for this. But, there are
lejvels of repair as I see it.
MR. BILES: That is why I was asking thts
question for further opinions about processing
and using because the statute allows us to
authorize uses of J*CBs in a non-1t:otally-enclosed
manner indefinitely. Theru is no 1979 ban
on the uses.
But, if that particular
activity also contains processing then there
ie a '79 ban on processing. And the question
we have is if EPA wantt; to adopt a policy of
allowing the continuing usciJrul life of the
transformer and therefore aJ.lowing the handling
of the PCE liquid and transporting of the
transformers, where do we draw the line betw«ien
say in one activity constitutes actually
really manufacturing the transformer which
we're trying to prevent and the other allows
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* - 163
the continuing of the: useful life of it.
I was still trying bo
find out where do you draw the line between
those that constitute making a new transformer
and those which are just, you know, routine
maintenance operations. That is the kind of
definition we are probably going to need.
MR. RICE: Maybe frow a utility stand-
point if you have to rewind the transformer
to the core now you are talking about some
type of raraanufactoring, but if you are just
painting the c&ae or if you have got a force
on a bushing and you're replacing a bushing/
or you're filtering the oil this, at least
from our standpoint, would be maintenance to keep
the useful life and that is all and it wouldn't
— from our standpoint wouldn't be reiaanufacturing
I don't know if that is
clear on both aides, but it is just bringing
the point so it is clear.
MR. WIRTK: I think it is clear now.
Is there another question?
MR. DONZALi My name is Dav« Donzal,
D-o-n-z-a-l, from Toledo Edison Company. I
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- 164
just want to make one comment in regards to
the spill prevention problem.
Generally speaking, w€»
have no problems with developing spill
prevention as we have for oil, obviously PCB»
are a lot worse environmentally than oil.
The two problems we hav®
found in getting our thoughts together and
developing these plans mainly ara network
transformers and precipitator transformers.
Mr. OnLshi mentioned sorao
oif the problems with natworx transformers,
in that a lot of time a you iiave atandpipes or
you have pumps. What we a:re looking at right
now is trying to g«t some :sort of: adequate
sensing device such that you can determine
when you have a detectable amount of PCB in
the water, the rain water that coiaes into
the vault, like in a downtown application,
determining when It is safts to pump the water
out.
The other problem which 1
air. told that we do have is the physical location
of sorue precipitator transl'ormersj which are
-------
165
aakarel containers, contain askarels because
they're in an indoor enclosure, obviously in a
power plant. And I guess there are sorao
problems physically in developing an adequate
spill prevention plan for this type of situation
MR. WIRTU: What were the two terms you
used, network transformera as one where, if Z
understand it correctly, the utility company
owns that is part oi: its distribution system?
MR. DONZAL: That is generally what I
was referring to.
MR. WIRTH: Whuc was the other ttirm?
MR. DONZAL: The thing I was pointing
out is that the objact right now is developing
a spill prevention plan for PCDs, obviously
it is coming up in the future.
We do have two problems,
one with network vaults and one with olectro-
static precipitator transformers. And the
only point I was trying to make was to point
out to the agency that there are soioe physical
problems associated not only with the network
transformers, as Mr. Onishi has pointed out:,
but also in the case of the -- when you have
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168
a transformer in a power plant, you know,
perhaps on top of the hollars or something.
Ma. WIRTH: Okay,, fine.
Any further questions?
Would you coma forward
loast to the middle of the room so the
reporter can hear.
MR. PEW: Yes*, I am Paul Few, from Ohio
Transformer Company. Wo do repair transformers
a» you were discussing her 2.
IM lixe to sffer this
advice that prices may be tae separation in
the repairs we accj talking about. w® get in*:o
major repairs of an askareL-filled transformer;
today the coat of aakarel Is rising and
practically puts us out of the market in cve>ry
major repair of transformers. Y?u may be
limiting tha major repairs in that aspect and
still allow the service to 90 on without
additional ruling on the tiing.
I'l appreciate it if you
would consider that. It i;3 hard enough to
try to compote in business without -~ you know,
without the additional rulings oa things.
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167
MR. WinTHs Okay, thank you.
Any further questions?
Jloviny on to the r^ext
witness, Mr, William Curtis, Manager of
the Electronic Diviuion Northern State-.s Power
Company/ Minneapolis;.
MR. CURTIS s I just (jot a promotion
I wasn't aware of.
My name is William
Curtis and I am Manager of Electronic
Distribution for NSPt, we're an electric
utility located in Minneapolis, Minnesota,
and we serve a four-state area, Minnesota,
Wisconsin, Worth ami South Dakota, an& our
headquarters are in Minneapolis.
It is enjoyable to follow
Rarry because he generated all the questions
that I was going to bring forth. But, I have
a couple of comments I'd like to address
myself to here.
fts fa;- as duration,
extant of use for existing equipment, it is
our recommendation that all field products
such as ca^icitors and transformers containing
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168
anfcarels bo allowed to remain in service for
their useful life.
The following reasons
support our recommendation: the cost of thin
replacement would be prohibitive. We have
1800 capacitor banks and approximately 900
transformers in service that if we were to
replace them immediately or in the near future
would cost approximately $'33,000,000 to
our repairs, environmental costs are passed
on to repairs.
We feel that we have
already made strides in th
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* 163
maintenance was answered very good by the
gentlemen that wore here, but I think at NSP
we would look at maintenance of transformers
and relate the question to economic decisions
whether the transformer would be scrapped or
repaired would be an economic decision, so I
see no reason to elaborate on that.
Some of the areas that
we have worked with, at NSP we have an
environmental department approximately fifty
people that work on all the regulations, we
audit and check on our division operating
people to make sure they're abiding by our
policy that we have established, we work with
other customers such as primary customers that
have PCD type transformers relating tc them
some of the problems! they are faced with ani
trying to ir.doetrin&te and educate.
That ;.s the extent of my
comments and I woulc, be willing to answer
some questions.
MR. WIRTH: The.nk you, Mr. Curtis.
I am going to take the chair's
peroc/ative to a&k the firj;t one or twc questions.
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110*
I understood Mr. Onishi,
I guess it is a point I_wan1; to make absolutely
straight in ny mind, that in an .Hskarel-fillod
transformer there is not a blow off or an
expansion device that under norra.al condition!*
that would normally would b«a releasing PCBs
to the environment/ that the only type of escape
from the tank was through a pressure valve i;n
the case of ntassivs overheating or failure,
i« this correct?
MR. CURTIS: That is correct.
MR. WIRTH: So that there should be no
formal -- there should bt» ;io release from a
transformer -•- askarel-f il Led transformer
unloas it jast completely !iiled on rare
MR. CUKTIS: That is correct.
rlR. WIRTH: The second question is back
on the trichlorobesnzene a3'3ition; is thare any
r«ason in the world why th; make-up fluid ha;ii
to be askarel in all cases or draw off only
for testing purposes in pi its? I mean, the
size of most of thase transformers, in my
understanding, would be that it vould be almost
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171
non detectable replacement make-up fluid thit
you would draw for analytical testing purposes
MR. CURTIS; Well, w« would draw a half
pint o£ fluid too.
if I understand ycur
question ~~ would you repeat It, I am sorry
1 lost you a minute there.
MR. HIRTHi I ar.i making sorae assumption
here that if a transformer has a thirty or
forty year life, I presume you test more than
once a yaar?
MR. CURTIS: We draw fluid once a year,
yes.
MR. WIRTSii Yo'j are drawing off n half a
pint, even over forty years is ten pints,
two and a half gallons that is make-up fluid
and that ten gallons were other than ^CBs
that will have a very voluble impact on the
performance of the transformer; is thare any-
thing wrong with that assumption?
MR. CURTISt No, that would dopeni on
the size of the transformer, and they vary
from sixty gallons up to five hundred. So,
I can't see that that is such a low percentage
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17
that it would cause such a problem.
MR. WIHTH: QJcay.
Is there any reason that
the PCBs should be removed from the transfonnttr
other than complete rebuilding; in other words
operations involving the rewinding or for th«»
replacement of the fluid once it is determined
on an analysis of the fluid that it is re-
quired to be replaced it will not function any
longer?
MR. CURTIS: I sea no reason why we
would not use a smaller transformer, a non-
PCB transformer, our distribution overhead,
or oil, and we would ship it; back to G.E.,
Weiscinghouso, the manufacturer.
Thca economics just aren't
there. You have to have people io do it.
You can't keep these people employed unless
you have a volume. We don t.
MR. WIRTHJ Oi:ay.
Is there anything wrong
with coming to the conclusion th
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173
from it could be destroyed and it continues
on in that way for its entire useful life?
.M^. CURTISs I oan't see a problesn
personally in my experience.
MR. WinTH: It nakos it relatively safer
environmentally to withdraw it and ser.d it to
disposal and in ray opinion it would greatly
reduce the possibility of environmental ex-
posure to it than if. you -cum around cintl
attempt to put some back in, is that a correct
assumption?
MR. CURTIS: I think so, yes.
MR. WIRTH: Let's start ^ith questions
at the oth«^r end of the table.
Mr. Pearson do you have
any?
MR. PEARSON; So.
Mil. PRATT: Realizing this may not be
totally appropriate since the Twin Ci :y are-a
is in the middle of a drought as I understand
it; but, if I recollact correctly NSP had a
problem xvith PCB transformers with flooding
conditions awhile back.
I wan wonderina w'iat
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* 174
type of procedures have you instituted to
ensure that this would not reoccur in all
of your facilities?
MR. CURTIS: I &K\ not aware of a drought
in the Twin City area. I am not aware of
flooding problems either.
But, w«s have instituted
policies that our distribution people follow
on handling, storage and disposal of PCDs;
we have forms that we fill out; we work very
close with the State, we record every spillover,
so many gallons; and as 1 said wa work very
closely with the State on this.
So, I am not aware of
the problem that you are referring to, but.
I can sure check when I geb back. Maybe it
happened while I was gone.
MR. BILKS: Does MSP parfora any repair
or Maintenance operations for non~2IS? trans-
formers?
MR. CURTIS: No, no we don't.
MR. BILES: Do you foresee that, assuming
you aren't going to be buying any new trans-
formers after the middle of ' 7 L> which is the
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175
date we are looking at, do you see any nead
for JMSP to buy or aell transformers other than
if you are selling thorn in tho sense of sending
them for disposal and momsy changes hands or
you sell a whole facility that contains a
transformer; ia thore any reason for you to
buy or sell any transformers after that now
or in the future?
MR. CURTIS: We wouldn't sell a trans-
former if it had usttirul life, if there is
any economics to it we keep it in useful
service.
Che only other ca*e, and
I think you are referring to this, is where
a municipality want.s to buy us out anc we are
willing to sell.
MR. BILES: And is the major work on your
transformers done by the people who m&ke the
transformer, if you have laajor work to be done?
MR. CURTIS: Most of the major work is
done, yes.
MR. BRKMER: I have Iiad the opportunity
about a year ago of testifying at the
Minnesota Sonata Hearings on PCBieg illation
-------
176
for the Stacu of Minnesota. And I was under
the impression at that meeting that Northern
States Power strongly objected to a ban on
PCBa because of a very Icirga facility that, was
in tiio planning stage for asinq a large number
of powgr factor correction capacitors. And
at that time the individual stated that they
definitely hud to be askar.2l-filied and that
this type of, you know, they'd have f;o have
exemptions to get this facility in some type
ol: order.
Now, I was wondering
do you have other replacements at this time
that you thiiik -- or have you solved that
problem or is this ban proposing a great
problem for your particular utility or do
you have replacements at this time for
power factor correction capacitors?
MR. CURTIS: Well/ as Harry mentioned lit
his testimony, we no longer are buying askarol-
filled capacitors or transformer.3. We are
buying a silicone oil.
HR. BRKMER: Also for capacitors'?
H.;<. CURTIS: Capaoito::*,
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177
MR. BREMER: They're filled with silicone?
MR. CURTIS: Our shipment cowing this
year will be silicor.o oil,
MR. BREMER: So, then, silicone can be
used in power factor type capacitors?
MR. CURTIS: That is what the bulk of
our capacitors are for, power factor correction
for our system.
I am not familiar with
that testimony,, but I surely can check, I am
not familiar with that instance that you are
quoting,
MR. BREMEtt: Weil, you Jcnow, 1 just
remembered that the:re was, you knov, a very
large problem by the very fact that they
said there was no replacement, but your
position now is that there are replacements
that can take over in the situation?
MR. CURTIS: This could have booa the
case last year on our order with the manu-
facturers on the power factor correction type
capacitors. We ordered quite a few of then
every year and it could have been the case,
But, this year we are getting ncm FCB type
-------
r/8
fluid.
."in. BREWER: Very gool. Thank you.
DR. S'PURNO; I have one question.
You have indicated, as
wuii as Mr. Onish, that about half a pint
o:: PCD is withdrawn for the test. Do they
use the whole half pint to dlo the teat, or
clo you use a small portion of it afterwards?
I raean, what do thoy Jo with it after they
tested it?
MR. CURTIS: They use the whole half
pint for testing. The/ ha/3 Uo test such
things as pour point, aeicli ty of the JJluic!,
Dielectric strength, they .ran a souple
Dielectric: atrengtJi to3t&. The whol«s --
taere isn't nuch loft when they fininh
their tos ts.
JR. STURINO: So, then the saiaple io
consumed during this testing?
Mil. CURTIS; ,.
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173
that it aou?.<3 not be used any more?
'ft soons to me a lot of
people have been t«l!:ln
-------
180
audience?
MR. OKflSHI : tfes, I just want ad to
comment. As I understood .you, you are
drivinj at since the amount: of fluid that
you ;;ook out of the saraplG is very small
arid the transformer IE totally enclosed then
the raake-up fluid requirement ought to be
very small. I think I mado the assumption
that in some cases th~ flu:.:I itsolf might be
contaminated by moisture 01: something, the
transformer itself might be„ In those cases
we would have to drain the frl.uid and refill
it so, in chose cases we wo aid have t :> ase a
roach greater amount o.f make -up f.'.uid than is
taken out during chemical c.nalysi.s.
MR. WIRTII; Yes, sir, If I didn't maka
it clear I understood that .if ttu; fluid test
poorly, or malfunctioned the enti.ro fluicl
would have to be replc'iced.
Mr. Brerr.er?
MR. 3REMER: On the sarr.e line there,
if you have a lot of moisture contamination
in a transformer, isn't it rather an open
systen?
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18.1
No, it .Joes moan you
probaMy have a leaky seal aom«wh«ra r.round
the bushinj.
J'.S. BP.SMER: Wharo I- would have tahan
the water fron th0 outside it wouldn't, be
takan out of the air then it would have been,
say, from rain water'*
MR. ONflSHI; I-*; could be rain vat.er.
If you ha-I a situation wh^ro you had .?. laaky
3eal it ',70-xld be accumulating ^oistiircs Trom
t-he transformer. Of course, there is no
»- that is not a nor;,^al condition but it
could happen.
MR. VTi:tTH: Do ;rou r<»placo tho-ie sr»als?
213. ONISHI: T" thsy are faulty, y«s.
M!?. 57TRTH: Is that :sn in-piace servicing
or is the transformer usually haulsti C'U1.. for
service at that time?
!!R. OMISHIt ICo. !r.haj; eoul-1 }->e ^on? in
place.
.MR. PHTNCIPE: -r?his is properly z
question '"'or both of you, but I will use
your numbors.
:lo'«;, ^''ou indicatec that
-------
you had 900 transformers in use, of those
900 transformers about; how many each year
do you find that you have to replace or
regenerate the fluids because of contamination;
do you have any idea what tliat number would be?
MR. CUKTIS: It depends. Vary few, I
wouldn't even want: to guess.
Looking back over the
past year I can't even recollect pulling a
transformer out ol: a vault .and moving it to
another location except only in ^ases where •che
load -- the customer reduced his load and we
had an oversized transforra»;r and economically
it would have been better oTf tonewimre else
I can't recollect one case of this type of
thing.
i-IR. WIRTH: Do you recall t.ie last time
you had to replace a transformer fluid in your
system?
MR. CURVIS: I'd only be ouassing, but
in the last year 1 can't really recall going
through any proceuu ot: replacing -- these
ara co:npl«tely sealed and anless we have ---
the roof falls in or a catastrophic failure,
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133
which I can't recollect, there is nothing
that can get in or oat to cause coatauii.aation,
especially moisture*
ii;t. PRINCIPE: I gue:»s my question then
has to go to Mr. On:'.:jhi, chon.
We have heard on ei number
of oceations peopla liave testified that
contamination can -cake place anu it appears
that contamination •*- that that Ly-pe of.
contamination where you have got to regenerate
the Dielectric fluid is very rare, is that
a sound conclusion?
MR. ONMSHI: ¥•* 3, I think it. is *!a ir.
MR, CURTIS: The tests that we go through/
just to aJtl to it, are for a specific purpose,
and that is to determine the chemical properties
of the material whiou is our insulating jaecia.
And, it tliare is something off, for our company's
standards, then we JD through this proceclme.
It is a normal procedure trying to maintain
the reliability of the electric dietrLtution
systen to bettor serve our customer's.
MR. RICK: Dan Rice again.
I just have one corr.ment..
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184
you mentioned buying or selling transformers.
And raaybe for some utilities it is rare, 1
guese it is for all utilities, it is rare, bat.
occasionally we buy or sell a transformer to
another utility where for some reason they
h«ive a particular emergency need for that
transformer and it may not be available from
a supplier for some period of time, we have
purchased and sold equipment such ae this.
MR. WIR^H: okay. Thank you.
Any other cocaments?
Thank you very much.
MR. CURTIS : Thank yo j..
Would you coiae forward.
and state your name and a£filiation?
MR. POWELL: My name is Walter Powell
from Midwest Technical.
\d« do a lot of work for
private industries as oppoaad to utilities.
Okay. And I think the pri/ate industry isn't
represented enought right aow. tfe do work for
ittunulaaturiixf procasaors, industrial customers
who have their own transformers, own theix own
equipment.
-------
18.1
Utilities watch their
equipment very closely so they may not nave
that much of a problem. We get involved with
these customers, quite often in the repair of
transformers ~- PCB-ffilled transformers.
Quite often we have to take the fluid out
of the transformer right on site and repair
it for whatever reaeon, it may be beca.use the
bushing leaks, becauae of a broken seal, or
because of moisture contamination.
In the private sector,
moisture contamination is not uncommon. I
mean you are not talking about a large per-
centage at all, you are talking about a
relatively low content of moisture, you aren't
talking about water as you might visualize it.
So, in the private area
as opposed to the utility, there is a 1 t of
on-the-site repair that involves taking out
fluid, putting it back in, you have a certain
amount of loss in the volame of gallons when
you do that because of the pumping equipment
that you use, this has to be replaced ,
Another area is when ycu
-------
•1 L1 1~>
I 0 0
have broken seals of gaskets, there may be a
loss. This may not show up for two or three
years because the private area does not watch
their equipment that closely as opposed to
utilities.
So, I want to make sure
you aren't underemphawizing the need for on-
site repair and replacement of fluid that ha:i»
been lost from maybe a period of ten years.
Have I made my point?
MR. BILES: The question on that is
if we follow a process of getting the PCBs
over the next several years to reclamation
where do you reclaim your PCBs from? You
obviously don't own transformers of your own?
MR. POWELL: No, we juat aro a service
organization.
MR. BILES; So, where in the future
would you get the PCBa to make up the difference
you take out?
MR. POWELLs Where will we?
MR. BILES: Would you buy your transformers
and drain them?
MR. POWELL* No. No. If wtt had a
-------
187
customer and that customer had a tran«forraer
who is low fluid, I cion't know where we would
get it. That is going to be a problem.
MR. BILES: That is going to be ft very
critical issue if we try to project some way
to maintain transformers.
I'm. under the impression
that people like NSP got their transformers
repaired all the tine. In fact, that was one
of the responses that I think one of the
transformer manufacturers who do perform that
work gave.
MR. POWELL: One area that we ar« looking
forward to or our hopes are in is retro fitting
area. We are hoping that this becomes* a
viable solution.
MR. BILES: What would you do if there
was a ban on the manufacture and import of
liquids after a couple of years?
MR. POWELL: If we have a circumstance
where a customer was low on fluid and we
could not get replacement fluid the only thing
we could do would be to advise the customer
to replace the transformer.
-------
188
MR. BILES: Okay.
MR. POWELL: But, just he aware of the
fact that there are a lot of customers in
the private sector who have this equipment
and these are the customers that you are
going to be careful of because they don't
watch the equipment as the utilities do.
And if you are very strict the customer may
get themselves in a bind where he is going
to say, "if I bring this up I am going to
have a major expense and a large can of worms."
MR. BILES: Do you have a suggestion
on what we should do in terms of dealing wit a
that problem, in terras of allowing you or
anybody else in your position to meet his
needs?
MR. POWELL: Well, I'd like to see you
work with the utilities or people who are
pushing the retro fitting idea, that is our
only real hope. And, possibly, if retro
fitting may be viable if you had to take
down a thousand parts per million instead
of five hundred, something in that area.
MR. WIRTH: Okay.
-------
189
Are there any oth«r
comments?
It is eight minut«s
to three. We will take a strict eighl:-
ninute break.
(WHEREUPON, a short
recess was had.)
MR. WIRTH: Okay. We will reconvene.
The next witness is
John Weizeorick, is that correct, from
the Association of Home Appliance Manufacturers?
I will reiterate to
spell your name and also the pronounciation.
MR. WEIZEORICK: All right, my name is
John Weizeorick, W-e-i-z-e-o-r-i-c-k. I am
Assistant General Manager for the Association
of Home Appliance Manufacturers and I have
with me Mr. William Beard, who is Director of
Engineering of Room Air Conditioners Engineering
for Whirlpool Corporation.
AHAM is a national trade
association representing the appliance industry,
The comments which we are presenting are the
consensus viewpoints o C "he Association racrrber-
-------
190
ship and particularly those members who use
small capacitors.
AHAM recognizes that
the American public should be protected
against unreasonable risks of injury associated
with consumer products. In accordance with
this, it is the policy and intent of every
AHAM member to discontinue bhe use of PCBs
in its products just as soo:n as adequate
substitutes are available.
Section 6 (e) (3) (A) (i:i)
of the Toxic Substance Control Act states
that after July 1st, 1979 no person may
process or distribute in commerce any PCB.
AHAM interprets this to mean that any product
manufactured prior to that date and containing
a PCB article is prohibited from being sold.
Even though the appliance
industry will stop using PCB small capacitor**
in its products during 197/1, some products
manufactured during or prior to 1978 and
containing PCB small capacitors are likely to
be in inventories throughout the nation for
a substantial period after the July 1st, 1979
-------
191
cut-off date. It would be impossible to
locate all products and prohibitively expensive
to change even some of these PCB small capacitors
to non-PCB capacitors.
When issuing rule*! con-
cerning the phased ban of PCB, AHAM requests
the EPA to consider an exemption for FCB
small capacitors in the household appliances
including room air conditioners and micro-
wave ovens.
AHAM believes that the
household appliance :.ndustry has made a good-
faith effort to eliminate PCB small capacitor
usage. Microwave oven manufacturers indicate
that they will be fully changed over by July
1st/ 1978. Room air conditioner manufacturers
have been working diligently with capa.citor
manufacturers to develop replacements for the
PCB small capacitors and present estimates
indicate that sixty-seven percent of the 1978
model line will be equipped with non-FC3
capacitors. The complete changeover vill be
accomplished during 1978 HO that the 1979
model line will be non-PC3 capacitors.
-------
192
So, again, we urge that consideration of an
exemption for small -~ for PCB s-tiall capacitors
used in household appliances be considered.
Mr. Chairman, that concludes
the statement regarding the PCB ban.
However, AHA.M does have
some concern with the labelling requirements
which were published under the proposed rules
for regulation: would a statement on this
be in order at this particular time?
MR. WIRTH: Mr. Wei2e*orick, the informal
hearing has been concluded on the labelling
arid disposal regulations. The reply comment
period to comment or to statements made in
the hearing is in order to discuss.
Because that entire
process was accelerated even over our own
stated procedures EPA has stated that it
would consider all comment!* basically relevant
to that regulation done until the final closes
of the reply comment or th« twenty-fifth of
this month. I think under that general rule
we would entertain a short statement on the
labelling and disposal. The panel will not
-------
193
comment nor ask any questions on that sub-
ject because the hearing is closed.
And we would also like
to invite you to submit those comments? in
writing, identify it as a reply comment
for the record before the twenty--fifth
to ensure that they are given full consider-
ation,
MR. WKIZEORICK: This comment was
submitted in writing to the EPA at tho time
of the hearing. Our problem was was that we
had so many conflicts that we couldn't
shake anybody free to go there to present
the information and thought it might appropriate
at this time to reiterate this position so that
it is on the record very definitely.
If that is appropriate,
then, according to AHAM's interpretation --
MR. BILES: If you submitted written
comments then it is on the record. You will
not have any problem with that.
MR. WEIZEQRICK: There is some additional
information I have which was not contained in
our comments which we gathered since that
-------
134
point and I have here.
Would you like that?
MR. WIRTH: Well, I might say I think:
we will be happy to take that.
MR. WEIZIORICK: Or should I just file
it with the authority? I can do that.
MR WIRTH: Yes, I think it would be
better to submit it in writing because I
do think it would be out of order for us
to comment on this.
This is another transcript
and we won't have it available probably for
seven to ten days and today is the 19th; that
makes it the 29th which is four days after
the close of that period.
I think we would rather
have it submitted, even if you have it
available I will be happy to take it for
that specific record if you will identify
it as a reply comment for PCB labelling arid
disposal.
MR. WEIZIORICK: Okay.
We would be glad to answer
any questions on the PCB ban.
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195
MR. WIRTH: Theink you.
<"?aryf do you have any
questions?
MR. BURIN: Hav« there been any
technical problems t:hat you are aware of
that they had to change over to non-PGB-built
capacitors?
MR. WEIZIORICK;; I can answer the.t, yes.
I think Bill might h« able to provide additional
detail if you'd like,
MR. BEARD: There have been a number of
technical details and some of the cape.citor
manufacturers are hejre in this room and they
know the problems of finding a substitute
material.
But, from a user's; stand-
point air conditioners -~ room air conditioners
went through a period some years back of poor
reliability on capacitors and the whole
industry got stung pretty badly. So, we have
a natural concern for going through that sort
of thing again. So, reliability has been
a primary consideration/ so that the new
materials that have been proposed and tried
-------
19G
in the capacitors have had to be tested.
And because of the
accelerated nature of the program we have
been trying to go as fast as we can and I
have to say from my own experience that we
have even moved probably a little bit too
fast in some cases and started production
on capacitors with a given material and run
into reliability problems i:a our testing
which was going on concurrently and had to
back up.
And, so, I would say
from that standpoint there has been a
problem, we are continuing to work on it,
we're moving as fast as we can in monitoring
the results of those non-PCIJ capacitors that
we put in the field during this past year.
It. has been an accelerated program.
MR. BURIN: What is it that you mean
by "reliability"?
MR. BEARD: In this particular case we
are talking about the capacitor performing
its function. It is a IOSB of capacitance
due to degradation of the f:.uid, it is not
-------
187
a problem of rupturo or failure of that
nature, it ia a failure of the. thing
electrically.
KR. BILES; In your industry is there
any reason whatsoever to use any capacitors
that are leaking other than disposing of
them?
MR. WEIZEORICK: None whatsoever.
MR. BILESr Putting together the test,
your statement along with what Mr. Rollins
said this morning/ I am understanding then
that you saying that the fact that the
capacitors -•- the manufacturers of the sma31
capacitors feel that they can be out of that
business by the end of "78, you feel that l:hat
is adequate to meet your needs?
He this morning made a
statement that they did not anticipate at
least at this tint© that at that point they d
need an extension beyond 1978 to manufacture
capacitors?
MR. WEIZEORICKr Present plans of all of
the memberB of AHAM are to be out of FOB type
capacitors during model year 1973; that would
-------
198
put them into a non-PCB capacitor about the
fall of '78, August, September, October, and
about that time when they start making their
1979 model line, totally.
MR. BILES: Okay.
So, then, you would be
able to buy all your capacitors prior to
the middle of '79.
Would there be any need
for you after the middle of '79 to be selling
any capacitors? Do you see any reason what-
soever to be selling any small capacitors as
snail capacitors, not just selling the air
conditioners, but small capacitors?
MR. WEISBORICK: Present indications
are that even replacement capacitors in the
field will be non-PCB, which would mean that
wo would have no use for PC a capacitors.
MR. BILES: Would you be able to have
sold most of your air conditioners and micro-
wave ovens prior to the middle of '79?
MR. WEIZEORlCKs No.
MR. BILES: Or capacitor sales?
MR. WEIZEORICK: That is our problem.
-------
1S3
MR. BILES: How long do you thin/; that
will take for you to complete your sale- o''
what you manufacture! prior to that date, what
is the period --
H.R. WEI2EOKICI'.: Well, if the summer
continues the way it has .and we have em other
summer like this next year, it is likely tc
bo no problem with room atr conditioners.
However, our past history indicates th.-.t we
have products floatitag around for up co four
years out in the fiald after they are manu-
factured at various locations.
This industry, as a
matter of fact, is fairly unique in its
handling of inventories. At the end of the
season it buys back much of the dealer and
distributor inventory, which is something
that isn't normally done by other industries.
Although it buys it back, it doesn't always
take physical possession of that material,
it is stored somewhere out in the field
and some of it might even be shipped fron
the Northern staters to the Southern states
and re-financed and resold down there;. And,
-------
2 o
C. *•* *~*
so, you do get models which are three,
four years old to get. mixed in with other
units and end up getting stuck in a warehouse
and get dug out somewhere three, four, or
five years later.
So, it is likely to be
around and it would be very difficult to get
your hands on it.
MR. BILKS: Maybe this is a question that
goes to your supplier: do you have any idea
of the percent of small capacitor market room
air conditioners and microwave ovens cover?
MR. WEIZEORICX: No.
MR. BILES: I will ast that later.
The laat question is;
are you aware of any importation of PCS
cetpacitors or air conditioners or microwave
ovens that have PCB in them that are competing
with your products?
MR. WEIEEORICK: No, t am not.
MR. BILES: That doesn't mean it doesn't
exist, you are saying you a:re not aware of
it?
MR. WEIZEORICK: I am not aware of any.
-------
201
MR. WIHTHr Any questions from the
audience?
MR. GOLDSTEIN: Do you anticipate any
problems wi i;h your warranty procedure because
of the* change from PCS to some other type of
material, an alteration of your warranty
policy on your small appliances?
MR. WEIZEORICK: ?Jo, we wouldn't plan
on it. That is one of th9 reasons we are
very concerned with reliability of th<» capacitor,
We are not changing the warranty and w<=> want
the new ones to last as long as the old ones
did.
MR. WIRTH: Thank you very much.
The next witness is Mr,
William Ward of the General Motors Corporation.
MR. WARD: In process -~ excuse ?ne, my
name is William Ward. I am the Senior Project
Engineer with General Motors Environmsntal
Activities Staff based in Warren, Michigan.
In preface, I havs
given a copy of our formal comments to the
hearing clerk, I do have a limited number of
additional copies if anyone in the panel
-------
would like to see them, oth-arwisa in the
interest of time I will just briefly sumr\ari;se
our formal comments.
The first issue ---
MR. WIRTH: Excuse me, Mr. Ward. Are
you going to read from your comments?
MR. WARD: I am going to read selected
portions of them.
MR. WIRTH: Can wo have a copy of this?
MS. WARD: Certainly.
I am sorry I only have
three copies here, but I did give th
-------
203
recommend that electrical devices which
contain PCBs and are factory sealed at the
time of manufacture also be classified as
totally enclosed when used with their original
seals intact.
An additional consideration
in defining "totally enclosed" is the in-
cidental contamination by PCBs of certain
fluids used in heat transfer and hydraulic
systems. Specifically, until 1972, PCBs were
widely used as fire-resistant hydraulic fluids.
When the environmental risks associated with
PCBs became known, General Motors ceased
purchasing PCB hydraulic fluids. Typically,
PCS-containing hydraulic systems were drained,
flushed, and refilled with non-PCB fluid.
After nearly five years, we still find PCB
contamination present in many hydraulic systems
at the parts-per-million. Hydraulic 3ystems
are, by nature, not permanently sealei.
However, they are sealed when in normal
operation. The same is true of heat transfer
systems used in some GM operations. Heat
transfer systems are less susceptible to
-------
204
leakage because they are not subject to the
pressures present in hydraulic systems.
Therefore, we request the EPA establish a
PCS concentration of five hundred parts~per-
million or less as being considered incidental
contamination and exempt such situations from
the "totally enclosed wanner" limitation.
Speaking to the exemption
provisions, an exemption should be granted
for any type of incidentally contaminated
system. The EPA has recognized, in the
proposed PCS disposal regulations, those
published on May 24, 1977, that incidental
contamination of various systems has occurred.
A cut-off of five hundred parts-per-million
is proposed in the definition of "PCB mixture"
for disposal purposes. This definition should
also pertain to all exemptions authorized
under Section 6E of the Act.
A hydraulic system
containing residual PCB concentrations of
less than five hundred parts-per-million
does not pose an unreasonable risk to health
or the environment. The system is enclosed,
-------
- 205
and, therefore, workers are shielded. Waterborne
discharges from the systems are controlled
under the provisions of the NPDES permit program
and other discharge regulations. We expect
that systems which once held mixtures containing
60 percent to 90 percent PCBs will cor.tinue
to show low levels of residual contamination
for many years, even after being cleaned.
It is unreasonable, in
our opinion, to require industry to r«-clean
hydraulic or other fluid systems presently
containing laps than five hundred part.'3-per-
raillion PCS. The incremental reductions
in PCB content gained by successive draining
of a system below about one percent residual
PC3 are minimal.
The material costs of
cleaning a system are about $2.45 per litro
of fluid replaced. In a facility having say
five hundred thousand litres of hydraulic
fluid the material cost alone would be over
one million dollars. I base this cost on a
$2.00 per litre new hydraulic fluid cost,
flushing fluid at $.30 per litre and a disposal
-------
" 206
cost of $.15 per litre. Labor and part
replacement would be an additional cost.
It is apparent that
the costs of removing residual PCB con-
centrations are very high and the expected
benefits are minimal. In our opinion,
residually contaminated fluid systems
containing less that five hundred parts-
per-million PCB should be exempted from
the provision of Section 6E.
As a general position,
General Motors believes PCB should not be
recycled. However, there should be a
small stockpile of PCB Dielectric fluids
available for routine maintenance of
transformers. This would help avoid costly/
premature scrapping of transformers due to
the unavailability of Dielectric fluids.
Transformers require
different types of scheduled maintenance.
Some units require no maintenance at all,
other units do require maintenance, some
once a year, others may go as much as five
years between scheduled maintenance or service
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207
checks.
During th© maintenance,
as it has been pointed out, a small amount
of Dielectric is removed, tested, and
discarded. If the technician performing the
teat exercises normal precautions to prevent
spillage, the risks of PCB loss are minimal.
In our opinion, these precautions include:
testing to be performed only by trained
qualified individuals; use of an absorbant
blanket to catch any drippage; and scrap
fluids and the absorbent blanket to bo
placed in labelled containers for proper
disposal.
The release of PCBs
resulting from the transformer maintenance
is negligible, if proper, common senso care
is exercised during maintenance there is no
reason to expect any uncontrolled release of
PCBs. Consequently, the health and environ-
mental impact of transformer maintenance
are also negligible.
Turning now to locomotives
— GM produces diesol-electric locomotives.
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208
There are several small capacitors used in
locomotives which haves contained PCDs. Thoso
capacitors contain paper impregnated with
approximately two kilograms, zero point two
kilograms of liquid PCS. The capacitors are
obtained from outsider suppliers who are in
the process of converting to non-PCB Dielectric
materials.
GM has initiated a
program to completely phase out all use of
PCB-containing capacitors and diesel-electric
locomotives by January 1st, 1979. Thus,
there does not presently appear to be a
need for GM to seek an exemption from the
July 1, 1979, ban on distribution of PCBs.
At this time, GM sees
no propelling need to use PCBs in diesel-
electric locomotives, but neither do we see
a compelling need to retrofit locomotives
presently in service with non-PCB capacitors.
Electrical gear in locomotives should be
allowed to remain in use until the end of its
normal service life and be replaced with non-
PCB gear at that time.
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209
The arvount of PCB& in
a diesel-electric locomotive is small, a
total of about one kilogram PCB per locomotive
and is well-protected by tho body of t.ha
loconotive. Allowing continued use of PCB-
containing electrical components in locomotives
does not present any unreasonable risk to
health or the environment. And by allowing
conversion to non~3?C13 components on a
scheduled maintenance basis rather the.n retrofit,
unnecessary cost an rail service disrxtption
can be avoided.
In closing we recommend
that EPA allow existing PCs-containing electrical
gear to remain in uae for the remainder of its
useful aarvice life. We also recommend that
EPA abide by its proposed definition of PCB
mixture and specifically exempt any materials
containing less than five hundred parts-per-
million PCB as a result of incidental PCB
contamination from the previsions of the
Toxic Substances Control -\ct Section 6E.
I'd be happy to answer
any question.
-------
MR. BILES: Thank you, Mr. Ward. 21-0
We will start at this end with any questions.
MR. SNYDER: Does GM make electric
locomotives other than diesel electric?
MR. WARD: We are currently producing
only diesel electric locomotives.
MR. SNYDER: So, you are not involved
in transformer issues as far as locomotives
are concerned? Do diesel electric locomo-
tives have transformers?
MR. WARD: They do not have what you
would normally consider a transformer.
MR. SNYDER: Okay.
Do you have any
scientific basis for considering less than
500 parts per million to be insignificant?
MR. WARD: I don't believe I used
500 parts per million as insignificant.
I believe I used the EPA definition of PCS
mixtures in the lower cutoff as a basis
for exempting secondary incidentally
contaminated systems.
I am using the same
rationale that the EPA used in establishing
-------
p2 a 500 part per million cutoff.
MR. SNYDER: So, you are saying then
you consider that to be reasonable exposure
rather than classifying it as insignificant?
MR. WARD: I would say that a 500
part per million cutoff for secondarily
or incidentally contaminated systems is a
reasonable cutoff.
MR. BILES: You indicated in your
written comments, I don't think you mentioned
this, but you provided some comments on
what is insignificant exposure?
MR. WARD: Yes.
MR. BILES: And a couple of the comments
you made are that because most of the data
is short-time high-dosage data it is hard
to say with any kind of quantitative data
to back up any conclusions as to what would
be an appropriate level of significance.
You also say it is impossible to state
the specific exposure level that is insigni-
ficant. And further you conclude that an
insignificant human exposure level might
be in the lower parts per million range.
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212
Is this based mostly
on -- or exclusively I guess on your re-
view of our criteria document?
MR. HARD: This is based on the lack
of data at present.
MR. BILES: You state again in that
discussion surveying the data, indicates
of EPA criteria document; is that basically
where you derived any of your comments
from?
MR. HARD: That and bibliography are
my main sources. There are other sources.
MR. BILES: In terms of hydraulic
fluid and system it is unclear to me the
position you are taking.
I understand you are
saying that anything lower than 500 ppm
should not require any flushing or cleaning
besides possibly preforming them?
MR. HARD: Right. Right.
MR. BILES: Do you believe that above
that figure we should prescribe some kind
of flushing, cleaning or whatever require-
ments on systems that previously were using
-------
p4 PCB hydraulics?
213
MR. WARD: Above about 500 parts per
million of cleaning and flushing will
give you — one cleaning and flushing would
give you some significant decreases.
Below 500 parts per million, or actually
the number is something like a thousand,
but below this point there is a very definite
cutoff, you no longer have good economics
in terms of getting much PCB removal per
flush.
To go from 500 to 100
requires much more extensive cleaning than
going from 90 percent to 500 parts per
million.
MR. BILES: Do you have any idea how
those cost figures might vary depending
on the size of the facility or the type
of system the fluids were used in?
MR. WARD: It might: be $2.45 per litre
cost figure is based on $2.00 per litre
as a current price for non-PCB fire-
resistant hydraulic flurid; 30 cents per
litre for a typical flushing fluid,
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214
straight mineral oil; and 15 cents per litre
for disposal. That would be -- those
would be invariable constants.
MR. BILES: It appears that we have
at least three options if we want to say
anything about those kinds of systems;
we can either — we have a fourth option;
we can do nothing; the three options if we
want some kind of regulation is either to
prescribe some kind of a process such as
anybody using that previously flushing
must go through the following procedure
or we can prescribe a number of achieve
such as 500 parts per million of above
or below that, or we prescribe a foundation
a combinationr flush and in the event get
down to 500 parts per million.
What is your feeling
about EPA prescribing the process for
cleaning or for saying that you have to
do this if you haven't done it in the past
rather than prescribing a number/ but
essentially saying to everybody, "You have
to flush and clean your systems to a
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215
p6 certain procedure and we are going to
assume that it will get you to a certain
level."
MR. WARD: I can envision a circumstance
where there would be a system which would
have contained a 90 percent PCB mixture or
a 60 percent PCB mixture at one time which
never would have been flushed but would
still be below say a thousand or 500 parts
per million, whatever the cutoff would
happen to be, even though it had never
been flushed, it would flimply be a very
leaky system; such systems are not unknown.
In that case what is the use of flushing,
you have already achieved a number.
MR. BILES: A couple of other questions,
one is that EPA may dispute that 500 parts
per million is an adequate number to
achieve, and the other is I know that in
your written comments you state one of
the reasons for not requiring even below
500 parts per million in the NPDES permit
program is handling that.
MR. WARD: No, the NPDES program will
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216
handle any water-borne discharge from a
facility which may at one time have con-
tained PCB hydraulic fluids.
MR. BILES: Are you aware at any of
your facilities is there an NPDES permit
which does contain such a limitation?
MR. WARD: Yes, there are.
MR. BILES: Do you know how many
facilities you have in which that permit
would contain a PCB limitation?
MR. WARD: I could stop and count,
one, two -- we have two definite, we have
one monitor only and we have one proposed.
MR. BILES: Okay.
The last couple of
questions deal with your transformer
maintenance, because that is the subject
we got in with the last couple of people.
Who performs your trans-
former maintenance; do you do this?
MR. WARD: No, we do not, we contract it.
MR. BILES: Do you contract back to
the people who sold you the transformer
or is it more the kind of people who have
-------
p8 spoken this afternoon in terms of -- are
you dealing with GE or Weatinghouse or
whoever you buy transformers from or are
you going to local transformer repair
operations?
MR. WARD: Yes to both.
MR. BILES: Do you have any idea which
you use more?
MR. WARD: No. I couldn't tell you
what the breakdown is on that/ that is
simply by local plant option and done on a
contract basis on ». purchase contract.
MR. BILESt You state in here that
you should be allowed to maintain a stock-
pile of PCBs for performing this maintenance
Do you have any suggestion on where this
PCS should come from? We talked about
reclamation, they aaid retrofilling would
handle that problem, but some of us believe
that we may find ourselves 10 years from
now having a lot of people to maintain
that but having no PCB to maintain it with,
that is a possibility.
MR. WARD: That is a very definite
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* 218
possibility.
MR. BILES: Do you have any thoughts
on how we can deal with that now rather
than 10 years from now and where those
PCBs should come from?
I assume for a corpora-
tion of your size this is not an insignifi-
cant problem —
MR. HARD: No, it is not.
MR. BILES: — saying you can't
maintain stockpiles but EPA turning around
and banning the manufacture and import
of liquids; do you know where you are going
to get them?
MR. WARD: We are going to find our-
self pretty much in the same position
as the service contractors.
Since we rely on service
contractors to the greatest extent, we
rely on service contractors we do not
as a rule maintain and service our own
transformers there will be transformers
pulled out of service at the given Decatur
rate on transformers you lose X number
-------
plO per year. The fluid in these transformers
possibly could be reclaimed or reused by
commercial entities specializing in trans-
former maintenance.
I am not saying that
this is the preferable way to go. I don't
intend or pretend to speak for the transformer
service segment of industry.
MR. BILES: Does most of the service
take place at your facilities?
MR. WARD: Yes.
MR. BILES: Almost all of it would.
Would you consider
once that transformer leaves your facility
that you are not going to get it back?
MR. WARD: Generally, yes. We would
rarely send one out for rebuild.
MR. BILES: What do you do with them
when they leave the facility, do they go
to disposal or do you sell them to somebody
else to rebuild?
MR. WARD: It depends on whether or
not the transformer can be used by someone
else, does it have any service life left.
-------
MR. BILES: I am assuming that if it
has service life you will want to use it?
MR. WARD: Not necessarily. In the
case of electrical monitors where for
example you had a plant that was using
4.8 kilovolt primary service and suddenly
they find it more advantageous to use
14.2 kilovolt electrical service they
would have to abandon their 4.8 transformers
and replace them.
These units still may
be perfectly good serviceable units for
someone else in which case they would have
some salvage value.
MR. BILES: I just want to make a
comment that one of the problems we're
having today is the future availability
of the liquids for maintenance. And, if
you, as well as anybody else have any
thoughts in the future, particularly
during the proposal as to where these
should come from I think it would be
very helpful to us in particular because
I think you and some other industries,
-------
221
p!2 some other users of transformers represent
industry that by and large have not b«ten
represented throughout the PCB hearing
that the EPA has conducted over the past
year and a half.
MR. WARDS This is very true. We
have not heard from the smaller transformer
repair shops and from the non-utility
industrial users.
MR. WARD: We have been there. We
have been listening and we have submitted
comments from time to time.
MR. BILES: Thank you.
MR. SHYKIND: It occurred to me that
you have the same hydraulic systems, same
problems presented to us by the Outboard
Marine Company that has 100 hydraulic
die cast press typo of thing where they
grind and still have problems.
How much real leaking
do you have out of these, are they real
serious sources of contamination?
MR. WARD: Leakage from a hydraulic
system is a function of many, many things.
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222
It is a function of system design, system
age, the cycle rate of the system, the
maintenance that is performed on the system,
the type of fluid used in the system, many,
many things bear on the leak rate.
Within a single given
location you can find hydraulic systems
that are virtually leak-tight and you can
find other systems that have very high
leak rates. One of the most --• let's say
that probably one of the major problems
that you would have would be a hose rupture,
this would cause you to lose the largest
volume of fluid at a given time if you
rupture a hydraulic hose.
MR. SHYKIND: So, you then collect it
or do you have facilities in case of a
rupture to pick it up?
MR. WARD: Basically the machines
are — do sit on pans so that normal leakage:
is collected.
If a machine breaks
a hydraulic hose you have oil under
several thousand pounds per square-inch
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223
p!4 pressure and it will go almost anyplace.
Generally within a
General Motors plant any drain within the
facility which is opened to the plant
floor to receive any type of drainage does
go to a process or trade waste treatment
system and any oils would be admitted to
the sewer in that direction would be
collected in the trade drain system and
removed.
MR. PRATT: Just to continue that
when you aay they'd be removed do you have
a specific disposal handling system in line
now for that type of waste oil so that
they would be separated out and disposed
of?
MR. WARD: A typical manufacturing
plant would have a waste treatment system
which would be designed specifically for
the type of waste that would be encountered
in the plant. If it is a plating operation
it would be designed to treat plating
solutions. If it is a machining plant
it would be designed specifically to treat:
-------
oily waste.
So, in a situation
where you have a need for higher-resistant
hydraulic fluids you would probably have
a waste treatment system that would be
compatible with oily waste.
MR. PRATT: Mo, the question was not
how you remove them, but what you did
with them once you removed them.
I would assume that
in many of the General Motors operation
you would have a lot of ordinary oily waste
that these would become mixed with, and
therefore these would be a combination,
therefore you might end up with 1,000
gallons of oil and 10 gallons of PCBs.
If at General Motors
practice now would you take those and have
them shipped down to Monsanto or some
other facility for proper incin-aration?
MR. WARD: First-off I don't think
we can use Monsanto anymore since they're
getting out of the incineration business
too.
-------
225
p!6 Our practice is to
collect waste oils, hold thero and than
have them removed by a person specializing
in reclaiming waste oils if the waste oils
do have a reclaim value.
MR. PRATT: Are they notified that
these contain PCBs and that they may be
hazardous?
MR. WARD: Generally in the waste oils
there is not a sufficient concentration
of PCBs. We are talking about a fraction
of a percent of the waste oil stream being
contaminated with a few parts per million
of PCIJ. So, when we dilute the thing
down in the waste treatment system we no
longer have any significant quantity of
PCB that is identifiable in the oil.
Now,, there are ~-
there are commercial concerns that can
take waste oils and convert them into
fuel oil in which case the fuel oil would
be burned, any trace of PCBs in the fuel
oil would be incinerated along with the
combustion process. Are you aware than
-------
" 226
if GM has incinerated waste oil containing
PCB that these materials are merely
volatilized and not destroyed they are
merely put into the air and come back down
to the city nearby or into the Great Lakes?
MR. WARD: I don't believe that is
true at all.
MR. PRATT: Do you have information
that says during normal process as GM is
employed there is significant destruction
of PCBs?
MR. WARD: I don't think I am in a
position to answer that question at the
moment.
I can't say that wa
have applied to the proper state air
pollution control agencies for permits to
incinerate PCBs that may be contained
and are contained in fuel oil.
MR. PRATT: That is not my understand-
ing but I don't think I will go into it
any further.
As far as going back
to the original thing, you are saying that
-------
227
p!8 hydraulic systems are basically a "closed
system". If they are a closed system
how do you explain the discharge of hundreds
of thousands of gallons of PCBs from General
Motors'facilities in Michigan, Indiana,
Wabash River, the Great Lakes? Isn't it
sort of incongruous when you say that
they are very tightly closed and yet thera
have been massive quantities of PCBs that
have come out of General Motors' facilities
via this source?
MR. WARD; I don't think I'd like to
address that question in this forum,
I would be more than happy to discuss that
with you, at your convenience, outside
this forum.
I simply do not have
the type of information that you are
alluding to at my command at this moment.
MR. PRATT: What type of testing
procedures does GM have to check as far as
— you said that oftentimes PCBs or PCS
materials would go down through the normal
collection system and would be mixed with
-------
* 228
the normal oil waste from that facility.
What type of a normal
procedure do you have for checking these
for PCB concentration before they would
be incinerated or otherwise discharged?
MR. WARD: If we have reason to suspect
that there are concentrations of PCBs in
any given material we have in-house
analytical capabilities to determine the
concentration of PCBs in those materials.
If there is a concern
over the material, the material may be
contaminated to the point where it is not
desirable to leave the material in service
or to allow the material to remain in the
environment the material will be disposed
of.
MR. PRATT: What type of program
does General Motors presently have for
evaluating say landfills where PCB waste
materials may have been disposed of
to determine whether or not they would be
making a long-term environmental affect
as far as getting out into waterways?
MR. WARD: We currently do not own
-------
- 229
?20 or operate any landfill disposal facilities
at all.
I believe that you
would be speaking to landfill operators
who are professionals in the field.
MR. PRATT: I an speaking of the normal
municipal waste facilities.
MR. WARD: In most places industrial
waste does not necessarily go to a municipal
facility. There are places of coarse,
where this in not true. There are cur
municipalities that will receive industrial
waste.
If we have a waete
which is a known hazard our procedures
are to landfill it if it is — if that is
the proper disposal landfill, to he.ve it
landfilled at a properly permitted and
licensed facility.
MR. PRATT: Thank you.
HEARING OFFICER WIRTH : Mr. Peetraon ,
do you have any questions?
I have just one
clarification on ny part and I thinK another
-------
' 230
question.
In the collection of
your waste oils does GM itself burn any
of those waste oils in any of its boilers
or do any other heat process, and if you
do not what do you do with them; do you
sell them to waste oil collectors and
in turn take them to burn?
MR. HARD: We burn some waste oils
in our boilers.
HEARING OFFICER WIRTH: Fro» your own
collection system?
MR. WARD: Some from our own collection
facilities, yes.
As Mr. Hesse pointed
out earlier today the State of Michigan
has found a massive concentration of
approximately 25 parts per million PCB
in waste oils. We find substantially the
same level maximum in our testing.
HEARING OFFICER WIRTH: And you have
burned some of these oils?
MR. WARD: We have burned some of tho««
oils. When you get to a point where you
-------
231
p22 have no more oil and you call the oil
company and say/ "We need oil" and they
ship you a. load and you have no idea
where that load came from and it is not
until you are burning it that someone say*?,
"Did you ever stop to think there might be
PCBs in it because it may contain waste
oils" and you run out and grab a sample
and you're halfway through the tank
and you say, "Gees, it does contain PCBs."
So, we do have to adjust our combustion
temperatures for it.
HEARING OFFICER WIRTH: It is commercial
oil you buy for fuel?
MR. WARD: YOB, we have found PCB
contamination in commercially purchased
oil.
HEARING OFFICER WIRTHs And that was
in fact waste oil, blended waste oil?
MR. WARD: The only thing we can
conclude is that it may have had some
waste oil blended in it.
HEARING OFFICER WIRTH: That i,9 a
conclusion you have never been able to
-------
232
verify whether you were receiving raw-
data refinery product or whether it had
been blended with waste oil?
MR. WARD: Let's say it is a strong
possibility it probably contained waste
oil.
HEARING OFFICER WIRTII: Do you ever
have an oversupply of this that you sell
to waste oil collectors?
MR. WARD: Wait a minute/ would you
clarify that?
HEARING OFFICER WIRTH: Well, on one
hand you burn some of it, do you burn all
of it, hold it until you can burn it,
or do you essentially sell or transfer it
to waste oil collectors of one type or
another?
HR. WARD: In many locations we do
transfer the oil to waste oil collectors.
HEARING OFFICER WIRTH: Are you aware
of the fate of that? Do most of them sell
it as waste fuel?
MR, WARD: Many of them re-refine
the oil and sell it back to us as functionable
-------
233
24 fluid, cutting oil, lubricating oil.
I should clarify one
point here. I get the feeling from the
panel that you're regarding us as having
X number of manufacturing operations that
are contaminating the walls with PCBs r
this is hardly the case, this is not at
all true.
We had very few facilities
within the corporation that ever used PCB
hydraulic fluids, very few locations. So,
as a general rule we do not have PCB contamina-
tion coining from within the plants.
There are like I say a
few shops that did at one tine use PCBs.
MR. PRATT: But, I think it should
be noted that there is 7 million pounds of
PCBs. Just as we heard from OMC there is
one facility there that has 106 million
pounds, it doesn't, take very much facility
to have that massive loss.
MR. WARD: I'd like to know where you
got your figures.
MR. BILES: One other question that
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234
I have.
You have urged that
we adopt a 500 parts per million cutoff
below which we wouldn't require anything
in terms of cleaning hydraulic systems,
and it appears that you base that number
on the fact that we proposed a definition
of FCB mixture of 500 parts per million.
If we change our
definition of mixture to 300 or so, 100
parts per million then should we do the
same thing from this number. In other words,
is this number tied to anything other than
the proposed definition that we proposed?
MR. WARD: No, it is tied to your
definition.
MR. BILES: For consistency only.
MR. WARD: For consistency only.
MR. BILES: Thank you.
HEARING OFFICER WIRTH: Any questions
from the audience?
Thank you, Mr. Ward,
we appreciate you coming in and explaining
GM's use of PCBs. And it is important
-------
235
p26 information for us as Mr. Biles pointed out
that we have not heard from the industrial
side in any great numbers.
Our apologies if we
made this appear that it was any investiga-
tion specifically into GM's program.
That is not our intent.
The next witness is
William Page of Dow Corning Corporation.
MR. PAGEt I am Bill Page, from Midland,
Michigan, and T want to introduce in the
audience a gentleman in the third row,
with the tan suit is Thor Orbeck; he is
here with me and he is the manager of
our dielectric liquid development program
and I may call on Thor to help with some
of the questions during the question
and answer period.
Now, Dow Corning
currently the major supplier of dimethyl-
silicone to the electrical industry as a
replacement for askarel in small power
transformers.
This material currently
-------
* 236
has been utilized in two ways, by far the
largest having been by transformer manu-
facturers for use in the manufacture of
new transformers. The other way the
material has been utilized has been in
retrofill and this has been a process —
and I have a prepared text here which I am
going to read, I have headings and I am
going to read the headings and go through
it.
Definition: In 1972
Dow Corning Corporation started using a
process we call retrofill to gain operating
experience on silicone transformer liquid
in various electrical devices. In a retro-
fill the original dielectric coolant is
drained, the device is solvent-flushed
for additional cleaning, and then the unit
is refilled with silicone transformer
liquid. We have been involved in askarel-
to-silicone retrofills and small power
transformers, transformer rectifier units
for smokestack precipitators, and electro-
magnets. We are not aware of any operating
-------
237
p28 problems with any of these retrofilled
units.
Second heading,
What is Accomplished: From an environmental
point of view the most successful retrofill
is one which reduces the PCB content to a
low level. We have used thorough draining
followed by solvent, usually trichlorobenzene,
flushing to do this. A key element to low
PCB level is complete draining of all
materials from the bottom of the transformer
tank after the askarel draining and after
each subsequent solvent flushing.
With the text I have
handed in there is an attached table. Th
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233
pressboard and other areas where it
was held.
Item 2: My second comment to the data
is optimizing the current flushing
techniques should allow routine
retrofilling to produce transformers
with post migration PCS in silicone
liquid levels of around two percent.
The next heading,
Future Technology! The above-mentioned
migration of PCB out of the core and coil
into the silicone transformer liquid offers
an opportunity to remove an additional
quantity of PCB from a transformer that would
otherwise be missed by simply draining
and flushing the unit. We have been working
on simple maintenance procedures that could
be performed on retrofilled transformers
after this migration has taken place.
Very preliminary laboratory studies on
contaminated quantities of silicone trans-
former liquid indicate filtering through
absorbing media can be used to greatly
reduce the PCB level. In one study we
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239
were able to clean up 50-pius gallons of
silicone liquid contaminated to 1.5 percent
down below 500 parts per million.
This study was
strictly experimental, but it is indicative
of the significant retrofill improvements
that will take place if this technology
develops further.
The next heading I have
is Toxic Substances Control Act Rules
Relating to Retrofill: Rules: In the
proposed rules you are considering allowing
the disposal of transformers in a chemical
waste landfill if no more than two percent
of the original volume of dielectric liquid
remains in the transformer. Please Refer to
the Federal Register, Volume 42, Number 100,
Tuesday, May 24, 1977, Page 26567 for the
full text. If this provision is accepted,
a person who owns a retrofilled transformer
will probably be able to simply drain out
the silicone transformer liquid and landfill
the unit in an approved manner at the <3nd
of its lifetime. In addition to the relative
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• .2.4.0
ease of disposal, the owner of that trans-
former will have greatly reduced the risk of re-
leasing a large quantity of PCB into the
environment during the operating life of
his transformer. In many cases that life-
time will be 20 to 40 years.
A second consideration
of the rules is to define mixtures that
contain 0.05 percent or greater of PCB as
"PCB mixtures." See Federal Register,
Volume 42, Number 100, Tuesday, May 24,
1977, Page 26565 for the full text. We
support your maintaining this 0.05 level
but feel that an exemption should be
made in the case of retrofilled transformers.
In a retrofill you go from 60 to 100 percent
PCB to begin with approximately down to
two percent PCB. The environmental gains
as we see them are as follows: I have
five items:
Item 1: PCB that otherwise would
be maintained for as many as 40 years
will be properly disposed of.
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Item 2: The potential of losing
a large quantity of PCD into the
environment is significantly reduced.
Item 3: Migration of PCD into the
silicone will result in less total
PCB going into landfill. The PCB
that migrates will either be removed
and destroyed as part of a maintenance
plan like the one mentioned above,
or it will be destroyed along with
the silicone transformer liquid at the
end of the transformer's operating
life.
Item 4: Spills from a retrofilled trans-
former will float on waterways and thus
should be easier to recover than spills
of askarel which sink.
Item 5: No need to maintain a PCB
top-off supply.
By exemption we do not
mean total protection from all PCB liability
but enough of a loosening to create some
incentive to do retrofilling. We all stand
to gain as pointed out in the five items above
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Additionally, the development of more
sophisticated PCB handling and disposal
techniques will go a long way toward
solving some of the current PCB problems.
Creating this incentive is one way to
make development of this technology more
attractive to the people who have the
resources to do it.
The next heading is
When to Retrofill: We do not support
across-the-board retrofilling nor do we
support legislating that retrofilling be
done. However, there are some instances
where it is justified* A good example is
a repair job when the askarel will need
replacement. In this situation when askarels
are no longer available, that equipment can
be kept in service by retrofilling with
silicone transformer liquid. The other
alternative would be to dispose of the
equipment by cleaning up, flushing and
landfill and then to purchase new equipment
to replace it. A second justified situa-
tion is a transformer which creates a
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243
special environmental risk due to its
location. Examples of such units are ones
located on ditches, docks, or streams where
liquid loss would result in direct loss
of FCB into a waterway.
The next heading,
Cost of Retrofilling: We currently know
of four service companies that are offering
the retrofill service. Their prices vary
considerably depending on the specific work
to be done. Most job bids we are aware of
have been in the $22 to $32 per gallon
range. This includes the total job, all
materials plus disposal of the PCB. This
economic consideration alone eliminates
some transformer candidates. In some older
transformers the gallons of dielectric
liquid per KVA is quite large. In many of
these units it is less expensive to replace
the old unit with a new transformer rather
than retrofill. However, many newer
units can be retrofilled far less expensively
than replacing them with new, particularly
when you also consider down time, delivery
time, cost of disposing of the old unit
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and many other factors. .«*-*-*
Next heading,
Technical Efficacy: Numerous technical
studies have been run substantiating the
efficacy of using silicone transformer
liquid to retrofill askarel-filled small
power transformers. We feel the technology
is sound and are in fact in a. program to
retrofill all of the askarel transformers
in all of our plants worldwide. Written
materials exist supporting our arguments
regarding the efficacy of this application.
Summary: Retrofilling
"change outs" from oil to askarel and
from askarel to oil using well known
methods has been used in the transformer
maintenance industry for many years.
Askarel-to-silicone retrofilling was first
used as a silicone transformer liquid develop-
ment tool in 1972 and since that time has
grown to be readily available commercial
service. This process offers many advan-
tages to man and his environment. We
request you strongly consider the effect
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245
the rules you promulgate will have on +•***•
retrofilling as it exists today and the
effects they will have on the ultimate
technique development of the future.
Now, that is the end
of my comments. I do have a slide series
on retrofill if you are interested in seeing
specifics or if you prefer to go to questions
that is fine.
HEARING OFFICER WIRTH : Panel, do you
want to see the slides?
MR. BILES: Can we get copies of
the slides?
HEARING OFFICER WIRTH; How many
slides do you have?
MR. PAGE: I don't know, it would
probably take seven to ten minutes to go
through.
HEARING OFFICER WIRTH: They are
basically explaining ~- showing the retro-
fill operation itself?
MR. PAGE: Just the mechanics of it.
HEARING OFFICER WIRTH: If we can have
copies of that I'd appreciate that.
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246
MR. PAGE: I will have to take
those and make them, I cannot give them
to you today.
HEARING OFFICER WIRTH: Okay.
Questions? Mr. Pearson,
Mr. Pratt, Mr. Principe?
MR. PRINCIPEs The silicone fluid
that is in the transformer once it has been
retrofilled contains say two to three
percent of PCBs. How can you dispose of
that liquid, can it be incinerated?
MR. PAGE: The silicone liquid in
our own plant we have occasion to dispose
of some silicone material. And the in-
silicone material we use incineration --
commercial incinerators in the area and
they have no trouble burning silicone,
it is a matter of burning a small amount
with other materials just to lower the
flash and fire point of the silicone
where it burns readily.
And in talking with
our waste disposal people they fill
the silicone trim retrofill that would
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247
have PCS in it that could very readily be
burned in a PCB burning facility, in other
words one with proper temperature and so on.
MR. BILES: Maybe it is in your slides
so maybe you can tell us then.
You identified cost
of being $22 to $33 a gallon. You indicate
that may eliminate some of the transformer
from application.
MR. PAGE: Yes.
MR. BILES: That strikes ine that that
may eliminate not some but most?
MR. PAGE: It eliminates a fair
number but transformers used to -- you take
a 15 or 20-year old transformer and it
used to have oh, half to seven-tenths of a
gallon per KVA, a number of them have been
coming out lately with anywhere from .12 to .15
gallons KVA. If you figure that out on
that basis it does come to the fact that
with some newer ones it is an economic
reality.
MR. BILES: I am sure you have cost
analysis of comparing this to other alterna-
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248
tives such as getting rid of transformers
or, you know --
MR. PAGE: I think I just did by
comparison with purchasing a new one.
MR. BILES: Where does retrofilling
take place, would it take place in GM's
operation or would they have to ship the
transformer?
MR. PAGE: There are two types of
retrofill. If you look at the table that
I have given you there you can see the
specifics, one is called a field job,
this is where you would move in on a trans-
former in a field. And the other is
called a shop job. And usually in a shop
job the core and coil are pulled out
because some other service is done on the
unit. In that situation you do end up
with lower PCB levels.
MR. BILES: Would you anticipate
that this would lead to simplifying the
retrofill operation or would it be more
field operations like for GM's needs?
MR. PAGE: I don't know.
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249
MR. BILES: If it's something that
industry itself could perform or some-
thing again to be specialized like a couple
of the other gentlemen representing that
they themselves are local transformer
repair operations. Do you see GM being
able to take this over — I am not trying
to pick out GM.
Do you see American
industry itself being able to do this
or is it something that will become localized
with a few operations?
MR. PAGE: Okay.
I have been involved
in a fair number of retrofills and they
have been done two ways, one by transformer
service companies and the other is I have
been involved in some private companies
doing it in their own repair shops.
And there are some companies that are
quite sophisticated and capable of doing
this, but I don't think it is something
that most companies who own a transformer
would want to do though, most of them would
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250
contract it out.
MR. BILES: And then the solvent
silicone liquid I would assume those would
be disposed of?
MR. PAGE: Yes.
MR. BILES: Can the solvent — is
there any way solvent can be reused?
MR. PAGE: Yes. We have in fact --
usually we will use like three flushings
on a transformer and you can take the last
flush from one unit and use it as the first
flush on the next unit.
This was very definitely
maintained in the fact that that liquid
was good, has no particle test or dielectric
properties and so on.
The other thing we
have looked into, the PCB and trichloroben-
zene have a very different vapor pressures
and it would be simple distillation, but
this has not been done by anyone yet.
And actually in the long range retrofill
could be used as a PCB-making procedure
-- not a PCB, as a trichlorobenzene-making
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251
procedure by simple distillation of the
askarels that come out, and at that
economically would cut the cost of the
solvent that is flushing and count the
amount of material that would need to be
burned also.
MR. BILES: Is there anybody else
in addition to your company who is in the
business and is advocating this kind of
a program?
MR. PAGE: Okay.
The one thing I can say
that is aware of that has been published
is that -- is that Union Carbide -- Union
Carbide, a man by the name of Bill Martin
recently wrote a paper -- a technical paper,
I can't even give you the reference on it,
but in it it did describe doing some
retrofilling in their own plant. And,
he didn't call it retrofilling, but it
was draining the askarel from the unit
and putting silicone in, and he measured
some of the performance values of the unit.
MR. BILES: But, you are the ones
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that have the silicone product?
MR. PAGE: Yes.
MR. BILKS: As far as you know,
are you the only ones right now who are
marketing that in this country?
MR. PAGE: There are four silicone
suppliers in the U.S. and -- or four major
ones/ and of the four I would say we are
most actively promoting, but two of the
other three would be glad to sell to a
retrofiller if he wanted to purchase from
them.
MR. BILES: I am not sure I understand
the intention of your request.
MR. PAGE: I can't say exactly what
I'd like, but if a person does a retrofill
he is doing the five things that I pointed
out. And you have certain restrictions,
you are considering a .05 percent PCB
material as a -- what was it a PCS --
MR. BILES: A PCB mixture.
MR. PAGE: A PCB mixture.
Mo, I don't feel I can
define it. I am just saying enough of a
change in the regulation to where there would
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253
be some incentive to do a retrofill.
If a person does a
retrofill now I feel you gain the five
things I listed but that person really
gains nothing if he still is above the
500 part per million. The only thing he
would gain would be the ease of waste
disposal.
MR. BILES: Okay.
And you would want us
to raise that 500 part per million number
up to the two percent number, is that
what I am to understand?
MR. PAGE: Not that -- can you
elaborate on that, Thor?
MR. ORBECK: Basically the practicality
of the whole method is dependent on the
£PA's regulations.
Basically what we are
saying is that you can over a period of
time potentially reduce the amount of
the PCB in the transformer by regular
maintenance procedures.
I elaborated on this in
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2 U
my last statement in previous hearings
and the point is that we are basically
saying that allowing this to take place
over a natural process in certain
select areas where people have exposed
units you have to put some exemptions
on the retrofill unit; you have to
classify it differently than you classify
a mixture or classify a PCB material.
MR. BILES: That is for disposal
purposes?
MR. ORBECK: Simply for the purpose
of giving that extension in accordance
with what for example Michigan Rule
dumber 66 I believe it is, Public Act 60
has made an exemption so you can apply
for an exemption for that particular
retrofill unit.
1 think that is the
only thing we are asking.
MR. BILES: The exemption would be
what you would do with the unit.
MR. ORBECK: No, that would --
no, that would be the way you classify it,
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the certain systems -- you have PCB
mixtures or PCB materials.
MR. BILL'S: It is conceivable that
we could authorize use and maintenance
of transformers and that is sort of one
alternative to that, you are saying that
in fact in exception there is going to
be soiae traces of PCBs. We can authorize
that anyway.
MR. ORBECK: You can authorize that,
the problem is that you would gradually
accomplish this reduction of PCBs by
regular maintenance, and that means that
you would at different time periods in
the time of that transformer you would have
different levels of PCBs in it. So,
that the classification of that system
would change.
For that, I simply
suggest that you classify the retrofill
transformer as a specific classification/-
do you see what —
MR. BILES: I aw not sure I under-
stand a need for that if we're authorizing
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256
the continued use of the transformers
anyway, that is what I an saying.
And the reason we won't
need to keep the number at 500 parts per
million is to cover the disposal of the
transformer. I don't think even at this
point that we have taken the point that
you shouldn't be allowed to use the trans-
former with 100 percent PCB during its
useful life. It is what you do with the
liquid in the transformer once you're done
with it.
All I can say is if
you raise the number then you are going to
let some of the liquid be exempt, from the
disposal requirement.
MR. ORBECK: I think it is just a
matter of definition. What you are saying
basically is that within the system you
are allowed to operate the unit whether
it is retrofilled or not retrofilled.
What we are saying
is basically to provide the incentive to
the industries that have the unit of a
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large number and some of them on a small
basis, that we would like to have the
possibility of classifying that unit
somewhat differently if it is retrofilled
or not retrofilled because it allows
in that what we call method as recommended
by our department a way to gradually
reduce that PCS level to the level that
would be less than 500 parts per million
or possibly five percent/ that is what
we are trying to do.
HEARING OFFICER VJIRTH : If I understand
what you are saying that is — correct me
if I am wrong, the labeling disposal
regulation and transformer that contains
PCBs is drained and goes to a chemical
waste facility?
MR. ORBSCK: Transformer?
HEARING OFFICER WIRTH: Wow, you are
saying if an individual drains his trans-
former, PCB or askarel-filled transformer
he must incinerate that, if he retrofilled
with silicone and it ends up with two percent
PCBs in it after its useful life you muat
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258
also incinerate the silicone with two percent
PCBa in it after its useful life; are you
suggesting that there should be some
relief provided for him on that second
two percent PCB-contained silicone so that
h« essentially doesn't end up with two
volumes of transformer fluid and incinerate
over its lifetime?
MR. ORBECK: Basically I am saying
that when you do retrofill you have in fact
reduced from 90 percent PCB to 60 percent
PCB, that Mr. Page had mentioned but,
you are stuck with two percent, that by
your definition is what they call a PCB
mixture.
HEARING OFFICER WIRTH: That is correct.
MR. ORBECK: Okay.
So, this material now
in effect has to be treated by the utility
coiupany or by the private Industry in
the same manner as the unit was filled
with PCB, that means there is very little
incentive whatsoever or any reason to do
the retrofilling.
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259
p50 However, we have
already established a condition where
we now over a six-month period leave a
PCS leach a PCB out of the — a substantial
amount of PCb out of the -- before
winding into the silicone and establishing
equal limit at a point where you dispose
of the thing you would get substantially
less than the two percent that you established
retrofilling for what you call landfill,
that is one point.
The second point we
are making is that our experience has
shown that if you use activated charcoal
at one point of the procedure and at that
later point/ six months after/ you may
be able to reduce that PCB contact at least
permanently to less than 500 parts per
million which would qualify the unit to
be less than that level that you set
for 500 parts par million.
Because we have not
proved this we have not got enough time:
before you rule-setting is set so that
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260
we don't even have an opportunity to continue
that work because of the lack of economic
incentive in the system, then, this will
never take place. So, I am saying that
no rule or regulation will all determine
the go and no-go to the retrofill to those
specific units. And the other alternative
is to be faced with in disposed areas and
to replace those units because the liability
associated in having those units in those
exposed places are too high. That means
the economic impact is they have to go
buy a new unit if they can.
That is why we don't
support a massive retrofilling, we are
trying to help some specific customers
that have asked for them in this particular
area.
MR. BILES: So, you do not advocate
that we should require retrofilling?
MR. ORBECK: All we want is an
exemption that on those few units that
need to be taken care of and for that
reason we want this to be under those type
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261
of circumstances.
HEARING OFFICER WIRTU: Any more
questions?
MR. SNYDER: Do I understand you
correctly you indicate that silicone filled
can be used to top off existing PCB trans-
formers?
MR. PAGE: I did not say that.
MR. SWYDER: Good.
What is the effect
when you -- the effect on a trans former
when you retrofill with silicone in
terms of the electrical capacity of the
transformer, is it reduced in any way?
MR. PAGE: Okay.
Electrical capacity
-- silicone -- if you take a liquid in
a transformer there are two factors to
determine how well that liquid cools
that unit and one is the viscosity of the
fluid, that gives you an idea of how fast
the fluid flows through the orifice and
so on; the other one is a coefficient of
expansion of the liquid.
Why fluid flows in a
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262
device like this is the difference in
density between hot and cold, it is
called thermofusion,it heats up and gets
wider and bigger and so it flows, it is
a difference.
Well, silicone is a
considerably more viscous than askarel
and as such this would be a negative,
in other words this would cause it to flow
slower through the openings. But, on the
other hand silicone has a greater coefficient
of expansion, it expands more when it's
heated and so this is a plus; you have
more push — pushing the material through
and when you balance these out if you
throw it into a computer program it will
come out saying that you can overheat
your transformer tremendously -•- and if
you actually put it in a transformer and
measure the values that you get, particularly
instrument the transformer you will
actually find some spots in the inside of a
silicone unit that are cooler than an
askarel unit and some spots vice versa.
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263
54 Overall the average
temperature will be slightly higher
with the silicone unit.
We have heard manu-
facturers make the claim --- in fact we
have actually seen data where they have
gone anywhere from no percent D rating
to 10 percent O rating on the unit.
MR. SriYDER: Do silicone fluids have
a lower prime point than PCBs?
MR. PAGii: Not much higher than askareis.
MR. SNIDER: So, what problems are
you alluding to when you dispose of PCBs
with -- or silicone contaminants?
MR. PAGE: Silicone has a high fire
point. A fire point is a temperature
that you heat a liquid to it, put a
flame to it, take that flame off the
liquid the liquid will continue to burn.
With silicone it is 600 degrees Fahrenheit.
And if you take silicone and throw it into
an incinerator, straight silicone-type
material sometimes you don't get good
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2S4
ignition on the silicone material.
What waste disposal
people that burn liquids will do is
take the silicone and other materials
that they're getting in from other
companies and mix it until it has a
particular BTU per pound ratio and they
will mix it so that there is a percent of
silicone with other material so that
the total mixture has the lower flash
and fire point so it will ignite more
easily.
MR. BURIN: I'd like to direct ray
question both to Mr. Page and to Mr. Orbeck.
Does Dow Corning to
your knowledge have any information con-
cerning the toxicity or environmental
persistence dimethylsilicone?
MR. PAGE; Thor -- wo are going to
pass the buck, neither of us want it.
Tremendous amounts of
data and I guess rather than comment on it
we would like to make a submission to you.
MR. ORBECK: May I make one comment.
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265
We have made a
submission to EPA of ali the data that
we have and what we do know about in
the technical work and that has been
submitted to EPA. That statement was
provided by Mr. Swaurter (phonetic) and
his viewpoint.
And there was some
question with regard to the effect of
silicone that has and these are in the
investigation and interfaced in the
silicone industry and have taken place
and some of this has been resolved.
Some of it has been resolved by an
investigation. Basically we have tried to
provide information that EPA has required
and that should be available to you.
MR. BURIN: Okay, thank you.
MR. PAGE: Do you want us to make a
submission to you?
MR. miRZU: Well, if you already
made a submission -- okay.
MR. ORBECK: May I make one very short
statement?
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266
Dow Corning is not
really commercially so interested right
now. We are a main supplier of silicone
to the manufacturers.
It has been at this
point where we ship silicone liquid trans-
formers in tankcars to the manufacturers
using it in the transformers, to us it
doesn't mean that tremendous in terms of
from shift to electrofilled to setting
new units.
But, basically we
started this type of thing to gain experience
in units because we were trying to learn
how silicone was in transformers, to
develop this technology to start our own
life-testing in transformers.
Now, we have, I think
Bill can verify, we have got 10 to 20
requests of this retrofill thing because of
people that are in special places. What
we are trying to do is find a way to
communicate with you so that for these
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267
particular people there is a way that they
can go as an alternative to buying a unit,
that's economics.
The only thing that
I can say -- the only thing that I can
see one way to go is to make some kind
of exemption on these retrofill units for
these particular cases that really check
in accordance with regulations that
there will be.
And there should be
an additional clause, that is all I am
going to ask for, to make it possible
for these and not to make what you call
regulations that require the retrofill.
1 think that is wrong. I think that
this is too much of an economical impact
but this had to be done because of --
to take care of it.
HEARING OFFICER WIRTH: Okay.
Are there any questions
from the floor?
MR. AGIN: My name is Jim Agin. I
just have one question perhaps for the
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2 6 8
people from Dow Corning.
It is my understanding,
this might be a simplistic understanding,
that there are some transformers that cannot
be filled with material other than askarel
because -- or unless that material were
as fire-resistant as askarel. In other
words, it wouldn't mean some National
Electrical Safety Code or something like
this .
Now, you mentioned
that Dow Corning was going to replace,
I think you said all -- retrofi.ll all of
its transformers. Do you have instances
like this where — or maybe you don't,
where there is a Code — there is a Code
problem or an insurance problem or some-
thing like this?
MR. PAGE: No.
MR. GRBECK: You will have to explain
the Code change.
MR. AGIN: I mentioned the National
Electric Safety Code. I am not familiar
with the details of it or with whatever
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269
other State Regulations there may be
or whatever. But, it is just my basic
understanding that there might be some
instances, in fact the company I work for,
United Power Associates has some transformers
within a power plant, in the basement of
a power plant that I understand couldn't
be readily retrofitted with another liquid
unless that liquid substantially met the
same specifications of the askarel.
HEARING OFFICER WIRTH: I personally
have that same understanding or came to
acquire it somewhere along the way that
the Electrical Code specifies askarel.
MR. PAGE: The NEC, National Electrical
Code is written by the National Fire
Protection Association every three years
and in 1978 will be the next revision,
the old one is the 1975 one. The HEC is
a list of provisions which should give
adequate safety to an electrical installa-
tion if it is followed.
And the NEC in May
of this year in their National Convention
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270
in Washington, D.C., approved -~ voted on
and approved a revision, I believe that
was May I am,not certain on that,
rewriting a provision — I think that
is Article 450/23 and silicone will meet
the new provision as defined in the
National Electrical Code.
Now, what remains to be
done is that in September of this year,
the 1978 National Electric Code book
will be printed.
Now, the Code itself
is not law, but the federal government,
OSHA namely adopted the Code as a concensus
standard, meaning that the National
Electric Code was federal law and such to
put silicone in installation, because the
old Code said you would have to use
askarel inside of a building which would
have then been against the federal law,
but OSHA, the Department of Labor came
out with a program directive allowing
the use of silicone as a replacement for
askarel on a one-for-one basis and that
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271
some time ago.
Perhaps in the briefcase
Thor can give us a reference on that.
We can send that to
you later.
But, we have no trouble
with insurance or Codes.
HEARING OFFICER WIRTH: This is in
fact fait accompli other than to have it
printed, is that correct?
MR. PAGE: Right.
HEARING OFFICER WIRTH: And it allows
one-to-one replacement with no additional
fire prevention?
MR. PAGE: It does not list the word
silicone. The old Code listed askarel
which was kind of statutorily illegal
because it established a monopoly as such.
The* new Code does list
a list of provisions and silicone does
in-set those provisions. That are listed.
It doesn't eliminate other liquids;
it leaves it open to competition.
HEARING OFFICER WIRTH: So it does
-------
list provisions? 272
MR. PAGE: Yes.
HEARING OFFICER WIRTH: What type,
how are those provisions stated?
MR. PAGE: It lists a fire point,
a propagation test and what is the third?
MR. ORBECK: The third test is signed
by the fact of mutual insurance to try
to verify the different aspects of high
fire point/ fire propagation, fire spread,
but there is a difference ~- these are
words in the National Electric Code --
they are not authorized to be -- not authorized
to be investigative tests, they are used
temporarily unless such a classification
system is established.
These three tests
function in the way to make sure that these
properties are not written into the Code
as a temporary situation until they get
it all.
HEARING OFFICER WIRTii : You Say this
is fire point, fire propagation, fire
spread?
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273
MR. PAGE: We can submit a copy
of that text.
HEARING OFFICER WIRTH: Any other
questions? Okay. Thank you very much.
That concludes the
previously registered witnesses which
brings us to the point to open the meeting
for any questions, statement or anyone
wishing to make any comment.
I would like to ask
if there is anybody in the room that
represents an environmental concern,
organization or group. We have not heard
from any such group today. Do they care
to make a comment on the things they
heard today or this proposed regulation?
If not the floor is
open for anyone who wishes to make any
sort of a statement.
Everybody is tired.
Okay, if there is nothing,
no further statements then this meeting is
adjourned. Thank you very much.
(WHICH WERE ALL THE PROCEEDINGS HAD.)
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274-
STATE OP ILLINOIS )
) SS
COUNTY OF C O O K )
SUSAN A. DIML, being first duly sworn,
says that she is a court reporter doing
business in the City of Chicago, and that
she reported in shorthand the proceedings
had at the hearing of said cause, and the
foregoing is a true and correct transcript
of her shorthand notes, so taken as afore-
said, and contains all the proceedings of
said hearing.
x.
SUBSCRIBED AND SWORN TO
before rae this _%7_-
of Oc*c&/... , A.D., 1977
-"?
'
.
Notary Public
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