v>EPA
United States
Environmental Protection
Agency
CMfice of
Toxic Substances
Washington DC 20460
Toxic Substances
PCB Manufacturing,
Processing, Distribution
in Commerce and Use
Ban Regulation
Proposed Rule—Support Document/Voluntary
Draft Environmental Impact Statement
Environmental Protection Agency
(40 CFR Part 761)
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ENVIRONMENTAL PROTECTION AGENCY
SUPPORT DOCUMENT/
DRAFT VOLUNTARY ENVIRONMENTAL IMPACT STATEMENT
for
Polychlorinated Biphenyls (PCBs)
Manufacturing, Processing, Distribution in Commerce and Use
Ban Regulation (Section 6{e) of TSCA)
Prepared by
Office of Toxic Substances
Approved by
T
Jon/i P. Dekany, Deputy
Assistant Administrator for the
Office of Chemical Control
May 1978
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VOLUNTARY DRAFT ENVIRONMENTAL IMPACT STATEMENT
SUMMARY SHEET
(Check One)
(X) Draft.
( ) Final Environmental Statement.
Environmental Protection Agency
Office of Toxic Substances
1. Name of Action. (Check One)
(X) Administrative Action.
( ) Legislative Action.
2. Description of Action.
This proposed rule is designed to implement Section
6(e) of TSCA prohibiting the manufacturing, processing,
distribution in commerce, and use of PCBs, and to
provide several limited exceptions to these general
prohibitions for activities which will not present an
unreasonable risk of injury to health or environment.
The use of PCBs has been extensive throughout the
United States, and therefore, its impact is expected to
be nationwide.
3. Summary of Environmental Impact and Adverse
Environmental Effects.
PCBs are a significant environmental pollutant
occurring throughout the biosphere. They pose a
significant risk to the health of man and numerous
other living things. A number of adverse effects on
living organisms has been demonstrated, including but
not limited to, bioaccumulation, biomagnification, and
cancer in laboratory animals. PCBs are extremely
persistent in the environment circulating among the
three environmental compartments (air, water, and
land); additional release of PCBs in the environment
will eventually result in widespread exposure and
increased risks.
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"1
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4. Alternatives Considered.
a. No Action.
Section 6(e) of TSCA specifically bans the
manufacturing, processing, distribution in commerce, and
use of PCBs. EPA's discretion with respect to these
prohibitions is to establish and clarify certain
definitions and to provide exceptions to the
prohibitions.
b. Action Through Other Statutes or Regulatory Bodies.
This alternative was rejected because it was determined
that using other statutes administered by EPA (i.e.,
Clean Air Act, Federal Water Pollution Control Act,
Safe Drinking Water Act, or Resource Conservation and
Recovery Act) was inappropriate because they could not
provide the comprehensive coverage necessary to
implement Section 6(e). This is also true of
attempting to utilize statutes administered by other
regulatory agencies or state governments. Furthermore,
there is a strong case that EPA is required by TSCA to
use Section 6(e) of TSCA to implement, and grant
exceptions to, the explicit prohibitions mandated by
Section 6(e).
c. Action Under Section 6(e) of TSCA
There are numerous alternatives considered within the
authority of Section 6(e) of TSCA. Please refer to
Chapters IV and VI for details.
5. Federal Agencies That Participated on EPA's PCB Work
Group:
Department of Commerce (DOC)
Department of Defense (DOD)
Department of Transportation (DOT)
Department of Interior (DOI)
Federal Railroad Administration (FRA-DOT)
General Services Administration (GSA)
National Institute for Occupational Safety and Health
(NIOSH)
Tennessee Valley Authority (TVA)
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On or about May 26, 1978 the draft statement was
officially filed with the Director, Office of Federal
Activities, EPA and was made available to the public.
Copies can be obtained from the Industry Assistance
Office, Office of Toxic Substances (TS-793),
Environmental Protection Agency, 401 M Street, S.W.,
Washington, D.C. 20460, (800) 424-9065, in Washington,
D.C., 544-1404. The official record of rulemaking,
including the draft EIS, is located in Room 520, East
Tower, Environmental Protection Agency, 401 M Street,
S.W., Washington, D.C. 20460, (202) 755-1188. It will
be available for viewing and copying from 9 a.m. to 4
p.m., Monday through Friday excluding holidays.
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TABLE 0 F CONTENTS
Page
I. Background 1
II. Alternatives to this Rule 3
III. Significance of the Release of PCBs into the Environment . 6
IV. Definition of PCB Mixture 30
V. PCB Substitutes 36
VI. Reasonable Ike Determinations 42
A. Transformers 43
B. Railroad Transformers and Self-Propelled Cars 48
C. Mining Machinery 53
D. Hydraulic Die Casting Systems 57
E. Carbonless Copy Paper 60
VII. Waste Oil 62
VEIL footnotes 64
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I. BACKGROUND
PCBs have been used in the United States since 1929. PCBs have been used in
' transformer cooling liquids, capacitor dielectric liquids, heat transfer and hydrau-
lic liquids, and as a die carrier in carbonless copy paper, a plasticizer in paints,
" adhesives, and caulking compounds, and a filler in investment casting wax.
Monsanto was the major U.S. manufacturer of PCBs. Since 1972, Monsanto
limited sales of PCBs to manufacturers of transformers and capacitors. Monsanto
ceased manufacturing PCBs in mid-1977, and shipped the last remaining inventory by
1
October 31, 1977.
Small quantities of PCBs may also be produced as unintentional byproducts of
other chemical processes. Similarly, chlorination of water which contains appre-
ciable concentrations of biphenyl can result in the unintentional formation of
2
PCBs. No natural sources of PCBs have been identified. PCBs have also been imported
for use in investment casting wax, for the maintenance of certain mining machinery,
and as the coolant in electrical transformers.
Prior to the enactment of the Toxic Substances Control Act (TSCA), the author-
ity of the EPA with respect to PCBs was limited to the regulation of contaminated
water from point sources. EPA promulgated a rule under Section 307(a) of the
• Federal Water Pollution Control Act on February 2, 1977 (42 FR 6532-6556), which
. banned the discharge of PCBs into navigable waters by electrical transformer and
capacitor manufacturers.
The enactment of TSCA in October 1976, placed additional restrictions on the
use of PCBs and required that certain actions be taken by EPA. Section 6(e)(l) of
the Act required that EPA promulgate a disposal and marking regulation for
.-PCBs. This rule was promulgated by EPA on February 17, 1978 (43 FR 7150-7164).
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This rule requires that special warning labels be applied to large capacitors,
transformers, and other PC3 equipment, and regulates the disposal of PCSs. The
regulation covers liquid PC3s and all other material and equipment components
containing or having contained ?C3s in concentrations of greater than 500 ppm
(0.050 percent).
TSCA also establishes cutoff dates for certain PC3 activities as follows: v
January 1, 1978: All manufacturing, processing, distribution
in commerce, and use must be in a totally
enclosed manner.
January 1, 1979: No further manufacturing or importing of
PCBs is allowed.
July 1, 1979: No further processing or distribution in
commerce of PCBs is allowed.
EPA is also authorized to grant authorizations and exemptions for continuation of
specific activities beyond these dates in certain circumstances.
This Support Document/Voluntary Draft Environmental Impact
Statement contains the same information as would be prepared to
meet the requirements of Section 6(c)(l) of TSCA. While not
legally required to prepare an environmental impact statement by-'
Section 102(2)(c) of the National Environmental Policy Act (NEPA).*
of 1969, EPA has voluntarily prepared this Support
Document/Voluntary Draft Environmental Impact Statement in
conformance with the spirit of its 1974 statement on voluntary
EIS's (39 FR 37419, October 21, 1974). The voluntary preparation
of this document in no way legally subjects the Agency to NEPA -
requirements.
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II. ALTERNATIVES TO THIS RULE
In developing these proposed rules, EPA considered whether there were other
regulatory or nonregulatory options available as alternative approaches to imple-
menting the Section 6(e) prohibitions against PCB activities and otherwise satisfy
the purposes of Section 6(e) of TSCA. The Agency has determined that there is no
alternative to writing regulations under Section 6(e) to fulfill the requirements
of the law.
Congress has explicitly mandated in the Act that the manufacturing, process-
ing, distribution in commerce, and use of PCBs be prohibited according to a certain
schedule. In taking any action relative to these prohibitions, EPA has the dis-
Tetion under TSCA to establish and clarify certain definitions and to provide
exceptions to the prohibitions. Such authority is not granted under any other
statute. Therefore, EPA cannot use other laws or rely on nonregulatory mechanisms
to make any exceptions to or otherwise alter in any way the impact of the prohibitions
imposed by TSCA.
Section 6(e)(4) specifically exempts EPA from the requirements of Section
6(c)(l), including that of considering the use of other EPA-administered authorities
as alternatives to rulemaking under Section 6 of TSCA. This indicates that Congress
intended that EPA use TSCA to implement these prohibitions on PCBs. The use of
other authorities to resolve the PCB problem addressed by Section 6(e)(2) and (3)
would be impractical, complex, time consuming, and in some cases impossible. No
other Federal statute grants the kind of authority necessary to directly control
the range of PCB activities covered by Section 6(e). Sections of several statutes
might have to be invoked in separate actions for each aspect of each PCB activity.
A number of indirect controls would be necessary to effectively prohibit PCB
activities as required by TSCA except in those cases where risks were found to be
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reasonable. The other relevant statutes, moreover, are often not designed to
provide this comprehensive coverage, even when used in concert. For example, many
sources of PCB air emissions are not included within the definition of sources
regulatable under the Clean Air Act (CAA). The concepts of area-wide standards and
controls in the Federal Water Pollution Control Act (FWPCA) and the CAA do not seem
appropriate for implementing these prohibitions on PCBs and specific PCB articles
or activities of concern. There are final regulations under Section 307(a) of
FrfPCA which set effluent standards prohibiting any discharge of PCBs, but only from
PCB manufacturers, electrical capacitor manufacturers, and electrical transformer
manufacturers. If the FWPCA, the Safe Drinking Water Act, or the Resource Con-
servation and Recovery Act were used, spills could be controlled, but other aspects
of the PCB problem 6ould not.
Some other Federal statutes not administered by EPA could also be utilized to
control some sources of PCBs. For example, the National Institute for Occupational
Safety and Health has set a workplace exposure criterion of 5 ppm for employee
exposure and recommended that the Occupational Safety and Health Administration
prepare regulations accordingly. But again, this only addresses a part of the
problem. A few States have regulations on PCBs, but they are not sufficient to
cover all activities addressed by TSCA nor, obviously, do they provide control of
PCBs on a national scale.
Existing rules were reviewed to identify any preemption problems, but no
exhaustive analysis was done of all the health, environmental, and economic impacts
of potential regulatory options other than action under Section 6(e). Implementing
the Congressional mandate with respect to PCBs by using other statutes and regula-
tions would be impractical. Not only would it be difficult to develop, understand,
comply with, and enforce, but it could not be done within the timeframe established
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by TSCA. Even then it is doubtful that all aspects of the problem would be ade-
quately handled as intended by Congress. Furthermore, there is a strong case that
EPA is required by TSCA to use Section 6(e) of TSCA to implement, and grant exceptions
to, the explicit prohibitions mandated by Section 6(e).
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III. SIGNIFICANCE OF THE RELEASE OF PCBs INTO
THE ENVIRONMENT
Introduction
TSCA prohibits the manufacture, processing, distribution in commerce, or use
of PCBs on or after January 1, 1978, in other than a totally enclosed manner
[Section 6(e)(2)(A)]. "Totally enclosed manner" is defined by TSCA to mean a
i+.r
manner which will ensure no significant exposure of human beings or the environment
to PCBs, as determined by EPA by rule [Section 6(e)(2)(C)]. The proposed regula-
tions, in turn, provide that human or environmental exposure to any detectable
quantities of PCBs shall be deemed significant. This provision is based on the
finding that any release of PCBs into the environment will eventually result in
widespread exposure of wildlife, including some of man's major food sources, and
humans to these chemicals and that any such exposure may have adverse effects.
The following sections summarize the variety of adverse effects which PCBs
have been found to induce in humans, laboratory animals, and other organisms, and
the extent to which PCBs released into the environment become distributed through-
out the biosphere. The adverse effects have been described in greater detail in
various documents, including EPA Report No. 440/9-77-021, "Criteria Document for
PCBs," July 1976; Criteria for a Recommended Standard: Occupational Exposure to
Polychlorinated Biphenyls (PCBs), National Institute for Occupational Safety and
Health, September 1977; and "Environmental Health Criteria: Polychlorinated Biphenyls
and Polychlorinated Terphenyls," World Health Organization, 1976. PCB-induced
effects were also reviewed in detail in expert testimony at a public hearing before
EPA and were acknowledged and described in a decision by the Administrator to
promulgate toxic pollutant water effluent standards for PCBs (42 FR 6532-6556,
February 2, 1977).
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Significance of Exposure to PCBs
A. Absorption and Storage
PCBs are absorbed through the lungs, the gastrointestinal tract, and the
intact skin.-'- After absorption, PCBs are circulated throughout the body in the
blood and are stored in adipose tissue and in a variety of organs and tissues,
o
including the liver, kidney, lungs, adrenal glands, brain, heart, and skin.
B. Specific Adverse Health Effects of PCBs as Observed in Toxicology
Tests and Epidemiological Studies
The view that human health risks resulting from exposure to chemicals may be
determined experimentally by testing laboratory animals is one that is widely
accepted in the scientific community and has been adopted by EPA. Because experi-
mentation on human beings raises ethical questions and because epidemiological
studies often provide incomplete information, toxicology studies on laboratory
animals are often necessary. However, because the extrapolation from animals to
man is subject to some uncertainty, corroboration of laboratory test data with
sound epidemiological information is desirable. The available toxicological and
epidemiological data relating to the effects of PCBs are discussed below.
1. Oncogenicity
PCBs appear to have caused malignant and benign tumors in rats and mice in
several experiments.^ In one carefully conducted experiment, rats fed 10.0 ppm
of Aroclor 1260 in the diet for 21 months developed a high incidence of carcinomas
(26/184) and neoplastic nodules (144/184) in the liver. Only one of 173 control
animals developed a carcinoma, and none developed neoplastic nodules. In another
experiment, rats were fed Aroclors 1242, 1254, and 1260 for 24 months. Rats
exposed to any of the three mixtures at 100 ppm in the diet developed malignant
liver tumors (hepatomas and cholangiohepatomas), whereas none was observed in the
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controls (3/20 for Aroclor 1242, 6/27 for Aroclor 1254, 7/27 for Aroclor 1260, and
0/20 for the controls). A high frequency of nodular hyperplasia in the liver,
considered by some authorities to be precancerous, was observed in the rats fed
100 ppm of the three mixtures. A significant increase in frequency in comparison
4
to controls was observed down to the 10 ppm dosage level.
to
The results of the epidemiological data, although somewhat ambiguous, provide ^
additional evidence that PCBs pose a carcinogenic risk to man. In 1968, at least
1,291 persons were afflicted with a disease known as Yusho as a consequence of eating -
rice oil contaminated with PCBs and relatively smaller amounts of PCDFs. Although
precise data are not yet available, a preliminary tabulation of the deaths among
Yusho victims through 1975 showed an excess in the rate of cancer, particularly of
tl1..' stomach and liver. In another preliminary study, 92 workers considered likely
to have been exposed to Aroclor 1254 at a New Jersey petrochemical facility between
1949 and 1957 indicated a significant excess of malignant melanoma and pancreatic
cancer. In the third study, an examination of the death certificates of 50 employees
formerly engaged in the manufacture of PCBs revealed seven cases of lung cancer, com-
pared with an expected 2.5 cases. However, these results were not corrected for
age or smoking habits and are only preliminary.
2. Teratogenic, Fetotoxic, and Reproductive Effects
Beagle dogs fed Aroclor 1254 at the rate of 1.0 mg/kg/day had offspring with a ."
significantly higher incidence of patent fontanelles than did controls but exhibited j
no decrease in the number of offspring. In the same experiment, dogs fed 5.0
mg/kg/day had a fetal resorption rate of 45.5 percent (a fourfold increase over
controls). Patent fontanelles were present in 50 percent of the offspring.
Sows fed Aroclor 1254 at a dose of 1.0 mg/kg/day for 21 days before breeding "~
and throughout gestation experienced a statistically significant rate of fetal
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resorption. Higher dosages further reduced fertility and caused a variety of
Q
defects in the offspring, including cleft palate, syndactyly, and patent fontanelles.
Female rhesus monkeys fed PCBs at 5 ppm and 2.5 ppm in the diet for 6 months
before mating with untreated males demonstrated severe reproductive dysfunctions.
Only one of the eight animals fed the higher dose gave birth, with five animals
experiencing abortions and two not conceiving at all. Of the eight monkeys fed the
Q
lower dosage, five gave birth to extremely small infants, and three aborted.
In another experiment, three of six infant rhesus monkeys born to mothers fed
2.5 ppm of PCBs died within 6 months of birth. The surviving three infants exhibited
behavioral and learning defects.
Studies with mink have also demonstrated the adverse effects of PCBs on repro-
uaction. Ranch mink fed coho salmon contaminated with 12-20 ppm of PCBs suffered
from reproductive failure and kit mortality. Female mink fed dosages as low as 5
ppm of Aroclor 1254 and 2 ppm of Aroclor 1016 experienced substantial reductions in
the number of live kits born.
3. Enzyme Induction by PCBs
It has been demonstrated in several experiments that PCBs induce various
microsomal enzymes of the liver, including mixed-function oxidases. Such induction
has occurred after administration of Aroclors 1016, 1242, 1248, 1254, and 1260 to
rats at dosages as low as 1 mg/kg/day for 21-28 days in the diet. Some of the
enzymes induced by PCB mixtures and chlorobiphenyl isomers in rats and other
animals are nitroreductases, dimethylases, deethylases, glucose-6-phosphatase, aryl
hydrocarbon hydroxylases, cytochromes P-450 and P-448, NADPH cytochrome reductase,
12
and delta-aminolevulinic acid synthetase.
The consequences of this enzyme induction may be quite significant. Some of
the enzymes induced by PCBs, such as cytochrome P-450 and cytochrome P-450 dependent
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N-demethylase, are involved in the metabolism of therapeutic drugs. Induction of
these enzymes would therefore be expected to alter the function of such drugs and
interfere with the treatment of diseases in humans. This possibility has been
clearly demonstrated in one experiment in which workers occupationally exposed to
Aroclor 1016 for the 2 years immediately before the experiment and to Aroclors
1242, 1254, and 1260 in earlier years were administered antipyrine, a prototype
drug substrate. The half-life pf the antipyrine in the plasma of the exposed
13
workers was approximately two-thirds of that observed in control subjects.
Another expected consequence of the induction of certain liver enzymes is an
alteration of the incidence of human cancer. Although the mixed-function oxidases
detoxify foreign chemicals in the body, they may also metabolize some of these
14
substances into more toxic or carcinogenic forms. However, it is difficult to
predict whether induction of these enzymes would have a net effect of increasing or
decreasing the incidence of cancer.
Induction of liver enzymes by PCBs could also result in alteration of the
overall metabolism of the body by altering the metabolism of the steroid hormones.
In addition, stimulation of the production of the enzyme delta-aminolevulinic acid
synthetase by PCBs has been demonstrated to cause porphyria and the accumulation of
porphyrins in the liver in rats, mice, and rabbits.
4. Effects on the Immunological System
Several experiments have demonstrated that PCB mixtures produce immunosuppres-
sive effects in laboratory animals. In one study, guinea pigs were fed Aroclor
1260 at 10 ppm in the diet for 8 weeks and received injections of tetanus toxoid to
stimulate antitoxin production by the lymphoid system. In comparison to controls,
PCB-treated animals exhibited reduced numbers of gamma-globulin-containing cells in
the lymph nodes as well as reduced serum gamma-globulin levels. Infant rhesus
monkeys dosed with 35 mg/kg of Aroclor 1248 for 4 weeks exhibited atrophy of the
10
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thymus. The same effect was observed in rhesus monkeys fed daily doses as low as 3
18
ppm of Aroclor 1242. In addition, decreased weight and atrophy of the thymus and
of the lymphoid system were observed in guinea pigs and rats administered oral
1 Q
doses of PCBs.
5. Mutagenicity
Whydam and co-workers demonstrated that 4-chlorobiphenyl is a potent mutagen
* 20
in the Ames test for bacterial mutagenesis. These workers also found that the
mutagenic activity of PCBs decreased with increasing chlorination and that the most
highly chlorinated mixtures had almost no activity.
In several studies, various doses of Aroclor 1242 and Aroclor 1254 were admin-
istered to rats and the chromosomes of the bone marrow and testicular cells of
these animals then examined for abnormalities. No significant increases in
chromosomal aberrations were observed in comparison with controls. In another
study, administration of these chemicals to rats did not appear to induce dominant
71
lethal mutations.
6. Effects on the Liver and the Stomach
The induction of hepatic microsomal enzymes and the causing of malignant
tumors of the liver by PCBs have already been discussed. Other adverse effects on
the liver have also been observed and are described here.
In one study, weaning rats fed Aroclor 1254 at 1 ppm in the diet exhibited
22
significantly increased liver weights. In another experiment, rats fed Aroclors
1248, 1254, and 1260 at 1000 ppm in the diet for 6 weeks were found to have hyper-
trophied livers weighing four times as much as those of controls. Abnormal ultra-
structural changes within the liver cells of the PCB-treated animals included
proliferation of smooth endoplasmic reticulum, development of large concentric
arrays of membranes, atypical mitochondria, and increases in lipid droplets.23
11
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In guinea pigs, liver damage has been observed at dosages of Clophen A60 (a PCB
mixture) as low as 250 ppm in the diet. Increased liver weight has been observed
O /
at doses down to 50 ppm.
Low oral doses of PCBs have resulted in stomach lesions in several species.
Dogs fed dietary levels of 1 ppm of Aroclors 1254 and 1260 and 10 ppm of Aroclor
1242 for 2 years suffered from stomach ulcers and nodules. Rhesus monkeys fed 2.5
ppm of Aroclor 1248 and 3 ppm of Aroclor 1242 in the diet developed stomach lesions
which were severe in some cases. Sows also suffered from stomach lesions after
being fed Aroclor 1242.25
7. Effects on Skin and Other Epidermal Tissues
Exposure to PCBs has resulted in various adverse effects on the skin and other
epidermal tissues in humans. Chloracne, a specific type of acne caused by certain
chlorinated hydrocarbon compounds, has developed among workers occupationally
O £L
exposed to air containing PCBs at levels as low as 0.1 mg/cu m. Skin lesions
similar to chloracne have been one of the major clinical signs observed in victims
of Yusho disease. In addition, Yusho victims have experienced eye discharges
caused by hypersecretion of the meibomian glands, swelling of the upper eyelids,
and hyperpigmentation of the skin, nails, and mucous membranes. It has been
estimated that Yusho disease has resulted from ingestion of PCBs in contaminated
27
rice oil at a rate as low as 67 yg of PCB/kg of body weight per day for 3 months.
8. Other Effects
•
Workers exposed to PCBs have experienced numerous other symptoms and adverse
effects, including digestive disturbances, Jaundice, impotence, dry or sore throat,
O Q
and headache. In addition, Yusho victims have suffered from abdominal pain,
menstrual irregularity, fatigue, cough, and disorders of the peripheral nervous
29
system.
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C. Effects on Wildlife
It is reasonable to expect that many of the adverse effects observed in lab-
oratory animals could also occur in wild mammals exposed to PCBs. Since, as dis-
cussed below, PCBs have a tendency to collect in waterways and bioaccumulate in
fish, fish-eating mammals such as otters, mink, and bears are particularly at risk.
t.
It has already been noted that mink fed PCB-contaminated fish suffered reproductive
I failure. Other adverse effects observed in exposed mink include increased mor-
-" 30
tality, enlargement of the liver, kidney, and heart, and reduced weight gain.
Many wild birds are probably also highly susceptible to PCBs. Several fish-
Bating birds, including two bald eagles, have been found dead with lethal quanti-
31
ties of PCBs in the tissues. Ring doves and American kistrels fed 10 ppm of
PCBs suffered from severe reproductive failure. In addition, birds exposed to PCBs
also exhibited induction of hepatic microsomal enzymes, porphyria, changes in
32
thyroid activity, abnormal behavior, and increased susceptibility to viral disease.
The various PCB mixtures are highly toxic to several aquatic invertebrates and
fish at extremely low concentrations. Aroclors 1248 and 1254 impair reproductivity
of Daphnia magna at concentrations as low as 0.48-1.0 ppb. Aroclor 1254 is toxic
to several types of shrimp at levels of approximately 1 ppb. Substantially increased
mortality of the fry of sheepshead minnows resulted from exposure to water contain-
ing 0.16 ppb of Aroclor 1254. It is thought that PCB levels of only a few parts
per trillion in Lake Michigan may be responsible for the reproductive failure of
several species of fish in that body of water. There is also strong evidence that
. PCBs at concentrations below 1 ppb may adversely affect aquatic insects and crusta-
33
ceans.
Concentrations of Aroclors 1242, 1016, and 1254 as low as 0.1 ppb have been
demonstrated to depress photosynthesis in phytoplankton and to reduce the rate of
13
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cell growth and division in these organisms. These effects are very significant
since the productivity of the entire marine ecosystem may depend on the productivity
34
of the phytoplankton within it.
D. Toxicity of PCDFs
Polychlorinated dibenzofurans (PCDFs) are found in small but variable quan-
tities as impurities in most PCB mixtures. In addition, PCDFs can be formed.by
photodegradation of PCBs in the environment. At present, it appears impossible to
differentiate the toxic effects of PCBs from those of PCDFs. Consequently, it is
necessary to regulate the commercial PCB mixtures with recognition that part of
their toxicity may be attributable to unavoidable contaminants.
E. Toxicity of PCB Metabolic Products
A number of studies have shown that PCBs are biodegraded into even more toxic
metabolites. For example, it has been demonstrated that tetrachlorobiphenyl, which
is a substantial component of several major commercial PCB mixtures, is transformed
into toxic intermediate byproducts, including arene oxides and dihydrodiols. These
substances have been found to cause cancer, mutations, and other toxic effects.
F. Relative Toxicity of the PCB Mixtures
PCBs are usually sold commercially as mixtures of biphenyl molecules with
varying degrees of chlorination. Aroclors 1016 and 1242 have relatively low
chlorine content, whereas the chlorine content of Aroclor 1254 is relatively high.
It has been argued that the less highly chlorinated mixtures and components may be
less toxic and hazardous than the more highly chlorinated mixtures, and therefore
the regulation of the former should be less stringent. This argument was con-
sidered in great detail at public hearings before EPA on Toxic Pollutant Effluent
07
Standards for PCBs and was rejected by the Administrator. There were several
bases for not establishing separate standards for the different PCB mixtures. It
14
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was determined that all PCB mixtures then in use, including the less chlorinated
ones (e.g., Aroclor 1016), are capable of inducing severe toxic effects at low
\
levels in mammals and aquatic organisms. In addition, the compositions of the
different PCB mixtures change and may become more similar after release into the
-environment, so that it would make no sense to regulate the mixtures under different
standards. Furthermore, important components of all the mixtures, including the
. t
.-less chlorinated ones, are highly persistent. Finally, while the less chlorinated
components of the PCB mixtures are not stored in tissues as efficiently as the
more highly chlorinated molecules, even the less chlorinated commercial mixtures
have substantial amounts of components that are subject to significant uptake and
38
storage.
Inability to Establish a "Safe" Level of Exposure for PCBs
Th>: available data indicate that PCBs may cause several adverse effects in
humans, mammals, birds, and aquatic organisms at extremely low concentrations.
Therefore, for all practical purposes, exposure of humans and other animals to any
level of PCBs should be deemed significant. This is especially true in light of
the demonstrated carcinogenicity of PCBs. EPA has adopted the view that "safe" or
"threshold" levels for carcinogens cannot be established given the present state of
39
scientific knowledge. This policy has been upheld by the Federal courts in
several decisions.
.,. Exposure of Organisms to PCBs
A. General
The purpose of this section is to discuss how PCBs released anywhere into the
environment may eventually become widely distributed, with the result that many
organisms, including man, may become exposed. This section also summarizes some of
15
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the data indicating that PCBs are already widely distributed throughout the physical -
environment and the biosphere and that this environmental burden is not likely to
become reduced in the near future because of the persistence of these chemicals.
B. Overview of PCS Transport in the Environment
Before presenting a detailed analysis of the manner in which humans and the -
general biota might be exposed to "free" PCBs (i.e., PCBs which have been released
into the environment), it is first necessary to determine the processes by which -
free PCBs are distributed throughout the three compartments of the environment—
air, land, and water. A number of processes affect the nature of this distri-
bution. Once a PCB substance has entered a physical compartment, it may be dis-
persed throughout that compartment. In addition, each compartment may have sinks
wherein free PCBs may be rendered physically unavailable to the biota or may be
^raded by chemical or metabolic processes. Finally, a more or less continuous
interchange of PCBs between the three compartments might be expected. The general
41
nature of these processes is illustrated schematically in Figure 1, and a summary
of the possible sources, sinks, and exchange processes is given in Table 1.
It should be pointed out that the processes described in Figure 1 and enu-
merated in Table 1 are theoretical possibilities that apply to any environmental
pollutant. Which of these processes play an important role in the environmental
transport of PCBs is determined by the specific chemical and physical properties of
the PCBs as well as the characteristics of each of the compartments. In view of
this, the physical and chemical properties of the PCBs are discussed next in order
to lay the proper framework for a more detailed discussion of the transport of the
PCBs.
16
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13
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C. Environmentally Relevant Properties of the PCBs
The PCBs are a group of compounds, some 209 in number, that are prepared by
the partial chlorination of biphenyl to yield a complex mixture of the chloro-
biphenyls in the form of high boiling point liquids of moderate viscosity. The
environmentally significant physical properties of several of the commercial mix-
v
. tures (Aroclors) are presented in Table 2. The properties of the PCBs that have
t taade them so commercially attractive include low water solubility, low affinity for
water (high lipid solubility), a high degree of chemical stability, and very low
. vapor pressure at ambient temperatures. A more detailed discussion of the rel-
evance of these properties to the environmental hazard posed by the PCBs is pre-
sented in the following sections.
1. Chemistry of the Chlorobiphenyls
The chlorobiphenyls have been demonstrated to undergo a number of chemical
reactions. Both oxidation and hydrolysis of these chemicals can be carried out,
but only under conditions that are considerably more rigorous than would be found
•
in an environmental situation. Another class of reactions to which the PCBs are
susceptible is that of cyclization. Of particular interest is the cyclization of
2,2'-dichlorobiphenyl, which yields the compound dichlorodibenzofuran. The oral
LD of the dibenzofuran for rats is approximately 250 mg/kg, whereas the LD..Q for
the chlorobiphenyl is in excess of 4000 mg/kg.
As discussed below, it is thought that transport as a molecular species or as
sorbed material on airborne particles is the major route of widespread transport of
. PCBs. ° Since such processes would cause the PCBs to be exposed to ultraviolet
radiation from the sun, considerable attention has been directed to the photo-
chemical stability of the PCBs. A number of effects have been reported, including
partial dechlorination and even, in some cases, the formation of very viscous
19
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48
semisolida apparently arising from some complex polymerization processes. The
environmental significance of these observations is difficult to assess since the
solvents usually used in these studies were hydrocarbons rather than water.
The hydroxylation of the PCB molecule is the first step by which organisms
• * 49
metabolize this chemical. Once the target chlorobiphenyl has been hydroxylated,
. f there appears to be a wide variety of species-specific addition processes that can
make use of the hydroxylated molecule. In this context, the failure to detect
. chlorodibenzofurans suggests that metabolic processes are not available to cyclize
the PCBs. The further observation that the residual body burden of PCBs usually
consists of only the more highly chlorinated PCBs suggests that the higher the
level of chlorination, the more resistant to metabolic processes.
Several of the PCBs with relatively low chlorine content are readily metab-
oiized by direct hydroxylation by both animals and microorganisms. Consequently,
52
di- and trichlorobiphenyls are not very persistent. On the other hand, the
highly chlorine-substituted PCB molecules are apparently not metabolized at all.
In addition, these species of PCB are not easily excreted because of their very low
aqueous solubility and high lipid solubility. As a result, these species tend to
5T
accumulate in exposed animals.
2. Physical Properties of the PCBs
As indicated in Table 2, the PCBs and their technical mixtures are charac-
*
terized by low water solubility, low vapor pressure at ambient temperatures, and
. very high octanol/water partition coefficients.5 The significance of the com-
bination of low water solubility and high octanol/water partition coefficient is
that when organic matter is exposed to an aqueous solution of PCBs, there is a
strong tendency for the latter to be preferentially taken up by the organic mat-
ter. -"5 Consequently, when animals are exposed to aqueous solutions of PCBs, the
21
-------
lipids of these animals will preferentially take up and store the PCBs. Since
there is usually little metabolic activity in lipid bodies, the stored PCBs are, in
some measure, protected from metabolic degradation. Therefore, larger and larger
t.
body burdens may be built up after continued exposure. It is this mechanism that
accounts for the very large bioaccumulation factors that have been reported.
In general, the volatility of a solute from a solution is governed by the
vapor pressure of the (pure) solute at the given temperature and the mole fraction -
of the solute in the solution. However, in those cases where there is either a
heat of mixing or a change in volume on mixing the solvent and the solute (nonideal
solutions), the volatility of the solute is not simply proportional to the molar
58
concentration of the solute in the solution. In those cases, it turns out that
the lower the ultimate solubility, the greater the effective molar concentration.
Thus, the volatility of the solute is significantly higher than would be expected
for the given vapor pressure and the actual molar concentration. This phenomenon,
which is known as codistillation, is responsible for the very short volatilization
half-life of PCBs in water as illustrated in Table 2. Codistillation from water
is thought to be a major route of entry of PCBs into the atmospheric reservoir
and is believed to be responsible for the worldwide distribution of these substances.
D. Transport of PCBs in the Environment
This section discusses the mechanisms by which PCBs are transported from each
compartment of the environment to the others.
1. Atmospheric Compartment
A number of investigators have determined that PCBs are very widespread in the
atmosphere both as molecular species and as adsorbed species on particulates and .
£0 '
aerosols. The mean air concentration of PCBs at several locations in Sweden
22
-------
was found to range from the detection limit of 0.8 to 3.9 ng/m . The highest
detected level was 12.5 ng/m . In the United States, levels were found to range
O £ O
from 1 to 50 ng/m . Over the Atlantic Ocean the airborne concentration was
determined to range from 5 ng/m near the northeast coast to 0.05 ng/m at a dis-
tance of 2000 miles from the coast. Numerous sources of airborne PCBs have been
identified, including the incomplete incineration of PCB-containing materials
(e.g., sewage sludge), volatilization of PCBs from paints and plasticizers,
codistillation from surface waters that are PCB contaminated, and direct vola-
68
tilization from PCB end uses and spills.
Various writers have pointed out that the atmospheric reservoir of PCBs is the
principal route by which the worldwide distribution of PCBs has occurred. Thus
the principal effect of the atmospheric reservoir is to serve as a mechanism for
the dissemination of PCBs to the other compartments of the environment.
2. Terrestrial Compartment
The most significant sources of free PCBs in the terrestrial compartment of
the environment include discarded consumer end use products that contain PCBs,
atmospheric fallout, and spills associated with the use of or the transport of
PCBs.72
For that portion of the free PCBs that is confined to terrestrial sites, the
primary mechanisms for dispersal are volatilization and solubilization by ground or
* surface waters. Since the vapor pressures of the typical PCB preparations (Aroclors)
-2 -^ ' 73
lie in the range of 10 to 10 mm Hg at ambient temperatures, the loss rate by
direct volatilization should be very small even in the absence of significant soil
binding. It is possible, however, that under certain conditions the heat produced
by oxidation of organic materials in a landfill could raise temperatures signi-
ficantly and thereby substantially increase the volatization of PCBs located in the
fill.
23
-------
PCBs are soluble in water so that direct solubilization by percolating waters
is a possible mechanism for the admission of these substances into the ground
waters. As an example, the limiting solubility of Aroclor 1254 in water is about
54 ppb , and the average rainfall on the continental liiited States is about 34.5
in. per year. It therefore follows that, with the normal long percolation time,
ry
the losses into the local ground waters could be as high as 0.04 g/m /year in a
region where PCBs have been landfilled.
In addition to solubilization, PCBs may be removed from land and enter the
aquatic compartment by surface water runoff. This latter effect is of great concern
in areas where contaminated oils have been used on highways or where land spills of
PCBs are possible. There is no direct evidence that PCBs are degraded by soil
microflora.
3. Aquatic Compartment
Figure 2 illustrates the nature of the processes that are involved in the
transport of PCBs to and from a body of water. It illustrates that the principal
PCB inputs to a body of water are contaminated inflowing streams and the PCBs that
precipitate from the atmospheric reservoir. An example of the significance of the
inflowing streams is given in a recent report which indicates that detectable PCB
levels were found in some 40 percent of a total of 900 industrial effluent streams
78
that were tested in Michigan. An earlier estimate indicated that as much as 1
ton of PCBs was entering the Clyde River in Scotland per year as a component of
crude sewage sludge from the Glasgow district. In addition, as noted above, PCBs on
land may enter the aquatic reservoir as a result of solubilization and surface water
runoff.
It has been demonstrated that the PCBs have a high affinity for soils in soil-
79
water systems but that these same hydrosoils may serve as a reservoir for resolu-
tion when the PCB concentration in the sediments becomes sufficiently high.
24
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Airborne
Fallout
Inflowing
Contaminated
Screams
Volatilization
WATER BOOT
SEDIMENT STORAGE
TERRESTRIAL
BIOTA
Figure 2
Model of Sources and Sinks for a Body of Water
In addition, when contaminated sediments are disturbed (as, for example, in river
. scour), some of the PCBs may be resuspended either in actual solution or as sorbed
material on resuspended solids. The processes associated with desorption from a
sorbent may also tend to fractionate the components of the commercial PCB mixtures
in favor of the more soluble components. In general, it is believed that the
material that is sorbed onto the sediments is eventually removed by migration to
the deep ocean depths. Thus, the sediments constitute a sink and, most probably,
the principal sink for the removal of PCBs from the environment.
25
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Measurements of the PCB concentrations in the sediments in the Hudson River
81
above the General Electric outfall indicated levels ranging from 0.0 to 16.3 ppm.
At Thomson Island, about 1 mile downstream, typical sediment levels ranged up to
o o
3700 ppm, with the PCB levels in the overwaters ranging from 0.06 to 3.0 ppm.
Fish collected within 1 mile of the General Electric outfall indicated PCB levels .
83
ranging from 78 ppm in minnows to 350 ppm in rock bass. Striped bass sampled near
West Point (well over 100 miles downstream of the GE outfall) had PCB residuals of
between 1.16 and 7.54 ppm.
The magnitude of the PCB losses through the process of volatilization (co-
distillation) is not fully established, but there is general agreement, as noted
above, that this process is of significance in the detailed mass balance for an
aqueous system and that volatilization from the air/water interface is a principal
85
source of the atmospheric reservoir of PCBs.
E. Exposure to PCBs
1. Current Environmental Load of PCBs
It has been estimated that between 300 and 400 million pounds of PCBs entered
the general environment up to and including 1975. Of this total, it is estimated
that some 25 to 30 percent is free material and thus constitutes the reservoir from
Q £
which exposure of the biota might occur. The remainder of the environmental
load, mostly in the form of industrial waste and discarded end use products, is
believed to be in landfill sites and thus constitutes a potential source of new
free PCBs. It is further estimated that, at any given time, approximately one-third
of the nonterrestrial free PCBs are in the atmospheric reservoir, while the remaining
87
two-thirds are in the aquatic reservoir.
2. Exposure of Organisms to the Terrestrial Reservoir of PCBs
As pointed out above, the largest portio;n of the terrestrial reservoir of PCBs
QQ
remains in the discarded PCB-containing products that are contained in landfills.
26
-------
The average soil concentration of PCBs taken in nonlandfill areas has been found
Q Q Q/"J
to be below detection level. A recent report indicates that only 0.1 percent
of the soil samples analyzed showed detectable PCB levels. Sixty-three percent of
91
the contaminated samples were from urban areas. It is not clear whether any
substantial exposure of the biota to the terrestrial reservoir of PCBs occurs.
3. Exposure of Organisms to the Atmospheric Reservoir of PCBs
Inhalation and dermal contact by humans and other animals are two possible
modes of exposure to the atmospheric reservoir of PCBs. Although measurements
taken at widely separated points have shown that there is a detectable level of
PCBs in most air samples, the observed levels are mostly close to the limits of
detection except in the vicinity of PCB sources. If the estimated atmospheric
load noted above were uniformly distributed throughout the atmosphere, the concen-
tration of PCBs in the air would be approximately 5 ng/m .
4. Exposure of Organisms to the Aquatic Reservoir of PCBs
The rather complex relationship between the aqueous phase, the biota, and the
sediments is illustrated in Figure 2 by the interconnecting lines in the figure.
The biota incorporate PCBs either by direct sorption from the contaminated waters
or through the food chain relationship between the benthic organisms living within
the contaminated sediments and the free-swimming organisms. There can be little
doubt that the direct pickup of PCBs from the surrounding waters is a major route
by which these compounds enter the biota. A large number of marine and freshwater
species have been demonstrated to take up PCBs selectively from surrounding water
and concentrate these compounds at levels many times higher than those in the water.
93
The phenomenon is known as bioconcentration. A typical example is the reported
bioconcentration of PCBs by the fathead minnow by a factor of 230,000.
At the present, there is considerable disagreement as to the role played by
the process of bioaccumulation (the selective retention of PCBs entering the
organism via contaminated foods) in the contamination of aquatic organisms.
27
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However, this process is apparently the major source of PCB contamination of terrestrial
animals that feed upon aquatic organisms. This relationship is illustrated by the "-
right-hand side of Figure 2. It should be noted that terrestrial animals may have sig-- 1
nificantly higher concentrations of PCBs in their tissues than the aquatic forms they - -
feed on. for example, while cod and pike have been found with PCB levels on the order
of 10 mg/kg of extractable fat, fish-eating birds such as herring gulls and cormorants » ,
have been found with levels of 600-700 and 400 mg/kg of extractable fat, respectively."
It appears that biocentration of PCBs by aquatic organisms is the principal
route by which these compounds enter the biota. However, as just noted, the impact
of this route of exposure is not limited to aquatic species. Man as well as fish-
eating terrestrial animals and birds also may be adversely affected. Fish con-
stitutes a substantial part of man's diet. Therefore, the concentration of PCBs in -
fish gives man the choice of either giving up an important food source or subjecting
himself to the adverse effects of PCBs. In addition, man may be exposed to lower
levels of PCBs by drinking contaminated water.
F. Present Distribution of PCBs in the Environment
This document has shown that the additional release of PCBs into any of the
environmental compartments may be expected to result in widespread distribution
into all three compartments and in the eventual exposure of large populations of
• M
wildlife and man. This conclusion is further supported by the fact that PCBs are
already widespread in the physical environment and in the biosphere. •>
QA
Since the earliest identification of PCBs in fish samples, literally thou-
sands of environmental and ecological samples from all over the world have been
analyzed and reported. For example, PCBs have been identified in Antarctic ice
95 •
samples from depths as great as 5.5-6 meters. Sea and air samples taken in the
Sargasso Sea showed PCB levels on the order of I ng/m in the air samples and up to
28
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10 ng/1 In the sea samples. Approximately 75% of human adipose tissue samples,
taken from 31 persons in the United States in 1973, showed PCB levels ranging from
97
1 to greater than 3 ppm. Polar bears, sampled as indicators of the top tropic
level in the arctic and sub-arctic food chains, have been shown to have PCB levels
98
of up to 8 ppm (wet weight in fat). Seals taken from a variety of Canadian
99
waters show levels of from a few ppm to a high of 52 ppm. In addition, PCBs have
been detected, frequently at high levels, in a large number of fish and bird species
100
inhabiting widely separated geographic areas. These samples, which are by no
means all-inclusive, indicate that PCBs are a global problem.
G. Conclusions
PCBs have been demonstrated to cause a number of severe adverse effects on
m.'^v living organisms at very low concentrations. As a practical matter, it is not
possible to determine a "safe" level of exposure to these chemicals. Because PCBs
are already widely distributed throughout the biosphere, they presently pose a
significant risk to the health of man as well as that of numerous other living
things. As a consequence, any further increase in levels of PCBs in the biosphere
is deemed unacceptable by EPA. It has also been demonstrated that PCBs released
anywhere into the environment will eventually enter the biosphere. Therefore, as a
corollary, EPA has determined that any such release of PCBs must be considered
"significant."
29
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IV. DEFINITION OF PCS MIXTURE
This proposed rule for the implementation of the TSCA bans on the manufacture,
processing, distribution in commerce, and use of PCBs covers all mixtures containing
50 ppm or greater of PCB chemical substance. The rule also proposes to revise the
definition of PCB mixture in the PCB Disposal and Marking Rule, which was promul-
gated on February 17, 1978 (43 FR 7150). That rule defines a PCB mixture to be any
mixture which contains 500 ppm or greater of PCB chemical substance. However, for
the reasons discussed below, that level was subsequently determined to be too high
to adequately control PCBs under Section 6(e) of TSCA.
The definition of PCB mixture was formulated to include within the scope of the
rule commercial products which intentionally contain PCBs and wastes contaminated
witi'i PCBs. Products intentionally containing PCB chemical substances include the
PCB cooling liquids in transformers, PCB dielectric fluids in capacitors, PCB hydrau-
lic and heat transfer liquids; the transformers, capacitors, and other systems which
use and contain these fluids; paints, adhesives, caulking compounds, rubber and
»
synthetic resins which contain PCBs as a plasticizer; inks, lubricants, cutting
oils, investment casting waxes; and any other products in which PCBs are used.
These materials may release PCBs during their manufacture, processing, or use
and can also expose the environment to PCBs upon their disposal.
Another category of materials which is intended to be within the definition of
PCB mixture includes items which do not intentionally contain PCBs but which are
contaminated as a direct result of the use or disposal of PCBs. These are items
such as soil, rags, other debris contaminated by a PCB spill; sludges from systems
into which PCBs have been dumped; oils to which waste PCB fluids or PCB-contaminated
fluids have been added; and equipment refilled with new fluid which has been con-
taminated by residual PCBs in the equipment or in the system used for the refilling
30
-------
operation. Also included are other organic compounds which contain substantial
amounts of PCBs as a result of an inadequately controlled manufacturing process.
The definition of PCS mixture has been modified so that commercial products,
byproducts, waste materials, and environmental media containing PCBs at levels
• well above those due to general environmental levels but below the 500 ppm concen-
" " tration promulgated in the Disposal and Marking Rule would be subject to regulation.
In prescribing a concentration at which regulation becomes operable, EPA has had to
. • consider the feasibility of controlling the introduction of PCBs into the environ-
ment. EPA has determined that the 50 ppm PCB concentration is a reasonable level
at which the Agency can feasibly begin to control PCBs entering the environment as
a direct result of the manufacture and/or use of PCBs or PCB-contaminated material.
Concentrations of PCBs below 50 ppm which enter the environment as a conse-
quence of background, or ambient, concentrations have been deemed not reasonable
or feasible to control. The definition of PCB mixture has been modified to exclude
low levels of contamination by PCBs which occurs merely as a consequence of exposure
to background levels in the environment. Due to the widespread use and the persis-
tence and ubiquitousness of PCBs, the chemical is present in detectable amounts
throughout the world. However, to control all PCBs in this regulation would be
impractical and unreasonable. Examples of such contamination are sludges which
2
do not have an identifiable source of PCBs but which contain low PCB concentrations.
Moreover, EPA has the authority to regulate these low PCB concentrations under other
•v t
statutes. This proposed regulation would not preempt those statutes.
The proposed definition of PCB mixture would also exclude certain organic
compounds (e.g., chlorinated organic compounds) which may contain trace amounts of
, PCBs despite the use of carefully controlled manufacturing processes. A facility
might emit exhaust gases which have a measurable concentration of PCBs, or the PCB
31
-------
concentration may be attributable to the PCB concentration in the ambient air which
is taken into the facility for use in the plant's process.
If the rule were carried to the extreme and anything containing a detectable
amount of PCBs were included within the definition of PCB mixture, practically
every object, material, waterway, and organism would be subject to the processing,
use, distribution in commerce, and disposal and marking regulations.
To prescribe a PCB concentration below which the rule will not apply is not
inconsistent with the Administrator's determination that any exposure to PCPs is
"significant." EPA recognizes that it would be unreasonable to regulate back-
ground concentrations of PCBs. The rule is intended to control those PCB activities
which are primarily responsible for contaminating other materials and for creating
background PCB levels. It is only these PCB activites which the rule can or should
address.
Obviously, a wide range of PCB concentrations occurs in various types of mix-
tures. PCB products and those materials to which PCBs are intentionally added
will have very high concentrations of PCBs and are within the scope of the rule.
R>r example, the fluids in electrical transformers may be 60 to 70 percent PCBs.
i
Those materials directly contaminated as a result of the use or disposal of PCBs
will generally exhibit high PCB concentrations, but low PCB concentrations are not
uncommon. Refilled hydraulic systems which formerly contained PCBs have been
measured with between 6,000 ppm of PCBs to concentrations below the level of
detection. Fbod packaging made with PCBs contaminated by recycled paper has been
found to contain from trace levels (<0.02 ppm) to 53.9 ppm of PCBs. Soil samples
taken near a PCB-manufacturing facility and a facility using PCBs decreased from »
over 20 ppm to 0.001 ppm as distance from that facility increased from less than
32
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1/4 mi?.e to over 1 mile. It appears that the lower end of the range of direct
contamination overlaps the higher end of the range of background contamination.
However, contamination caused by background concentrations would be very unlikely
to reach the high levels of PCBs that directly contaminated mixtures do.
Background levels of PCBs in municipal sewage treatment sludge have been found to
range from an average of 15.6 ppm of PCBs in some areas to approximately 1 ppm in -
__ others. Ocean water in the North Atlantic averaged 35 ppt of PCBs, and uncon-
8
taminated freshwater levels of PCBs are found to be in the 0.5-ppt range. PCB
• levels in the Hudson River, measured at points above any industrial discharge,
range between 0.0 and 1.0 ppb, while immediately below a PCB-using industrial
9
facility, PCB levels of 6,6 to 6,700 ppm were measured. However, these back-
ground-level exposures are not realistically controllable and are intended to be
exc'-ided from the rule.
The 50 ppm PCB concentration has been chosen to represent the level at which
EPA can regulate PCBs. EPA believes that it would be technically impossible and
administratively unreasonable to establish a separate level to define each type
of PCB mixture or PCB exposure.
During the development of the rule for the disposal and marking of PCBs, it
seemed that a reasonable level for regulation was 500 ppm of PCB. However, in view
of information outlined below, which was acquired after the proposal of that rule,
' it appears that the 500-ppm level is too high by a factor of 10. There is not an
extensive amount of data on PCB levels in municipal sewage sludge. However, studies
which have been done indicate that concentrations of PCBs are normally less than
500 ppm. Surveys of persistent organic chemicals in municipal sludges of 10 U.S.
cities have shown that PCB concentrations normally range between 10 and 30 ppm.
-A study at Cornell University analyzed municipal sewage sludges of 16 American
cities for 68 elements, dieldrin and PCBs. Levels of PCB ranged from less than
-------
0.01 ppm to 23.10 ppm.11 In 1976, EPA's Office of Solid Waste (OSW) in Region I
conducted an analysis of samples of sewage treatment sludge for three types of PCS
in five cities. The nine samples taken exhibited levels of PCB ranging from "not
detected" (normally less than 1 ppb) to 74 ppm—the one sample which contained more
12
than 50 ppm PCB. Another study undertaken by OSW measured PCB levels in sewage
*
sludges applied to agricultural lands around nine cities. In the 38 samples taken-,
PCB levels ranged from less than 0.01 ppb to 5872 ppb (5.9 ppm). A 1976 survey by
EPA of 10 cities in the Northeast found levels of PCB in sewage sludge ranging from
less than 0.001 ppm to 1.18 ppm. EPA's Regional Office in Kansas City sampled the
municipal sludges of 36 cities in that region for pesticides and PCBs. Only five
cities had PCBs above the level of detection and levels ranged from 2.3 ppm to 99.1
ppm, although the latter was the only one to exceed 37.9 ppm. It is assumed from
th* studies cited that the PCB levels found to be above 50 ppm are associated with
the known PCB-using activities in the area, and that the numerous other samples which
have PCB concentrations well below 50 ppm represent the results of background levels.
It was learned in testimony from the industry that similar levels (a maximum of
approximately 25 ppm of PCBs) are present in chlorinated organic compounds. The
ambient level of PCBs appears to be much lower than had been believed. Similarly,
it was found that exposures to PCB concentrations below 500 ppm do occur as a
result of direct action. Many such sources are controllable and should be within
the scope of this rule. For example, hydraulic systems that once contained PCB
hydraulic fluids may be drained and refilled with non-PCB fluid. The new, non-PCB
fluid may become contaminated from residual PCBs and, even though the PCB concen-
tration in this fluid does not reach 500 ppm, this fluid would represent a potential
problem if it were spilled or otherwise improperly used or disposed of.
It appears from the information summarized above that a more appropriate
concentration for regulation is 50 ppm of PCBs. Since the rule for the disposal
-------
and marking of PCBs has been promulgated with a definition of PCB mixture at 500
ppm, there would be an inconsistency if this rule contained a different definition.
The result would be restrictions on uses of certain materials, but no control
whatsoever with respect to their disposal. To correct this inconsistency, a new
definition of PCB mixture, at 50 ppm of PCB, is proposed for this rule and for the
disposal and marking rule. The result will be that all appropriate provisions of ~
. both rules will apply to all mixtures with PCB concentrations of 50 ppm or more.
35
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V. PCB SUBSTITUTES*
The following is a discussion of substitutes available or in the process of
development for PCB dielectric fluid used in capacitors and transformers. This
discussion of substitutes is intended as a brief summary. Inclusion or omission of
any substance in this discussion should not be construed as an indication of EPA
approval or disapproval of its use.
A. Capacitors
1. Phthalate Esters
Dioctyl Phthalate (DOP) has been used in capacitors manufactured in Japan since
1974. It is presently being used in most of the capacitors manufactured in the
United States.
Advantages of DOP are: (1) the cost is approximately one-half that of PCB; (2)
DOP is now available as a substitute since it is currently used as a plasticizer for
polyvinyl chloride; and (3) its dielectric constant is 5.3, similar to that of PCB.
Disadvantages of DOP are: (1) the maximum service temperature of capacitors
containing DOP is 85°C, as opposed to 95°C for PCB; (2) the corona inception voltage
is lower than that of PCB but can be raised by the addition of trichlorobenzyne to
the mixture.
Diisononyl phthalate is a potential substitute for PCB. It is manufactured by
Exxon under the tradename Enjoy 2065 and is not available in large quantities.
Diisononyl phthalate is similar to DOP, although it is more stable chemically.
A
The information on substitutes for PCB capacitors and transformers was primarily
based on data contained in the Versar study, PCBs in the United States: Industrial
Use and Environmental Distribution. Some of the facts in that study have been
updated based on a review by Versar of this discussion of substitutes. Information on
Uniroyal PAO-20E was provided by the Uniroyal Chemical Company.
36
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The flash points for OOP and diisononyl phthalate are relatively high (220° for
OOP), yet both of these phthalate esters are more flammable than PCBs. It should be
noted that a particular class of phthalate esters, the alkyl phthalates, were rec-
2
ommended for testing by the TSCA Interagency Testing Committee.
3
2. Alkylated Chlorodiphenyl Oxide
Butylated monochlorodiphenyl oxide is marketed by Dow Chemical Company under the
.tradename XFS-4169L. Based on four years of testing, McGraw-Edison, a capacitor
manufacturer, has found this material (which they tradenamed EDISOL) to be a "viable
* substitute" for PCBs in high voltage power capacitors. Although the dielectric
constant of EDISOL is somewhat lower than that of PCB (4.5 versus 5.85), the size of
EDISOL capacitors marketed by McGraw-Edison is the same as PCB capacitors at equal
KVAR ratings.
vlvantages of butylated monochlorodiphenyl oxides are: (1) a lower loss-tangent;
(2) a higher corona inception voltage than PCB by 20 to 30 percent; (3) a higher
flash point (174°C). Advantages of this substitute vis-a-vis toxicity are that it
(1) is more biodegradable than trichlorobiphenyl; (2) has been shown to be non-
mutagenic in an Ames test; (3) has a lower bioconcentration factor than PCB; (4) has
a lower adipose concentration than PCB; and (5) does not show chloracnegencity.
Disadvantages of butylated monochlorodiphenyl oxide are: (1) the higher mate-
rial costs, and (2) a lower fire point (199°C) than that of PCB.
B. Transformers
4
1. Fluorocarbons
Certain fluorocarbon compounds have properties similar to PCBs. Fluorocarbons
are highly volatile in comparison to PCB, and they are about six times as expensive.
37
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Perfluoroethane is extensively used as a dielectric gas in totally enclosed gas
filled transformers, which can be used to replace PCB transformers in certain hazar- ~ •"-
dous locations.
2. Silicones
Low viscosity silicone fluids, on the order of 50 centistokes, are possible
substitutes for PCBs in transformers. They are produced by General Electric, Dow
Corning, Union Carbide, and SWS Silicones. Polydimethyl siloxane, a potential
substitute, has the molecular structure:
CH3 CH3 CH3
H,C Si 0(—Si—0—) Si CH,
CH d "cH
Silicone fluids have the special advantage of a relatively temperature-
independent viscosity. The silicone fluids have somewhat poorer heat transfer
characteristics than askarel but can be substituted directly for askarel in existing
transformers, resulting in only a small decrease in the transformer rating.
Electrical Properties;
Dielectric Constant 2.72
Dielectric Strength 200 volt/mil
14
Resistivity 7.1 x 10 ohm-cm
Dissipation Factor 1.8 x 10 at 100 Hz, 23°C
Polydimethyl siloxane has a higher flash point than conventional, non-PCB trans- "
former coolants: 280°C for mineral oil (PCBs have no true flash point). The heat of
combustion of 50-centistoke polydimethyl siloxane is lower than that of mineral oil—
7.67 kcal/gm versus 11.0 kcal/gm—and since the Silicones burn more slowly, they are
considered poor fuel.
38
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On the Underwriters Laboratories' fire-hazard classification (in which water is
rated as 0 and ether as 100) polydimethyl siloxane is classified as 4 to 5, which is
slightly higher than the 2 to 3 rating given to PCBs, but is considerably less than
the mineral oil rating of 10 to 20.
These compounds do not biodegrade, as measured by sewage sludge breakdown to
C0_. However, there is evidence that they partly depolymerize to low molecular
weight compounds upon contact with soil and water. Since ultraviolet light decom-
poses methyl silicones, sunlight exposure may be the mechanism for environmental
degradation.
No tendency for bioaccumulation or bioconcentration has occurred in experiments.
In mammals the compound is not absorbed through the gastrointestinal tract or the
skin.
The PCB substitute developed by Dow Corning for transformers is called DC561.
This is a mixture of polydimethyl siloxanes of various chain lengths which have a
viscosity of 50CS. The literature on environmental and health characteristics of
silicones refers to at least six fluids, most of which are probably similar to the
DC561, but some of which could be other mixtures with certain additives. By neces-
sity, the usefulness of published toxicological data depends on the validity of the
assumption that all of these compounds have identical persistence, bioaccumulation,
and toxicity properties.
A review of toxicological studies of silicones reported the following results:
Dietary Toxicity:
LD5Q (rats) >28 gm/kg
Extended Feeding Tests:
Guinea pigs—47 gm/kg/day for extended period—no toxic effect.
Mallard ducklings and bobwhite quail—5000 ppm for 5 days—no effect.
39
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Rats—20 gm/kg/day for 28 days—no effect.
Rats—190 mg/kg/day for 90 days—no effect level.
Beagle dogs—300 mg/kg/day for 120 days—no effect.
Mice—3 percent in diet for 80 weeks—no effect.
Man—FDA allows silicones as food additives at up to 10 ppm.
The major deficiency in knowledge of the silicones appears to be in their fate
in the environment and the toxicity of their breakdown products.
The silicone transformer fluids currently cost up to twice as much as PCBs on a
volume basis.
Dow Corning has completed evaluation of polydimethyl siloxane as a high voltage
insulating fluid. They report, though, that a near term 100 percent replacement of
PCBs in transformers by this fluid is not possible. If a transformer market were to
de >elop for polydimethyl siloxane, the present domestic capacity could be adequate to
supply new transformers. The time lage for a 100 percent replacement of PCBs in
transformers by polydimethyl siloxane would be on the order of 5 to 10 years.
3. Mineral Oils6
Mineral oils are widely used in transformers. The flash point of mineral oils
is a function of its molecular weight. Since crude petroleum can be refined to have
any required molecular weight over a wide range, it is possible to specify any parti-
cular flash point that is desired for the minimal oil transformer liquid. This
approach has been taken by RTE Corporation in the development of their proprietary
transformer liquid, which has the tradename RTEmp.
RTEmp is a highly refined paraffinic mineral oil that has a flash point of
285°C, approximately the same as the 50CS silicone liquid proposed by Dow Corning as
a PCB substitute. To achieve this higher flash point, the oil is refined to have a
40
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higher molecular weight and consequently a higher viscosity, which reduces its
effectiveness in convective cooling.
The major current advantage of the high flash point mineral oils is their low
price relative to silicone and askarel and their inherent biodegradability and low
toxicity.
4. Synthetic Hydrocarbons
Certain mixtures of synthetic hydrocarbons may result in a liquid having the
high flash point characteristics of RTErap or silicone combined with a relatively low
viscosity and satisfactory heat transfer characteristics. Examples of synthetic
hydrocarbons being tested as PCB substitutes include FR Dielectric Fluid manufactured
by Gulf Oil Chemical Company and PAO-20E.
Q
PAO-20E produced by Uniroyal Chemical was designed for use in transformers.
Its dielectric strength (KV/0.25 cm) is 50, and its dielectric constant is 2.15, as
compared with 40 and 4.3, respectively, for PCB. It has a flash point of 276°C and a
fire point of 307°C. Its acute oral LD5Q (rats) is over 40 mg/kg.
41
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VI. REASONABLE USE DETERMINATIONS
The intent of Section 6(e) of the Toxic Substances Control Act (TSCA) is to ban
activities using PCBs in a nontotally enclosed manner. However, the Administrator
may authorize the manufacture, processing, distribution in commerce, and use of PCBs
in a nontotally enclosed manner. For such an authorization to be granted, the Adminis-
trator must make a finding that each activity authorized will not present an unreason-
able risk of injury to health or the environment [TSCA, Section 6(e)(2)(B)]. Since
the intent of the law is for PCB activities and their uses to be banned, it must
clearly be evident that an activity is not unreasonable. In the absence of such
clear evidence, an activity is banned.
Section 6(c)(l) of TSCA contains the factors which EPA considered in determining
whether a PCB activity conducted in a nontotally enclosed manner is reasonable or
unreasonable. In addition to the effect of PCBs on human health and the environment,
the other factors that were considered are summarized below:
1. The likelihood, magnitude, and nature of exposure of human beings or
the environment.
2. The availability and characteristics of substitutes for the particular PCB
activity.
3. The economic significance of the activity, including its importance to
the national economy, small business, technological innovation, the environ-
ment, and public health.
Only if a ban on a nontotally enclosed use activity would cause major and
extensive economic disruptions would EPA consider granting a limited authorization
for that activity.
42
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A. Transformers r •.'•,/•.•"•• •
1. Manufacture of PCS Transformers
As of June 1977, only one transformer manufacturer produced transformers filled
with PCB fluid. That firm stopped producing these transformers in late 1977. No
other transformer manufacturer has any PCB fluid in inventory., Transformers without
2
PCBs presently account for about 98 percent of those in use. Since no one is either
. manufacturing or planning to manufacture PCB transformers, the absence of an author-
ization for that activity will have no economic impact.
•
2. Transformer Servicing
Servicing of PCB transformers falls into two general categories: 1) routine
servicing of functioning transformers, and 2) rebuilding failed transformers. Routine
servicing can be performed by either the owner of the transformer or a contractor.
There are two distinct types of owners of PCB transformers: public utilities and all
others. Utilities are more likely to consistently perform routine maintenance than
the other users, who almost exclusively own small transformers.
PCB transformers rarely fail. If nothing warrants a more frequent inspection,
3
utilities will generally check a PCB transformer once every 3 to 5 years. Routine
maintenance includes taking a sample of the internal fluid to determine its moisture
content as well as other physical properties. The fluid may be filtered through
Fuller's earth to cleanse it of impurities and then returned to the transformer.
» *
. Filtering increases the expected life of the transformer and also provides an indica-
... tion to the owner of the condition of the transformer, particularly with respect to
failure.
Inspection of the exterior of the transformer takes place at more frequent
intervals. External servicing is performed when gaskets leak. If a gasket below the
43
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internal liquid level leaks, the internal liquid must be drained below the level of
the gasket so that'it can be repaired. When this operation is performed, the PCB
fluid is pumped out of the transformer into a closed container and returned after the
repair is completed.
The average failure rate for large utility transformers is approximately 0.2
4
percent per year ; however, smaller transformers fail more frequently because of poor
servicing procedures. Rarely will a transformer fail such that PCB liquid is spilled
from the transformer. When transformers fail, they are removed and sometimes rebuilt.
•
The rebuilding process includes draining the internal liquid, removing the coils,
rewinding the coils, and refilling the transformer. Since owners and contractors
prefer not to handle PCB fluid or PCB articles, rebuilding is less frequently per-
formed. Rebuilding is universally regarded as a messy operation and one which results
in great exposure of both humans and the environment to PCBs. Most failed trans-
formers are now taken to a disposal site. In fact, many working PCB transformers are
now being removed from service because owners do not want to incur the liability of
servicing them.
During routine servicing, exposure occurs when the liquid is removed or fil-
tered. Exposure could be either direct through contact with spilled liquid or
through handling of contaminated equipment. Air emissions occur when the liquid
sample is taken unless a closed system is used. If the fluid is filtered, the
filter media must be disposed of. During disposal, exposure to both humans and the
environment can result. In addition, solid waste is created in the form of rags and
other materials used to clean PCBs from different surfaces. Should additional
liquid be required to replace that lost due to spillage, sampling, or filtration,
humans and the environment may be further exposed to PCBs.
44
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Exposure during rebuilding is much greater because of the nature of the opera-
tion involved. Liquid must be drained from the transformer. The coils, which are
saturated with PCB fluid, are removed, cleaned, and reworked, and the transformer is
t!.,en refilled. The original fluid must be disposed of properly, and some disposal
method must be found for the old coils. There is no enclosed method of performing
these operations, and the result is exposure of humans and the environment to large
quantities of PCBs. It appears that PCBs end up as air emissions, water discharges,
and solid waste from this process. The actual extent of this exposure is not known;
i
however, the amount of liquid involved in a large transformer is considerable. In
Idition, the coils are disposed of separately instead of remaining in the casing, as
would be the case if the transformer were simply drained and disposed of. Disposal
r •' th 5 coils would probably result in greater environmental exposure since the coils
a -,- saturated with PCBs and would be directly exposed to the environment.
There are three generally available substitutes for PCB transformer fluid:
mineral oil, siloxanes, and RTEmp fluid. Mineral oil has been in use for many years
and is generally accepted by transformer users. Mineral oil is usually required in
larger quantities than are PCBs; however, the mineral oil is substantially cheaper
than PCB fluids. The service life of mineral oil is shorter than for PCB fluids, and
it cannot be used in circumstances where there is a danger of fire.
Siloxanes are a more recent substitute for PCBs. They appear to be between
mineral oil and PCBs in their physical properties. The most recent substitute for
PCBs is RTEmp. Its manufacturer claims properties superior to both mineral oil and
siloxanes, at a cheaper cost than either. All of these substitutes are commonly
available, and the only impediment to their use is the standard delivery time for new
transformers, 18 months. Mineral oil transformers have been found to require more
-------
servicing than PCB transformers, but the service life of siloxanes and RTEmp has not
yet been determined. No evidence has yet developed of any health or environmental
risks associated with the use of these substitutes.
Option 1
The prohibition of routine servicing of transformers and the rebuilding of
transformers.
Discussion
This option provides for minimum exposure, since routine servicing would not be
permitted. Any exposure resulting from the handling of liquid or rags of filter
media or sampling would be eliminated. Transformers would be contained in a closed
system from the time they left the factory until eventual failure and disposal.
However, there are high costs associated with this option.
If it is not possible to routinely check transformers, there is a good pos-
sibility that the rate of catastrophic failure could increase and that as a result,
both humans and the environment could be exposed to a large quantity of PCBs (an
average transformer contains about 2150 pounds of PCB mixture). At present, it is
exceedingly rare for a PCB transformer to fail in a manner such that the PCB liquid
inside is spilled outside the container. This is partially because of the nature of
the PCBs and partially because the routine servicing permits the owner to assess the
condition of the transformer and remove it from service whenever there is any possi-
bility of failure.
Furthermore, owners of transformers would experience additional problems due to
an increased failure rate of the transformers, Because routine preventive servicing
would not be permitted, transformers would fail with greater frequency. It is
expected that without routine maintenance, the failure rate of PCB transformers would
increase from 0.2 percent per year to 2-4 percent per year. This tenfold increase
46
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would increase the capital outlay required for replacing transformers by about the
same amount. This means that about $15 million would be spent each year to replace
transformers that otherwise would not have failed. In addition, there will be
increased costs associated with the expected increase in failures that result in
..liquid losses. These costs would include cleanup labor costs, paperwork costs, and
legal costs, as well as the cost of replacing the failed transformer.
2
Permit the routine servicing of transformers but prohibit the rebuilding of
•
tr?nsf ormers.
Discussion -
Rebuilding transformers would be banned because of the extensive exposure
resulting from this activity. However, failure to perform routine servicing on
tr formers may lead to catastrophic failures and therefore extensive and hazardous
exposure to PCBs. The risks associated with catastrophic transformer failure far
outweigh the relatively small risks associated with servicing transformers.
The major economic impact of this option would be the closing of the PCB trans-
former rebuilding industry, which represents a very small percent of all transformer
rebuilding. The replacement of failed transformers with new transformers instead of
rebuilt transformers would impose an additional cost on the transformer owner. This
additional cost should not be burdensome. In addition, it appears that many owners
•3
are replacing PCB transformers with new transformers instead of rebuilding them.
«,- This trend would further reduce the economic impact of this option.
Option 3
Permit the continued routine servicing and rebuilding of transformers.
Discussion
This option would cause no adverse economic impact for either the transformer
owner ; or the transformer rebuilding industry. However, this option would permit
47
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the continuation of practices which result in large exposures of humans and the
environment to PCBs.
Decision
Option 2 was chosen since exposure risks will be greatly reduced without creat-
ing a severe adverse economic impact. EPA believes that although there is some
exposure to PCBs during routine servicing, this exposure is very small and does not
pose an unreasonable risk, particularly in light of the extensive and hazardous
exposure that will occur when a transformer fails because it has not been serviced.
Allowing existing transformers to remain in use and permitting routine servicing
vMjld prevent a substantial economic loss to transformer owners. Rebuilding of
transformers whose fluid contains 500 ppm or greater will not be authorized. EPA has
found that the extensive exposure associated with the rebuilding activity poses an
un i -sonable risk. Moreover, EPA believes that no undue economic burden will be
placed on transformer owners by not authorizing rebuilding.
B. Railroad Transformers and Self-Propelled Cars
Background
There are 1009 transformers containing PCB fluid which are utilized in railroad
o
locomotives and self-propelled cars. The equipment is used exclusively in the
9
Northeast by AMTRAK, Conrail, and five intracity transit authorities.
Transformers in these applications are known to be a servicing problem because
of the design limitations imposed by space requirements, in addition to the shock,
vibration, and mechanical impacts encountered in service. Thus, leakage of PCBs
resulting from punctures or overheating of the transformer while in use is not an
unusual occurrence.
48
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The leaked PCBs are frequently discharged into well-drained roadbeds, causing
serious exposure of the environment to PCBs. Clearly, the use of railroad trans-
formers presents a substantially higher risk than use of their stationary counter-
parts.
There are several alternatives with respect to controlling the risk associated
with use of railroad transformers:
1. Replacement of PCS transformers with non-PCB units. This would be extremely
expensive ($50,000-$185,000 per transformer), and considerable lead time would be
necessary.
2. Draining, flushing, and refilling PCB transformers with a substitute dielect-
ric fluid. This option is much less expensive ($5,000-$15,000 per transformer),
but there are questions with respect to the technological feasibility of this process.
The Federal Railroad Administration has sponsored research by Westinghouse and
General Electric (GE) to determine the feasibility of refilling existing PCB railroad
12
transformers with silicone. The performance characterization of a 418 KVA transit
car transformer which contained 168 gallons of askarel was compared with that of a
transformer filled with silicone after it had been drained, flushed, and refilled.
The results obtained by GE indicated that hot draining of the transformer
removed 85 percent of the askarel, and that circulating hot silicone through the
"ransformer for 288 hours reduced the residual askarel to 107 pounds. The rate of
'residual askarel leaching into the silicone was found to be diffusion limited. The
operating temperature of these transformers was 9.7°C hotter with silicone than with
askarel. No conclusions were drawn as to whether the silicone-filled transformer
would have satisfactory long-term performance.
A similar procedure was performed by Westinghouse on a different transformer of
the same age and model. The transformer was initially flushed with mineral spirits,
49
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followed by circulation with silicone. The report concluded that there was no reduc-
tion in operating performance when using silicone.
Westinghouse has succeeded in reducing the PCB concentration below detectable
levels at least temporarily. Dow Corning.1 s results, reportedly using Westinghouse's
approach, have been very promising but seem to reach a lo«rer concentration limit even
with multiple filtration using fresh filters. Nor is there any evidence yet that the
lower levels achieved by filtration can be maintained in operations without periodic
refiltration.
Dow Corning has a joint development project with Transformer Consultants of
Akron, Ohio, and DC Filter & Chemical Inc. of Sandusky, Ohio, assisted by the Westvaco
13
Chemical Division of Covington, Virginia. The third phase of the project, using a
fujl-size transformer (a GE 1967 building substation unit) began in November 1976 and
shows very promising results:
Date
After refill* 11-05-76
2 months 01-05-77
6 months 05-06-77
9 months 08-17-77
After filter cleanup (8 hr)** 09-16-77
Resampled 10-25-77
After 5 hr on 6 filters 11-10-77
After 1 additional hr on 3
replacement filters 11-10-77
Percent PCB
0.7
2.22
2.33
2.53
0.43
0.615
0.0677
0.0472
*With Dow Corning 56i Silicone Transformer Liquid (180 gallons).
**Six Brute filters (120 #WV-G Carbon).
50
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Option 1
No authorization for use or servicing of the equipment.
Discussion
It would be impossible to immediately replace all railroad transformers. A ban
"against the use of PCB railroad transformers would cause massive economic and social
disruption in the Northeast United States with an adverse impact on the nation's
« •
- "economy.
Option 2
Phase out PCB railroad transformers by requiring refilling to lower the PCB
level to 5 percent PCB over a 5-year period and replacement of the transformers over
a 10-year period.
Economic Impact
14
Annual costs to the railroads will be:
1978-1981 1982-1987
$6.5 million $5.2 million
Thus, the total cost by the end of 1987 would be $57.2 million. These costs are
based on the assumption that replacement transformers will be available as needed and
that the total cost of replacement is due to the regulation.
Replacement transformers are available with a 21- to 30-month lead time.
Therefore, it is necessary that flexibility be built into the replacement schedule.
~*
By requiring that 30 percent be replaced by the end of 1980 and 10 percent per year
*" each year thereafter, the necessary lead time for orders is available under this
option.
There do not appear to be any employment costs to railroads, although there
could be some additional employment requirements in railroad service shops. Record-
keeping and monitoring the concentration of PCBs will require additional expenses,
but these will be minor compared with costs of replacing transformers.
51
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Option 3 - •
Phase out the use of PCBs in railroad transformers by authorizing the use of
PCBs in the following concentrations:
1. 40,000 ppm of PCBs starting 15 months after the effective
date of the rule.
2. 1000 ppm of PCBs starting 36 months after the effective date of
the rule.
This would offer the railroad transformer owners a choice—to replace the PCB
transformers with a non-PCB unit, or to refill existing transformers with either non-
PC.3 fluid or fluid which has been filtered through carbon.
Assuming the railroads will choose the latter (less costly) option, the total
annual cost to railroads would be:
Amount Timing
Cost of retrofill program $7,043,000 1979
Cost of processing program 5,200,000 1980-1982
Final analysis for PCBs 100,000 1983
Reporting 5,000 1979
Spill prevention plans 20,000 1979
Total $12,368,000
Decision
Option 1 was rejected because of the massive adverse economic impact that would
-esult. Option 2 was rejected because, although environmentally effective, it would
require the replacement of transformers before the end of their normal lifetime of
over 30 years. Option 3 was chosen since it would allow the continued use of equip- , .,
ment while substantially reducing the PCB levels in that equipment. Option 3, while
not requiring the equipment's replacement, would achieve a significant reduction in
possible environmental exposure and allow for the eventual removal of virtually all
PCB contamination from the transformers through refilling and filtration.
52
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C. Mining Machinery
Background
There are -two types of mining machinery containing PCB fluids—loaders and
continuous miners. In both types the fluid functions as a nonflammable coolant which
_also lubricates bearings for large alternating current electric motors. The moving
parts of the motors are totally immersed in the fluid, which by convection and conduc-
. tion carries heat from the electrical windings to the external surfaces of the motor
casing.
There are approximately 533 loaders and some 652 PCB cooled loader motors which
are currently operable. For continuous miners there are 18 machines and 46 motors
currently operable. Each loader uses two motors, and each continuous miner uses
three motors.
One firm, Joy Manufacturing Company, has been the sole manufacturer of mining
machinery which utilizes PCB-filled motors as part of its equipment. Joy dis-
continued production of loaders using PCB-filled motors in early 1973; continuous
miners have not been produced with PCB-filled motors since 1970. Production of these
units was discontinued because of the PCB environmental issue.
Although mining equipment using PCBs is no longer manufactured, Joy does provide
service and repair for equipment. The steps undertaken in servicing a failed motor
are:
-I
1. Opening
v- ' 2. Draining of PCB fluid
3. Degreasing of internal parts
4. Cooking of case
5. Burning out of insulation
6. Rewinding, reassembling, and filling
53
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All of these operations are carried out in an open area, with the fumes vented to the
atmosphere through the roof by exhaust fans. It is estimated that from 1 to 5
percent of the total PCB volume in each motor could be lost during this maintenance.
The motors in the loaders require rebuilding every 18 to 24 months. Motors in
the continuous miners are operated under heavier loads and require rebuilding every
12 weeks. Rebuilding, from the time the motor is removed from service until the time
18
the machine is put back into service, usually requires 1 to 2 weeks.
Normal operation of mining machinery causes losses of PCB fluids by overflow as
a result of overfilling and subsequent leaking and expansion of the fluids. The PCB
fluid lost in the operation of the equipment in the mines is replaced by operators in
the field.
Quantities of PCB used in this machinery vary, depending on the type of motor.
Loaders have two motors, each using 4 gallons of PCB fluid. Continuous miners have
three motors, holding either 4 or 5 gallons of PCB fluid.
New motors using non-PCB liquid coolant could be installed in all the machinery.
However, no non-PCB motors are currently available. The PCB motors on the loaders
can be replaced with air-cooled motors. The present motors can also be rebuilt to be
air-cooled. This cannot be done with the continuous miners because of space limita-
tions. The cutting head on most of the miners can be replaced with one which does
not use PCB-cooled motors. The only other alternative is to cease using the machin-
ery and replace it with new pieces of equipment.
A procedure for refilling the continuous miner motors has been developed; how-
ever, it is understood that the PCB content of the fluid in the motors is in the
19
range of 100 to 500 ppm. Also, there is a controversy as to possible fire hazards
associated with operating continuous miners that have been refilled with a non-PCB
fluid.
54
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Equipment not using PCS fluid accounts for around 99 percent of the miners and
85 percent of the loaders currently in use. All currently produced mining machinery
contains air-cooled motors.
Option 1
No authorization for use or maintenance of PCB mining equipment.
Discussion
There are many costs associated with replacing the 652 PCB-cooled motors on the
70
loaders. It costs $6,258 to replace each motor." The total cost for the motor
replacement would thus be $4.1 million. If it is assumed that new motors could be
sispplied at the same rate as are conversion kits (30 per month after 6 to 8 weeks),
it would take 24 months to supply enough motors to complete all the conversions.
Delivery of the first motors could not take place for 6 to 8 months after an order is
21
received. The loaders would be out of commission for an average of 12 months,
resulting in lost coal production. In addition, 3,700 jobs would be affected ini-
tially, with the number declining as the loaders were converted.
Joy has been converting motors in the loaders to air-cooled motors. There are
currently approximately 320 conversion kits, each valued at approximately $3100,
which would have to be scrapped. There are also higher maintenance costs associated
with using air-cooled motors. In addition to the overall costs listed above, some of
the individual mines dependent upon the loaders would be severely affected.
Replacing the cutting heads on the 18 "9 CM" continuous miners in use would cost
approximately $80,000 to $100,000 per machine. It is doubtful whether this would
be an economically viable alternative for an older machine which cost $120,000 when
it was new.
55
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The only other alternative for the continuous miners is scrapping the old
machines and buying new ones. New miners roughly comparable to those scrapped would
23
cost approximately $250,000 to $300,000. Replacing the 18 continuous miners cur-
rently in use would cost $4.5 million.
The loss of 290 loaders and 18 continuous miners would cause a curtailment in
coal production of around 150,000 tons per day assuming a production of 250 tons per
shift, 2 shifts per day. If this production rate is assumed to occur 5 days per
week, 50 weeks per year, this would be equivalent to 38 million tons per year, or in
the range of 5 to 10 percent of the nation's annual coal production. The value of
the lost production, at $20 per ton, would be around $3 million per day. In addition
to lost revenues and reduced coal production, the jobs of the miners who work on the
involved sections would be affected.
Option 2
Authorize servicing and use of the equipment in a nontotally enclosed manner
until December 31, 1981, with certain conditions: the motors in the loaders will be
converted to dry operation as they are serviced, and the continuous miners will be
converted to non-PCB operation as they need rebuilding beginning 12 months after the
effective date of the rule.
Discussion
i-t /
It costs $3,100 excluding labor to convert each motor in a loader to dry
operation, for a total cost of $2 million. Since the economic life of the loader
equipment will continue for many years, the cost of eliminating PCBs from the equip-
ment must be incurred before the equipment is at the end of its lifespan. Conversion
at normal maintenance intervals will enable a smooth transition from PCB motors
without disrupting coal production, as would probably occur with a conversion period
of less than 3 years.
56
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Replacing the cutting heads on the continuous miners would cost approximately
$80,000 to $100,000. Since these machines cost $120,000 each when new, it is doubt-
ful that this would be an economically viable alternative for a machine owner.
Thus, the machines would be replaced in lieu of PCS motor replacement only. New
continuous miners cost approximately $250,000 to $300,000. Because continuous miners
with PCB motors are very near or at the end of their economic lifetime, their value
» •
is relatively small. The order time for a continuous miner is currently as long as 6
months, and it is estimated that a large number of orders made at once in response to
g.
this rule would only marginally affect delivery lead times. Therefore, beginning the
phase-out of this equipment twelve months after the effective date of the rule would
allow for a smooth transition if new equipment must be ordered and would not cause an
interruption of coal production.
Decision
Option 2 was chosen. Option 1 would cause severe economic disruption, while
Option 2 allows for conversion as quickly as possible without causing equipment to be
idle for long periods. Therefore, this option balances the environmental effects
with economic impact and eliminates this use of PCBs as soon as possible without
causing economic disruption on a large scale.
D. Hydraulic Die Casting Systems
PCB fluids are contained in a large number of hydraulic systems used in die
.casting. PCB' fluid is used in such systems because of high-temperature stability and
fire resistance. In 1972, when PCB hydraulic fluids were no longer available, the
users had to switch to substitute fluids. Since the substitutes were compatible with
the PCB fluids, the machines were not drained and flushed but were simply topped-off
as required with the new fluid. Topping-off generally requires adding new fluid at
7 f\
"the rate of 2-10 times the system capacity per year.
57
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When hydraulic system owners were made aware of the environmental hazards
associated with PCBs, many of these owners drained and flushed their machines and
refilled them with non-PCB hydraulic fluid. The success of refilling varied con-
siderably as shown in the following table.
27
PCS Levels in Drained & Flushed Hydraulic Systems
. i
Company PCS level (ppm)
Cast Forge Co. 80
Caterpillar Tractor Below detection limit (systems " * *
are drained twice a year)
General Motors 100-500
Outboard Marine 90-6000 (currently average 500)
There are several sources of PCB contamination at these facilities. The high
operating temperatures cause vaporization of the hydraulic fluid during use, and as
a result, PCBs are emitted to the ambient air around the plant. The inherent leaking
of these systems, characterized by the large amount of topping-off required, results
in water effluent and solid waste (e.g., rags and cleaning agents). Because of the
contribution to ambient levels of PCBs, several studies have been conducted of these
facilities by regional offices of EPA.
Option 1
Require the disposal of all die casting machines that have used PCB hydraulic
fluid. ,f
Discussion
This option would remove PCB-contaminated equipment from use and would thereby
drastically reduce the environmental contamination resulting from the continued use
58
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of these machines. These machines, however, represent a very large capital invest-
ment by their owners. The removal of these machines would create problems for their
owners not only because of the amount of capital lost, but because of the loss of
production during replacement and the length of time required to replace each
machine. It is presumed that from time of order to time of replacement would be at
least 6 months.
» •>
. Option 2
Hydraulic fluid in die casting machines with a PCB concentration greater than 50
*
ppm would be replaced with fluid with no more than 50 ppm within 1 year of the
effective date of the rule. The fluid would be checked every 6 months to test the
PCB concentration; fluid with a 50-ppm or greater PCB concentration would have to be
filtered or replaced.
i .uasion
This option would significantly reduce the environmental contamination from the
use of these machines and would eventually reduce the concentration of PCBs in the
hydraulic fluid to very low levels. It has been suggested that such a procedure will
not be able to reduce the hydraulic fluid to a low-level PCB concentration. However,
the experience of Caterpillar Tractor shown in the table above would seem to provide
ample evidence that such a goal is well within reach of the other companies owning
systems. General Motors has stated that the cost of this operation would be about
.$9.40 per gallon of hydraulic fluid. This is broken down as follows:
•v Cost per gallon of
Item fluid replaced ($)28
Solvent 2.26
New hydraulic fluid 7.57
Disposal 0.57
Total 9.40
59
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Option 3
This option would place no requirement on the owners of these machines based on
the presumption that the high flushing rate that already exists as a result of the
high leakage will eventually reduce the PCB concentrations to acceptable levels.
Discussion • >
This option would impose no additional cost on the companies that use hydraulic
>-.«...
die-casting systems. As described above, the refilling rate on these machines is •-
approximately two to ten times their capacity every year. The results show that
4
there has been some reduction of PCB concentrations, and it can be expected that
these levels will continue to drop. However, some systems have not achieved the same
levels as others, and this might be explained by possible reuse of the leaked hydrau-
lic fluid. For those systems with existing high levels, it could be quite some time
before they achieved a PCB concentration of 50 ppm or less.
Decision
Option 2 has been chosen because it does not require that companies with these
systems suffer large capital losses. PCB concentrations in the hydraulic fluids will
be reduced. This will result in a reduction in PCB emissions to the environment.
The Caterpillar Tractor experience in reducing PCB concentrations in the hydraulic
fluid is evidence that substantial reductions in PCB contamination levels can be
achieved. Costs will be imposed on companies operating these systems, but they will
c-
not be continuing costs since the PCB concentration should drop below 50 ppm in less
than 5 years. *-
E. Carbonless Copy Paper
Prior to 1971, carbonless copy paper distributed by NCR Corporation was made
with ink containing PCBs. There does not appear to be a way of distinguishing PCB
60
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carbonless copy paper from non-PCB carbonless copy paper, with the possible exception
of dates or other indications in unused inventories. A large portion of the PCS
carbonless copy paper that has not been destroyed is probably in files. The proposed
rule authorizes the use of PCB carbonless copy paper for the following reasons: (1)
,. the inability to readily distinguish between PCB and non-PCB carbonless copy paper;
(2) the enormous undertaking that would be required of both business and government
» w
- to purge files of PCB carbonless copy paper, even if a way to distinguish it from
non-PCB carbonless paper were devised; and (3) the small amount of PCB on each piece
i
of carbonless copy paper. In addition, paper recyclers have for some time been
careful not to accept any carbonless copy paper for recycling.
61
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VII. WASTE OIL
Sealants, coatings, and dust control agents made from waste oil are often con-
taminated with PCBs, and because of their particular uses, these PCBs are quickly
introduced directly into the environment. For example, waste oil is frequently used
as a coating for roads, which have well-drained surfaces and whose run-off frequently
goes to municipal treatment plants or rivers and streams. In addition, although the
PCB concentration is low, the large volume of oil that is used results in a large
quality of PCB entering the environment. Because the PCBs in waste oil can so easily
find their way into the environment through these uses, the EPA is proposing that
waste oil containing any amount of PCB contamination shall not be used as a sealant,
coating, or dust control agent. Waste oil containing less than 50 ppm may still be
ur s a fuel, as a feedstock for rerefining, or any other use except as a sealant,
coating, or dust control agent.
Approximately 1.3 billion gallons per year of used oil is collected for use as
road oil, fuel oil, rerefined hydraulic oil, and rerefined lubricating oil. Much of
the waste oil previously used in applications other than automotive lubrication has
been contaminated with low levels of PCBs. Dissipative uses of this contaminated oil
can introduce PCBs directly into the environment. These include the use of conta-
minated waste oil as a dust control agent, sealant, or coating. The PCB contami-
nation of the waste oil could originate from contaminated industrial hydraulic oil or
transformer oil or from PCB additives used in lubricating oils prior to 1973.
Unless there has been an unusual incident of contamination, normally the level
2
of PCB in waste oil should be well below 50 ppm. Examples of such incidents include
mixing oil with PCB dielectric fluids or with large amounts of PCB hydraulic fluid.
62
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The use of waste oil contaminated with any level of PCB as a dust control agent,
coating, or sealant is prohibited by this proposed rule. However, waste oil contami-
nated at levels below 50 ppm may still be used for such things as boiler fuel or
feedstock for rerefining.
If, as expected, virtually all use of waste oil to control dust on roads is
3
ended, 319 million gallons of waste will be diverted to fuel usage. Past users will
be forced to forego road oiling or use a substitute. The cost to users has been
estimated to be approximately $100 million annually if a synthetic substitute is
used. However, it is possible that the substitute may require application less
4
often.
Because of contamination above 50 ppm of PCBs, transformer oil will not be
available to collectors, initially reducing the total supply. However, transpor-
tation of the contaminated oil to chemical waste incinerators will be required and
could offer new market opportunities to the collectors.
Rerefiners should be operated at capacity and thus be more profitable as a
result of this proposed rule. Increased interest in the use of recycled oils and
rising oil prices should increase the market for all uses of waste oil.
Those industries whose waste oil contains more than 50 ppm of PCBs will incur
disposal costs of $0.0832 per pound. Waste oil containing less than 50 ppm of PCBs
can be mixed with virgin oil for use in industrial boilers.
63
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VIII. FOOTNOTES
I. BACKGROUND
1. Microeconomic Impacts of the Proposed PCS Ban Regulations, Versar, Inc.,
Chap. 1.
2. Microeconomic Impacts, Chap. 1.
III. SIGNIFICANCE OF THE RELEASE OF PCBs INTO THE ENVIRONMENT
1. World Health Organization; "Environmental Health Criteria 2: Polychlor-
inated Biphenyls and Polychlorinated Terphenyls"; pp. 43-44.
2. World Health Organization; "Environmental Health Criteria 2: Polychlor-
inated Biphenyls and Polychlorinated Terphenyls"; pp. 44-45.
3. EPA; Toxic Pollutant Effluent Standards - Standards for Polychlorinated
Biphenyls (PCBs), Final Decision; (Hereinafter referred to as EPA Final
Decision); 42 Fed. Reg. 6537-8.
4. EPA Final Decision; 42 Fed. Reg. 6538.
5. EPA Final Decision; 42 Fed. Reg. 6537.
5a. Bahn, Anita K., "Report on Paulsboro, N.J., Mobil Oil Plant Study"
(unpublished, University of Pennsylvania School of Medicine, April 27,
1976).
6. NIOSH; Criteria for a Recommended Standard: Occupational Exposure to
Polychlorinated Biphenyls (PCBs); (Hereinafter referred to as NIOSH
Criteria); 65.
7. NIOSH Criteria; p. 98.
8. NIOSH Criteria; pp. 98-99.
9. EPA Final Decision; 42 Fed. Reg. 6535.
10. EPA Final Decision; 42 Fed. Reg. 6535.
11. EPA Final Decision; 42 Reg. 6535-36.
12. EPA Final Decision; 42 Fed. Reg. 6536.
13. Alvares, Alvito P. et al.; "Alteration in Drug Metabolism in Workers
Exposed to Polychlorinated Biphenyls"; Clinical Pharmacology and Ther-
apeutics; 22:140-145 (1977).
14. EPA Final Decision; 42 Fed. Reg. 6536.
64
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15. EPA Final Decision; 42 Fed. Reg. 6536.
16. EPA Final Decision; 42 Fed. Reg. 6536.
17. NIOSH Criteria; pp. 73-74.
18. EPA Final Decision; 42 Fed. Reg. 6535.
19. NIOSH Criteria; pp. 74-75, 87.
20. Research Communication in Chemical Pathology and Pharmacology, 15:563-570
(1976).
21. NIOSH Criteria; p. 119.
22. EPA Final Decision; 42 Fed. Reg. 6537.
23. NIOSH Criteria; pp. 78, 81-82.
24. NIOSH Criteria; pp. 74-75.
25. EPA Final Decision; 42 Fed. Reg. 6537.
26. NIOSH Criteria; p. 54.
27. NIOSH Criteria; pp. 41-42.
28. NIOSH Criteria; pp. 49-53.
29. NIOSH Criteria; pp. 47-48; EPA Final Decision, 42 Fed. Reg. 6537.
30. EPA Final Decision; 42 Fed. Reg. 6535.
31. EPA Final Decision; 42 Fed. Reg. 6534.
32. EPA Final Decision, 42 Fed. Reg. 6534.
33. EPA Final Decision; 42 Fed. Reg. 6534.
34. EPA Final Decision; 42 Fed. Reg. 6534.
35. EPA Final Decision; 42 Fed. Reg. 6543.
36. EPA Final Decision; 42 Fed. Reg. 6542, 6533.
37. EPA Final Decision, 42 Fed. Reg. 6541-3.
38. EPA Final Decision; 42 Fed. Reg. 6541-3.
65
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39. E.G., See Health Risk and Economic Impact Assessments of Suspected Car-
cinogens: Interim Procedures and Guidelines, 41 Fed. Reg. 21402; Notice
of Intent to Suspend and Findings of the Imminent Hazard Posed by Regis-
tration of Pesticides Containing Heptachlor or Chlordane, 41 Fed. Reg.
7552, 7554.
40. E.G., See EDF v. EPA, 510 F.2d 1292 at 1298 (D.C. Cir. 1975); EDF v. EPA;
548 F. 2d 998 at 1006 (D.C. Cir. 1976).
41. G.E. Blau and W.B. Neeley, Advances in Ecological Research, 2, No. 133
1975); F.C. Whitmore, EPA Technical Report 560/6-77-006 (1977).
42. N. Nelson, Environ. Res., 5, 249 (1972) [pp. 349ff], "Report of the
Subcommittee on the Health Effects of PCBs", Dept. of HEW, Washington
D.C. (1976).
43. S. Hutzinger, S. Safe, and V. Zitko, The Chemistry of PCBs, CRC Press,
Cleveland, Ohio (1974).
44. Hutzinger, Safe, and Zitco*
45. Toxic Substances List, DHEW (1973).
46. A. Sondergren, Nature, CCXXXVI (1972), p. 395.
47. S. Hutzinger, S. Safe, and V. Zitko, "The Chemistry of PCBs", CRC Press,
Cleveland, Ohio (1974); Monsanto Industrial Chemicals Corp., Tech. Bull
0/PL-306A.
47a. D. Mackey and P.S. Leinonan, Environmental Science and Technology, 9
(1975), p. 1178.
48. T.H. Maugh, Science, 1180, 578 (1973); R.L. Metcalf et al.f "Proceedings,
National Conferences on PCBs", EPA-560/6-75-004 (1976), p. 243.
49. H. Yoshimura and H. Yamanto, Chemical Pharm. Bulletin, 21 (1973), p.
1168.
50. M. Berlin et al., Archive of Environmental Health, 30, (1975), p. 141.
51. "Background to the Regulation of PCBs," 1976. Canadian Task Force,
Technical Report 76-1. B. Jannson et al., Ambio 4 (1975), p. 93.
52. "Background to the Regulation of PCBs."
53. "Background to the Regulation of PCBs."
54. Hutzinger, Safe, and Zitko; Monsanto Industrial Chemicals Corporation,
Technical Bulletin, 0/PL-306A.
66
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55. J.L. Hemelink et al., Trans American Fisheries Society 100 (1971), p.
207.
56. A.V. Nebeker, "Proceedings, National Conference on PCBs," EPA 560/6-75-
004 (1976), p. 284.
57. K.. Denbigh, Principles of Chemical Equilibria, Cambridge (1955).
58. Denbigh.
59. D. Mackey and P.S. Leinonen, Environmental Science and Technology, 9
(1975), p. 1178.
60. A, Sondergren, Nature, CCXXXVI (1972), p. 395.
61. G.R. Harvey and W.G. Steinhauser, Atmos. Environment, 8 -(1974) , p. 777.
62. G. Lund, Ambio, 5 (1976), p. 207; C.E. Junge, Fate of Pollutants in Air
and Water Environments, Part L, I.H. Suffet, ed., Wiley, New York (1977).
63. Panel on Hazardous Substances, Environ. Res., 5, 249 (1972).
64. Harvey and Steinhauser.
65. F.C. Whitmore, National Technical Information Service, PB-258, 162
(1976).
66. PCBs in the United States, Industrial Use and Environmental Distribution.
67. Makey and Leinonen.
68. I.C.T. Nisbet and A.F. Sarofim, Environmental Health Prospectives (1972),
p. 1.
69. R.W. Risebrough et al., Nature, 264 (1976), p. 738.
70. PCBs in the United States, Industrial Use and Environmental Distribution.
71. F.C. Whitmore, National Technical Information Service, PB-258 162 (1976).
72. PCBs in the United States, Industrial Use and Environmental Distribution.
73. Monsanto Industrial Chemicals Corporation, Technical Bulletin 0/PL-306A.
74. R. Hague, D.W. Schmedding, and V.H. Freed, Environmental Science and
Technology, 8 (1974), p. 139.
75. The World Almanac, 1977, Washington Star-News, Washington, D.C.
76. R. Bartha and D. Pramer, Science, 156 (1976), p. 1617.
67
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77. J.L. Hesse, Proceedings, National Conference on PCBs, EPA 560/6-76-004
(1976), p. 127.
78. A.V. Holden, Nature, 228 (1970), p. 1220.
79. P.C. Oloffs, L.J. Albright, S.Y. Szeto, and J. Lau, J. Fish. Res. Board
of Canada, 30 (1973), p. 1619.
80. G.D. Veith and V.M. Comstock, J. Fish. Res. Board of Canada, 32 (1975),
p. 1849.
81. P. Moskowitz et al., Troubled Waters, Environmental Defense Fund, New
York (1977).
82. Moskowitz et al.
83. PCB Point Monitoring Program, New York State Department of Environmental
Conservation, Albany (1976).
84. PCB Point Monitoring Program.
85. Mackay and Leinonen.
86. PCBs in the United States, Industrial Use and Environmental Distribution
Task I Final Report, EPA Contract No. 68-01-3259; Working Group on Pesti-
cides, PB 197-144 (March 1970); I.C.T. Nisbet and A.F. Sarofim, Environ-
mental Health Prospectives, 1 (1972).
87. PCBs in the United States, Industrial Use and Environmental Distribution;
Nisbet and Sarofim; F.C. Whitmore, National Technical Information Service,
PB-258, 162 (1976).
88. PCBs in the United States, Industrial Use and Environmental Distribution.
89. A.E. Carey and J.A. Gowen, Proceedings, National Conference on PCBs, EPA-
560/6-76-004 (1976), p. 195.
90. J.L. Hesse, Proceedings, National Conference on PCBs, EPA 560/6-75-004
(1976), p. 127.
91. Hesse.
92. T. Murphy, Oral paper at the 10th Great Lakes Regional Meeting of the
ACS, 1976.
93. A.V. Nebeker, Proceedings, National Conference on PCBs, EPA 560/6-75-004
(1976), p. 284.
94. S. Jensen, New Scientist, 32 (1966), p. 612.
68
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95. R.W. Rlsebrough et al., Nature, 264 (1976), p. 738.
96. T.F. Biddleman and C.E. Olney, Science, 183 (1973), p. 516.
97. D. Ruopp and V.L. DeCarlo, Private Communication, 1977.
98. G.W. Bowes and C.J. Jonkel, J. Fish. Res. Board of Canada, 32 (1975), p.
2111.
99. Background to the Regulation of PCBs, 1976, Canadian Task Force Technical
Report 76-1.
100. Panel on Hazardous Substances, Environ. Res. 5 (1972), Background to the
Regulation of PCBs, p. 249.
IV. DEFINITION OF PCB MIXTURE
1. Risebrough, Robert W., "Recent Studies of Transport of PCBs to Marine
Environments", National Conference on Polychlorinated Biphenyls. Spon-
sored by: Environmental Protection Agency, Conference Proceedings, March
1976, p. 230.
2. Review of PCB Levels in the Environment, Office of Toxic Substances, EPA
560/7-76-001, January 1976, p. 105.
3. Microeconomic Impacts of the Draft PCB Ban Regulations, Versar, Inc.,
Chap. 10.
4. Testimony of Paul E. Corneliussen. In the Matter of Polychlorinated
Biphenyls in Paper Food-Packaging Materials, Dock No. 75N0013, Department
of Health, Education and Welfare, Food and Drug Administration, 1975.
5. Environmental Assessment of PCBs in the Atmosphere, The MITRE Corpora-
tion, for the Environmental Protection Agency, April 1976, p. 5-34.
6. Review of PCB Levels in the Environment, p. 105.
7. Review of PCB Levels in the Environment, p. 65.
8. Environmental Assessment of PCBs in the Atmosphere, p. 5-19.
9. Review of PCB Levels in the Environment, p. 58.
10. Review of PCB Levels in the Environment, 105.
11. Furr, A. Keith et al., "Multielement and Chlorinated Hydrocarbon Analysis
of Municipal Sewage Sludges of American Cities". Environmental Science
and Technology, Volume 10, Number 7, July 1976.
69
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12. "PCBs In Sewage Sludge", unpublished report under contract to USEPA,
Region I, Office of Solid Waste.
13. "Municipal Sludge Agricultural Utilization Practices—An Environmental
Assessment, Volume I", unpublished report under contract to USEPA Office
of Solid Waste.
14. USEPA Office of Solid Waste, unpublished data from EPA Environmental
Research Center, Cincinnati (1976).
15. Municipal Sludge Monitoring Survey, USEPA, Region VII, Kansas City, MO
(1977).
16. Testimony, Informal Hearing on the Disposal and Marking of Polychlor-
inated Biphenyls (PCBs) conducted by the Environmental Protection Agency
Volume II, June 27, 1977, p. 50.
17. Microeconomic Impacts of the Draft PCS Ban Regulations, Chap. 10.
V. PCB SUBSTITUTES
1. PCBs in the United States Industrial Use and Environmental Distribution,
EPA Contract No. 68-01-3259, February 25, 1976, pp. 230-231.
2. 42 FR 55026, October 12, 1977.
3. PCBs in the United States, pp. 232-233.
4. PCBs in the United States, p. 264.
5. PCBs in the United States, pp. 264-266.
6. PCBs in the United States, p. 267.
7. PCBs in the United States, pp. 267-268.
8. Contained in communications from R.A. Stengard of Uniroyal Chemical to
Peter P. Principe of EPA.
VI. REASONABLE USE DETERMINATIONS
1. Microeconomic Impacts of the Proposed PCB Ban Regulations, Versar, Inc.,
Chap. 1.
2. Microeconomic Impacts, Chap. 7.
3. Conversation with Robert Westin of Versar, Inc.
70
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4. PCBs in the United States Industrial Use and Environmental Distribution,
p. 103.
5. Conversation with A.J. Cutshall, Electrical Maintenance Supervisor,
Tennessee Valley Authority Power Service Shops.
6. Microeconomic Impacts Chap. 1.
7. Conversation with Robert Westin, Versar, Inc.
8. Microeconomic Impacts, Chap. 6.
9. Microeconomic Impacts. Chap. 6.
10. Microeconomic Impacts, Chap. 6.
11. Microeconomic Impacts, Chap. 6.
12. Microeconomic Impacts, Chap. 6.
13. "Removal of PCB from Dow Corning 561 Silicone Transformer Liquid by
Charcoal Filtration", Dow Corning Corporation, Midland, Michigan.
14. Conversation with Robert Westin of Versar, Inc.
15. Microeconomic Impacts, Chap. 6.
16. Microeconomic Impacts, Chap. 8.
17. Microeconomic Impacts, Chap. 8.
18. Microeconomic Impacts, Chap. 8.
19. Conversation with Robert Westin of Versar, Inc.
20. Microeconomic Impacts, Chap. 8.
21. Conversation with Robert Westin of Versar, Inc.
22. Conversation with Robert Westin of Versar, Inc.
23. Conversation with Robert WEstin of Versar, Inc.
24. Microeconomic Impacts, Chap. 8.
25. Conversation with Robert Westin of Versar, Inc.
26. Microeconomic Impacts, Chap. 10.
27. Microeconomic Impacts, Chap. 10.
28. Microeconomic Impacts, Chap. 10.
71
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VIII. WASTE OIL
1. Microeconomic Impacts, Chap. 13.
2. Microeconomic Impacts, Chap. 13.
3. Microeconomic Impacts, Chap. 13.
4. Microeconomic Impacts, Chap. 13.
5. Microeconomic Impacts, Chap. 13.
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