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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                                         -2-
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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                                         -2-A-
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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                                          -2-B-
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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                                           -3-
     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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                                           .-7-
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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                                           -10-
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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                                           •11-
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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                                           -12-
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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                                           -13-
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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                                           -14-
          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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                                           -15-
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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                                           -16-
•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
 - i

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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                                           -18-
          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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                                           -19-
          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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                                           -20-
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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                                           -21-
•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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                                           -22-
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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                                           -23-
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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                                           -24-
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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                                           -25-
     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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                                           -26-
          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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                                         -27
          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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                                         -28-








          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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                                         -29-








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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                                         -30-
          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

-------
                                         -31-








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

-------
                                         -32-








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

-------
                                         -33
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

-------
                                          -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

-------
                                          -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

-------
                                         -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.

-------
                                         -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

-------
                                         -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

-------
                                         -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?

-------
                                         -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

-------
                                         -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

-------
                                          -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.

-------
                                          -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

-------
                                         -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

-------
                                         -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

-------
                                         -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

-------
                                          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?

-------
                                         -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.

-------
                                         -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.

-------
                                         -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.

-------
                                         -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

-------
                                      -67-








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

-------
                                      -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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                                      _ f. Q „
                                       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.

-------
                                      •70-
     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

-------
                                      -71-








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

-------
                                      ~ 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.

-------
                                      -73-








          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.

-------
                                       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

-------
                                      -75-
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.

-------
                                      -76-








          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

-------
                                      — 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

-------
                                      -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

-------
                                      -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

-------
                                      -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

-------
                                      _ 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

-------
                                      -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

-------
                                      -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

-------
                                      -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

-------
                                      -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-

-------
                                      -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?

-------
                                      -87-
          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

-------
                                      -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

-------
                                      -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.

-------
                                      -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.

-------
                                      -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-

-------
                                      -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

-------
                                      -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

-------
                                      -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

-------
                                      -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

-------
                                      _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.

-------
                                      -98-
     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.

-------
                                      -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

-------
                                      -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

-------
                                      -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

-------
                                      -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.

-------
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.

-------
  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).

-------
 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.

-------
  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

-------
 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

-------
                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

-------
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

-------
                                           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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                                          -5-
     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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                                          -6-
                                         •    127




                    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

-------
                                           • 7 -
                                          4    128
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

-------
                                          -8-
                                         ~ •   129




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

-------
                                           •9-
                                            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

-------
                                          -10-
                                          -    131




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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                                          -11-
                                               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

-------
                                             -    13-1
— 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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                                             .13o





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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                                              I Q ?
                                              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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                                             14 0





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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                                              14?
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

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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

-------
                                           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.

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     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 
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     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
-------
                                       *   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

-------
                                        * -  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

-------
                                       -    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

-------
                                             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.

-------
                                           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

-------
                                             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
-------
                                         *    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.

-------
                                              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

-------
                                              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

-------
                                               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
-------
                                              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

-------
                                          *    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

-------
                                             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::*,

-------
                                            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;  ,.
-------
                                              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?

-------
                                               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,

-------
                                             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..

-------
                                           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.

-------
                                           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

-------
                                          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.

-------
                                           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.

-------
                                         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.

-------
                                             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,

-------
                                             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

-------
                                                     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

-------
                                          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

-------
                                       *   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.

-------
                                           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

-------
                                                        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

-------
                                          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
-------
                                          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

-------
                                            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

-------
                                       •    .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.

-------
     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

-------
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

-------
                                          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

-------
                                            ••244
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

-------
                                              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.

-------
                                            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

-------
                                            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-

-------
                                           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.

-------
                                           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

-------
                                           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

-------
                                          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

-------
                                             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.

-------
                                             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?

-------
                                              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

-------
                                              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

-------
                                          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

-------
                                             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

-------
                                             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

-------
                                           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?

-------
                                             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

-------