905R77012
             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

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             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
                    Diane HrofflSfc --
                    Court Reporter

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                                         -2-
PANEL MEMBERS:
GEORGE WIRTH, CHIEF, HEARING OFFICER
Regulations Development
Office of Toxio 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.



I 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 PCS problems as well aa 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 thi* 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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                                            • 4-
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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                                           — 5*"
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 aro
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 additives,.
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.
          Hater 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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                                           -6-
          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 am positive that your contribution



will be of great significance*



          At this time 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



starting 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 havo



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 representa-

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                                           -8-
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 chloroflourocarbona, 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 be



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 witness.



          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 may 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



X 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, X 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 thair 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-
          This testimony pertains to informa-



tion regarding PCBs printed in the Federal



Register Volume 42, Number 123, dated Monday,



June 27th, 1977 — Page 32555.



          This document indicates that Section 6(e)



of the Toxic Substances Control Act provides



that after January 1, 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



PCBs 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 fixture*



works 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 sells



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
electrical contractors who subsequently install
the lighting system for the user.

          There are, then, in this manufacturing

and distribution chain, no less 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 PCB 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
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.

          I would hope that the Agency would
agree that the important ban involved here is

the one affecting future production processing

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                                           -17
and distribution of the PCB fluid and PCD



capacitors.



          Ballasts intended for lighting fixture



applications, which have already been produced,



or will be produced in the process of using up



capacitor inventories must not be subject to



further restrictions on their distribution and



use.



          These are small capacitors containing



less than one pound of PCB fluid in sealed



containers.



          Any exposure to human beings or the



environment to PCBs from these capacitors must



certainly be deemed insignificant.



          Once these capacitors are produced,



legally, in conformance to whatever rules are



promulgated by the Agency, it makes no sense



to say that they cannot be used.



          The lighting industry is a large one,



consuming 20 percent of our total electrical



energy.



          It should not be surprising that it



has tremendous inertia.

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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 I thank you for the opportunity to present



than today.



     HEARING OFFICER WIRTH:  Thank you.



          Thank you, Mr. Freegard.



          Okay/ let1* 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 PCB 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 is scrapped we don't



get away from the disposal problem of the PCB



article which is inside.



          I have -- Z 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:  Mo, we do not.



     MR. PRINCIPE:  You buy capacitors?



     MR. FREBGARD:  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 basin



of having to label them.



          I reckoned the cost to my company of

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                                           -22-
something 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. FREEGARD:  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. FREEGARD:  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. FREEGARDs  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. FREEGARD:  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 worda,  they are in short supply.



          They also cost more.



     MR. PRINCIPE:  Okay.



     HEARING 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. FREEGARDt  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. SHYKINDi  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. FREEGARDi  No.



     MR. BILES:  Do you have any economic use



for those that are leaking other than —



other than disposing of them?



     HR. PREEGARD:  No.



     MR. BILES:  Is there anything you — in which



you can do in which there is liquid PCB coming out



of it?



     MR. FREEGARD:  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. FREEGARD:  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. FREEGARD:  I really —



     MR. BILES:  Or would that be possible to



come up with some information?

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                                           -25-
     HR. FREBGARD:  It would be — it would be



— any answer I would give you would be rather



speculative.



          X 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 night happen in the future, I don't know,



That is about as good as I could do.



     MR. BILESi  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. PREEGARD:  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.

-------
                                         -30-
          The first application was on a



continuous mining machine known as a CU-4.1.



          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 — 1965.



          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 83 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-fillecI



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 ir-, 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 PCB 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 is 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.




          PCS 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 conslderatior.,  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 ton

-------
                                         -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 reed



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 PCB 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 -- these 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. BURIN:  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 possible



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. STURINO:  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 ^hat 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 PCS 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

-------
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-^3.



     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

-------
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.

-------
                                          -US-








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 my thought is what — what kind of a

-------
                                         -47-
prograra 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. WARMER:  Yes, Mr. !3ayder, 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 mine 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

-------
                                          -49-
chemically for Aroclor 1242.




          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 12*12.




     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 required 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?

-------
                                         -32-
     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 my 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 — I



recognize you said there were ? or 3 means 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 WP 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 PCS.




          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.

-------
                                         -57-
          Something about expressing concern?



     MR. BILES:   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.



          From 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 electrical!




fails.




          It was  going 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. BILESs  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-
     HR. 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. WARMER:   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. WARMER:  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 back 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. 3ILES:  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 PCE 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 PCB




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 me, rebuild.




          We rebuild all of the various




motors on Joy mining equipment  so the PCB

-------
                                      -6ft
motors only represent a small part of what




is done.



          Your question is could we clo




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 tell




you the answer to that.




          When machines are taken out of




operation, they are very often brought




outside the mine.

-------
                                      -69-








          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-








motors, 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

-------
                                      -72-
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 comments




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 PCS 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 EPA 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 PCS fluids for




servicing of transformers to use these




fluids following the July 1979 deadline




on distribution.




          Strict control over the storage

-------
                                      -77-








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

-------
                                      -7R-








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 availablef 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 WIRTH:  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

-------
                                      -81-
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 PCS 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-

-------
                                      — Q £ ~
                                       O D
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 it, 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 PCS?




     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

-------
                                      _„ ft o _
                                       o O
until just recently.  And I think I did read



somewhere, but I have no personal knowledge



of it.



     HEARING OFFICER WJRTH:  And you say



moat 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 problera -- 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 arc -- 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 terns 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 PCS 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 seen 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

-------
                                      -96-








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 I960'




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




PCS 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 lii'espan, 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.




          He v/ill 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. ROLLIMS:  No, Mr. Tylenos (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 PC8, 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.




".All PCBs 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 PCB 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 PCB 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 Goods'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 must 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
committed 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 was 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 utock 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. BILESs  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 components



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 terms of




electrical capacity, safety, exact replace-

-------
                                      -111-








ments for January inspection, multi-inspection,



capacitors that will fill the replacement



of secondary --



     MR. ROtLItfS:  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



raultimillion 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, porhaps 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-








exposvtre 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




toxicologist, 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 ?CBs?



          My question is that should we follow

-------
                                      -116--








your argument that manufacture or proces3ing




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



you nuide 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?



     AR. ROLLINS:  OSHA, in its Act, has



put i.o 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

-------
                                      -lie-








familiar with on this particular point.




          The effluent guidelines, both




capacitor companies and tha EPA are very




familiar with what is being done there.




     HEARING OFFICER WIRTH:  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-








levela 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«a United States would be out of the



use of PCBs.



     MR. BILES:  Okay, fine, thank you.

-------
                                      -120-








     HEARING OFFICER WIRTHs   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 tha

-------
                                      -121-








final 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, 1 perhaps I shouldn't,



that your industry will be able to do that



at least physically from an engineering point



of view, 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 AGENCY




         	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 PCB  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 could




 occur,  if a  total ban  were to be placed on  PCB's beginning  in  1978.




 As long  ago  as March,  1972,  our company advised  our customers  of  th




 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



explosion 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 we;




 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.   Prom 1967 until  1970,  sixty-four




 of  these miners  were constructed,   it is estimated that  30 of thes




 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 Aroclt




 1242  (PCB).  Nineteen different chemical companies  were contacted am




 twenty-one fluids were evaluated in the  search for  a replacement,  fl




 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




nine motors constitutes a minimal risk to the environment.  Although




 PCB filled mine motors cannot be classed as totally enclosed,  groat




 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-

-------
                                                               5.


 tions,  such as a motor winding failure,  PCB vapor may be emitted


 from a  pressure relief valve.   The only  6ther possible leakage poir


 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 suggestioi


 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




 single 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




   of 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 tp

   $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
Offico of Toxic Substances      -2-              July 1 H. I «>77
     We presume that any discussion 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 "insignificant1
     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 "use"  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
     arc 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 ! S,  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 dies el-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.
*
 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 1 8, 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 alloxving  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-contaminated
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  bo 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 ppm
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  •?

                                 W. R. Jolinson, Director
                                 Plant Environment

pm

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                PCB HEARING




             SPECIAL MEETING OP

U.S. ENVIRONMENTAL PROTECTION AGENCY

          REGION V - CHICAGO, ILLINOIS
              July 19, 197''

                1:30 p, EI .
        Pick Congress Hotel
           Chicago, Illinois
                      Susan A, Dime
                      Court Reporter

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PANEL MEMBERS
GEORGE WIRTH, CHIEF, HEARING OFFICER
Regulations Development
Office of Toxic Substances
U.S. Environmental Protection Agency
Washington, O.C.

GARY J. BURIN, CHEMIST
U.S. Environmental Protection Agency
Washington, D.C.

DR. EMILIO STORING, 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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                                           12:1
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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     MR.  MIRTH:  Let's get started, gentlemen.
                     Good afternoon,, ladies
and gentlemen* we wll reconvene this session
on the polychlorinated 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 is
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.  STEINBURG:  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-
     7
                                         •    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. Breraor



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 -
                                              128
were prepared by Reliance Electric Company

which essentially reflect that work.  And I

would be happy to share it with anybody at ths

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 rather

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

-------
                                        - -   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 the 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 ^?



tho deadlines contained in the act, but direct




pales if concluded before the statutoru deadlines

-------
                                          -9-
                                            13H
may simplify transportation of the fluids

which presumably will also be in areas regulated

                    In talking 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 are any.

     MR. WIRTHI  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-
                    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 PCBs.
                    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. WIRTHt  DO we know where the other

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                                                 13.1
-- where all three facilities are?  One is
Bluefield —
     MR.  STEINBURG:  One is Bluefield, West
Virginia, the second is the Meadowlanes facility,
I believe, in Cannonsburg, Pennaylvannia, and
the third is the Mount Vernon facility which
ia here in Illinois.
     MR.  WlRTHt  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.  ONISHIt  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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                                         -  •  13-




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:  nuraber




one war, that existing "closed system*' usas




such as transformers and power capacitors




reraain in service for the remainder of their




usaful life and that the PCB 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.  Ami




accordingly wa 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 arn additional requirements associated



with the promulgation of reqv.lations concerning



the manufacture, processing and distribution

-------
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 is 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 inadvertant 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 in 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 will not supply PCB-filled




capacitors.  So, we are purchasing non-PCB

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                                                o
power capacitors and transformers.  I think




there may be one or two suppliers that will




still supply an askarel-filled transformer,




bat most companies are changing.  And I would




think the ordering of new askarel-filled




transformers is very rare.




                    The unavailability of




PCB 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 PCB




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 PCB-filled transformers,



however, there ar^ nominal nake-up fluid




requirements.  I think the industry intends




to provide these make-up requirements by




using in-stock PCBs initially and ultimately




as we go look down the roacl, we figure it will




have  to be done by reclaiming PCBs from




existing transformers that are ronoved fron

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                                              I 3 •
                                              J. O »
7
service.




                    Co, with this in mind




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.  V7IRTK:  Thank you very much.




                    fary, 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.  ONZSHI:  Well, for disposal I think




most companies are sending them to a suitable




disposal facility, whether it be Rollins or

-------
                                             136




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. STURIHO:  Is anybody doing it at




this time?




     MR. 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. ONISHI:  Well, many utilities




will santplo periodically the Dielectric




fluid to make sure it is maintaining its




properties.  r?his would be a small quantity

-------
                                               133
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 PCBs




to undertake such a change versus future



situation where supplies would be limited for



all reasons that we have discussed here today,




and by virtue of this limitation that one




might find that they don't have to undergo




the change of Dielectric flxiids that they




rri=iy have undergone before; meaning that you




sort of decide maybe life is getting a little



tougher, raaybo w«a don't, have to fiddle around

-------
                                            14 0






BO much with these fluids.




                    Is there any basis for




that kind of a thought?




     MR. ONISHI:  I den'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 contaminents in this sort thing,




because it is far more economical in nost



oases to keep a transformer serviced that it




is to replace it.




     MR. SttYDER:  What are some of the



consequences of PCBs becoming contaminated,




•whether it is raoistare -- or perhaps -- you




have mentioned moisture as a contaminantr




what other kinds o" contaminants would you




describe and for those contaminants what




kind of ill effects would oc^ur 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 be ralated to the level of contaminants




and location of those contaminants, 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. ONISHI:  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 f:o an environmental




release and also a lowering of the level whicn




may require nake-up, that there is an off




aspect of the transformer, it becomes overheated,




for whatever reason —




     MR. ONISHI:  You mean to an operation of




a pressure ralief device or something of this

-------
                                              14;'
sort.
                    Normally, I should say
on most transformers from the distribution
level  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 dees
not release unless you have -- generally it
is a failure that will crack or rupture that
device, it is not a breathing device.
     MTl. SNYOER:  If in the course of
developing these ban regulations we wero to
Jevelo£j essentially spill-protection regulations
which might involve things !?uoh a.s secondary
containment 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 rel.Vced way, what some of
the cost impact vru\y  ;>e?
     MR. OSISHI:  '-Tali, I tl.ink -.he usefulness
of some sort o*~ spill prevention — nost
utilities I think -re very actively looking

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                                           143
in that area.
                    We clo 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.
                    I 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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                                        •  -  14





     MR. SNYDKR:  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. OiJISHI:  Well, let me say first




tae tyt*3 of occurrance or failure where you



would have a tank raptare or something is '




extremel; rare.




                    The way of improving




that, of course, is if you do have a failure




to have your protective equipment, remove that




equipment from aarvice rapidly.




                    I think most utilities




do have equipment that operates in a matter

-------
of secondc.  And that does not preclude the



possibility of having a catastrophic rupture




under certain conditions.  7Vnd in most cases




I think you have to rely on the secondary




containment.




     MR. SNYDER:  Are you aware of any




cases whore 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 service,




in examining the cost of disposal or in-




convenience or whatever, elect really to




bypass that unit, tako it out of services




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. ONICHI:  *Io, I am not aware of it.




Personally I could force the situations under




which that might occur.




     MR. SNYDER:  Would you consider it




unreasonable if wa had requirements tha': would




preclude that  sort  of  practice>  in  othier  wordg

-------
                                           143
truly define the useful life of the transformer




as one that somehow relates to its useful lif.3



in its electrical system or as time passes




properly removing the item 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 leak?




     MR. CNXSHI:  Well, I would think — I



would thir.k it would probably be -- we would




think it would be unreasonable to take that oat




                    I think if you have that



equipment on a standby basis, standing there




idle, we would tMr-!c that it would be perfectly




secure as far as environmental releases to the




environment.  And I don't thin?< it would bo




nocessary to pull that out. and dispose of it.




     !-'?.. S'lVDE^r  ..y "standby" are you su




that it could be back into service until such




tine as it has no further useful service 3ife




     MH. OMISHT:  Well, if it has no further




aseful  Iif3 I thin'--, it should ba disposed of.




     M3. 3HBMER:  Mr. Onishi., you indicated




that a  good majority of comparie- are not

-------
                                           147





ordering PCBs or askarcl-filled transformers




and capacitors at this time?




     MR. OUXSHI:  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




Electric Institute recommending at this tine




fox both transforraers and capacitors?



     MR. ONISHI:  For capacitors Edison




Electric Institute is not recommending any-



thing.  They are relying on the manufacturers




of power capacitors and many of the manufacturers



have come out with substitute fluid, General




Electric, KoGraw Edison, Westinghouse ~-




     MR. BR2MER:  They're letting the actual




manufacturers wake their owi; recommendations




then?




     ?IR. OiJIClI:  That is correct.

-------
                                           148





     MR. BREMER:  They haven't select rid any?




     MR. ONISHI:  Mo.




     MR. BREMER:  I thought that the Institute




was going to select, in fact they had some




tyi>e 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




IE concerned, again this would be a similar




situation and there e.re several substitv.te



fluids, most prominent being silicone, that




har been a rcplacertcrt fluid for askarcls.




     MR. BRTMFR:  f>J:ay.




                    Let's say foz example




Commonwealth Edicon has to replace a trans-




former  in. the city of Chicago in a public




building that was required by electrical

-------
                                       -    149




code to have an askarel-filled transformer



in a particular situation you would use a



silicone base fluid transformer oil at this



time or would you use an askarel?



     MR. ONZSHZ:  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, so 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. ONISHI:  In a new building we would



probably go to oil and in some cases we are



trying out some silicone transformers.



     MH. BREMERs  So, the Electrical Code



doesn't keep you frost using say mineral oil



inside a building?



     MR. ONISHI s  No,. I dees not.



     MR. DREMSR:  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

-------
specific places, public places where a  number




of people would be exposed to, you know,  let's




say fire from a trans former that they were




required to vise an askarel -filled transform®::.




     MR. ONISHI:  That is correct.




     MR, BREMER:  But, now you are saying that




you can go to oil-filled?




     MR. QNIEHI:  Well, in our locations  we




do have the transformers installad in a fire-




proof vault.  In many locations the transforners




are not installed in a fire-proof vault,  whicsh




means that it does have to be a non-flammablo




or f ire-resi&tant type tramsf orm-ar ,  In thoso




cases you would have to go ':o as>.arel or  sili.cone




or something that is approved from an electrical




code standpoint.



     MR. BREMER:  Is the siLlieone-filled




acceptable at this time?




     MR. ONISHI:  My u,nderutandi:ig is that




the National Electrical Co
-------
     MH. ONISHI:  I don't think it has been




formalized, but indications are that it will




be.




     MR. BREME2:  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 Hea how ypu can help




us interpret this.




                    One torm that this act




uses throughout, not only in sixty is the




term due process, not fron a legal standpoint,




but  just fron a standpoint of how people



actually use transformers, do you consider the




repair of the transformer to be the processing




of the PCB liquid itaelf?



     MR. QNTSHI:  What wa:? that question again?




     MR. BILES:  Do you consider the handling




of liquids and putting th«m in a transformer




to repair and maintain a transformer, is that




processing of the liquid.  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 the fluid, that
would be part of the processing.
     MR. BILES:  Okay.
                    That loads into ray next
question.  X 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
batween what is necessary for routine
maintenance to keep things for their current
life and the activity necessary and associated
with really building new transformers.  Is
that going to be a hard line for us to draw
in your opinion?
     MR. ONXSIII:  I don't think so.  I think

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                                           1 ^ 1
                                           jL 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. BILESi  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. OSfXSHX:  I am directing ray 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 whether you can havu a




transformer repaired or whether you purchase




a new one.




     MR. BILES;  If we attempt to wri^:e soire




regulations that account, for repair, however

-------
                                        "   154





we define that term, another issue that we



have got to face is 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 liquid*



that could be needed and promulgate the



regulations as opposed to being ailent on th&



issue and just assume that you can't make



any new ones, you can't import, ao 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. ONXSBZ:  Well, I think it would be



vary 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 I si that a lot of reclamation
processes may be a source of a lot of sloppy
handling of PCB, T 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 fn the past that night
be where a lot of PCBs are getting into the
environment, not by the large companies that
have their repair sho s.
                    I 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 ones, to what extent we are buying a
bigger problem in twrsnty years or ten years.
Laave that to the market.
     MR. ONISHI:  I think we le.ive it to
the market, but I don't think it is going
to be a real problem.  Ths requirements or
restraints on handling FC3s are so rerstrictive
that I think repair of transformer facilities
is going to be fairly costly.

-------
     MR. BILES:  The other provision we have



to deal with and people have commented on is



the provision on resale.  I think it is



obvious that one of the things it was in-



tended to cover in the maintenance of the



transformers.



                    The Act says that you



can distribute in commerce the liquids if



in effect they ware sold prior to the middle



of '79 and are for purposes other than re-



sale.



                    How possible is it for



industry now to essentially get in stock



the FCBs it is going to neei because otherwise



wo 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

-------
                                         •    157




the question,  but 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 may 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 resale.



                    It sounds like you are



going to have PCBs being sold after July 1



of '79, which in itself can —



     MR, OHXSRI:  Wait a minute, I don't



quite follow you.



     MR. BILES:  You are talking about



reclamation then in selling ~-



     MR. OWTSHI:  I am not talking about



reclaiming and selling, I am just talking



about reclaiming an3 reusing.



     MR. BILES:  Just one -- the one .repair'



so yon are not different entities?



     MR. ONISHI:  No.



     MR. BILE?:  Than* vou.

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                                             isa
     MR. PRINCIPE;  On the maintenance of



transformers, it is my understanding that



when they take a sample of liquid to teat,



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. OHXSHI:  I think I understand



our sample quantities to bo a half a pint.



But, I think you would hav.a 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 trichlorobensene to dilute PCBs in



transformers to the point where you have



approximately 60 percent TCB solution to



40 percent PCB.  Is it possible that instead



of using TCB to replace PCUts 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 trichlorrobenzene,



and then over the life of ^lie equipment it



wouldn't really iaa,ke much difference because



your distribution factor its so  small.

-------
                                            159
     MR. ONISHI:  You are correct,
trichlorobenzene is added to PCB and PCB
fluids, but it is a mixture at present..  We
have baen looking at the cse of trichlorobenzene
as an additive rathe): than PCBs.  Certainly  if
it is feasible we intend to do it.
                    There are some  supply
problems with trichlorobenzene and  a few
other properties tluit they have some
difficulti«2:5 with, a); least in my last, review
of this literature i<: indicated that they
had some difficulties:;.
     MR. PRINCIPE;  Could you elaborate- what
the difficulties wer»; arts they safety?
     MR. ONISHI:  Safety, I think there was
a pour problem, tenparature and a few problems
of that nature, chemical problems.
     fiR. PHINCIPE:  Do you have any i3ea
what stockpile in a normal utility  wojld
have today of PCBs, that is what quantity?
     V.3.. CXMISHI:  No, I think you would find
considerable variations, but it would
probably raug« froir. a few gallons to maybe
a couple of thousand gallons.

-------
                                        -    160




     MR. PRINCIPE:  Thank you.



     MR. PEARSON:  This may be a little



repetitive, but have you looked into the



possibility of thes difficulties that smaller



electrical utilities and cooperative*? and



municipal electrical companies are going to



have with this?



     MR. ONISHI:  Moat of the smaller utilities



have a very limited number of transformers.



Almost all utilities use capacitors nnd



capacitors are primarily a replacement and



the new product would not be PCB problems, you



would not have make-up fluLds in this sort



of thing.



                    As long as the capacitor.**



have the same electrical characteristics and



possibly the same physical dimensions the



ra:ijor problem facing those utilities is record



keeping and disposal.



     MR. PEARSON:  Well, tae way I looked at



it though waa at  what point whera concern is



going down to prevent the  Last drop of PCB



to get out to the environment ani the small



electrical company hag only one r>r two trans-

-------
                                       -   161
formers it would still be important.

     MR. ONISHI:  Well, that ie correct,

     MR. PEARSONj   Would they have had to --

would you fore»ee 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 questions?

Any questions from the audience?

     MR. RICE;  Dan :*ice, R~i~c~e, from the

Illuminating Company, Clearwater, Ohio, and

I address the question we had on repair here

for transformers,  basause I think when we're

talking about the larger power transformers

most of them go back to the manufacturer or

the repair shop.

                    At least in some companies

what we might call minor repairs is doing :.t

in a shop within the facility of the utility

and minor repairs might be replacing bushings,

-------
repainting the case to make it last 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 i» for this.  But/ there are




levels of repair as I see it,.




     MR. BILES:  That is why I was asking th«s




question for further opinions about processing




and using because the statute allows us to




authorize uses of PCBs in a non-totally-enclosed




manner indefinitely.  3?hen» is no 1979 ban




on the uses.




                    But, H: that particular




activity also contains processing then there



is a '79 ban on processing.  And the question



we have is if EPA wantu to adopt a policy of




allowing the continuing usoJrul life of the




transformer and therefore allowing the handli.ng




of the PCS liquid and transporting of the




transformers, where- do we draw the line betw




say in one activity constitutes actually




really manufacturing the transformer which




xve're trying to prevent and the other allows

-------
                                        * -  163




the continuing of th« useful life of it.




                    I was still trying to



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:  Mayba frou a utility stand-



point if you have to rewind the transformer



to the core now you are talking about some



type of raraanufactoringt but if you are just



painting the case 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 remanufacturing



                    I don't know if that is



clear on both aides, but it is just bringing



the point ao it is clear.



     MR. WIRTH:  I think it is clear now.



                    Is there another question?



     MR. DONZALs  My name is Dav« Donzal,




D-o-n-z-a-l, front Toledo Edison Company.  I

-------
                                       •••-  164





just want to make one comment in regards to



the spill prevention problem.



                    Generally opaaking, wo



have no problems with developing spill



prevention as we have for oil, obviously PCBs




are a lot worse environmentally than oil.



                    The two problems we have



found in getting our thoughts together and.



developing these plans mai-aly are network



transformers and precipitator transformers.



                    Mr. OnLshi mentioned sorao




ol: the problems with network transforraersr



in that a lot of tiraea you iiave atandpipes ox*



you have puraps.  What we a;:e looking at right;



now is trying to got sorae ;jort oE adequate



sensing device sucli that you can determine



when you have a detectable amount: of PCB in



the water, the rain water that coraes into



the vault, like in a downtown application,



determining when it is safe to pump the watex'



out.



                    The other problem  which  1



air, told that we do have is the physical location



of souie precipitator translformersj which are

-------
                                            16
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 transformers as one where, if Z



understand it correctly, the utility company



owns that is part of its distribution system?



     MR. DONZAL:  That is generally what I



was referring to.



     MR. W1HTH:  Whuc was the other ttsrm?



     MR. DGHZAL:  The thing I was pointing



out is that the object right now is developing



a spill prevention plan for PCBs, obviously



it is coming up  in the future.



                    We do have two problems,



one with network vaults and one with alectro-



static precipitator transformers.  And the



only point I was trying to make was to point



out to the agency that there are some physical



problems associated not only with the network



transformers, as Mr. Onishi has pointed out:,



but also in tha case of the -- when you have

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                                             168
a transformer in ei power plant, you know,




perhaps on top of the boilars or something.




     M2. WIRTil:  Okay,, fine.




                    Any further questions?



                    Would you coma forward a*:




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




an you were discussing her 2.




                    I'd lice to :>ffer this




advice that prices may be the separation in




the repairs we ares talking .about.  We get into




major repairs* of an askare L -f illad transf orraor ?




today the coat of aakarel La rising and




practically puts us out of tho market in every



major repair of transformers.  Y3U may be




limiting the major repairs in that aspect and




still allow the service to <;jo on without




additional ruling on  the tiing.




                    I'l appreciate it if you




would consider that.  It i;3 hard enough  to




try to compete in business without -- you know,




without the additional rulings on things.

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                                           167
     MR. WIRTHs  Okay, thnnk you.

                    Any further questions?

                    Moving on to the r;«xt

witnesa, Mr. Williari Curtis, Manager of

the Electronic Diviuion Northern States Power

Company/ Minneapolis;.

     MR. CURTISs  I just got a promotion

I wasn't aware of*

                    My name is William

Curtis and X am Manager of Electronic

Distribution for NSI\, we're an electric

utility located in Minneapolis, Minnesota,

and we serve a four-atate area, Minnesota,

Wisconsin, North ami South Dakota, an£ our

headquarters are in Minneapolis.

                    It is enjoyable to follow

Harry because he generated all the questions

that I was going to bring forth.  3ut, I have

a couple of coauaents I'd like to address

myself to here.

                    ?ls fa:c as duration,

extent of use for existing equipment, it is

our recommendation that all field products

such as capiicitors and transformers containing

-------
                                             168
ankarels be 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



1000 capacitor banks and approximately 900



transformers in service that if we were to



replace them immediately or in t.ie near future



would cost approximately $ 30,000,000    to



our repairs, environmental costs are passed



on to repairs.



                    We feel that we have



already made strides in the requirement of



40 CFR 761 to implement programs in handling..



storage and disposal.  It would oe impractical



and wasteful use of our resources at this



time to change all usable 
-------
                                         *    163





maintenance was answered very good by the



gentlemen that ware here, but I think at MSP



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



»O;HG of the problems* they are faced with ani



trying to indoctrinate and educate.



                    That :.s the extent of ray



comments and I wouJlc be willing to answer




some questions.



     MR. WIRTH:  Thank you, Mr. Curtis.



                    J. am c/oing to take the chair's




perogative to a&k the firs;t one or twc questions.

-------
                                              110?
                    I understood Mr. Onishi,




I guess it is a point I_wanl: to make absolutely




straight in my miricl, that in an askarel-filled




transformer there is not a blow off or  an




expansion device that under norn.al conditionn




that would normally would be releasing  PCBs




to the environment, that the only type  of  escape




from the tank was through a pressure valve in




the case or massifs overheating or failure,




i« this correct?




     MR. CURTIS:  That is correct.




     MR. WXRTHt  So that there should be no




formal -- there should be no release from  a




trans£ormer -•- askarel-f il L<3d transformer




unless it just completely  Bailed on rare



occasions?




     MR. CURTIS:  That is oorrecb.




     i*!R. WIRTII;  The sdcoti'l question is back




on the trichlorobonzene ad'lltionr io there aiiy




ruason in the world why th 2 nake-up fluid  ha:j




to be askarel in all cases or draw off  only




for testing purposes in pints?   I mean, the




size of most of thase trans fforn-.etrs, in  my



understanding, would ba that  it  vould  be  almost

-------
                                              171
non detectable replacement make-up fluid th;it




you would draw for analytical testing purposes,




     MR. CURTIS:  Well, we would draw a half




pint o£ fluid too.




                    i £ I understand ycur




question — would you repeat .It, I am sorry




1 lost you a minute there.




     MR. WIRTH:  I ai.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.




     HR. WZRTU:  Yoi are drawing off a 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 ^Clia




that will have a very voluble impact on the



performance of the traauformer; is thare any-




thing wrong with that assumption?




     MR. CURTISs  Ho, that would depend on




the size of tho 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. WXRTH:  Okay.




                    la there any reason that




the J?CBs should bo removed from the transformer




other than complete rebuilding; in other words




operations involving the rewinding or  for th
-------
                                              17.1
from it could be destroyed and it continues




on in that way for its entire useful life?




     M^. CURTIS:  I i.jan't see a problem




personally in my experience,




     MR. WIRTH:  It nakos it relatively safer




environmentally to withdraw it and ser.cl it to




disposal and in my opinion it would greatly




reduce the possibility of environment*,1 ex-




posure to it than if you -cum around ctncl




attempt to put some back in, is that a correct




assumption?




     MR. CURTIS:  I think so, yes.




     MP. WIRTH:  Let's start fr/ith questions




at the oth^r end of the table.




                    Mr. Pearson do you have




any?



     MR. PEARSON:  SD.




     Mil, PRATT:  Realizing this may not be




totally appropriate since the Twin Ci:y area




is in the middle of a drought as I understand




it; but, if I recollact correctly 1-iSP had a




problem with PCB transformers with flooding




conditions awhile ba.sk.




                    I wan wondering what

-------
                                              174




type of procedures have you instituted to



ensure that this would not reoccur in all



of your facilities?



     MR. CURTIS:  I am not aware of & drought



in the Twin City area.  I am not aware of



flooding problems either.



                    But, w« have instituted



policies that our distribution people follow



on handling, storage and disposal of PCIis;



wo have forms that we fill out; we work very



close with the State, we record avery spillover,



so many gallons; and as 1 said we 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 get back.  Maybe it



happened while I was gone.



     MR. BILES:  Does MSP parfora any repair




or maintenance operations for non-HSP trans-




former s?



     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 aiddle oi  '7i> which is  the

-------
                                             175




date we ara looking at/ do you see any nead



for NSP to buy or aell triinsformers other than



if you are soiling them in tho sense c£ sending



them for disposal arid money changes hands or



you sell a whole facility that contains a



transformer; is thare any reason for you to



buy or sell any trarutformors after that now



or in the future?



     MR. CURTIS:  W« wouldn't sell a trans-



former if it had uatti'ul life, if there, is



any economics to it we keep it in useful



service.



                    Che only other ca*e, and



I think you are reforring to this, is where



a municipality wanta 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:  Moat of the major work is



done/ yes.



     MR. BRKMER:  I have had the opportunity



about a year ago of testifying at the



Minnesota Senate Hearings on PCDleg iylation

-------
                                            176





for the St&tit-j of Minnesota.  And I was under




tha impression at that meeting that Northern




States Power strongly objected to a ban on




PCBs because of a very Icir^a facility that was




in the planning stage for  a sing a large number




of power factor correction capacitors.  And




at that tiioe tha individual stated that they




definitely had to be askar.al-filied ana that




this type of, you know/ they'd huve to have




exemptions to get thia facility in some type




oil order.




                    Now/ I was wondering



do you have other replacements at this time




that you thii;k ~- 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?




     HR. CURTIS:  Well, as Harry mentioned  in




his testimony, we no longer are buying askarul-




fillad capacitors or transformers.  We are




buying a silicone oil.




     MR. tJRKMER:  Also for capacitors?




     i'l.'i. CURTIS:  Capaoito:::3, ^e.J.

-------
                                            177






     MR. BREWERj   They're filled with silJcone?




     MR. CURTIS:   QUJ: shipment coming this




year will be silicorx. oil,




     MR. SREMER:   So, then, silicone can be




USQ..I in power factor type capacitors?




     H3. 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 auroly can chec}:, I am




not familiar with that instance that you are




quoting.




     MR. BRiSMEU:   Weil, you know, 1 just




remembered that the::e waa, you knov, a very




large problem by the very fact that they




said there was no r&plaeexaent:, but your



position now is that: there are replacements




that can take over in the situation?




     MR. CURTIS:   This could have boon the




case last year on our order with the manu-




facturers on the power factor correction type




capacitors.  We ordered quite a fev; of then




every year and it could have been tha case,




But, this year we are yetting non pcB type

-------
                                               178
fluid.




     :ra. BREMCR:  Ver/ gooi.   Thank you.




     DP.. S'i'URNOi  I have  one  question.




                    You have  indicated,  as




well as Mr. Onish, that about half a pint




of PCB is withdrawn for the tost.   Do they




use the whole halt" pint to 3o the  teat,  or




do you use a siaal}. portion of it afterwards?




I raean, what Jo  thoy do with  it after they




tested it?




     MR. CURTIS:  They use  the whole half




pint for tasting.  The*/ ha/ 2  uo test such




things as pour point, aciJi t ^  of the J'luit!,




Dielectric strength/ they .c an a aoupie




Dielectric strength ttistt.  The whol« --




taere  isn't nuch  left when  they finiish




their  toscs.




     OK. STURINO:  So, then the sawple is




consumed during  this  Last.lag?




     !R. CURTIS:  Jo, it  i.sn't consuaied, then




it. is  dispoacs:d according  to the .stato




regulations in Minnesota.




     O.-.I. STURINO:  What  I iwan by consumed




if. thvi physical  characteristics \Tore changed

-------
                                              173
that it aou?.d not be  ucuvl  any  nore?




                    'it  soesns to  roe  .1 lot of
people have been talking  ttbout  adding the




trichlorobortzene bui. nobody  has indicated




any toxicity or any of  the. other problems




which are posed by triehlorobenzene;  and it




seems to me after touting if the PCS  is still




maintained in Its characteristics I don't see




any reason why it can't b
-------
audience*?




     MR. ONISHI:   V&s,  I  just  wanted to




comment.  As I understood you,  you are




drivinj at since  the  araounc  of fluid that




you 'cook out of the saraplo is  very small




and the transformer is  totally enclosed then




the make-up fluid  requirement  ought to be




V€»ry small.  I think  I  made  the assumption




that in some casas th~  flu;.:l itsalf might be




contaiainated by moisture  or  something, the




transformer itself might  bo,   In those cases




we would have to  drain  the !:l.uid and refill




it so, in chose cases we  wo.ild have t :> use a




roach greater amount o.f  make;  -up f.'.uid than is




taken out during  chemical c.nalys:.s.




     MI*. 7JIRTH:   Yes, sir, If  I ciidn' t maka




it clear I understood that if  thii fluid test




poorly, or malfunctioned  hhe entj.ro fluid




would have to be  replaced.




                    Mr. Brerr.er?




     MR. BREWER:   On  the  sar.e  line thare,




if you have a lot of  moisture  contamination




in a transforner,  isn't it rather an  open




systenT

-------
                                               18.1
        .  O'JEGHT:   Mo, It does  moan you




probaMy  have a leaky aoal  aomt»wh«re r.round




the bushinj.




     ".I*.  SSSMEr-::   Whtsrci i-  would have takan




the v/atar fron the outside  it  vroulcln't. be




takan  aut of  the  air then it would have been,




say, from rain water'*




     MR.  0:;?rSHT:   I-*; coal:1,  be  rain vat.er.




If you  ha. I a  situation whora you ha-Jl .«. loaky




3-sal it voald be  accumulating  in




t-he transformer.   Of cour-.se, there is no




•-- that is not a  normal condition but it




could  happen.




     MR.  VTi:iTH:  Do VTOM replace-
     M3.  or'TISHI:   T,': thay are  faulty, y»s.




     Mrs.  T7TRTH:   Is that "?n  in-place servicing




or is the transformer usually  hauled c-u'..  for




service at that
     I!?..  OMISHIt   Wo. t.haj:  coul'l he ddn* in




place .




     .MR.  PRINCIPE:  7?his is  properly s




caestion  cor  both of you, but  I  will x;r>e
your numbors.
                     .'lo1':, you  indicated iliat

-------
you had 900 transformers in use, of those




900 transformers about how many each year




do you find that you UAVO to replace or




regenerate the fluids because of contamination;




do you have any idea what ttiat number would toe?




     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 of: a vault .and moving it to




another location except only in. ::ases where v;he




load -- the customer reduced his load and we




had an oversized transform a:r and economically




it would have been better o~f sonawhere else.




I can't recollect one case of this type of



thing.




     HR. WIRTH:  Do you recall t.io last time




you had to replace a transformer fluid in your




system?




     MR. CURTIS:  I'd only be ouassing, but




in the last year 1 can't really recall going




through any process ot: replacing -- these




are completely  sealed and aaless we 3iave  -~




the roof falls  in or a catastrophic failure,

-------
                                              183





which I can't recoJ.l-.jet,  there is nothing




that can -jec in or  oat  to cause contamination,




especially moisture,




     ii;*. P3INCIPE;   I 'ju<->;»s ray question then




has to go to Mr.  o?i:'.»hi,  cheja.




                     We  have heard on ei number




uf oceations people have  testified that




contamination can cake-  .^lace aau it appears




that contamination  — chat that Ly^e of




contauiiaaciou wher*j yoxt have got to regenerate



the Dielectric  fluid is very rare, is that




a sound conclusion?




     MR. OXIS1II:   Y.is,  I  think it is f!air.




     MR. CURTIS:   Tiie tests that we go through/




just to add to  it,  are  for a specific purpose,




and that is to  determine  the chemical properties



oC the material whicu i*  our insala i.ijvv. laecia.




And, Li thare is  uoiaething off, for our corr.pany's




standards, then we  33 through t'ais pr<.'cec*me.




It is a normal  procedure  tryiny to malntairi.




the reliability of  the  electric dist.r LLution




systen to better  serve  our customers.




     MR. RICE:  Dan Rice  again.




                     I just have one comment./

-------
                                           184





you mentioned buying or selling transformers.



And maybe for some utilities it is rare, I



guess it is for all utilities, it is rare, bat



occasionally we buy cr aell a transformer to



another utility where for some reason they



have a particular emergency need for that



transformer and it may not be available frora



a supylier for some period of time, we have



purchased and gold equipment such ac this.



     MR. WIRTH:  okay.  Thank you.



                    Any other comments?



                    Thank /ou very much.



     MR. CURTIS:  Thank yoa.



                    Would you coiae forward,



and state yoxir name and aEEiliation?



     MR. POWKLL:  My name is Walter Powell



from Midwest Technical.



                    v4« do a lot. of work for



private industries as opposed to utilities.



Okay.  Anci I think the pri/ate industry isn'c



represented enought right now.   ?a do work for



manulaoturiny processors, industrial customers



who have their own transformers, own theii ovr»




equipment.

-------
                                           18.]






                    Utilities watch their



equipment very closely so they may not aave



that much of a problem.  We get involved with



these customers, quite often in the repair of



transformers — PCB-filled transformers.



Quite often we have to take the fluid out



of the transformer right on site  and repair



it for whatever reason, ii: may be because the



bushing leaks, because of a. broken seal, or



because of moisture contamination.



                    In th«s 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 th® volume of gallons when



you do that because of the pumping equipment



that you use, this has to be replaced ,



                    Another area is when ycu

-------
                                          ife'S
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 underemphaaising the need for on-



site repair and replacement of fluid that hail



been lost from maybe a period of ten years.



                    Have I made ray point?



     MR. BILES:  The question on that is



if we follow a process of getting the PCBs



over the next several year:j to reclamation



where do you reclaim your PCBs from?  You



obviously don't own transformers of your own?



     MR. POWELLi  No, we just 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. POWELLi  Where will we?



     MR. BILES:  Would you buy your transformers




and drain them?



     MR. POWELLt  No.  No.   If we had a

-------
                                          18?
customer and that customer had a transformer




who is low fluid, I don't know where we would




get it.  That is going to be a problem.




     MR. BILES:  That is going to be a. very




critical issue if we try to project some way




to maintain transformers.



                    Ita 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 arts looking




forward to or our hopes are in is retro fitting




area.  We are hoping that this become» 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 circuniBtance




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 worra.3."



     MR. BILES:  Do you have a suggestion



on what we should do in terms of dealing witi



that problem, in terms 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.

-------
                                          183





                    Are there any othor




comments?




                    It is eight rainuttss




to three.  We will take a strict eighl:-




rcinute break.




                    (WHEREUPON, a short




                     recess was had.)




     MR. WIRTH:  Ok.ay.  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, ray n.ame is




John Weizeorick, W-e-i-z-e-o-r-i-c-k.  I am




Assistant General Manager for the AssDciation



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 r J;he Association no::her-

-------
                                          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 the use of PCBs



in its products just as soon 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 1973, some products



manufactured during or prior to 1978 and



containing PCB small capacitors are likely to



b€s in inventories throughout the nation  for



a substantial period after the July 1st,  1979

-------
                                            13.1.





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 rules* con-



cerning the phased ban of PCB, AHAM requests



the EPA to consider an exemption for TCB



small capacitors in the household appliances



including room air conditioners and micro-



wave ovens.



                    AHAM believes that the



household appliance industry has made a good-



faith effort to eliminate PCB small cs.pacitor



usage.  Microwave ov«n manufacturers indicate



that they will be fu^.ly 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 will be



accomplished during 1.978 no that the 1979



model line will be non-PCB 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, ARAM 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. Weizesorick, 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 comments basically relevant




to that regulation done until the final closet




of the reply comment or the 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

-------
                                          133
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 comment!? in

writing, identify it as a reply comment

for the record before the two r. ty --f i fth

to ensure that they are given full consider-

ation.

     MR. WKI2EORICK:  This comment was

submitted in writing to the EPA at the 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. WEIZEORICK:  The-.re is some additional

information I have which was not contained in

our comments which wo 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 and

disposal.

     MR. WEIZIORICK:  Okay.

                    We would be glad to answer

any questions on the PCB bein.

-------
                                           195





     MR. WIRTH:  Themk you.




                    >r;aryr do you have any




questions?




     MR. BURIN:  Have; there been any




technical problems that you are aware of




that they had to change over to non-PCB-built




capacitors?




     MR. WE1ZIORICK:;  I can answer ths.t, yes.




I think Bill might b« able to provide additional




detail if you'd lik«,




     MR. BEARD:  Th«jre have been a number of




technical details and some of the eaps.citor




manufacturers are h«re 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;i 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-PCB 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 loss of Ceipacitance




due to degradation of the fi.uid, it is not

-------
                                           187




a problem of rupture or failure of thc.t




nature, it is a failure of the thing




electrically.




     y-.R. iULKS;  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, 3ILES:  Putting together the test,




your statement along with what Mr. Rollins




said this morning, I am understanding then




that you saying thafc the fact that the




capacitors -•- the maaufacturers of the small




capacitors feel that they can be out of the,t




business by the end of '78, you feel that that




is adequate to meet your needs?



                    He this morning made a



statement that they did not anticipate at




least at this time that at that point they d




need an extension beyond 1978 to manufacture




capacitors?




     MR. V?EIZEORICKr  Present plans of all of




the members of AHAM are to be out of PCD t'/pe



capacitors during model year 1973; that wcrild

-------
                                        •    138




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 sea any reason what-




soever to be selling  any small capacitors as




small capacitors, not just soiling 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 PC3 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. WEIZEORICK:   No.



     MR. BILES:  Or capacitor  sales?




     MR. WEIZEORICK:  That is  our  problem.

-------
                                         IS3




     MR. BILES:  Hovr long do you thin/; that




will take for you to complete your sale-; o"




what you manufactured prior to that date, what




is the period --




     MR. WEI2EORICX::  Well, if the aumnor




continues the way it has .and we have another




summer like this next year, it is likoly tc




be no problem with room air conditioners.




Howevesr, our past history indicates that we




have products floating 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 poasession of that material,




it is stored somewhere out in the field




and some of it might even be shipped from




the Northern states to the Southern states



and re-financed and resold down there;.   And,

-------
                                      200
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. BILES:  Maybe this is a question th.it




goes to your supplier;  do you have any idea




of the percent of small capacitor market room




air conditioners and microwave ovens cover?




     MR. WEIZEORICK:  No.




     MR. BILES:  I will ask: that later.




                    The Ias3t question is;



are you aware of any importation of PCB



capacitors or air conditioners or microwave




ovens that have PCB in them that arc competing




with your products?




     MR. WEIEEORICK:  Mo, I am not.




     MR. BILES:  That doesn't mean it doesn't




existr you are saying you are not aware of




it?



     MR. WEIZEORICK:  I am not aware of any.

-------
                                           201
     MR. WIHTH:  Anv questions from the
audience?
     MR. GOLDSTEIN:  Do you anticipate any
problems with your warranty procedure because
of the change from PCB to some other l:ype of
material, an alteration ot your warranty
policy on your small appliances?
     MR. WEIZEORICK:  No, we wouldn't plan
on it.  That is one of th9 reasons we are
very concerned with reliability of th
-------
would like to see them, otherwise in the




interest of time I will just brisfly sumnariise




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 WQ hav<» a copy of this?




     M«. WARD:  Certainly.




                    I am sorry I only have




three copies here, but I d:.d give the original




to the hearing clerk previously.




                    The firsjt itfim I would




like to address myself to i« the issue of the;



totally enclosed manner.




                    GM doeft not nanufacture cr




process PCBs.  However, GM does use PCBs in




electrical capacitors and transformers, which




arc closed and sealed unitsi,  We recommend that




such units be designed as  * totally enclosed"




even though they are physically capable of



being opened  in some means.  But are  sealed




during normal operation.   Likewise, we

-------
                                            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 connideration



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,



PCB-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 systems



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 PCB 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 leps than five hundred part.-s-per-



million PCS.  The incremental reductions



in PCB content gained by successive draining



of a system below about one percent residual



PCB are minimal.



                    The material costs of



cleaning a system are about $2.45 per litr«



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-raillion 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 the 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 PC3 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 be



placed in labelled containers for proper



disposal.



                    The release of PCBs



resulting from the transformer maintenance



is negligible, if proper, common sanso 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 have contained PCBs.  Thosei



capacitors contain paper impregnated with



approximately two kilograms, zero point two



kilograms of liquid PCS.  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



PCS-containing capacitors and diosel-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





                    Th® anount of PCB& in



a diesel-electric locomotive is sraall, a



total of about one kilogram PCB per locomotive



and is well-protected by the body of the



locomotive.  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-PCD components on a



scheduled maintenance basis rather the.n retrofit,



unnecessary cost an rail service disrxiption



can be avoided.



                    In closing we recommend



that EPA allow existing PCB-containincf electrical



gear to remain in usse for the remainder of its



useful service 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 GE.



                    I'd be happy to answer



any question.

-------
     MR. BILES:  Thank you, Mr. Ward.       2|.Q




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 PCB




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

-------
                                                    *    Ell
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 kiad 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. WARD:  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. WARD:  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. WARD:  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 fluid; 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

-------
                                                     2X5




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 simply 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 i« the NPDES permit



            program is handling that.



                 MR. WARD:  Ho, 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 Westinghouse 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 a purchase contract.



                 MR. BILES:  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 said 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. BILESi   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. WARD:  No, it is not.



     MR. BILESi  — 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 nay



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 been



            represented throughout the PCB hearing



            that the EPA has conducted over the past



            year and a half.



                 MR. WARD:  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. SHYKINDs  It occurred to me that



            you have the same hydraulic systems, same



            problems presented to u« by the Outboard



            Marine Company that has 100 hydraulic



            die cast press typo of thing where they



            grind and still have problems.



                                How much real leaking




            do you have out of these, are they real



            serious sources of contamination?



                 MR. WARD:  Leakage from a hydraulic



            system is a function of many, many things.

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                                           222
It is a function of system design, system



age, the cycle rate of the system, the



maintenance that is performed on the system,



the type of fluid used in the system, many,



many things bear on the leak rate.



                    within a single given



location you can find hydraulic systems



that are virtually leak-tight and you can



find other systems that have very high



leak rates.  One of the most -- let's say



that probably one of the major problems



that you would have would be a hose rupture,



this would cause you to lose the largest



volume of fluid at a given time if you



rupture a hydraulic hose.



     MR. SHYKIND:  So, you then collect it



or do you have facilities in case of a



rupture to pick it up?



     MR. WARD:  Basically the machines




are -- do sit on pans so that normal leakage



is collected.



                    If a machine breaks



a hydraulic hose you have oil under



several thousand pounds per square-inch

-------
                                                        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 say 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

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                                           224
oily waste.



                    So, in ft 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:  Ho, 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 incineration?


     MR. WARD:  First-off I don't think



we can  use Monsanto anymore since  they're


getting out of the incineration business


too.

-------
p!6                             Our practice is to



            collect waste oils/ hold them 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 rnay 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 PCB.  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 t:hen

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                                            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, outsi.de



            this forum.



                                I simply do not have



            the type of information that you aru



            alluding to at my command at this moment.



                 MR. PRATTs  What type of testing



            procedures does GM have to check as far as



            — you said that oftentimes PCBs or PCB



            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 am speaking of the normal
           municipal waste facilities.
                MR. WARD:  ID most places industrial
           waste does not necessarily go to a municipal
           facility.  There are places of course,
           where this in not true.  There are cur
           municipalities that will receive industrial
           waste.
                               If we have a waste
           which is a known hazard our procedures
           are to  landfill  it if it is — if that is
           the proper disposal  landfill,  to hev« it
            landfilled  at a properly permitted and
           licensed facility.
                MR. PRATT:  Thank you.
                HEARING OFFICER WIRTH:  Mr. Pearson,
           do you have any questions?
                               I have just one
           clarification on ny part and I thinX 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. WARD:  We burn some waste oils

in our boilers.

     HEARING OFFICER WIRTHi  From 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 WIRTHi  And you have

burned some of these oils?

     MR. WARD:  We have burned  some of  those-

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 saya,



            "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:  Yos, we have found PCB



            contamination in commercially purchased



            oil.



                 HEARING OFFICER WIRTH:  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.g 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 WIRTH:  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?
     MR. 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 PCBsr

            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 coming 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 PCB 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. PAGE:  I am Bill  Page, from Midland,



            Michigan, and I 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

-------
                                       *   23G
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 PCB 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-plus 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 
-------
                                       •   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 PCB into the



     environment is significantly reduced.



     Item 3:  Migration of PCB into tho



     ailicone 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 PCS 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 Retrofillings  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, ail



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

-------
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 serd.es




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 WIRTHr   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 WIRTU:  Okay.



                    Questions?  Mr. Pearson,



Mr. Pratt, Mr.  Principe?



     MR. PRINCIPE:  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 me 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 PCS 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

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                                          251
procedure by simple distillation of the

askarels that come out, and at that

economically would cut the cost of the

solvent that is flushing and count the

amount of material that would need to be

burned also.

     MR. BILES:  Is there anybody else

in addition to your company who is in the

business and is advocating this kind of

a program?

     MR. PAGE:  Okay.

                    The one thing I can say

that is aware of that has been published

is that -- is that Union Carbide -- Union

Carbide, a man by the name of Bill Martin

recently wrote a paper -- a technical paper,

I can't even give you the reference on it,

but in it it did describe doing some

retrofilling in their own plant.  And,

he didn't call it retrofilling, but it

was draining the askarel from the unit

and putting silicone in, and he measured

some of the performance values of the unit.

     MR. BILES:  But, you are the ones

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                                         252
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 PCB --

     MR. BILES:  A PCB mixture.

     MR. PAGE:  A PCB mixture.

                    No, 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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                                           2S4
ray 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.




                    I think that is the




only thiny 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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                                             255



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 soiue 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 am 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 am 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 PCS 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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                                             £5-7
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 PCB 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 WIRTH:  If I understand




what you are saying that is — correct me




if I am wrong/ the labeling disposal




regulation and transformer that contains




PCBs ip drained and goes to a chemical




waste facility?




     MR. ORQSCK:  Transforner?




     HEARING OFFICER V7IRTII;  Now, you are




saying if an individual drains his trans-




former, PCB or askarel-filled transformer




he must incinerate that, if he retrofilled




with silicons and it ends up with two percent




PCBs in it after its useful life you must

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                                             258
also incinerate the silicone with two percent
PCBs 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
he essentially doesn't end up with two
volumes of transformer fluid and incinerate
over its lifetime?
     MR. OR3ECK:  Basically I am saying
that when you do retrofill you have in fact
reduced from 90 percent PCS 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
company 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
            PCB leach a PCD out of the — a substantial
            amount of PCb out of the -- before
            winding into the silicons 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 PCD 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 per 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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                                                      26L
>2         of circumstances.

               HEARING OFFICER WIRTli :  Any more

          questions?


               MR. Si\l\'DER:  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  transformer

          when you retrofill with silicone in


          terms of the electrical capacity of th«j

          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 f&st


          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.

-------
                                                       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. SrtYDLRt   Do silicone fluids have




           a  lower  prime point  than PCBs?




                MR. PAGE:  Not  much higher  than askarels.




                MR. SNYDER:   So, what problems  are




           you alluding to when you dispose of  PCBs




           with --  or silicone  contaminants?



                MR. PACK:  silicone has a high  fire




           point.   A fire  point is  a temperature




           that you heat a liquid to it,  put  a



           flame to it, take that flame off the




           liquid the liquid will continue  to burn.




           With silicone it  is  600  degrees  Fahrenheit.




           And if you take silicone and throw it into




           an incinerator, straight silicone-type




           material sometimes you don't get good

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                                             2*4


ignition on the silicone material.


                    What waste disposal
            t

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 all 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. BURIiJ:  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



Dill 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.




I 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

-------
                                          2138
people from Dow Corning.
                    It is my understanding,
this might be a simplistic understanding,
that there are sonie 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 — retrofill 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. ORBECK:  You will have to explain
the Code change.
     MR. AGItf:  I mentioned the National
Electric Safety Code.  I am not familiar
with the details of it or with whatever

-------
                                                       269
0         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
nrset 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?                           etc




     MR. PAGE:  Yes.




     HEARIHG OFFICER WIRTH:  What type,




how are those provisions stated?




     MR. PAGE:  It lists a fire point,




a propagation test and what is the third?




     MR. ORBECK:  The third test is signed




by the fact of mutual insurance to try



to verify the different aspects of high




fire point, fire propagation, fire spread,




but there is a difference — these are




words in the National Electric Code --




they are not authorized to be -•• not authorized




to be investigative tests, they are used




temporarily unless such a classification




system is established.




                    These three tests



function in the way to make sure that these




properties are not written into the Code




as a temporary situation until they get




it all.



     HEARING OFFICER WIRTii:  You Say this




is fire point, fire propagation, fire




spread?

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                                            273




     MR. PAGE:  We can submit a copy



of that text.



     HEARING OFFICER WIRTH:   Any other



questions?  Okay.  Thank you very much.



                    That concludes the



previously registered witnesses which



brings us to the point to open the meeting



for any questions, statement or anyone



wishing to make any comment.



                    I would like to ask



if there is anybody in the room that



represents an environmental concern,



organization or group.  We have not heard



from any such group today.  Do they care



to make a comment on the things they



heard today or this proposed regulation?



                    If not the floor is



open for anyone who wishes to make any



sort of a statement.



                    Everybody is tired.



                    Okay, if there is nothing,




no further statements then this meeting is



adjourned.  Thank you very much.



  (WHICH WERE ALL THE PROCEEDINGS HAD.)

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                                              2/4-
STATE OF ILLINOIS )
                  }  SS
COUNTY OP C O O K )
     SUSAN A. DIMC, 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 &nd correct transcript

of her shorthand notes, so taken as afore-

said, and contains all the proceedings of

said hearing.
SUBSCRIBED AND SWORN TO

before me this  ^7 ,: day

of   CWlA/      , A.D., 1977
     Notary Public

-------