-------
T5HLS 7.3-2
Annual Cpgrg^'ing Posts for 0:n'|"^nuaat'3d. pi'l
Plant Capacity: 50Q. gal/Tir. (4,000 Ib/hr.l
Ceerating Factor: 7,300 beurs/year
Capacity: 3/650,000 gal/year ( 30/000/000 Ib oil/year)
Investment: $3,210,000
Cests:
Direct Ccerating Later, 2 aen/shift S $10/hr. $ 175,000
Supervisioi & Acoiaistratica S 30% of direct
operating lafccr -. 87,000
Activated Carfccn Systaa^ 122,000'
20% oi cacitaJL uwestaHOt 640,000
Pc«er: 100,000 SHH 8 3«?/SKH " 3,000
Sampling and 'analysis " . 100,000
^51,127,000
Fixed' Costs:
Setum on Invested Capital (10%) ' 321,000
Recovery (10 years 9 10%) . 321,000
"Haxes *r4 Insurance (4% of capital cost) 128,000
Total Fixed Costs $ 770/OOQ
Total Annual Costs . . $1,897,000
7^_^.-,.^.,^...^.. -.^....;...-- ....... $ .0632
Cost/cal. .osntaminatad oil-'-'. ---------- '--- $ .51
(1) This ^nr-ii-r»gg rsplacscsnt of 43,000 Ib/yr. of spent activated caricn and
incineration of the spent itaterial by a general purpose chsnical.waste
-44-
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the "PC3 Disposal Fegulaticns," The incineration ccst of $.0632 'per pound
of contaminated oil is similar to the lower bound estimates of- probable'^-
market prices reported informally by presently operating chemical waste in-
cineration catpanies. Transportation costs incurred in delivering the oil
to the incinerator would be about $.02 per pound based on costs previously
calculated for askarels,
Tne effect of the proposed regulations 'will be to require the in-
cineration of oil contaminated with PCEs. Control of the disposition and
use of used transformer oil will require the analysis of oil for PCBs.
Analysis of oil for PCBs will only be economically justified if . the- expected-
value of the savings in disposal costs if .the oil is r»t ^contaminated exceeds
the cost of analysis. For instance, it would ccst $75 to sample and analyze
the oil in a transformer that has a 45% expectation of being' contaminated
with PCBs at a concentration in excess of 30 ppm. The value of oil to the
transformer owner is zero if the concentration of" PCBs is less than 50 ppm
(i.e. , a commercial collector will be willing to pick it up and haul if away .
for free) . Disposal would cost $0.0832 per pound for transportation and in-
cineration if the oil is contaminated above 50 ppm..'' The expected savings
to be obtained by analyzing the oil would be equal to (0.0832/lb * number of
pounds of oil * probability the oil is- not contaminated 'with 'more than '50
ppm PCBs) minus the cost of the analysis. .Analysis is therefore a good in-
vestment for large transformers and those transformers less likely to be
contaminated with PCBs. -This relationship- .is presented in graphical form
in Figure 7.3-1.
CD Versar Inc., Microeconpniic Impacrs of the Proposed Marking and
Disposal aagulations for PCBs, (EPA Report No.' 56Q/6-77-Q13) ,
Springfield, Va.: NatSnaTlechnical Information Service (NTIS
No, PB-267 833/2WT1 April 26, 1977, pp. 3-19.
-45-
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100
I
T
cc
UJ
UJ
cc
e»
2
S
<==
0)
O
CC
o.
80 -
59
60 _^
45
40 -
32
20 -
SO 100 150 200 260
GALLONS OF OIL IN TRANSFORMER @ 8.1 lb/0al.
«
300
FIGURE 7.31 DECISION CRITERIA FOR ANALYZING TRANSFORMER
OIL FOR PCBs BEFORE DISPOSAL
-------
Although the average anoint of oil per transformer has been calcu-
lated to be about 250 gallons, no information is available on'the-distribution
of transformers by oil capacity. As a reasonable guess, the median trans-
former capacity might be 150 gallons. A lower bound estimate of ..the fraction
of transformers contaminated is 32%. At ***'« level, testing would be justi-
fied for approximately one-half of the oil filled transformers other than
pole mounted units. These larger transformers would account for perhaps
75% of the total oil. Incineration would therefore be the required disposal
method for all of the 25% of the oil in the small transformers and 45%.of .
the rest of the oil. The resulting analytical and disposal costs would then
be calculated as shewn in Table 7.3-3, below:
TREES'7.3-3
Testing and Disposal Costs for Transformer Oil
Assume: 32% of all transformers con-
'' . tain more than 50 ppra PCSs.
'Size- of Transformer
Number of transformers
Analytical Costs @ $75
Oil in transformers
Oil ream', ring incineration
Incineration cost 3 $.0832
> 150 gal.
2,500,000
$187.5 million
7.9 billion Ib.
2.5 -billion Ib,
$210 million
< 150 gal.
2,500,000
0
2.6 billion Ib.
2.6 billion li.
$215 million
Total analytical and incineration costs: $612.5 million
The upper bound estimate of the fraction of transformers that- are
contaminated was calculated to be 59%. At this level of contamination,
testing would be justified only for transformers containing irore than. 270
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gallons of oil. This criteria may- result in the testing of perhaps 20% of..
all transformers containing 50% of all of the oil. The calculation of .the
resulting analytical and disposal costs are surmarized in Table 7.3-4:
' ' 'TABES"7.3-4
Tasting and Disposal Costs for Transformer Oil
Assure: 59% of all transformers con-
tain more than 50 ppm FCEs.
Size of Transformer
Number of transformers
Analytical Costs @ $75
Oil in transformers
Oil requiring incineration
Incineration cost' <§ $.0832
> 270 gal,
1,000,000 '
$75 million
5.25 "billion Ib.
3.1 billion Ib.
$257 minion
< 270. gai.
4,000,000
0 . '
5.25 billion UD.
5.25 billion Ib,
$437 million
Total analytical and incineration costs: $769 million
By comparison, arbitrarily incinerating all 10.5 billion pounds of
possibly contaminated transformer oil would cost $380 million. Assuming
that no additional contamination of transformer oil by PCBs will occur, re-
placement of the oil in any contaminated oil filled transformer would be
expected to reduce the concentration-of -.residual -SC3s-. to- weil^unde-g-oO-'-ppms - -
The rate at which these disposal 'costs will be incurred depends" en
the rate of disposal of contaminated -transformer-oil. -The regulations do -
not prohibit the processing of- contaminated oil so long as it is returned to
the same transformer it was taken from. Processing losses are expected to
be low, so most of the contaminated oil would not be disposed of until the
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transformers are ratirad from service due to failure. If one-half of the ?C3
contaminated transformers will be scrapped or refilled with new oil within the
next twenty years, and the rate of such oil disposal dees not depend on the ace
of the transformers, the rats of disposal would be 3.4% per year (i.e., a
failure rate of 3.4% per year irolies a 20-year half life). Based on these
assumptions, annual analytical and disposal costs would be from $21.4
million to $26.1 million in 1979, and decrease in future years by 3.4% per
year as the number of contaminated transformers in service decreases by
ttn.s fraction.
7.4 ' 'Summary
Analytical and Disposal Costs: . . .
1979 - $21.4 million to S-26-.1 million '
Succeeding Yrs - 3,4% less each year
Total - ' $612 million" to $769 million
577Dlovrnsnt Effects:
Analytical services Assuming that 50%-of-the-cost-of the"
analysis is for labor and that the burdened labor rate is
'$30,000 per year, the analytical costs of $75 million to .
$187 million iroly a total labor demand of 1250 to 3117 man
years, .Initial_derrendlwciild.J2e_3-.4i..of .this,._cr-2n_inr :...
creased erolcyment in 1979 of 42 to 106 jobs.
Disposal - The disposal cost analysis presented in Table
7.3-2 --assumed that -direct-labor-and-supear/isor-iaijor costs
were 14%- cf-the^cost-bf -'disposal-:ftf-fahe labor-ratss --=
assumed in the table, disposal demand'of $425 million to'"
$69.4 mil i.cn-would-inply- a^ labor- aemancV-a-t-- an^average>---r3=te-=:
of $30,000 per year of C$435 million x .14/S30,000/man year =
20301 to C$694 million x .14/$30,000/man year = 3239) man
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years of labor.. At a demand rate of 3.4% during the first
year, this implies an increased employment of 69 to 110
jc£s in the disposal industry in 1979.
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8.0 MINING MACHINE ' .
The only known use of PCSs in electric motors was fay Feliance
Electric Conpany of Cleveland, Chio, which used PC3s as a coolant in certain
specialized rotors.- These motors were used by Joy Manufacturing Corpany of
Franklin, Pa. , in several types of mining machines built during the late
1960s and early 1970s. The motors require rebuilding every few years. Al-
though PCBs are seldom lost from the motor housing when the1 motor fails , such
loss of fluid would result in substantial exposure of the machine operator
to PCBs. The proposed regulations allow a limited period of time for conver-
sion of the machines to motors which do not use PCBs.
8.1 Requirements of the Proposed Regulations
All of the' PCS motors must be removed from service in mining
machines by December 31, 1981. The motors on the continuous miners may be
rebuilt as PCS motors for one year after the effective date of the regula-
tions.' The motors" on" the~locidtdLS. &uatr'be rsbccrit «ib Ja.y t^ue- noucirs wiiiri trie
motors are returned to the shop for servicing. Continued "use of PC3 motors on
mining machines' must be reported to EPA within 90 days after the effective
cats of the regulation, and a spill response plan must be developed and
8.2 Ownership and Use of PC3 Mining Machinery
Joy Manufacturing- Company was- the -sole- CJ.Sv producer- of- mining
equipment .which used.. PCSs. as a_motor coolant. __ an^j-LrrrrHT^-OTng m-inor-
loaders were built using -PCS motors; Table 8 . 2-1 summarizes -the production
statistics and the present use status of these machines.
One small coal mining operation located in Pennsylvania is
operating the three remaining model CU43 continuous miners known to be
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Table 0.2-1
Production Statistics C. Present Use Status of PCB-Cooled
Mining Machines
ui
K)
I
I'lt-XllKJtlOi!
OL.nliii.iL.ua Milker 1961-1966
Mxlel OKI
Miner 1UU/-1970
»971-1!)7J
Kxlul lul 14UUIO
Of
lluilt
5JI
J4 uoLora
of
s tit ill
in Ueivice
- 15
of
.i^£_
3
of
Nunliar of Ga
In tioivice of K'U thkxl 1'ur
-------
still, in servica. Two of these machines presently use siliccne-ccoled motors
while the third machine..has only one" PCS-motor remaining - i.e., two of the
three motors are silicore-ccoled.
Fifty-four of the fifty-seven model 9G4 continuous miners built
by Joy Manufacturing have been located in the course of this investigation.
Thirty-five of those located are idle (standby service or stored as a source
of snare parts), thirteen are being used to mine coal, three are in uses
other than coal production (e.g., cutting overcasts and clearing air courses),
two are used as spare equipment, and one is being used in a training program
at a vocational school. TWo of the three model 9CM continuous miners that
have net been accounted for were reportedly sold. Therefore, it is estimated .
that a total of approximately fifteen units are still in service.
The PC3 loaders were sold to eighty-eight different mining opera-
tions, the majority of them small coal mines. " Sixty of these mines use"
three or fewer loaders and, based on a survey of thirty-six mines, it is esti-
mated that nearly all of these loaders are still in service.
The motors in loaders generally require rebuilding, every IS to 24.. .
months,, the tains to failure depending upon operating conditions. The motors
used in continuous miners usually require rebuilding every 12 weeks because
continuous miners are operated under relatively severe conditions. Pebuilc-
ing, from the time the motor is removed from service until the machine is
returned to service, usually requires one to two weeks.
Both the continuous miners and the loaders are used in underground
mines. Joy Manufacturingreported. ±hat,..a_ few_ of., the-.machines, .were, nrf gi na IT y.....
sold for use in potash mines, but all of the mines that wereidentified in
the course of this survev.were coal mines. The continuous miners ccuce
* «
the coal off the face of the seam and continuously load it onto shuttle
cars which haul it to a conveyor. After the miner has driven into the seam
about twenty feet, it is moved to a nearby section while the roof that it
-------
exposed is bolted. The'leaders are used in conventional raining in which the
coal face is drilled and undercut fay a drilling machine. After the coal is
blasted, the leader scccps it up and leads it into a shuttle car* Pcof
bolting is also required in this type of mining operation. In either con-
tinuous or conventional mining, an entire section with all associated equip-
ment will be idle if the miner or loader is out of service and there is no
stand-by capacity, as is generally the case for small mining operations.
The output of conventional and continuous mining operations has
been conservatively estimated at 250 tens of coal per section per shift
(eight hour working day). Given two shifts per day, each coal mining tech-
nique produces ever $10,000 worth of coal per day (valued at current prices).
Conventional coal mining operations generally require eleven to thirteen . .
men; continuous mining operations require only eleven men.
3.3 Conpliance Costs - - - , -
Loaders
The PC3-cooled motors presently used in loaders can be readily
replaced or converted to air-cooled (i.e., dry) motors when serviced every '
18 to 24 mantis. The cost of replacement with a new air-cooled .unit is
$6,258 per motor or $12,516 per leader. However, conversion kits are avail-
able from Reliance Electric Company, sole motor supplier to Joy Manufacturing
Company, for $3,100 per kit. Each kit converts one motor, and each loader
uses two motors.
Over the past few years, Jcy Manufacturing has been converting
the motors'T3T TfvAa-rg -try-ayrrf^nl^?;' r--g^''a-tpr^-'^ar^;naf' rrr-rv-fgygn-nrr .Tirly -:
19, 1977, Joy Manufacturing stated that they had converted- 353 of -these -
motors. .An additional 95'motors had been converted..as .of the middle of
Noveirber, 1977, leaving 652 loader motors to be converted (nets that this
figure includes the thirty-four spare loader motors). Jcy Manufacturing
estimates that all remaining PC3-ccoled loader motors can be converted to
-54-
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air-cooled by the end of 1981. The cost of this conversion is S3100 per.
motor/ resulting in a total cost of 'about 52 million to convert the regain-
ing 652 motors,
Continuous Miners
The PC3 and s11Icons-cooled motors in miners present transition
problems. As a result of the proposed regulations, the market for used
PCB-ccoled continuous miners equipment will virtually disappear. Therefore,
various mining operations will be confronted with obsolete equipment perhaps
prematurely, resulting in substantial capital losses which, depend upon the
rertaining useful life of the equipment.
All but one of the nine motors .in. the. Joy. Manufacturing Msdel CU43
continuous miners that are still in service have been converted to silicons
coolants by the cwner. ' However, it has recently been found that silicone
vapors may deactivate the electrodes in methane detectors which are used to
monitor the ambient air conditions in underground mines. Thus, silicbre
fluids may not be acceptable where such detectors are used.
Model 9CM continuous miners cannot be refitted with air-cooled
motors due to space limitations, nor can such'equipment house converted .
motors. Therefore, unless a satisfactory replacement heat transfer liquid
can be developed for use in motors, this equipment must-be scrapped-.^nd .ne^ ...
equipment purchased.
The value of the continuous miners is best approximated by its
value of $40,000 on the used equipment market. -"The'TSw replacement.machirss"'
will have a much higher' price,"but will--be'more productive' and require less
maintenance. Historically, mining equipment has become obsolete after about
ten -years of service, and rrcst mining operations" tsnd-'tD'- axii'dus- their'-^qgiy
ment prior to the end of its useful life. Since 1970 was the last production
date of PCB-ccoled continuous miners by Joy Manufacturing Company, all such
-33
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equipment is likely to reach obsolescence-by the proposed compliance cats -
i.e., 1981. Replacement of .this equipment, therefore, may occur regardless
of the proposed ?C3 ban regulation. -However, mining operations wil-l no longer
be able to employ the obsolete equipment as spare equipment to take up the
slack resulting from machine servicing, nor will they be able to sell it in
the used equipment market. Forced scrapping of this equipment prior to the
end of its useful life can result in significant costs (losses) to a mining
operation, depending upon the remaining useful life of such equipment.
Six of the eight, companies using the PC3 miners are relatively small,
with, production of from .7 to 4.2 million tons per year. -The other PCS
miners are in use in mines owned by conglomerates which produce considerably
greater tonnage of coal. Any costs "which are likely to be borne by these
companies as a result of the lost opportunity to sell their PCS equipment in
the used market will have little or negligible impact on the market price of
coal. This stems from the small market share-of U. S. coal new mined. by ..PCSr.
cooled continuous miners and the ability of competitors, to expand operations.
Furthermore, Versar estimates that whatever costs are incurred by..these eight
mining companies will not result in company closures and subsequent losses of
employment. . .
Table 8.3-1 summarizes the possible economic costs of the proposed .
?C3 ban regulation to the eight mining companies using the continuous miners.
Note that only ?C3-ccoled continuous miners that are still in service are
considered in this analysis because it is not known how many of the remaining
forty-one continuous miners located have a positive market value and useful
life. Assuming that forty of these miners can be sold in the used equipment
market (i.e., .emitting the. one continuous-miner-.-that.-is- -beiag-used-by -the-; - -
vocational school), the additional economic costs .<*ould be a-maxunum or --
C$40,QOG x 40 = $1,600,000)-. In no case does the economic impact en any
company exceed one percent of the annual value of the coal mined by the.
company.
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'8,3-1
Company
NO.
1*
2*
3*
4*
5
6*
7
8*
Cost L-ncact of Forced Retirement of ?C3
Number of Number of
Continuous Continuous
Miners Miners
Model CU43 Model 9CM
in Service
1 (1) 0
3
2
1
1
1
2
5
'Continuous .Miners
Opportunity '
Cost Due to
Absence of
Used Equipment
Market
5 40,000
$ 120,000 '
$ 30,000
? 40,000
$ 40,000
' $ 40,000
$ 80,000,' .. ..
S 200,000
TCT&L
15
$ 640,000
(1) Note that company no. 1 operates three ncdel CU43 continuous mines
but cnly one machine still uses PC3s as a rrotor coolant; and only
one motor of the three used to operate the machine does contain
?C3s - i.e., the other two motors employ silicone as a coolant.
* Small, producer (less than five million tons per year total ccirpany
production).
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Reporting Casts
The proposed regulations would require that the SPA be informed of
the identity and ownership of each FC3 mining machine within 90 days of the
effective data of the regulation, and that the owners maintain, current
records of the machinery and report changes of ownership to the EPA. There
are approximately 96 mining cocpanies which own PC3 machines. The informa-
tion required for the initial report should be available from inventory .
records, and preparation of the r^ort should require no more than one to
two days per corrpany. Assuming an average of one and one-half man days per
company report, and an average burdened labor rate of $30,000 per man year/
the. reporting rsquirsrent will result in costs of (96 corpanies x 1.5 nan
days.,pea? company x $30,000 per man year/240 man days per man year = $18',000)'.
The other' record keeping requirements are similar in scope to normal inven-
tory prccscfratas :and should not result in significant additional costs to
the mining corrpanies.
Sti'CZl Prevention and Control Plans
A formal contingency plan will be required of each,.carpany which -.
operates PC3 mining machines. This plan will have to be specific for each.
company, and will have to be reviewed and approved by a registered profes-
sional engineer. A sample plan for these machines will be prepared by
Versar Inc. under a contract sponsored by the U. S. Bureau of Mines. Using
this published plan as. a basis for the preparation of a specific company plan
should reduce the effort to one day of company time and ore day of profes-
sional engineering services per corpany. This will result in costs to the
mining ccirpanies of (1 man day x $30,000 per man year/240 man days per man
year + 1 day consulting x $250 per day = $375 per company). For the entire
industry, total costs will-be '(96 cotpanies x $375' per company = $36,000),
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8.4 Sunxnarv
Cost Lmoacts:
Loaders -
Febuild: 652 motors @ 53100 $ 2,021,000
Continuous Miners -
Premature scrapping: 16 operating
miners @ $^0,000 640,000
40 other miners § 0 - $40,000 0 - 1,600,000
Reporting Costs - ' 13,000
Spill prevention and control plans 36,000
Total $ 2,715,000
[Plus up to $1,600,000 additional. All
costs will be incurred in the period
1979 through 1981.] ._
-------
9.0 EJZCTH2M&Q3EIS . . . .
Large electromagnets are installed ever conveyor belts to remove
train? iron from non-magnetic commodities such as coal and grain. Most of
these electromagnets are cooled with 100 to 150 gallons of mineral oil.
Where increased fire safety was required, the magnets were often filled with
PCBs. The three magnet manufacturers who used ?C3s were:
Sterns Magnetics, Cudahy, Wls.
Eriez Magnets, Erie, Pa.
Dings Co., Milwaukee, Wis.
Dings Co. stopped using PCBs in mid-1976; the other two manufac-
turers have rot used PCBs since 1971 or 1972. A total of about- 250- PCS-
magnets were manufactured; approximately 200 of these may still be in use
in the Chited States. Most of the FC3 magnets are being used in coal mines,
coal preparation plants; and in coal-fired generating stations. It is
possible, but not confirmed, that sons of the PCS magnets may be used on
grain conveyors because of the flarnrability of grain dust.
The electromagnets are of completely welded construction, and
very few leakage incidents have occurred with either oil filled or PCS
filled magnets. Based en design considerations, electromagnets would be*
expected to be less likely, to fail than would transformers. Those leaks
which have occurred have been caused' by physical abuse or lack of adequate
maintenance. Maintenance requirements do not expose workers or the environ-
ment to contact with PCSs.
9.1 Reouirements of the;" PrcDOsed~ Peculations-
Cnly transformers and capacitors are defined as "totally enclosed
uses" of PCBs. All other PCS equipment, inclining PCS'electromagnets, must
be rsroved from service by the effective date of the regulation, and dis-
posed of in accordance with the "PCS Disposal and Marking" regulations..
-60-
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Since incineration of the electromagnets is not feasible, each, owner will
.be required to submit a written application to the Regional Administrator
requesting permission to- dispose of the -units in a chertrLcai waste landfill.
9.2 Compliance Posts
The PC3 electromagnets could be replaced with oil filled units at
an average cost of $3,000 per magnet. Ecwever, use of mineral oil in these
applications would significantly increase fire risks. All of the manufac-
turers regularly furnish, magnets filled with, siliccre fluid for use where
[
fire characteristics superior to transformer oil are required. Such, silicone
filled transformers are 40 to- 50% more expensive than oil filled units, i.e.,
$12,000 per average unit. . ... .
Eriez also offers a proprietary air cooled electromagnet which
has Underwriters laboratory approval for use in dirty and dusty environments.
This unit costs about 30 percent more than an oil filled magnet, i.e.,
$10,400 per average unit.
Seplacement costs for suitable magnets would be $10,400 to $12,000
x 200 units = $2,080,000 to $2,400,000. Delivery and installation costs would _
be an' additional ten to twenty percent. As in the case of mining machines
(chapter 8) , the increased costs would be expected to be absorbed by the coal
mines as reductions in profits. These costs should not result in anv loss of
nr PTTYTI y*11 nn T
'QjL 200
au ~s~ WVAJ. J
i-iS". ' ' *F^ r ^ ^T ' "*t ' Or" l~>'*~ f_ii^l i : r i !gr%j_r -^ WLllVjiiL prril i2.'"i.r;n LTJ LgJuiiT
TTvaf-?>1 rrmTr? rpcnl ^ in ^ hirrh r-j clc nf r^^rnacp nf *-h«a nr'ghta'rs run'^K s^ir^j-ar.t"! al
Fadio rjLwJUfei^cy - uBi.rt'lr'dtriLiScLjrs can cetcOL rrcta*! ar.c
shut down a conveyor belt until the metal is removed manually. These systems
CD. Consensus of industry opinion obtained through a phone
survey by Versar Inc.
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are expensive in terms of manpower and lost production compared to the use
of separator magnets, but metal detsctors could provide the temporary pro-
tecticn needed until replacement magnets were delivered. Detector syststis
which are presently in use are not manned continually, so it must be assumed
that the lost production from belt stoppages is less expensive than manning
would be. Assuming that a two-month delay would be experienced in obtaining
replacement magnets, full tins (3-shift cceraticn) manning of the detectors
at a burdened labor rate of $30,000 would cost (60 days x 24 hours per day.
x $30,000 per man year/1920 man hours per man year = $22,500 per magnet) .
Actual labor requirements might reasonably be 10% of this figure. This labor
requirement would have to be added to the cost of a detector system. All of
these additional costs are very dependent on the timing of the effective
date of the regulation, and would be eliminated if the industry had six
months notice of the intention of the Agency. .
9.3 Smeary
Cast Impacts:
Replacement cost - 200 electromagnets - $2,080,000 to 2,400,000
Delivery- and installation costs - 200
electromagnets - $208,000 to 480,000 . - .
Labor cost increases due to short term lade
of reolacement macnets - $0 to $4,500,000 (probabiv
$500,000)
Production cnd.Pr-ise Irrrpacts: .
COStS .are* (ayy^ar^-ty? t-n r>a afasrft*^* hv frrija rftal Tiinirig; _ fp
as a reduction in profits.
Employment Effects:
.No loss of employment at the mines is anticipated. Assuming
that one-third of the manufacturing and installation costs of the replacement
units represents labor at $30,000 per man year, distressed labor of
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(52,238,000 to S2,380,000/ 330,000 cer man year x 1/3 dollar later per
dollar cost = 25 to 32 roan years 1. would be required in' late-1978 -and early
1979. Extra labor due to a lack of replacement units might increase em-
ployment by ($500,000/530,000 per nan year = 17 nan years) during the first
few norths of 1979.
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10.0 EXDPHJLIC SYSTEMS
PC3 fluids were used In a large number of hydraulic systems, particra-
larly in die-casting machines ard in steel ijxiustry applications where high-
tanperature stability and fire resistance were important considerations. In
1972, when ?C3 hydraulic fluids, were no longer available, users were forced
to switch to substitute fluids. Since the substitutes were compatible with
the PCS fluids, the machines were not drained and flushed but were simply
topped off as required with the new fluid. Topping off usually requires
addition of new fluid at the rate of 2 to 10 times the system capacity per '
year to replace leakage losses.
Available data on residual PCS levels in die casting machine hydraulic
systems indicate that many of the tested machines contained PCSs in concentra-
tions of 60 ppm to as high as 50% in a few cases. The differences in cph-
'''..;*
centration apparently reflect differences in the rate of leakage from various
machines and differing company maintenance policies regarding periodic tetaJL.:' -.
replacement of hydraulic fluid. _. '
10.1 Requirements of the Proposed Peculations
The proposed PC3 ban regulations would prohibit the use of fluids
which contain over 50 ppm PCSs in open or semi-closed systems. However,
hydraulic systems on metal die casting machines which contain fluid with more'
than 50 ppm PCSs would be allowed to remain in service if they ars drained,
flushed with clean solvent, and refilled-with uncontaminated hydraulic fluid.
The fluid must be re-processed or replaced at intervals of six months to
remove ?C3s until the concentration of PC3s remains below 50 ppm. In addition,
users of contaminated systems would have to- report such use to EPA and petition
annually1' 'for3 exempt±cns"TST ccntintETisintr arxi~ periodically" 'decontaminating the""'
equipment.
The provision"fcr~cont±nneS-TJse"''CTf--these"'systems'Is-limited to
five years in the proposed regulation. However, it is anticipated that the
required periodic decontamination of the systems will reduce the concentration
of PCSs to below 50 ppm before the provision expires. Hydraulic systems en
-64-
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other types of machines would, not be allowed, to continue in service if the
fluid contains more than 50 pan PC3s. .The machines would have to 'be removed
fron service by the effective date of the regulation and not used until the
PC3 level in the fluid is reduced to a concentration below 50 pan.
10.2 Ownership and Use of Contaminated Hydraulic Systans'
A previous EPA sponsored study reported that sales of ?C3 hydraulic
fluid during the period 1970-1971 totaled over 13.5 million pounds to 585
different firms. Except for a ' few companies with contaminated die casting
systems which have been identified through statements at public hearings on
PCBs, little information is available on the ownership of contaminated systems
or the levels of PCBs in the fluid.
Based on statements''made, by several die casting companies and by '
a representative of the American Die-.Casting Institute, PCBs were used as
a premium priced alternative fluid"--ih. the''hydraulic systems of die casting
machines used to form aluminum, magnesium, and zinc castings. There are
apparently few barriers to entry in this industry/ and the constant entry
of new die casting companies has provided a ready market for used machines.
A review of the Monsanto customer list reveals that about 30% of
the 40 largest companies purchasing PCS hydraulic fluid in 1970 and 1971 were
die casting ixauianies. Assuming that die casting companies purchased 30%
of the fluid sold and used it in die casting machines, a total of (13.5
(lt~' Versar £ncT7"gsage of~PCSs"ia Oce:i and1 3e.Ti"clcsed-Svstams and-the- -Re
^ .-suiting: Jasses?o3Ss~.£o^feteB£rCT3in^^ .
.. 4EPA^ntr^t-fe.-.^H}l~32Si7-ye£sa^.Ste^
1976, p. 13.
__(2) Telephone. conversation, Mr.. Gomel (American pie ..Casting Institute^ Inc.)
with Robert Westin (VersarT," April "25, '1978"." "" ~" "
-65-
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million lb x 0.3 / 11 lb per gallon = 1 million gallons) of PCS fluid was used
in these cnachir.es during the two year period. Assuming further that each
machine had a hydraulic system containing 300 gallons and required* that amount
each year to replace leakage, the total one million gallons of fluid could have
been used by 1000 machines which used 1000 gallons each.
The remaining 20% of the largest purchasers of ?C3 hydraulic fluid
were steel mills. PCS hydraulic fluid was reportedly used as a standard fluid
in many plants in those applications'where leakage would present a fire hazard.
Representative uses would include steel furnaces, ladles, strip mills, vacuum
degasers, and continuous casting machines. There is no information available
on the total number of hydraulic systems in the steel industry that used PCS
fluids, nor is there any information available as to the present concentration
of ?C3s in these systems.
10.3 Compliance Costs
Die Casting Machines
Most die casting machines were flushed and refilled with a^ ron-PCB
hydraulic fluid after the owners became aware of the environmental and health
hazards associated with ?C3s. The hydraulic fluid recommended by .Monsanto .
as a replacement for the PCS fluid in 1971 was based on polychlorinated ter-
phenyls (PCTs). -The manufacturing of PCT fluid was discontinued in 1972 or
1973 and the product.lines were, replaced with other types of hydraulic liquids.
The refilled hydraulic systems have been -raintained in use by
topping off when necessary to replace leakage losses, and in some cases by
periodic replacement of the fluid. As a result of the continual removal of
contaminated fluid, the concentration, of. PC3s has..been, .graduaIly. r°dncari .to ,~
low levels-, although in many cases the- residual -?C3s exceed the 50 pair limit
proposed by the regulation. The available information on present levels of
PC3s in the hydraulic systems of die casting machines is summarized in Table
10.3-1.
-------
Table 10 .'3-1
Present ?C3 Levels* in Die Casting Machine Hydraulic Systems
Company PC3 Level (pan)
Cast Forge Co. (1) 80
Caterpillar Tractor below detection limit (systems
are drained twice a year)
Outboard Marine ' 90-6000 (currently average 500)
Outboard Marine Corporation owns approximately 130 die casting
machines that at one time used FC3 hydraulic fluid. These machines each
contain an average of 500 gallons of fluid , and are all contaminated with
?C3s in concentrations above 50 pern. ' '
Several companies provided estimated costs for replacing hydraulic
fluid, although rot all of the figures were for the permitted draining and
flushing procedure. Outboard Marine estimated a cost "of $340,000 to drain
their machines, flush them twice with .mineral oil,- and refill them with r.ev
1 ' I "i " , __ if
(40
avoid flatiroability problems the cost would be $1.2 million.
General Motors stated that the cost of materials for replacing
the fluid in their hydraulic systems would be as follows :
(1) Telephone conversation, Tom Grover (Cast Forge 'Co.) with Brace r»vcccccck
(Versar) , September 22, 1977.
(2) Telephone' co^wersatiTsrrrTtm 3arl5tr~(Catsrpillar- Tractor) with' Bruce
-Thonas , Hugh- (Gutbea^d-Maglfie-Corp-.->- ,-Pgeser.ta-tien-5-t-the'EP.ar Inf
Hearings on the PCS 3an Regulations, Washington, D.C. , July 15, 1977
(p.. 91 of. transcript) . _ ._ ....
(4) Telephone conversation, Hugh Thomas (Outboard Marine Corp.) with 3ruce
Woodcock (Versar), September 23, 1977.
(5) Ward, William (General .Motors Corporation) , Presentation at the EPA
Hearings on the PCS San Regulations, Chicago, Illinois, July 19, 1977,
(p. 201 of transcript) .
-------
Item Material Cost
(?/gal of replaced fluid)
Solvent ~ $.2.26
Nev Hydraulic Fluid 7.57
Disposal 0.57
Total $ 9.40
Chevrolet estimated that it would cost $500,000 to replace the hydraulic fluid
0 A
in the 25 systems (29,000 gal total capacity) in their Bay City (Mich.) plant.
Representatives of two companies stated that if they were forced
to use hexane or some similar solvent they would be severly affected as the
seals in their machines would have to be replaced. Also, there was .concern .
among those who have already flushed their machines .that further flushing
would rot significantly lower the ?C3 level in their machines.
All of the available industry cost estimates are. summarized in
Table 10.3-2.
Table 10.3-2
Industry Estimates of the Cost of Draining,. Flushing, and
Refilling Die Casting Machine Hydraulic Systems
No. of
Machines
: 25
totors
Marine 130
No. of
Gallons
29,000
65,000
Total Cost
$
500,000
340,000
$/Gallon
17.24
9.40*
12.92
Company Machines fumnng $ $/Gallon S/lMachine
Chevrolet 25 29,000 500,000 17.24 20,000
6,500
"Material cost only.
(1) Michigan Departnent. of Natural Resources, File Memo, undated.
-63-
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The industry cost estimates are roughly comparable to the cost
estimate irade by Versar and presented in Table 10.3-3. .Since the Versar
estimates do not include "inventory costs ~or the cost of decontaminating the
waste liquid truck, a figure of $14 per gallon might be a .Tore realistic
estimate of the average price of decontaminating hydraulic systems.
The effectiveness of the decontamination procedure will depend en
hew thoroughly the system can be drained of both the contaminated liquid and
the flushing liquid and also on the amount of PC3s which are absorbed into
gaskets and other porous material. Assuming that the draining and flushing
procedure will remove 80% of the total PC3s , a system originally contaminated
with PC3s at 1000 ppm will still be contaminated with 200 ppm six months
after the first flushing/ but the level of PC3s after the second flushing will'
never exceed 40 ppm. Since there will probably be considerable leakage and
topping off between the flushings, the concentration of PC3s is likely to be
even lower than these calculations indicate. -
Assuming that each of the 1000 presently contaminated systems must
be flushed and refilled twice, and that chemical analysis for PCSs is required
six months after each flushing, the total costs involved will be: . . .
First flushing 500 gal. @ ?14/gal . $ 7,000
Chemical analysis 300
Second flushing . 7,000
Chemical analysis 300
Total per machine . $14,600
Total for 1000 machines $14,600,000
A- majorsactSE-ia-^he-csst-of deeeRt5iTiiaa^dag-hyerau±±c--systgns--±s
the cost of
..-steed -that- both--Gutbcara-Mar-iae-aM-geRe£al--M3tsr3^ have-eerdacted- ca
methods to remove PCSs from hydraulic fluids . It is not known whether these
methods involve distillation or adsorption. The feasibility of such pro-
cessing may have a substantial effect on the costs of decontaminating hydraulic
systems and on those companies which reclaim hydraulic fluid.
-69-
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' Table 10.3-3
Estimated Cost: of Decontaminating Hydraulic Systems
c Fluid (1)
sphate ester)
id(1) - 1 gal/gal
Cost per
500 gallon
system
7.80
1.15
gallon
2700 gallon
'. system
7.60
1.15
Flushing Fluid
(lew viscosity mineral
oil without additives)
Transportation . .41 ..41
(400 miles, includes
flushing fluid)
Incineration - $.15/Lb 2.85 2.85
(includes flushing fluid)
Labor
(2 man days per machine .48 .09
at $15 per burdened man hour)
Total "12.69 12.10
(1) 'Telephone .conversation, John Colucci (E.F. Hcughton) with Brace Woodcock
(Versar). April 27, 1978. .
(2) Versar Inc., Microeconcmic Impacts of the Proposed Marking and Disposal
Regulations for K3g> Sprungrxeld, Va.: National Technical Infonration
Service (OTIS PB 267 833/2NP), April, 1977, p. 3-20.
-70-
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Other Hydraulic Systems
Approximately 20% of the firms purchasing PCS hydraulic fluid in
1970 and 1971 were steel-companies and other firms rot engaged in die casting.
It is therefore likely that 20% of the usage of PCS hydraulic fluid was in
systems other than in die casting trachines. Although there is little informa-
tion available on the use of this material, apparently not all of the systems
are still contaminated with significant concentrations of PCBs. Budd Co.
stated that their operations should not be significantly affected by the pro-
posed ban regulations since the hydraulic systems on each oftheir welders
have been drained and refilled on the order of 120 times over the last five
years.(1)
The procedure of draining, flushing, and refilling any of these '
other hydraulic systans to reduce the level of PCBs should cost approximately
the same per gallon of fluid as a similar procedure performed on a die casting
machine hydraulic system'. As a rough estimate'" based on the proportion of PC3
hydraulic fluid used in such systems, the cost of decontaminating these other
hydraulic systems should cost 25% as nuch as the cost of decontaminating the
die casting machines, or a total of $3,650,000.
The proposed regulations would require that the level of PCBs in
these other hydraulic systems be reduced to less than 50 ppm by the affective
date of the regulations or the- systems removed
1 *-< ^ I 7^"*
additional costs due to disrupted production in steel mills, as the hydraulic
systems are central to the operation of the large equipment used in these
- facilities-; Sewever; there is r.ot sufticiaiiL infcrmaLioii availciLli=! Lo~ y
'Whether' the~rsqu2-red~ '^"-"'n^ni^'gt "nii-r^f1 \-&* acciiiiuicLslitsi L/y tlm bjI_»jt_i.'
of the regulation, nor to estimate what the costs due to production intsrrup-
(1) Telephone conversation, C.W. Habitz (Budd Co.) with Bruce vvcccccck
(Versar), September 22, 1977.
-71-
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P.sau.'irsmants
The proposed regulations would require that owners of die casting
machines having hydraulic systems contaminated with over 50 pan PCSs report
the identity of each contaminated machine and the concentration of ?C3s in
the fluid. This will require the identification of all machines that ever used '
?C3 fluid and those that may have used PCB-contaminated reclaimed hydraulic
fluid and the chemical analysis of the present fluid in these machines for the
presence of ?C3s. This sampling and' analysis .program may cover as many as
2500 machines and must be completed within 90 days of the effective date of
the regulation. :
Chemical analysis for the quantification of ?C3s in hydraulic
fluid would be considerably more complex and expensive than that required to
determine the concentration of PC3s in 10-C transformer oil. This is be-
cause the presently used hydraulic fluids may be based on 'chemicals such as
phosphate esters which require that the FC3s be extracted from the sample ..
prior to analysis. The possible presence of PCTs in the fluid could interfere
"" . *
with the analysis for ?C3s, and discrimination between these similar chemicals
would require the use of a gas chrcnatograch/mass spectrometer rather than
the simpler gas chromatograph usually used for PC3 determinations. Versar
estimates that the complete analysis of contaminated hydraulic fluid for PCBs
may cost as much as $300 per sample on the average.
Review of the. records.-..to dfftprmip.e-vrJ.ch.machLne.s..3ay hf»_con-=.-_ ____
taminated with PCBs and the preparation of the- report to EPA would be expected
to require an average of three days for each of the 335 firms which purchased
PCS hydraulic fluid in 1970 and 1971. This would result in a net employment
--demand of -(585 cmitjanies-x-3 iays..pqr-*ggss^y--^240 -aaa~days .ger-iaan-.-year-gfr --?.a
7.3 man years). At -a. burdened- rats. -of-. ^30^000 per -man year r- this -would
result in total . reporting costs of (7.3 x $30,000 = $220,000).
Total costs attributable to the reporting requirsnent would be
($300 per sample x 2500 machines = $750,000) + $220,000 clerical = $970,000.
Spill Prevention end Control Plans
Each ccmpany which uses or services a die casting machine that is
contaminated with ?C3s will be required to develop and implement a formal
-72-
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spill prevention and control plan. Because of the complexity of the machines
and the assumed requiranent for periodic flushing and decontamination, the'
plan will be rather complex and may require the services of a registered pro-
fessional engineer for one week at $250 per day. Preparation of these plans
by all 585 affected companies could cost a total- of (585 plans x 5 days x
$250 per day = $730,000). This cost could be reduced by perhaps one half
if a pro fonna plan were developed under the sponsorship of a trade association
or major manufacturer and made available to all affected firms.
Total expected cost of this part of the regulations would therefore
be expected to be $365,000 to $730,000.
10.4 Summary
Identification of Contaminated Die Casting Machines
Analysis and Sampling $ 750,000
Clerical - Report to EPA " 220,000
Spill Prevention and Control Plans $365,000 to $730,000
Decontamination of Die Casting Machines 14,600,000
Decontamination of Other Hydraulic . 3,650,000
Systems
Cost of Production Interruptions when ? (potentially
other Hydraulic Systems Removed from large)
Service
Total $19,720,000
Employment Effects
T^bor equals (.43/12.50 = 3.3%)'-of per gallon cost. Total labor
cost = (.038 x 13,250,000 = $693,000). At $30,000 per man year, this is equal
to 23.1 man years of labor, or 12 jobs for 2 years. Spill prevention plans
would require 5 man years of effort. Reporting requirements would require an
additional 7 man years.
-73-
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Effects
The impact of these regulations may effect almost all die. casting
and steel companies. Increased costs would therefore be expected to be passed
along to the consumers in higher product prices, although no individually
significant price increases are expected.
-74-
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11.0 HEAT TRANSFER SYSTEMS
PCBs have been extensively used, as heat transfer liquids- because of. -
their excellent thermal stability and inherent fire safety. Although the
heat transfer systems are usually quits tight, leakage can occur.due to
mechanical damage of the system or because fittings have loosened as a result
of thermal cycling. The Yusho incident in Japan in 1963 caused the PCS
poisoning of 1001 people due to the leakage of PCBs from a heat transfer
system into rice oil that was being heated by the system.
A previous EPA sponsored study estimated that total usage of PCBs in
(2)
heat transfer systems in the United States has been over 21 mil linn pounds.
Most of this material was manufactured by Monsanto and distributed under the
trade name Therminol. Monsanto stopped producing PCS based heat transfer
liquid in 1971 and advised its customers to drain and flush their -systems
before replacing the fluid with a non-PCB based liquid. An additional one
million pounds of PCB heat transfer liquid was "manufactured during the period
1971-1973 by Geneva Industries of Houston, Texas. There was at least one
(4)'
company still using PCB based heat transfer liquid as late as 1976.
11.1 Requirements of the Proposed Regulations-
As of the effective date of the regulation, heat transfer systems.
containing a liquid contaminated with more than 50 pern PCBs could not be used until
the concentration of PCBs is reduced to less than 50 ppm.
(I) Kuratsune, Masanori, et. al., "Yusho, a poisoning caused by rice oil con-
taminated with polychlorinated biphenyls", RKSMHA Health Reports, Vol. 36,
No. 12 (December, 1971), pp. 1083-1091.
(2) Versar Inc., Usage_of PCBs in Open and'Senu^-closed Systems and the
Resulting losses of PCBs to the Environment, Unpublished Draft Report,
(EPA Contract No. 68-01-3259, Versar Report No. 474-5C), September 30,
1976','p.'13.
(.3) Ibid.
04) Ibid, p. 26.
-75-
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11.2 Ownership ard Use of Contaminated Heat Transfer Systems
There is no data available on the total number of heat, transfer.
systems which have used PC3 based fluids in the past. However, a review of
Monsanto 's customer list for 1970 and 1971 indicated that 8.2 million pounds
of PCS based heat transfer fluid was sold by Monsanto during those years to
a total of 533 different fians. (1)
The present concentration of PCBs in the heat transfer fluid in
any of the systems which previously used PCBs depends on how thoroughly each
system was flushed when the PCS fluid was replaced and the amount of leakage
and topping off that has occurred since then. Data on present PG3 levels is
available for only one system: a 14,000 gallon capacity PC3 heat transfer
system was drained and flushed in 1972 and refilled with a ron-PCB fluid;
the system has been in constant use since 1972 and presently contains fluid
that is contaminated with two. percent PCBs. ( ' - '
Lacking any addi-Hopa! information, it must be assumed that most
of the 533 companies which purchased PCS heat transfer fluid are still operating
the systems and that most of these systems are contaminated with PCBs in
excess of 50 ppm. It must further be assumed that the use of these systems
is central to the iranufacturing processes in which they are used, whether
for drying, heating, or temperature control in exothermic processes.
11.3 Compliance Costs
It is not possible to estimate the total costs of decontaminating
the existing heat transfer systems to comply -with the requirements of the pro-
posed regulation because neither the total number of systems nor their
capacity is known. In principle, the costs of draining, flushing, and re-
filling the systems should be about the same per gallon for heat transfer
systems as for hydraulic systems (see Section 10.3).
UJVersar Inc., Usage of PCBs in Open and Semi-closed Systems and the
Besulting Lssses of PCBs to the Environment, Unpublished Draft Report,
(EPA Contract No. 68-01-3259, Versar Report No. 474-5C), September 30,
1976, p. 9.
(2) Confidential information obtained from the user of the system by Versar
during a telephone survey of major users of PCS heat transfer systems.
-76-
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The disruption of industrial 'production caused by the requirement
that contaminated heat transfer systems be removed from service inrnediately
upon the effective date of the regulation may result in far larger" costs than
will the requirement to decontaminate the systems. Here again, the available
information will not support even a guess at the magnitude of the economic
impacts of the disruption on costs, production, and employment.
11.4 Summary
Over 500 heat transfer systems may be contaminated with PC3s in
concentrations exceeding 50 pan, but available data is rot sufficient to
support an analysis of the costs of decontaminating the systems or the economic
iinpacts resulting from disruption of related industrial production.
-77-
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12.0 CCMPPESSOBS .
Turbirol 153, a PCB-faased fluid, was tried as a turbine lubricant and
working fluid in natural gas pipeline compressors by several companies during
the late 1960s and early 1970s. Monsanto ceased producing this product in
1972, and the companies that were using it switched to alternate-fluids at
that time. .
12.1 Requirements of the Proposed Regulations
The proposed regulation would prohibit the use of any systems which
contain liquids contaminated with ECBs in concentrations exceeding 50 ppm after
the effective date of the regulation.
12.2 Compliance Costs
TWo purchasers of Turbinol 153, Columbia Gulf Transmission and
Texas Eastern Transmission, were contacted fay phone. Neither company had
information available on the residual levels of PCBs in the turbine fluid/ _.
but both indicated that the systems were relatively tight, and there was
seldom the requirement to top off the systems. Based on data available for
hydraulic systems and heat transfer systems, it must be assumed that the
compressor fluids are probably contaminated with PCBs in excess of 50 ppm.
There are perhaps ten gas pipeline compressor turbines in use that
have their oil contaminated with PCBs. The proposed regulations would require
that these turbines be removed fron use until the concentration of PCEs is
reduced to below 50 ppm. It is not known what costs would be involved nor the
disruption to the delivery of natural gas- that would result from removing
these turbines from use. Assuming that the complexity of the turbines is
similar to that of the hydraulic systems discussed in Chapter 10, a cost of
perhaps $20,000 and $40,000 per machine may be involved in the decontamination
of the oil systems. Total costs might be several hundred thousand dollars
plus the cost of disruption of the gas delivery system.
The cost of shipping gas by pipeline is established by long term
contracts. Additional costs resulting from the provisions of the draft
regulations would have to be absorbed by the pipeline companies.
-78-
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12.3 Stannary
Decontamination Costs - ~ $200,000.
-79-
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13.0 RECLAIMED OIL
Approximately 1.3 billion gallons per year of used oil.is collected.for
use as road oil, fuel oil, re-refined hydraulic oil, and re-refir.ed lubricating
oil. Much of the waste oil previously used in applications other than auto-
motive lubrication has been contaminated with lew levels of PCBs, and dissipative
uses of this contaminated oil can introduce PC3s directly into the environment.
A total of 2,376 million gallons of new oil were sold during 1975, the
major conrercial uses being automotive lubrication (50.8 percent); industrial
and aviation lubrication (30.5 percent); and other industrial uses primarily ,
in materials processing (17.4 percent). The amount available for collection
and recycle was estimated to be 1,154 million gallons, or 48.6 percent of
total sales. Data on U.S..usage of new (virgin) refined oil and availability
of used oil for recycling are presented for the year 1975. in Table 13.0-1. '
(2)
Data generated by Recon Systems for a.12-month period during. 1970-71
indicate that, out of a total U.S. production of 2,480 million gallons per
year, approximately 901 million gallons, or about 36.3 percent, were actually
collected for recycling or use as fuel. An additional 601 million gallons
were estimated to be used on roads (application for dust control and possibly
in asphalt) or as fuel oil; this used oil could conceivably have been col-
lected for recycle so that the maximum amount of oil available for collection,
based on the Recon Systams estimates for 1970-71, may be as much as 60 per-
cent of that produced.
A flow chart shewing the distribution and utilization of waste oil in the
United States, based on the 1970-71 data of Recon Systems, is presented on
Figure 13.0-1. Summary data for disposition and usage frcm Figure 13.0-1 are
as follows:
(1) Adapted from Table 1, page 24 of Assessment of Industrial Hazardous Waste
Management Practices, a document prepared for E?A's Office of Solid
Waste and presented with testimony of H. I^nier Hickman, December 12, 1977.
(2) Weinstein, Norman J., (Recon Systems, Inc.), Waste Oil Recycling and Dis-
posal, ZPA-670/2-74-052, Princeton, N.J.: August, 1974.
-80-
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Table 13.0-1
New Oil Usage and Waste Oil Availability for Recycling in '1975
Tvee of Oil Outlet or Use
Autcnctiva Lube Oil Service Stations
fj^wwo**^* a j *sp«'Ti T?^
-r- _ -L tmy MI i i
fleets
Mew car dealers
Auto Hast and ctr-jsr
iebe oil uses
Hetail qalips far COB-
nercial engi-es
Garaqes, auto supply
stsss
Discount stores
Factory ?-m« (auto i
fa r^n ectiianBnt)
. Subcotais
yl^fJ-?«P*^*-* 3^1 4 Aviation
Luba Oils SYrfraalic a cirsi-
lac.in? syststa oils
vjetal -«czjci.-^5 oils
Aviation 4 cr±er
Gas engine oils
Stri'rmrt scc^a cils
Suctatals
,-it^o^ T^A'», i»l rH1i r-1a< i-,^ «jjj
?rccess oils
assrigeration cils .
Subtotals
L-cca Oils P'jrsrASPd
iy 'J.3. Gavessnent
C3UJO TdALS
"Traction avaiiaoie :cr sscyclisg after
losses in use and to environment.
'11 J»i-gr°inr Jtorsan J. , (Secon Systsns, -T:.),
0. 3. S-tLna
1375
(gal x ID"4)
239
22S
103
131
95
90
250
54
OJT
.
314
145
147
SO
53
724'
52
240
1 1
~TIT
32.
2,375
Fraction
.\vailabls*
for Sac-^le
.53
.30
.90
.20
.S3
.63
.22
*
.30
.^
.70
.50
.90
.53
.90
.10
.50
.50
rfeor} .-ni
Available
:sr Secvciirs
150
112
93-
75
oO
' 57 '
55
49
651
_
132
101
7.3
54
31
-3sT
56
34
S_
9o
1£
1,154
Waste Oil ?ac^cli.T= ard
OisBosal, 3A-o70/2-74-352, ?rirceton, X.J.: August.
15/4.
-81-
-------
Figure 13.0-1. Distribution and Utilization of Waste Oil in
the United States During 1970-71
I'nxluctJori of
Virgin Oil
(241)0 x JO6
gal/yr.)
^
Sales
(2234 x 106 qol/yi.)
I'roJuctlon HrtuLaiii
Spain
(2<6 x 10° -
nunk Aftur Use
(HIS x I06yal/yr)
OlnulfiatoJ to Uie
tlwitr« ntuil , Mrtstua,
iuxl Spills
(1365 x 106 ijol/yr)
oo
K)
Somuu; Adapted turn Table 26, i>. 12U of Htiinatelii, llomun J., (Ifecxxi SyaLuna, Iiw.J.
Uaate Oil l^c-ycHny atid t)ls|Xaal, B'A-670/2-74-052, Prlnodtoii, H.J.i August, 1974.
-------
Fate of Oil After _ Percentage of New
Primary Use Oil Production
Used as fuel . . . 41.5:
Dissipated to environment 42.3
and waste disposal
Applied to roads
Ee-refined lube oil products
100.0
The general distribution portrayed in Figure 13.0-1 is believed to be
valid at present, although the magnitudes of the specific flows have fluc-
tuated as prices of virgin lube oil and fuel oil have varied. The value of
fuel oil has increased since 1970-71, and virgin lube oil was scarce during
the period of the Arab boycott and during a portion of the period- of price
controls. One result of these factors has been -increased use of waste oil
as fuel, either internally by industrial concerns which generate waste- oil
or via processors.
Ihe primary sources of waste oil available to collectors are service
stations and other automotive-related facilities. Industrial and avaiaticn
facilities are also significant sources. A significantly larger fraction
of available oil is collected in urban areas than in suburban-or rural areas.
Based on studies in the Pittsburgh area, spills and other wastes frou product
pipelines are a locally significant source of waste oil for collection.
The use pattern of processed or rerefined waste oil.is extrsnely dif-
fuse. Users include states and municipalities (road application), indus-
trial and caranercial facilities (fuel, re-refined lube oils, read oil),
utilities (fuel), and the consuming public (re-refined motor oil).
A small portion of the collection and processing of used hydraulic
oils does not follow the general pattern of scattered sources, many re-
claimers, and numerous users indicated for the waste lube oils. Reclamation
of used hydraulic oil, performed in most part by four companies, results in
a product which is marketed as hydraulic oil.
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13.1 Requirements of the Proposed Regulations
The disposal of oil contaminated with ?C3s in excess of 500 ppm is
regulated by the 'PCS Marking and Disposal Regulations'. The proposed 'PC3'
Ban Regulations' would change the definition of 'PCS Mixture1 used in the
Marking and Disposal Regulations to include all mixtures containing more than
50 ppm PCSs. This will affect the allowable uses and disposal of oil con-
taminated with lower concentrations of PCBs.
Under the provisions .of -the proposed ban regulations, oil con-
taminated with PCBs in excess of 50 ppm would have to be identified, segregated
for purposes of disposal, and burned in an approved chemical waste incinerator.
Oil containing measurable amounts of PCBs less than 50 ppm could be processed
for any use including as fuel, or reclaimed lubricating or hydraulic oil, but
could not be used as road .oil -or as a constituent of any sealant,- coating,
or dust control agent. " -4 ' '
13.2 Sources and Amounts''of Contaminated Waste Oil _ . , -
Eydr
-------
Monsanto manufactured almost. all the FCB-based hydraulic fluids;
When Monsanto discontinued manufacturing PCB-based hydraulic fluids in 1971 ,
they did rot recoimerd draining or flushing of hydraulic systems but that
replacement fluids should be added to the remaining PC3 fluids in the system.
As a result/ hydraulic systans which used PC3s in 1972 and prior, years new
contain replacement fluids contaminated with .006 to 50% ?C3s as discussed
in Chapter 10. The total amount of contamination is a function of the system
leakage and dilution during the past five years.
A portion of the available used industrial hydraulic oil is refined
and sold for reuse as hydraulic oil. This special: zed reclaiming service is
furnished by the following four companies which reclaim a total of about
150,000 gallons of hydraulic fluid per year.
E. F. Houghton and Co.,. Philadelphia, Pennsylvania . ' J , '"
Radco Corporation, LaFox, Illinois - . "'"" v,y-
Findett, Inc., St. Charles, Missouri ' ..,.';
Wai lover Corp., East Liverpool, Ohio ' " - .
Autamob'its and Industrial Lubin.aizti.na 0-1,2. The amount of usqd oil
collected for reuse in 1970-71 was about 900 million gallons per year, with
an additional 600 million gallons used internally for fuel or dust control
on roads. Thus, about 60 percent of the amount of new oil sold was reused.
Major uses of this oil were as fuel (1028 million gallons) , road oil (319
million gallons) , and feedstock for- re-refined lubricating oil (138 million
gallons) .
The extent of PCS contamination of this oil was studied on a
limited basis by the EPA National Enforcement Investigation Center (NEIC) in '
(2)
Denver. Samples of oil were taken from selected tank truck lots of used
oil that had been collected in Virginia, Maryland, and North Carolina. This
oil had been delivered to Continental Forest Industries in Hopewell, Virginia,
(1)Weinstein, N.J. (Becon Systems, Inc.), Waste Oil Recycling and Disposal,
EPA-670/2-74-052, Princeton, N.J.: August, 1974.
(2) Magruder, Robert S. (Continental Forest Industries), testimony presented
at the US EPA informal hearings on the PC3 ban regulations, Washinoton,
D.C., July 15, 1977.
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for use as supplemental fuel in a steam boiler of a paper mill. The oil had
been collected primarily fron automobile service stations, although it is ..
possible that some industrial oil, including hydraulic oil, had been included
in some of the lots. PC3s were found in the samples of oil at concentrations
ranging fron 3.2 ppm to 19.4 ppm. Although these oil samples were collected
from a restricted area, the extent of PC3 contamination is probably repre-
sentative of waste oil collected throughout the United States.
The PCS contamination of the waste oil could come from contaminated
industrial hydraulic oil or transformer oil or from PCS additives used in
lubricating oils prior to 1973. In applications such as railroad car journal
box oils, PCBs may have been used as lubricant additives. PCBs may also
have been added to automobile transmission fluids to control the swelling of
oil seals.
It would not be expected that PCBs would be destroyed during- re-
refining of waste oils. PC3s were reported to"-be present in-concentrations"
of several parts per million in reclaimed oil used to lubricate whetstones.
13.3 Compliance Costs
Collection of any waste oil likely to be contaminated with PCSs
for a controlled use would not be attractive financially unless the oil were .
known to contain PCBs at levels belcw the control amount. Analytical costs
for determining low levels of PCBs will be'considerably higher than the
costs quoted for transformer oil because naturally occurring sulfur and
chlorine ccnpcurds in petroleum oils cause interferences in the use of electron
capture gas chromatography at concentrations of 5 ppm PCBs or belcw. These
(1) Monsanto Chemical Company, Arcclors for / St. Louis, tfc.: undated.
(2) Weems, George, (United States Department of Interior, Denver, Colorado),
"Polychlorinated Biphenyls", File HLS 3-3-10h, June 13, 1977.
(3) Hbfstader, R.A. (Exxon Research and Engineering Co.); Lisk, D.J., Bache, .
C.A. (Cornell University), "Interference in the Electron-Capture Technique
for Determination of Polychlorinated Biphenyls by Sulfur-Containing Corn-
rounds in Petroleum Products", Bulletin of Environmental .Contamination and
Toxicology. Vol. 11, No. 2, 1974.
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interferences result in false positive indications of the presence of PCBs.'
The PC3 components can only be resolved through.complex clean-up procedures
or the use of gas chrcmatography/inass spectronvstry, techniques that wold-
cost up to several hundred dollars per sample.
Road Oiling . . ' .
The most recent data indicates that road oiling consumes 319
million gallons of waste oil per year (Figure 13.0-1). At an application rate
of 1/2 gallon per square yard, this is sufficient to oil 45,000 miles of
roadway 24 feet wide. The proposed ban regulations would forbid the use of
oil containing detectable amounts of PCBs for dust control. Fluids from trans-
formers are likely to have detectable amounts and other industrial sources are
at least somewhat suspect. Currently these industrial oils are collected along
with used motor oil. Although virgin motor oil has no PC3s, used motor oil
may have PCBs from previous recycling which included industrial oil sources
among the feedstocks or from old transmission oils which contained PCBs as an
additive. Nevertheless, used motor oil unmixed with industrial sources is
unlikely to contain as ntuch as 10 pan PCBs, and may have PCS concentrations
that are undetectable without unusually elaborate and expensive analysis. None
of the reported analyses of waste oil for PCBs was based on used motor oil
withoutany possibility of industrial contamination. Presumably waste oil
solely from automotive sources would contain fewer PCBs. It is doubtful that
road oiling could stand the costs of even "simple" tests at $70 per sample.
Prospective road oilers therefore would be safer using waste oil if they take
precautions to ensure that it does not contain industrial oils (and certainly
no electrical oils).
Compliance with the requirements of the proposed regulations could
be achieved by either of the following strategies:
(1) Avoid all waste oil and substitute virgin oil at considerable
monetary and energy cost where the customer is willing to pay the increased
price. At an average price of $.375 per gallon for 22 fuel oil vs $.03 per
gallon collection costs for used crank case oil, the cost of road oiling
would increase (.375 - .08) x 139 million gallons = $94 million per year.
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(2) Use synthetic road stabilization chemicals which both reduce
dust and provide surface stabilization. The increased cost of this type of
material is presently offset by lower road maintenance costs, on heavily
traveled dirt roads at mines and other industrial facilities. Savings in
maintenance on lightly traveled roads would be less significant and would
only partially offset the increased material costs. A typical synthetic
material is "Coherex", manufactured by Witco- Chemical Co. This material is
an organic resin in a water emulsion which is sold for $1.25/gallon, and
applied after a 5 to 1 water dilution at a rate of one gallon per square yard.
Increased costs.incurred by the use of this material would be:
Coherex: 1/6 gallon per square yard 3 1.25 = .203
minus: Used Oil: 1/2 gallon per square yard
@ .08 » .04 .
equals: increased material cost per square yard. ._ .168
x 14080 so. yds. per mile of road 24 .
feet wide . -. = $2365 per mile - .
x 45,000 miles = $106 million per year.
These increased costs will be incurred until the concentration of
PCBs in used motor oil crops below detectable levels. In perhaps five years, it
may be possible to use waste motor oil for road oiling with little chance of
releasing PCBs to the environment/ provided that care is taken to avoid using .
waste industrial oil. The diverted industrial oil can be made up at modest
added costs by more, extensive collection efforts particularly in rural areas.
The costs of obtaining this replacement motor oil for road oiling consists of
costs to persuade service stations to accept used oil from persons who change
oil themselves, and perhaps either greater .storage capacity at stations or more
frequent collections. Alternatively, collectors could travel further in rural
areas and rtins visit- rnnrs* sertrioa s-ha-Honff nrrtr nnw part o£ the racyclinrj systems.
These extra costs will not be incurred unless road oilers will accept necessary
price increases to cover these costs. Total.costs might reasonably be expected
to increase .02 per gallon ($6.4 million per year) plus the risk of inadver-
tently using contaminated oil in occasional instances. After an additional ten
years, it may no longer be necessary to segregate the industrial oil, and
costs would return .to their present levels.
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Users Other tnan Road Oilers'
About 27 mil] ion gallons ?er year of transformer- oil will not. be
available to collectors, thus initially reducing the total supply. Other
industrial oils may or nay not be contaminated with PCBs; to be absolutely
safe, the recycling industry would avoid them. 'Individual industrial firms
can probably continue to use their own waste oil as fuel oil if they make
initial and occasional later spot check laboratory analyses to make sure their
oils continue to contain less than 50 ppm PCBs.
The impact on re-rsfiners (who make re-refined lube oil) and
external processors (who process waste oil for use as fuel oil) will depend
on what happens to road oiling. A strict enforcement policy with occasional
all-out efforts to find PCBs in waste oil could prevent its use as road-oil.
Diversion of waste oil from this use would- create a -large increase in supply
for processors and re-refiners* Probably most of this would originally go to
fuel oil use since the capacity of re-refiners" is limited and the consumer
acceptance of used rotor oil is limited. later/ a majority of the increase
might go to re-refiners if the Frost and Sullivan market projections of 23
percent growth per year until 1985 proves to be even roughly accurate.
Ihis would provide an extra use as lube oil while retaining most of the heat
value for later use.
Collectors
If collectors avoid transformer and industrial oils, their total
business will decrease. However, haulage of the contaminated oils to chemical
waste incinerators will be required and could offer new market opportunities
to the collectors.
Processors
Waste oil for fuel use should become more- plentiful as use for
road oiling is discouraged or made impossible by the regulation. The effect
of a larger supply of waste oil on the price to processors theoretically would
(1) Maugh, T.W., "Rerefined Oil: An Option That Saves Oil, Minimizes Pollution"
Science 193, p. 1108-1110, September 17, 1976.
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be to lower the price. However, since use on coal in boilers is relatively
troublefree and expendible, this use is probably very eleastic. Consequently
if coal burning plants can absorb the increased supply,' 'which seems likely,
the price decrease should be negligible.
Re-refiners . .'"'
Re-refiners of lubricating oils should be operated at capacity and
thus be more profitable. The recycling ethic potentially can be used to
expand the market for used lube oil faster than industry capacity. This will
be especially true for industrial and commercial fleets, but might be extended
to personal cars. Similarly, increases in domestic crude oil prices would
increase the market for all uses of waste oil.
Information-collected through telephone interviews indicates
that at least three of the companies which re-refine hydraulic, fluid receive
hydraulic fluids which are contaminated with PCBs. These fluids are sometimes
contaminated to the extent of 6000 ppm. In most cases, the reclaiming process
removes no more than 10% of these PCBs.* ' It is also reported that the con-
centration of PCBs in sane of the hydraulic fluid applications encountered
by these companies remains at approximately 2000 ppm despite repeated flushings
and drainings. In such cases, Icwer PCS levels may be achievable through the
use of activated carbon filtration. - - .
Those hydraulic systsns contaminated with PCBs will be identified
as required by other provisions of the draft regulations. Cnce this is done,
waste oil from- these machines and from the oil separators in plants using the
machines will probably have to be diverted from fuel use to chemical waste
incinerators.
The price differential between re-refined and virgin hydraulic
fluid is about four dollars per gallon. The requirement that contaminated
hydraulic oil be incinerated may reduce the supply of re-refined oil from
150,000 gallons per year to 50,000 gallons per year. This would result in
increased costs of ($4.00 per gallon x 100,000 gallons per year = $400,000
(1) Telephone conversation, Dwain Fcwkes (BADCO Corp.) with L. Pourt (Versar)
September 19, 1977.
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year) , arid could force the closing of three small firms with a total
.ovment of 12 to IS persons-.
Industr-ial Waste Oil Generators
Those industries whose waste oil contains more than 50 ppm. PC3s.
will have to incur disposal costs of $.0832/lh. Even industrial oil con-
taminated with less than SO ppn PCBs may be avoided by waste oil collectors.
This will not be a big problem for coal burners. Fuel oil burning conpanies
can use a mixture of waste and virgin oil but there are technical problems
to be mastered in this use. Continental Forest Industries indicated that up
to 14 percent waste oil mixed with £6 residual oil is feasible. The result
may be the; development of a separate market for industrial oil with lew levels
of PCBs' fqr use as fuel. Long term economic impacts should not be significant.
' r ** '
13 . 4 'Sunanary
Costs
Bead Oil - 'increased costs of virgin or
synthetic material (years 1-53 $100 million/year
Bead Oil - increased cost of obtaining
adequate supplies of segregated used
motor oil (years 6-15) $6.4 million/year
Lost production of re-refined hydraulic
fluid $ .4 million/year
Employment Effects
Three small re-refiners may close with a loss of 12 to 15 jobs.
Shifts will occur in the collection segment of the industry, but will probably
have little net impact on employment.
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14.0 PCBS AS UNiOTEtfncNAL PBCDUCT
Although most of the PCSs in use were produced by Monsanto as the primary
product of a reaction process , other chemical reactions can produce PCBs as by-
products, resulting in contamination of commercial chemicals. Similarly, contam-
ination of existing material may result in PC3 contamination of products made
by recycling these materials. Recycled paper is known to be contaninated with
PCBs at lew levels, but a detailed study of this industry indicated that it would
not be affected by the 50 ppm limit on PC3 contamination. Polychlorinated
terphenyls have also been reported to be contaminated 'with PCBs formed as a side
(2) '
reaction during manufacturing, but the sole U.S. distributor of this material
has reportedly assured its major customer that it would warrant that future
shipments will contain less than 50 ppm PCS. ' ....
The only chenicals known to be contaminated; with PCBs in. concentrations
exceeding 50 ppm are certain phthalccyanine blue and green pigments and the
diary lide yellow pigments.
14.1 Bequirements of the Proposed Pegulations
The regulations ban the continued manufacture of PCBs after
December 31, 1978. This ban also applies to mixtures containing rrcre than
50 ppm PCSs regardless of whether the- PCBs were added intentionally or formed . .
during manufacture as an unintenticnal by products.
14.2 Compliance Costs
Phthalo cy
-------
copper used in the reaction, apparently catalyzes the dehydrochlorination of the
trichlorobenzene (TC3) solvent used' in. the process to form varying amounts of
trichloro and pentachloro biphenyl residue in the product. Further chlorinaticn
of phthalo blue to make phthalo green pigment results in the formation of FG3s
residues in the green product. Domestic and foreign manufacturers of phthalo
pigments, using the TGB solvent process, have tested these pigments for PC3s
level. Results indicate that this process consistently produces pigments with,
PCBs residues in the 100-300 ppm range. One analysis from a domestic manufacturer
reported concentrations as high as 1000-2000 ppm. Several U.S. companies manu-
facture the phthalo pigments from the basic raw materials,. while the other U.S. i
companies marketing these pigments import foreign TC3-based crude pigments and
purify them for sale in the United States. Under the proposed PC3 ban regulations,
all of these manufacturers are in effect producing a PC3 mixture which could riot
be sold or distributed in conmerce effective 30 days 'after- promulgation of the
draft regulations. ' . '
Discussions with the domestic phthalo pigment manufacturers
have disclosed that only one manufacturer dees not use the TC3 solvent process
(kerosene is used as the solvent in a proprietary process and the pigment pro-
duced has essentially zero PC3s) . All other domestic ard foreign manufacturers
use TC3 solvent, .-and are accordingly faced with major process revisions to comply
with the proposed 50 ppm PCBs limit in their product.
The concentration of PCBs in the phthalocyanine blue and green
pigments can reportedly be reduced to below 50 ppm by a change in the solvent
used in the manufacturing process. Such a change will require modifications of
the process and quality control procedures, and may cost $100,000 for each of the
five or so manufacturers and iirpcrters of the material. Sinca uncontaminated
pigment is available from one U.S. manufacturer, there is sufficient price com-
petition to prevent these increased costs from being passed along in higher
product prices. The effect would therefore be a decrease in corporate profits.'
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Dior./lids- Zellcw Pigments ...
Diarylide pigments are the major yellow pigments used in
printing inks. These pigments are made fay reactions of precursors T«hich indues
didilorobenzidine. A minor side reaction results in the examination of the
benzidene resulting in the formation of 3,3'dachlorcbiphenyl. According to
Don Morgan of the- Dry Color Manufacturers Association, most diarylide yellcw
pigments ars contaminated with PCBs at concentrations of several hundred parts
per million. Although a few batches of pigment have been found to contain less
than 50 ppm PCBs, the industry is net yet able to control the manufacturing
process to reliably achieve this lew level of PC3 contaninaticn.
Sales of diarylide yellow pigment in 1976 were accut 12.66
million pounds having a value in excess cf $52 mill ion.(~' This pigment .was .
.contaminated with perhaps several thousand pounds, of .3,3'dichlorcbiphenyl, which
is a relatively bicdegradible iscmer cf PCS. If the proposed PC3 ban regulations
result in an effective ban on the manufacture of this yellcw dye, -rest" colored
printing inks will have to be reformulated, resulting in some lest production
while technical changes are made in the $690 million/year ink industry 'and the
$43 billion per year graphic arts industry.
There is no technology available that can reliably reduce the
concentration of PCBs in diarylide yellcw pigments to belcw 50 ppm. If the ban
en the manufacture of PCSs after December 31, 1978, results in an effective ban
en the manufacture of this pigment, lost sales of this material will be about
$52 million per year. Alternative pigments are available, but their use results
in higher ink costs as the alternative materials are less effective and/cr more
expensive. Increased costs due to the conversion to substitute materials may
equal 20 percent to 50 percent of the value of the discontinued yellcw pigments,
or $10 million to $25 million per year. There should be no net employment effects
as the production of substitute materials will offset the losses from the discon-
tinuation of manufacture of the diarylide yellcw. However, several hundred jobs
may be affected at the impacted manufacturing facilities, and an unknown amount
of production equipment would lose economic value.
TT5 Telephone ccnversaticri, Don Morgan (Attorney for the Dry Color Manufacturers
Association) with R. Westin (Versar), September 22, 1977.
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14.3 Sunmary ...
Complianse Costs . ."-,..
Phthalccyanine Blue - Production changes $500,000 - 1978
Diaxylide Yellow - Increased costs of $10 million to
substitute pigments $25 million per year
Employment Effects
Several hundred, jobs would be affected if the manufacture of
diarylide yellow pigments were banned. These would be offset by employment
increases in the segments of the pigment industry supplying the substitute i
materials.
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15.0 CAPACITOR MHiGEACEUKENG
The use of PC3s in the manufacture of new capacitors is .expected to. end
by mid 1978 due to a number of factors including the ending of production
of PCBs by Monsanto in October, 1977 and the zero PC3 discharge requirements
imposed on the manufacturing plants by the EPA under authority of the Federal
Water Pollution Control Act.(1^ However, the decision of the capacitor manu-
facturers to discontinue the use of PC3s without attempting to develop
alternate sources of supply after Monsanto stopped production was made in
anticipation of the iirolementation of the Ban Regulations of Section 6(e) of
the Toxic Substances Control Act. Although the EPA apparently has no dis-
cretion in the implementing the ban en the use of PCSs in the manufacture of
capacitors, the economic impact of the change to alternate materials and
designs is undoubtedly the result of the provisions of the Act as imple-
mented by the proposed regulations.
15.1 Requirements of the Proposed Regulations
The proposed regulations would ban the manufacture of capacitors
containing PC3s after December 31, 1978 as the EPA has determined that the
ban in Toxic Substances Control Act on the manufacture of PCBs applied also
to the manufacture of items which are considered to be "PC3 Articles" or
"PC3 Equipment."
15.2 Capacitor Production and Sales
PCBs have been used as a dielectric liquid in most of the alternating
current capacitors manufactured since 1930. PCBs provided the advantage of
ncn-flammability which is not available with electrically suitable alternative
liquids. The development and carmercial introduction of non-PCB capacitors
started in 1975 in response to growing concern over the environmental effects
of PCBs. The time required to develop various types of non-PCB capacitors .
(1) EPA, "Final Decision," Federal Register, February 2, 1977, pp. 6531-6555.
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has been a function of the fire hazard which would result from the failure of
type of capacitor. Segmentation of this industry by type of capacitor is
to calculate the impacts of. the draft regulations.
PC3 capacitors have been made in many different sizes and in designs
suitable for many different voltages and applications. For the purpose of this
analysis, all of the various types of PC3 capacitors will be classified as
either power factor capacitors or industrial capacitors. Fewer factor capacitors
are those large high voltage .units used by utilities to correct for lagging
i
power factor in electric transmission and distribution systems. Industrial
capacitors 'include all other types of FC3 units which are used in association
with specific types of equipment such as electric motors, fluorescent light
ballastsr and electronic circuitry.
Census figures for capacitors are collected by the U.S. Deparurjent
of Connerce on the basis of seven digit SIC codes. The most recent data at this
level of disaggregation was obtained in 1972 and is summarized in Table,15.2rl-
belcw. More information at this level will be obtained in 1378, but will not be
available for several years.
Table 15.2-1
PC3 Capacitor Production and Sales: 1972(1)
Type 'Production-Units Sales-Million ?
Shunt and Series Power Factor Correction 192,700 41.1
General Purpose Motor Control " 22,100,000 39
Fluorescent Light Ballast Capacitors not available 32.3
and other capacitors except electronic
(1) Source: U.S. Department of Comerce, Electrical Measurement, and Distribu-
tion Equipment, Publication MCU-3SA).
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Annual estimates of capacitor sales volume ara available on an -
aggregate basis from a 20% survey of manufacturers at the five digit SIC cede
level. The recent information available from this source is summarized.in .
Table 15.2-2.
Table 15.2-2(1)
PCS Capacitor Sales - by Year
Year Sales - Million Dollars
1972 112.4
1973 143.1
1974 157.3
1975 119.3
1976 149.0
(1) Source: U.S. Department of Commerce
15.3 Compliance Costs
There are two basic technological alternatives available to capac-
itor manufacturers who must develop ncn-PC3 capacitor product lines. The
direct, and probably short term, solution to the problem is to develop a di-
electric liquid'which can be used as.a direct replacement for'PCBs within the
presently 'used technology of capacitor production involving aluminum foil and
paper as a solid dielectric. This type of construction has been developed to
maximize the advantages achievable using PCBs as a liquid dielectric. An
alternative approach would be to develop a new technology which makes optimum
use of the materials remaining available to product designers.
Much effort has been spent in evaluating materials for use as
PCS substitutes in both .the U.S. and in foreign countries. No substitute
liquid has been developed which equals PCS in dielectric properties, fire
resistance, and stability. Any trade-off entails enhancing electrical per-
formance at the expense of environmental or safety considerations. Impregnating
capacitors with alternative dielectric fluids and/or redesigning them may
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result in substantial retooling, research and development, and other production-
kated costs. Such costs are normally high at first,, since the industry is
entially characterized as infant; .i.e., it is facing' a nev learning curve
due to the production of technologically new capacitors. However, since all
manufacturers are developing non-?CB capacitors, and since these nev products
will be introduced essentially simultaneously, there will be substantial ccra-
petition which will prevent the rapid recovery of development and tooling costs
through market skiirming. Therefore, it is expected that the initial product
prices will closely approximate the long term competitive price structure of
the capacitor industry. A review of the present status of each of the irajor
segments of the capacitor industry should provide an accurate picture of the
response of this industry to the PCS ban regulations.
Power Factor Cc&ac'itors
large power factor correction capacitors which operate at voltages
above 2000 volts are used by electric utilities to compensate for inductive-
current lags caused by inductive motors and other similar machinery. These
capacitors are usually mounted out of doors in substations or on..power poles,
wd little risk of significant fire losses is incurred by the use of a
flammable dielectric liquid in these units.
Prior to 1977, there were four manufacturers of ?C3 power factor . .
capacitors. All four of these manufacturers discontinued the use of ?C3s during
1977 and introduced non-PC3 capacitors having the same functional specifica-
tions as replacement products. Table 15.3-1 lists the manufacturers of
these large capacitors and summarizes the technology used in the new products
introduced by each manufacturer. The selling prices of these large capac-
itors are negotiated on the basis of large orders, and no published price
lists are available. However, Versar estimates that the prices of the capac-
itors manufactured by Westinghouse, General Electric, and Sangaino increased
10% to 15% following the introduction of npn-PCB units, and the price of the
McGraw Edison capacitors increased 15% to 20%. McGraw Edison claims exceptional
product life and efficiency for their product, and the higher price has
apparently not had a significant impact on their share of the market.
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Sales of ?C3 power factor correction -capacitors in 1976 are estir
mated to have been approximately $54.5 million. Assuming relatively-
constant output and demand, a ten to twenty percent price increase of can-
parable ncn-?C3 power factor correction capacitors will result in sales of
approximately $60.0 to $65,4 million (using constant cellars). Hence,
utilities and other users of power factor capacitors are expected to pay
approximately $5.5 to $10.9 million-more.
Utilities employ approximately ninety-five percent of all power
factor correction capacitors. The ability of utilities to pass all of the
additional costs associated with non-PC3 capacitors on to residential and
eumercial users in terms of higher prices will depend upon state regulatory
conmissions' attitudes toward rate structures. Total revenue for all
electric utilities was $46.2 billion in 1975. It is estimated that total
revenue for all utilities in 1976 will have been approximately $50.0-billion.
If all the utilities additional costs associated with using ncn-?C3 capacitors
is passed on to residential consumers, and that their average monthly electric
bill is fifty dollars, it is estimated that residential consumers will incur
an increase in their electric bills of approximately .02 percent, or one cent
per month. [Note that this is the long run effect; in the short run the
extra costs of non-?C3 capacitors will appear as a capital item in the rats
base. If depreciation and replacement are both straight-line functions, over
a ten year period, the rate base and the return on it will rise until the
tenth year at which point a small return- on capital will be obtained as well
as capital replacement costs.] Since part of the costs will be passed on to
industrial users, the relative price impacts will be even less, and are not
expected to significantly impact either the price or demand for electricity.
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Table 15,3-1
Currently Available *ton-?CB Power Factor
Correction Capacitors
Manufacturer
Westinghouse
General Electric
Sangamo Electric Co.
McGraw Bdison
Solid Dielectric
Paper and plastic film
confaination
Paper
Paper
Plastic film
Liquid Dielectric*
Iscpropyl biphenyl
Phthalate ester**
Phthalate ester**
Butylated monochloro-
diphenyl ether
* All of the liquid dielectric materials contain small amounts of additives
as free radical scavengers, etc. The identity of these minor constituents
is proprietary information. . . . . .
** The phthalate ester based" liquids reportedly contain a significant amount
of trichlorobenzene as an additive to raise, the.corona extinction-.voltage..
Industrial Cc3G.ci.tors
PC3 capacitors have been used in a number of diverse industrial,
appliance, and lighting applications including arc welders, induction heating
furnaces, fluorescent light ballasts, and television sets. Table 15.3-2
lists the manufacturing plants known to have used PC3s in the manufacture of
this type of capacitor in the early 1970s. Versar contacted these manu-
facturers in September, 1977 to determine whether they were still using PCBs,
and if so, when they anticipated ending their use of PCBs. The results of
these contacts are suntnarized in Table 15.3-3.
All of these manufacturers plan to introduce rr>n-PC3 capacitors
to replace the discontinued PC3 products. In all cases, the new capacitors
will use liquid phthalic acid esters (phthalatas) as a direct substitute for
PCBs. As a result of this material change, an increase of 6% in the size of the
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TKELE 15.3-2
N&nufacturers .of PCS Industrial Capacitors in 1976
Company Name location of the Plant
General Electric Corcany Hudson Falls , N.Y.
Ft. Edward, N.Y.
Aercxox . New Bedford, Jfess.
Universal Mmufacturiiig Corp. Bridgeport, Conn.
Ibtcwa, N.J.
Cornell Dubilier New Bedford, Mass.
P. R. Mallory & Co., Inc. Waynesfccro, Tenn.
Sprague Electric Co. North Mams, Mass.
Electric Utility Co. laSalls, 111.
Capacitor Specialists Inc.' Escondido, Calif.
Jard Corp. Benningtbn, Vt.
York Electronics .. Brooklyn, N.Y. -. .
RF Intercnics Bayshore, L.I./ N.Y.
Axel Electronic, Inc. Janaica, N.Y.
Tbbe Deutschmann Labs. Canton, Mass.
Electro i^gnetic Filter Co. Sunnyvale, Calif.
Source: Versar Inc., PC3s in the United States; Industrial
Use and Environmental Distribution, Springfield, Va.:
'National Technical Infornation Service, (NTIS P3 251 402/3WP) ,
"February_25, 1976, p. 89. Updated by Versar in later
studies, Contract 68-01-3259.
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Table 15.3-3
Manufacturers of Small Liquid Dielectric AC Cacacitors
Company
General Electric
Aerovox
Universal Mfg.
P. R. Mallory
Cornell Dubilier
Jard Corporation
Electric Utility Co.
Others
Small Capacitor
Sales (1975)*
MI n^on $/year
30
24.
13
10
7
4
3
3
Status of PC3 Use as of Late 1977
No PC3s used
PCBs inventory sufficient until
June 1978
Will end PCS use by mid 1978
PCBs inventory sufficient through
March 1978
No information available
Will end use of PCBs during first
quarter, 1978
PCBs inventory sufficient 'throuch
mid 1978 - - -
No use of PCBs after 1977
Source: Office of Environmental Affairs, U.S. Dept. of Commerce
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capacitor is required to provide the same electrical function. As a result of
the size increase/ sore manufacturers who use capacitors in their products will
have to redesign to allow room for the larger capacitors. Capacitors using
metallized plastic film and phthalic acid ester liquid dielectrics are being
tested; if successful, such units would bs the same size as equivalent ?CB
capacitors.
The phthalates are more_flammable than PC3s, and satisfactory
fire safety can be achieved only by incorporation of adequate circuit breakers
(pressure or thermal types) which will prevent rapture of the capacitor case
following electrical failure of the capacitor. Substantial testing has been
required to prove the adequacy of these circuit breaker devices to the satis-
faction of the users of.the capacitors because of the possibility of sub-
stantial product liability claims should a fire problem develop with the non-
PCS units. The development and testing requirements have delayed the intro-
duction of the non-?C3 capacitors. However, rone of the manufacturers'of
small capacitors contacted anticipate using PCBs after mid 1978. Use of PCBs
until then will be based on existing inventories, as Monsanto stopped' shipping
PCBs in October, 1977, and no importation of PCBs is planned by any capacitor
manufacturer.
The switch to phthalic acid esters will increase the demand for "
this class of chemical by approximately twenty million Ib/year, compared to
a total production of about one billion Ib/year. This two percent increase in
demand will not significantly affect either the availability or price of this
material.
Estimation of the unit cost impacts of the PC3 ban regulations on
the industrial capacitor segment of the market is.difficult for several reasons.
First,. Monsanto significantly increased the price of PCBs during 1976 and 1977.
These price increases reflected greater production costs due to environmental
percautions in handling and shipping the material, plus costs incurred through
Monsanto participation in the regulatory process. Monsanto was also in the
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sition of supplying a unique product having a lew price elasticity of
The anticipated regulations presented a high barrier, to entry -into
this market for other possible manufacturers of PCBs, so Monsanto was in a
monopoly position, and their pricing may have reflected this market condition
in addition to general inflationary pressure on all comcdity prices during
this period. The net effect was to increase the price of PC3 capacitors
above what would have been expected under long term competitive conditions
had there not been the threat of regulatory action on the manufacture and
use of PCBs.
At present/ both PC3 capacitors and ron-PCB capacitors are
available/ although from different manufacturers. The non-PC3 industrial
capacitors are selling for about ten percent more than the PC3 units having
the same functional characteristics. Since themanufacturers of 'non-PCB
capacitors do not have the option of producing PC3 units, this price in-
crease may reflect the premium which users are willing to pay for avoiding
any possible impacts of the ban regulations on their operations and inven-
tory rather than reflecting increases in 'manufacturing costs. Equilibrium.
pricing would not be expected to result until PC3 capacitors were no longer
available.
The demand for capacitors is highly inelastic, because close sub-
stitutes are not available and the number of uses to which capacitors ray
be put are limited. Consequently/ capacitor users will be confronted with
prices for non-PCB units which reflect'the additional costs of production
of such units due to the proposed regulation. The increased price of PC3
capacitors and the present competitive pressure' on the pries of non-?C3
capacitors suggests that the long term price increase due to the banning of
PCBs will be more than the present differential of 10 percent. A total
price increase of 50 to 20 percent is perhaps a more reasonable estimate of
the price increase for non-PCB cacacitors.
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Sales of PC3 industrial capacitors in 1976 are estimated to have
been approximately $51.7 million. Assuming relatively-constant output .and.
demand, a fifteen to twenty percent price increase for comparable non-?C3
industrial capacitors will result in sales of from $59.5 to $62.0 million
(using constant dollars). This suggests that users of industrial capacitors.
will pay approximately $7.8 to $10.3 million more for non-PC3 units.
Manufacturers of electrical equipment which will use ncn-?C3
industrial capacitors may face various redesign problems. For example, manu-
facturers of miniature electrical equipment, who specialize in optimizing
space in the construction of their products, may find that the production of
a new, larger capacitor makes the continuation of their miniaturized product
line uncertain. Apartfrom the market for miniature equipment,, most
electrical equipment can be redesigned to.acccmodatje the. sonewhat larger
non-PC3 capacitors at relatively little cost. . '
Capacitors represent a very small fraction of the total production
(i.e., input) cost of a given appliance. Any price increases in final prod-
ucts due to employing ncn-?C3 capacitors will be imperceptable to consumers -
i.e., the increase in price per unit will be so small that the percentage
change .in quantity demanded will be very close to zero. It is expected that
sales of electrical appliances will not be affected appreciably nor will"
there be any dramatic effects on employment in the capacitor production in-
dustry nor in the electrical appliance manufacturing industry.
Users of non-PC3 industrial capacitors may face greater risks of
fire as they switch to such units. Insurance rates will increase to reflect
any increased fire losses, but only after a tiae lag sufficient for new
risks to be incorporated into the experience record.
Any decrease in the expected service life of industrial capacitors
will have a disproportionate effect on economic impacts due to the proposed
regulations. It is estimated that fewer than two percent of all small
capacitors fail before the equipment is scrapped due to obsolescence. The
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t of replacing these capacitors includes cut of service time and high
costs, and may total ten times the retail price of the replacement.
capacitor. The cost of replacing failed capacitors may therefore be
equal to 20 percent of annual industrial capacitor sales. If shortened
service life results in an increase of the rate of failure to 5 percent of
the non-?CB units prior to obsolescence, the increased replacement costs
could be 50 percent of the value of the total small capacitor market.
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15.4 Summary
Costs:
Redesign of equipment-to acconcdate
larger capacitors
Long Term Costs:
Power factor capacitors
Price increase for ncn-PC3 capacitors $5.5 to 10.9 million
per vear
Industrial capacitors:
'Price increase for ncn-?C3 capacitors . $7.8. to-10.3 million
per year
Increased fire risk * . '
Decreased service life *
Employment Effects: Not expected to be significant
*Insufficient data available to support estiirate of impact.
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16.0 TRANSFORMER
Liquid filled transformers containing a PCS based liquid known generically
as 'askarel1 have been used for many years in those installations "where'the
risk of fire justified the usa of a fire resistant fluid. Askarel transformers
have been .allowed to be installed in hazardous locations such as "in buildings '
without the requirement for a fire proof vault or fire sprinklers. No sub-
stitute transformer liquids have yet been developed which have fire resistant
properties equal to the PC3 based askarel.
16.1 Requirements of the Proposed Regulations
i
The proposed regulations would prohibit the manufacture of new
PC3 tranformers after December 31/ 1978, but classify continued use of existing
PCS transformers except, those used in railroad locomotives as use in a totally
enclosed Tanner. The regulations would authorize certain minor maintenance of-
existing transformers for five years after the effective date of the regulation
but would prohibit major rebuilding of failed-'units. It is 'assumed that
authorization for minor maintenance would be granted on request after the five
year servicing authorization has expired as such maintenance decreases the
risk of catastrophic failure of transformers and minimizes the risk of loss of
?C3s to the environment. Disposal requirements for failed askarel transformers
are specified by the PC3 Marking and- Disposal Regulations, and these require-? .
ments would not be changed by the proposed PCS Ban Regulations.
16.2 Industry Structure, Production, and Sales
A review of Monsanto's customer list for PCBs in the early 1970s
indicated thirteen companies which used PCBs to manufacture askarel trans-
formers. These companies and the location of their transformer manufacturing
plants are listed in Table 16.2-1. Production of askarel transformers averaged
5000 units per year in the early 1970s. When these companies were contacted
by Versar in September, 1977, only-one manufacturer was still producing askarel
transformers, and it anticipated' ceasing production of this type of unit prior
to the end of 1977. All of these manufacturers produced both oil filled and
askarel transformers in the same plants. Oil filled transformers are inter-
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Table 16.2-1
U.S. Transformer Manufacturers Which Used PC3s After 1970
Company Name Plant Location
Westinghouse Electric Corp. South Boston, Va.
Sharon, Pa.
General Electric Company Home, Ga.
Pittsfield, Mass.
Pesearch-Cottrell Findeme, N.J.
Niagara Transformer Co. : Buffalo, N.Y.
Standard Transformer Co. Warren, Chio
Medford, Oregon
Helena Corp. Helena/-Alabama
Hevi-Duty Electric Goldshnrs, N.C.
Kuhlman Electric Co. Crystal, Scrings, Miss.
Electro Engineering Works San Leandro,. Calif. '- -
Envirotech Buell Lebanon, Pa.
R..S. Uptegraff Mfg. Co. Scottsdale, Pa.
H.K. Porter Belmont, Calif.
Lynchburg, Va.
Van Tran Electric Co. Vandalia, 111.
Waco, Texas
Source: Versar Inc., PC3s in the United States; Industrial Use
and Environmental Distribution, Springfield, Va.: National
Technical Information Service (NTIS P3 251 402/2WP),
February 25, 1976, p. 89.
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changable with askarel transformers in new applications provided that the
installation is properly engineered. Other substitutes for askarel transformers "
are also available. The 140,000 askarel transformers presently in service.total .
only two percent of the total number of power and distribution transformers in use.
16.3. Substitutes for PCB Transformers '"'
The askarel transformers presently in service were specified
because this type of liquid filled transformer offered advantages in size,
reliability, and fire safety-that were not available with other types of trans-
formers. Alternatives to PCS transformers have always been available, although
all of the other types of transformers have different design characteristics
and none are direct substitutes for the PCS units. Therefore, eventual re-
placement of the existing PCB transformers will require that each of the pre-
sent installations be re-evaluated and that the necessary engineering changes
be made to allow use of the best available replaceirent::uni£i,r New transformer
' ", *'"'*'-."
installations will be designed to make optimumaise of. trie avail-able rten-PCBs--- ' -
transformers. The choice among the available alternate transformer types and
materials depends on the requirements of each specific application and-the
characteristics of the available non-PC3 units.
A number of alternatives to the use of PC3s in fire resistant
liquid filled transformers and to the- use of transformers which contain any . .
dielectric liquid have been developed and are conmercially available. These
substitutes for PCB transformers differ in-, their performance characteristics,
applicable fire code installation requirements, and cost. The following sections
discuss the major types of substitute units which are available.
3-igh Fire Po'int Lion-id Insulated.-Trimsformers
The 1975 National Electrical Code and previous issues allowed
only the use of askarel and dry type transformers in hazardous locations with-
out vault- protection. Askarel was essentially defined as PCB based liquid.
The 1978 NBC has added a specification (Article 450-23) for 'High Fire Point
Liquid Insulated Transformers' which can be used under these same conditions.
The 'High Fire Point Liquid1 must have a fire point of at least 300°C,. and
must not propogate flames.
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Underwriters Laboratory, presently lists three liquids as
meeting the 'High Fire Point1 property requirements for transformers operating
at voltages below 600V: - - . "
Dow Corning 561
General Electric SF-97 (50)
SWS Silicones Corp. F-190 . .
Factory Mutual Research has not yet completed developing
formal approval requirements and procedures for 'High Fire Point Transformer
Liquids'. However, based on preliminary tests, Factory Mutual has issued
interim guidelines to its field offices that six silicone 'liquids and three
hydrocarbon liquids could be accepted at Factory Mutual insured locations
without special fire protection. The list of Factory Mutual accepted liquid
includes:
Supplier ' Designation Type .of Fluid
Dow Coming DC 561 Silicone
Dew Corning DC 200 Silicone
General Electric SF-97 Silicone
Union Carbide L-305 ' Silicone
SWS Silicones . F-101 ' Silicone
SWS Silicones F-190 Silicone
KTE Corporation RTEmp- . Hydrocarbon
Gulf Oil Chemicals Co. EF Dielectric Hydrocarbon
Fluid
Uniroyal ' PAO-20E Hydrccarbon
Mineral Oil-Filled Transformers
If fire safety were not a consideration, there '.vculd be no rea-
son why oil-filled transformers could not be used in all applications. In the past,
PC3-filled transformers have cost about 1.3 times as much as oil-filled units
of the same capacity, and thus most users preferred the oil-type where possible.
The oil-filled transformers are the same size as the askarel units, and are
considerably lighter in weight. Also, mineral oil has somewhat better heat
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transfer characteristics .than askarel, and an electrical arc in mineral oil"
results in breakdown products that are non-corrosive.
The major disadvantage to mineral oil is flairmability; trans-
former mineral oil has a flash point of 145°C. If an arc occurs with the
transformer, the breakdown products will be hydrogen and methane /'both of which
are flammable. Detailed records of such failures are maintained by the
electrical industry. Fire Underwriters dees not approve of the use of oils and
other flaimahle liquids for indoor applications. Where oil-filled transformers
are not specifically prohibited as on-site replacements for PCS-filled units,
the National Electrical Code imposes certain restrictions- upon their mode of '
installation.
Oil-filled transformers are used in almost all power trans-
former applications and for most substation distribution applications where
the transmission .line high voltage is reduced to 12.8 kv for local distribution.
Most rural pole-mounted transformers which reduce the voltage to 220"-volts are ' -
also oil-filled. The issue of flammability only beccmes important where the
distribution transformer must be buried, as in many urban applications-, or
located close to, within, or on the roof of the building it serves. PCS-filled
transformers have, in the past, been used in most such applications. Oil-fill^
transformers can be used in these applications only if they are suitably iso-
lated from flaimable structures or if these structures are suitably safeguarded
against fires. When transformers are located outside the building they service,
the low-voltage power must be brought into the building via cables or insulated
buses. This causes additional energy losses due to heating in the low-voltage
transmission 1 ^«=»g from the transformer to the point of use.
Oven A-Lv-Cooled Transformers
Transformers can be built without the use of a liquid cooling
medium. One type of dry transformer that is quite successful, under limited
conditions, is the open air-cooled transformer. In this design, cooling air
is driven through the transformer by either natural convection or forced circu-
lation. In those sizes where air-cooled transformers are available, they are
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about equal in pries to askarel-filled transformers of the same kva rating. '
However, the following limitations prevent open-air-cooled transformers from
being considered for many applications using askarel-filled transformers;
Heat capacity; The power drawn from a transformer usually
varies over a wide range. The rating of a transformer is established by the
power it can handle continuously without over-heating. If a liquid-filled
transformer is operated at overload conditions for a short period of time, the
liquid will act as a heat sink, absorbing the excess heat produced in the trans-
former without a rapid increase in temperature. The result of this thermal'
inertia is that liquid-filled transformers can operate at-outputs of up' to 200
percent of rated capacity for a period of one to two hours without damage.
Air-cooled transformers do not have this heat sink effect and are limited to
operating at a maximum service rating not much higher than the continuous
rating. Where the current draw on the transformer does not vary greatly during
the day, this limitation is not a problem. However/ in most cases the varia- .
tion in load requires dry transformer to have a 20 to 30 percent greater capac-
ity than liquid-filled transformers in the same application.
Dielectric strength; The liquid coolant in a liquid-filled
transformer also provides a significant level of electrical insulation between
the various current carrying components within the transformer. Air has a much
lower dielectric strength, and open-air-cooled transformers are limited to a
maximum voltage of 25 to 40 kv.
The problem of electrical insulation is even more severe
if the open-air-cooled transformer only operates intermittently. When the
transformer is operating, the heat generated within the windings keeps the
insulation dry, and maintains a high dielectric strength of this solid insula-
ting material. However, when the transformer is net operating, the coils cool
to ambient temperatures and the insulation can absorb moisture from the air
which reduces its dielectric strength. Open air-cooled transformers must be
thoroughly.dried before being put into service after each cool period.
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One other problem with air-cooled transformers is the tendency "
of dust to be attracted from the air to the coils by electrostatic forces.' Dust
can build up in the coils and block the flew of air, or it can form conductive
paths and cause short circuits.
Cpen-air-ccoled transformers are generally limited to dry,
clean locations where the load requirements are fairly even and constant, and
where the maximum voltage dees not exceed 30 kv. Such transformers are being
successfully used in large office buildings, particularly tall buildings where
the transformers are located every few floors. Even in this application, though,
conditions arise that exceed the capabilities of the transformer; for instance,
in the Sears Tcwer in Chicago, which is over 1400 feet tall, the electric power
is brought into the building and up to the distribution transformers at .128 kv,
which is beyond the voltage limitations of open-air-ccoled transformers.
Closed Gas-^Zlsd Trans formers
Transformers can be built with dry inert gas (usually at an
elevated pressure) as a heat transfer medium. These transformers, avoid the
maintenance problems caused by moisture and dust in open air-cooled transformers,
but they are similarly limited in overload capacity because of reduced thermal
inertia (-oompared to liquid-filled transformers.
Closed gas-filled transformers must be installed in pressure-
tight containers due to the changes in gas pressure caused by changes in temper- '
ature. However, the maximum voltage ratings of gas-filled transformers can
be equal to that of liquid-filled units.
A number of different gases have been used as heat transfer
media in closed gas-filled transformers. The most camion gas used in the U.S.
is the fluorocarbon hexafluoroethane (CjFs). Nitrogen and sulfur hexafluoride
have also been used successfully in certain applications. Helium has not been
found to be a satisfactory gas for this application because its low dielectric
strength results in corona discharges within the transformer. Hydrogen is un-
satisfactory as any leak in the transformer would result in a severe fire
hazard.
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Because' of the necessity for a pressure vessel container/
gas-cooled transformers are- 30 'to 40 percent heavier than PCB-filled transformers,
and cost two-thirds more (and twice as men. as oil-filled transformers). In ad-
dition, the gas-filled transformers must be sized larger than oil-filled units .
to allow for the expected heavy load peaks of power ccnsunpticn,
16.4 Relative Prices of Nsn-PCS.Transformers
The relative prices of distribution transformers of the size
and type commonly installed in office buildings are summarized in Table 16.4-1.
If the KTSnp high fire point liquid filled transformer proves to be acceptable (
for installation without auxiliary fire protection, there should be no cost
increases for new transformer installations resulting frcm the ban on the
manufacture of PCS transformers. The open dry type transformers are also quite
cost conpetitive with the PC3 units for most applications,
Table 16.4-1(1) .-. .. '- -. - -
Relative Transformer Prices
Type of Unit Price; 1000 KVA Unit Price: 2000 KVA Unit
Oil filled $ 15,300 ' $ 23,300
FCB - . 19,900 30,300
SlSnp 18,400 28,000
Siliccne 22,300 34,500
Open air cooled 20,700 35,000
Sealed gas cooled 30,600- 46,600
Source: MCC Engineers, "Distribution Transformer Status -. wn Project",
Memorandum to U.S. General Services Pdministraticn, June 1, 1977.
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16.5 Compliance Costs
Clean-uv Costs.
The only costs incurred by transformer manufacturers due to the
ban on the use of PCSs will be clean up and disposal costs incurred in flushing
PCBs from storage and material handling equipment prior to using this equip-
ment to store high fire point liquids. This equipment consists primarily of
storage tanks, filters, pumps, and piping. Clean up costs, including disposal
of contaminated solvents, should not exceed $10,000 per plant, or a total one
time cost impact of perhaps $100,000 in 1977 and 1978.
i
Cost of Subati.tu.tes
The 'high fire point liquid cooled transformers' and air cooled
transformers will cost about the same to 10% more than askarel units' depending
on the acceptability of hydrocarbon base high fire point transformer liquids.
Based on past sales of 5000 askarel units per year at an average price -of
$20,000, a 10% cost increase would increase to sales and costs to the users by
(5000 x $20,000 x 10% = $10,000,000 per year). There should be no effect on
total demand for transformers for new applications. The ban on rebuilding askarel
transformers may increase the demand for new transformers by 1000 to 2000 units
per year. This additional demand should be easily supplied as the transformer
manufacturing industry as it has recently been operating at only about 60% of"
capacity.
Market structure should not be significantly affected as all of
the former manufacturers of askarel transformers will have equal access to
the 'high fire point transformer liquid' materials and technology. Access to
this market segment will open to those transformer manufacturers who did not
offer askarel as an alternative to oil. This will primarily afford a marketing
opportunity to RIE Corporation which has never supplied askarel units but which
has a strong market position in the high fire point liquid transformer market .
segment. The increased sales by RIE will probably be less than the total
increase in transformer sales, so this small shift in market structure should
not result in a net decrease in the sales by any of the other manufacturers.
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. Increased ?£re Losses ' '
It was implicitly -assumed above that the high fire point liquids
are satisfactory replacements for PCBs in tenns of performance and fire saftey.
In fact, the high fire point liquids can burn under certain conditions including .
exposure to an external fire, and can release flammable gases if an electrical
arc occurs within the transformer. It will be several years until a complete
evaluation of the relative transformer fire risks is conpletsd by the Fire
Safety Division of the National Bureau of Standards under a research project
currently being funded by the U.S. Department of Energy.
It will not be possible to accurately predict the increased fire
losses that may result fron the use of substitutes for PC3s transformers until
the work of the Bureau of Standards is conplete. Any estimates made at .this
time must necessarily be based on rather crude assumptions. It could be assumed,
for example, that the 20% price premium for askarel transformers vs oil filled
transformers was justified by a decrease in-fire losses. The- use of a- high- fire
point transformer liquid might achieve 95% of the additional fire safety that
would otherwise be achievable by using askarel. The increased fire losses re-
sulting fran the use of the high fire point liquid filled units v*3uld then be
one percent of the 'cost of the units. Based on a production of 7000 new and
replacanent units per year at an average price of $20,000 each, this loss _
would be $1,400,000 per year.
16.6 Summary
Transitional Costs
Clean up costs for manufacturers. $100,000 1978 only
Lang Term Costs
Increased cost of ncn-PC3 transformers $0 to $10 million
per year
Additional fire losses frcra use of
ncn-PC3 transformers $1,400,000 per year
(very rough estimate)
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Employment '
Increased demand for replacement transformers should generate
employment equal to that lost in the transformer rebuilding segment of the
industry (see Chapter 5). An additional 78 jobs would be expected in 1979.
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17.0 TOTAL COST AND ECONOMIC IMPACTS ...
The preceding chapters have discussed the' various costs which will
result from compliance with the proposed regulations. Costs of decontaminating
or scrapping existing equipment, preparation of spill control plans, and the
costs associated with the. ban on rebuilding askarel transformers are all'
transitional costs the annual costs will eventually decrease to zero, though
this may require 20 years or more. Cost increases due to the increased prices
for non-PC3 capacitors and transformers will be long term costs they will be
expected to continue indefinitely.
Bconcmic impacts, as distinct from cost impacts, include employment
effects, changes in market structure, and impacts on energy demand and the
international balance of trade. These impacts, too, can be both transitional.
and long term. .
17.1 Transitional Cost Impacts
See Table 17.1-1.
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Table 17.1-1
Itam (O tauter)
PCU Tranafonnerat
Manufacturer clean up coats (16)
Ban on Rebuilding (4)
Foregone Savings
loot Service Tline
Transformer Service (5)
Lost Kagea
Spill Prevention Plan
locomotive 'IVaiibfoimert (6)
Retrofill Pctxjrun .
Proceaalivj Program
Final Analyaia for KBa
Spill Prevention Plan
PCB Capacltora
&jtil(iieiit Rolealcjn (15)
Inventory Ct>aoleaceix:a (3)
Oil Filial Trans fonnara (7)
1CU Analysis aid
Transitional Cost
Impacts
$ Million Per Year
1979
.» -1
14.3
2.4
1
' 1
7
0
0
.005
.02 "
Succeeding $ Million
Years Ibtat
0 $ .1
3.4% less 420
per year
3.4% leaa 75
per yuar
0 1
0 1
0 7
2.7 (2 yeara) 5.4
.1 (1983) .1
0 .005
0 .02
Estimated
I(el lability
of 'lUtal
-50% +500%
150%
150%
1100% '
1100%
120%'
120%
120%
1100%
150%
Mining Machines (0)
Heliuilt] loadera
Scrap Continuous Mineru
RiL-|ortii>j Coat a
Spill Prevention Plaita
3.4% lesa
per year
Ly Doc. 31, 1901
OD»i>lete lv Due. 31, 1901
.02 . '0
i
.04 . 0
700
.6
.02
.04
1100%
130%
120%
150%.
1100%
1501
*Data not available to aupport eatinptoi probably tanall coat lic|iact.
-------
Table 17.1-1 (Con't)
Transitional Cost Impacts
Itvm (Clvapter)
Kluctranagneta (9)
Replacement Coat
Increased Labor Coata
Hydraulic Systems (10)
Die Casting Machines
Analysis ai
Prevention Plans
Decontamination
OtJier llyilraulic Syutema
Decontamination .
Production Inter nipt ions
Heat Transfer byatuus (11)
Ouui-uressora (12)
Reolaiinud Oil (13)
Increased (lust of Syritlietic: Road
Oil Material
Increased Cost of Kotui Oil
lost 1'iixlictloii of
Hydraulic FluM
Plitlialocyanine l'l<)ii«aita (14)
Process
1979
$ 3.5
.5
.a
.2
.5
7.3
3.6
«
*
.2
100
.4
.5
$168.3 millkiu
Succeeding
Years
0
0
0
0
0
7.3 (1980)
0
0 *
I'
0
0
100 (yeara
6.4 (yeara
.4 (1980)
0
$ Million
Tt>tal
$ 3.5
.5
.a
.2
.5
14.6
3.6
*
*»
.2
2-5)**** 500
6-15) 64"*
.8
.5
$1,802 million
caiiuauBa
Reliability
of total
120%
-100% 1900%
150%
150%
140%
-30% 1200%
-30% +100%
A*
. **
-50% 1100%
-80% 110%
-80% 1200%
120%
-50% +200%
-60% 140% ,
[vita not available to support eatiiitate. (oteiitlally larue coat ln|joct.
Ooatu to continue Indefinitely until waste iuliiatrlal oil no loivjev oontaina maasurabla amounts of
Hipper bouiKl estimate. Decreased ilaiuiiJ nuy result ill alcjnlCicantly roJucttl
-------
17.2 long Term Cost Impacts
Transformers: (Chapter 16)' ..-...
Increased cost of non-PCB transformers $0 to 10 mi11.-i.on/year
Increased fire losses Data not available
Capacitors; (Chapter 15)
Increased cost of non-PC3 power factor
capacitors . $5.5 to 10.9 million/year
Increased cost of non-PCB capacitors $7.8 to 10.3 million/year
(± 50%) ' -
Increased fire losses Data not available
Decreased service life Data not available
Diarylide Yellow Pigment (Chapter 14)
? .
Increased cost of substitute pigments $10 to 25 million/year^ '
Total $23 to 56 million per year
Present value of long term cost iinpacts assuming
10% discount rate = $230 to 560 million
17.3 Bnployment Impacts
Item (Chapter) : ' tto. of Jobs ' (1979) Total Man Years
PC3 transformers ' -
Rebuilding -50 -1470
Railroad transformers (6)
Ketrofilland decontamination
program - +5s + 165
Oil Filled Transformers (7)
Analysis +42 to 106 +1235 to 3118
Disposal services +69 to 110 +2029 to 3235
Mining Machines (8)
Spill Prevention Plans +2 +2
Electromagnets (9)
Increased demand +50 +25 to 32
Additional T^hnr for Operations
without Magnets +50 + 17
Hydraulic Systems (10)
Decontamination Program +12 + 24
-123-
-------
Item (Chapter)
Nb. of Jobs (1979)
Total Man Years
lost Production frcm
closing of facilities during
decontamination
potential for thou-
sands of layoffs early
in 1979 in the steel
industry for several
months
-500?
Spill prevention plans
Reporting requirements
Heat Transfer Systems (11)
Decontamination program
Compressors (12)
Decontamination program
Reclaimed Oil (13)
Ban on reclamation of contaminated
hydraulic fluid
Diarylide Yellcw Pigments (14)
Loss of jobs in manufacture of pigments
Capacitor Manufacturing (IS)
Transformer Manufacturing (16)
+5
+7
+1
-12 to'15
-200
0
-i-15
5
7
-24 to 30
Job losses offset
by"increased employ-
ment in manufacture
of substitute
materials.
0 -
+1470
17.4 Other Scoromic Impacts
No significant-market shifts are anticipated to result from the ban
on the use of PCBs in the manufacture of capacitors or transformers.
The only significant impact on energy demand will be for the oil
required to replace the contaminated transformer oil, hydraulic fluid, heat
transfer fluid, and compressor fluid which must be drained and incinerated as
part of the decontamination program. This requirement will be insignificant
when compared with total oil consumption, particularly since the increased
demand for transformer oil will be spread over 20 years or more.
-124-
-------
A number of minor effects on the balance of trade may be
anticipated. The ban on the importation of PC3 capacitors in foreign made
electrical equipment might decrease 'the availability or slightly increase
the price of imported appliances. The restriction on the PC3 contamination
of diarylide yellow pigments might end the importation of this material,-
However/ the ban on recycling contaminated transformer oil would be expected
to result in an increased demand for new oil, and the ban on the rebuilding
of transformers will increase the. number of new transformers being manufactured
resulting in an increased demand for bauxite to make the aluminum wire used"
in their construction. Sufficient data is not available to support a qoantita-
tive analysis of these effects, and the total impact on the balance of trade
is not expected to be significant.
No significant impacts on supplies of strategic materials were
identified in the course of this study.
-125-
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APPQDIX A
TOXIC SUBSTANCES CONTROL ACT
Public Law 94-469"
90 Stat. 2003 et aeq
Page A-2: Section 6(e): Polychlcrinated
Biphenyls
Page A-3: Section 6(a): Scope of Regulation
A-l
\
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PUBLIC LAW 94-469OCT. 11, 1976
90 STAT. 2025
(e) PoLTCHtoRt^ATTD BiPHE>tTxs.(1) Witliia sis months after Rule*.
the affective date of this Act the Administrator ahull promulgate
rules to
(A) prescribe methods for the disposal of polychlorinated .. -
biphenyis, and ' '
(B) require polychlorinated biphenvls to be marked with clear
and adequate warnings, and instructions with respect co their
processing, distribution in commerce, use. or disposal or with
respect to any combination of such activities.
Requirements prescribe^ by ntles under this paragraph shall be con-
sistent with the requirements of paragraphs (2) and (3).
(2) (A) Except as provided under subparagniph (B), effective one
year after the effective date of this Act no person may manufacture,
process, or distribute in commerce or use any polychlorinated biphenyl
in any manner other than in a totally enclose'd manner.
(B) The Administrator may by rule authorize che manufacture,
processing, distribution in commerce or use (or any combination of
such activities) of any polychlorinated biphenyl in a manner other than
in a totally enclosed manner if the Admuustmtor finds that such manu-. . . ,
facture, processing, distribution in commerce, or use (or combination
of such activities) will not present a-n unreasonable risk of injury to -
health or the environment.
(C) For the purposes of chis paragraph, the term "totally enclosed "Totally enclosed
manner" means any manner which will ensure ahac any exposure of manner."
human beings or the environment to a polychlorinated biphenyl will
be insignificant as determined by the Administrator by rule.
(3) (A) Except as provided in subparagraphs (B) and (C)
(i) no person may manufacture any polychlorinated biphenyl
after two years after the effective date of this Act, and
(ii) no person may-process or distribute in commerce any poly-
chlorinated biphenyl after two'and one-half years after such date.
(B) Any person may petition the Administrator for an exemption Pearioo for
from the requirements of subparagraph (A), and the Administrator exemption.
may grant .by rule such an exemption if the Administrator finds
that
(i) an unreasonable risk of injury to health or environment
would not result, and
(ii) good faith efforts have been made to develop a chemical
substance which does not present an unreasonable risk or injury
to health or the environment and which may be substituted for
such polychlorinated biphenyl.
An exemption granted under this subpaitigraph shall be subject to Terms »d
such terms and conditions as the Administrator may prescribe and condition*.
shall be in effect for such period (but not more than one year from
the date it is granted) as che Administrator may prescribe.
(C) Subparagraoh (A) shall not apply to the "distribution in com-
merce of any polychlorinated biphenyl if such polychlorinated
biphenyl was sold for purposes other than resale before two and one
half vears after the date of enactment of this Act. "
(4) Any rule under paragraph (1), (2)(B), or (3) (B) shall be
promulgated in accordance with'paragraphs (2), (3), and (-1) of sub-
section (c).
(5) This subsection does not limit the authority of the Adminis-
trator, under any other provision of this Act or any other Federal law.
to take action respecting any polychlorinated biphenyl.
A-2
-------
SEC 8. REGULATION OF HAZARDOUS CHEMICAL SUBSTANCES AND
MIXTURES.
IS USC 2605. (a) SCOPS OP REon-moN1.If the Administrator finds that there is
__ a, reasonable basis to conclude that the manufacture, processing, dis-
tribution in' commerce, use, or disposal of a chemical substance or
mixture, or that any combination of such activities, presents, or-will
present an unreasonable risk of injury to health or the environment.
the Administrator shall by rule apply one or more of the following
requirements to such substance or mixture to the extent necessary to
protect adequately against such risk using the least burdensome
requirements:
(1) A requirement (A) prohibiting the manufacturing, process-
ing, or distribution in commerce of such substance or mixture, or
(B) limiting the amount of such substance or mixture which may
. be manufactured, processed, or distributed in commerce.
(2) A requirement
(A) prohibiting the manufacture, processing, or distribu-
tion in commerce of such substance or mixture for (i) a
particular use or (ii) a-particular use in a concentration in
excess of a level specified by the Administrator in the rule
imposing the requirement, or
(B) limiting the amount of such substance or mixture
which may be manufactured, processed, or distributed in
commerce for (i) a particular use or (ii) a particular use
"in. a concentration in excess of a level specified by th"e
Administrator in the rule imposing the requirement.
(3) A requirement that such substance or mixture or 'any
article containing such substance or mixture be marked with or
accompanied by clear and adequate warnings and instructions
with respect to its use, distribution in commerce, or disposal or"
with respect to any combination of such activities. The form and
content of such warnings and instructions shall be prescribed by
the Administrator.
(4) A requirement that manufacturers and processors of'sucn
substance or mixture make and retain records of the processes
used, to manufacture or process such substance or mixture and
monitor or conduct tests which are reasonable and necessary to
assure compliance with the requirements of any rule applicable
under this subsection,.
(5) A requirement prohibiting or otherwise regulating any
manner or method of commercial use of such substance or
mixture.
(6) (A) A requirement prohibiting or otherwise regulating any
manner or method of disposal of such substance or mixture, or
of any article containing such substance or mixture, by its manu-
facturer or processor or oy any other person who uses, or disposes
of, it for commercial purposes.
(B) A requirement under subparagraph (A) may not require
any person to take any action which would be in violation of
any law or requirement of, or in effect for, a State or political
subdivision, and shall require each person subject to it to notify
each State and political subdivision in which a required disposal
may occur of auch disposal. .'"*
(7) A requirement directing manufacturers or processors of
such substance or mixture (A) to give notice of such unreasonable
risk of injury to distributors in commerce of such substance or
mixture and. to the extent reasonably ascertainable, to other per-
sons in possession of such substance or mixture or exposed to such
substance or mixture, (B) to give public notice of such risk of
injury, and (C) to replace or repurchase such substance or
mixture as elected by the person to which the requirement is
directed.
Any requirement (or combination of requirements) imposed under
this subsection may be limited in application to specified geographic
areas.
A-3
-------
-------
Assessment of Industrial Hazardous Waste Management Practices, a document pre-
pared for EPA's Office of Solid Waste and presented with testimony of H.
Tinier Hicknsn, December 12, 1977.
flnttrak, 1976 annual Report.
Aratrak, Five-Year Corporate- Plan, 1977.
Bureau of the Census, Electrical Measurement and Distribution Eouicment,
Report No. MT72(2)-36A, Table 6A.
Consolidated Rail Corporation, Annual Report, 1976.
/m
Dow Corning Corporation, Removal of PG3 from Dow Coming 56V Transformer
T igni^, by Ctv*'T|!?ev*V F^ ltra.t"^on, updated.
Electrical Apparatus Service Association Inc., 1977-1978 Yearbook; St. Louis
MO: 1977. --.-
ENSCO, General Information ENSCO-PC3-001 Rev. 3-73, El Dorado, Arkansas:
March 1973!~
PA, "Final Decision", Federal Register, February 2, 1977, pp. 6531-S555,
PA, "Polychlorinatsd Biphenyls (PCBs): Disposal and Marking", Federal
rister, February -17, 1978, pp. 7149-7164.
Foss, Stephen D.; Higgins, John B.; Johnston, Donald L.; McQuade, James 'Ji.:
(General Electric Co.), Retrofilling of Rai.lroad Transformer, Draft Finail
Report, Contract DOT-TSC-1293, July 1977. :;":"
Hofstader, R.A. (Exxon Research and Engineering Co.); Ldsk, D.J., Bache, C.A.
(Cornell University), "Interference in the Electron-HCapture Technique for
Determination of Polychlorinated Biphenyls by Sulfur-Containing Compounds in
Petroleum Products", Bulletin of Snvironrental Contamination and Toxicology,
Vol. 11, NO. 2, 1974.
Kuratsune, Masanori, et. al. / "Yusho, a poisoning caused by rice oil con-
taminated with polychlorinated biphenyls", RHSMHA Health Reports, Vol. 86,
No. 12 (December 1971), pp. 1083-1091.
Lapp, T.W. (Midwest Research institute), The-Manufacture and Use of Selected
Aryl and Alkyl Aryl Phosphate Esters, EPA 560/6-76-008, February i97lT
-------
REFERENCES, CXUTINOED
y- Robert ^."^Continental Forest Industries) , testimony presented at
infernal hearings on the PCS ban regulations/ Washington, D.C. ,
JUly IS, .
, v' -''7'',"*'*"" " " '
Majaeh,. T.W. , "Rerefined Oil: An Option That Saves Oil, Minimizes Pollution",
e -193.., p. 1108-1110, Septsnber 17, 1976.
'
Authority, Annual Report, 1976.
Michigan, Department of Natural Resources, File MSno, undated.
,';'"' ': '.'. .-"«' '
Jtoisanto Chemical Conpany, Arcclors for -, St. Louis, Mo.: undated.
of .Transportation, Hichliohts of activit-ies, 1976.
*/ T.'; ..Faab, E. (General Electric Co. ) , U. S . Transf cnner '_ Oil.' Supply and
, ,197S-l;985, Interim Report,- Palo Alto /Calif.: Electric. Power" Research
-Ihstsl-tiite -(Report No. EL-303) , Nov. 1976. . .
SS^CIA,; ..-gegort .to the Public ard Financial Statements for 1374 and 1975 - -
Staite?nent qt Operations.
(Outboard J'larine Corp.) , Presentation at the EPA Informal ' Hearings
on the PCS; San' Regulations , Washington, D.C. , July 15, 1977.
U.S. Department of Agriculture M Hoc Group on PC3s. Agriculture's Responsi-
bility Concerning Polychlorinated Biphenyls (PCSs) Washington, D.C. : Orrice
of Scieraee and Education, U.S. Departrnent of Agriculture, 1972.
U.S. Departinent of Comierce, Electrical Measuranent and Distribution Squipnaent,
Publication tC(2-36A) .
Versar; Inc. , Assessment of the Environigntal and Sconanic impacts of the San or.
Imports of; PC3s, EPA 560/6-77-007, February 22, 1977.
Versar Inc., Involvement of PCSs in the Pulp ard Paper Industry, EPA 560/6-77-005,
February 25,, 1977.
Versar Inc;.., MicrcecDTxinic Impacts of the Proposed Marking and Disposal Regu-
lations for PCBs, (EPA Report .No. 560/6-77-013), Springfield, Va.:' National
Technical Information Service (NTIS No. PB-267 333/2vP) , April 26, 1977.
Versar Inc., PCS Activity Analysis Papers, Special Report, EPA/OTS, July 11, 1977.
Versar Inc., PCBs^in the United States; Industrial Use ard Snyironnental Sistrihu-
tion. Springfield, Va. : National Technical Information Ser/ice (NTIS ?S
23T"402/3WP) . February 1976.
-------
REFERENCES, CCOTTOUED
Versar Inc., Price Schedule' Quantitative Analysis of PCSs in 10-C Transfpaner.
Oil (Price Sheet 100), Springfield, Va.: May 1/1978. " :\>: ^
Versar Inc., Usage of PC3s- in Cpen and Semi-Closed Systems and the" Resulting y''%:-
Dosses of PCBs to the Environment. EPA 560/6-77-009 (unpublished Draft Repjiart).,...
September 1, 1976. . f'-~ ''^ : -^
Walsh, E.J.; Voytik, D.S.; Pearce, H.-A. (Westinghouse Electric Corp.) Svaluajt^jQji.,
of Silioone Fluid for Replacement of PCB Coolants in Railway Industry,
Final Report, Report No."DCT-TSC-1294, July, 1977.
Ward, William (General i^totors Corporation), Presentation at the EPA Hearings---'ori:-.
the PC3 Ban Regulations, Chicago, Illinois, July.19, 1977. .'/ ' :'.. ->.^-
George (United States Department of Interior, Denver, Colorado), &.
"Polychlorinatad Biphenyls", File HLS 3-3-10h, June 13, 1977.
Weinstein, N.J. (Recon Systans, Inc.), Waste Oil Recycling and Disposal,JP' " v" ":""^
670/2-74-052, Princeton, N.J.: August, 1974. . _ .
- -.*.'<: «'\
.-^-t^-
'?*+% , , ;;?"' *:
,-'' . v v. ""'£ **J^'.
-------