POLYCHLDRINATED BIPHENYLS
           1929  -  1979:
           FINAL .REPORT
             May 1979
U.S. EJ^VTRaMEOTAL PROTBCTICN AGENCY
     Office of "toxic Substances
       Washington, D. C. 20460

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      This document is available in limited quantities through the U. S.
Environmental Protection Agency, Industry.Assistance Office, Office of Toxic
Substances (TS-793), 401 M Street, S.W., Washington, D.C.  20460.
      This document will subsequently be available through the National
Technical Information Service, Springfield, Virginia, 22151.

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560/6-79-004
              POLYCHLORINATED BIPHENYLS 1929-1979 :

                          FINAL REPORT
                          Final Report
                          Submitted,to:

              U.S. Environmental Protection Agency
                   Office of Toxic Substances
                     Washington, D.C.  20460

                   Attention:  Mr. Thomas E. Kbpp
                               Project Officer
                     Contract  No. 68-01-3259
                          Submitted by:

                          VERSAR,  INC.
                      6621 Electronic Drive
                  Springfield, Virginia  22151
                          (703) 750-3000
                           May 16,  1979
                              C

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      This report has been reviewed by the Office of Toxic Substances, U. S.
Environmental Protection Agency/ and approved for publication.  Approval does
not necessarily signify that the contents reflect the views and policies of
the Environmental Protection Agency, nor does mention of tradenames or cottner-
cial products constitute endorsement or recommendation for use.

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      This document is available in limited quantities through the U. S.
Environmental Protection Agency, Industry Assistance Office, Office of Toxic
Substances  (TS-793), 401 M Street, S.W., Washington, D.C.  20460.
      This document will subsequently be available through the National
Technical Information Service, Springfield, Virginia, 22151.

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      This report has been reviewed by the Office of Toxic Substances, U. S.
Environmental Protection Agency,  and approved for publication.  Approval does
not necessarily signify that the contents reflect the views and policies of
the Environmental Protection Agency, nor does mention of tradenames or ccrrmer-
cial products constitute endorsement or recommendation for use.

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                                 PREFACE
     This report summarizes the work on Polychlorinated Biphenyls  (PQBs) that
Versar performed for the U.S. Environmental Protection Agency under Contract
No. 68-01-3259.  Mr. Thomas E. Kopp was the Program Manager for the EPA
throughout the performance of this work, and his patient support is gratefully
acknowledged.
     PCBs were first manufactured in canmercial quantities in the U.S. in
1930, and during the next 40 years they were widely used as solvents, resins,
and electrical dielectric liquids.  Recognition of their environmental persis-
tence and toxicity  in the late 1960's eventually led to a ban on the manufac-
ture and use of PCBs in the Toxic Substances Control Act of 1976.  This report
summarizes the use  of PCBs and much of the early literature on the uses and
toxicity of this material.  In addition, the report reviews the regulatory
actions that have been taken to limit the hazards to health and the environment
resulting from the  accumulation of PCBs in the environment and from their con-
tinued use in certain electrical equipment.  The report is primarily a summary
of the reports that Versar has prepared in support of the EPA's regulatory
activities involving PCBs.
                                       11.

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                             TABLE OF CONTENTS
1.0  INTPODUCTION
2.0  POLYCHLORINATED BIPHENYLS.
     2.1  History of PCB Usage	1
     2.2  PCB Use Restrictions and Government Regulations	5

3.0  CONTRACT SUPPORT OF EPA ACTIONS ON PCRS	7

     3.1  Support of Office of Toxic Substances 	   7
     3.2  Support of the Criteria and Standards Division	10
     3.3  Support of PCB Work Group - Disposal and Marking Regulations.   12
     3.4  Support of PCB Work Group - PCB Ban Regulations	13
     3.5  Support of EPA Office of Planning and Management -
           PCB Ban Regulations	14

APPENDIX A - FEDERAL REGISTER NOTICES REGARDING PCBs

APPENDIX B - CONTRACTOR REPORTS TO EPA RELATED TO PCBs

APPENDIX C - SUMMARY OF MAJOR VERSAR REPORTS REGARDING PCBs
                                    ill.

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1.0  INTRODUCTIOSI
     On June 26, 1975, the U.S. Environmental Protection Agency awarded
contract no. 68-01-3259 to Versar, Inc.  Under this contract, it was antici-
pated that Versar would be assigned a number of tasks to assess the micro-
economic impacts of regulatory alternatives which the EPA would consider for
various toxic substances.  The first task assigned under this contract required
Versar to review and sumnarize the existing data on the use of polychlorinated
biphenyls and to identify the industrial segments that might be dinpacted by
regulations limiting the use of PCBs.
     Before this task was completed, PCBs became a major issue within EPA,
and the scope of the work assigned to Versar was increased as the agency
required additional support.  This report summarizes the work that Versar
performed over  the next four years for the EPA under the subject contract and
a follow-on contract that was closely related to this work.  All of this work
supported regulatory activities involving PCBs, so the description of the work
performed necessarily includes a  history of the use of PCBs, a summary of
regulatory development, and references to related research and reports.
2.0   POLYCHLORINATED BIPHENYLS
      Polychlorinated biphenyls are a group of related compounds  formed by the
addition of chlorine to the aromatic hydrocarbon  "biphenyl."  The reaction
can be described by the following equation:
            H
                                     Fed,
                             H+nCI,
                 X+nHCI
                          H
X    X    X   X
 WHERE X = nCI, 10-nH
      2.1  History of PCB Usage:
           PCBs were first synthesized and described in 1881 (Schmidt, 1881).
 Commercial production of PCBs did not become possible until after an economical
method was developed during the 1920s for the manufacture of biphenyl from benzene.
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 Biphenyls were first produced in commercial quantities in the U. S.
 by Swann  Research,  Inc., of Anniston, Alabama.  Shortly after they started
 manufacturing  biphenyls, Swann Research described the manufacturing process
 (Jenkins,  1930) and the properties of the PCBs they were marketing under the
 tradename Aroclor  (Penning, 1930).  The various Aroclors were described as
 mixtures  of chlorinated diphenyls with a wide range of  properties from a
 light oil to a hard resin depending on the degree of chlorination.   A number of
 commercial applications were  suggested, including use in varnish,  as a
 fireproof ing agent  for wood,  in electrical equipment as a  liquid dielectric
 and as a component of electrical insulation, as an ingredient in adhesives, as
 a replacement  for Canada Balsam in microscopy, as a substitute for chicle in
 chewing gum, and in miscellaneous uses including printing  inks and textile
 finishing (Penning  1930).  A  separate technical article described the compati-
 bility  of PCBs in nitrocellulose lacquer resins (Jenkins,  1931).   The first
 major use of PCBs was apparently as a liquid dielectric in capacitors manu-
 factured  by General Electric Co. starting in 1930 (Clark,  1962).   General
 Electric  also  developed the use of PCBs in other electrical applications as
 described in articles published during the 1930s (Clark, 1934;  Clark,  1937).
      PCBs were manufactured at the Anniston, Alabama, plant by Swann Research,
 Inc.  and  its corporate successor, Monsanto Chemicals Co.,  until the plant was
 shut  down in 1971.  Monsanto also manufactured PCBs at  its plant at Sauget,
 Illinois,  until 1977.  The only other known U.  S.  manufacturer of PCBs was
 Geneva  Industries of Houston,  Texas, which manufactured PCBs  for heat transfer
 applications from 1972 through 1974.
      Most  of the applications of PCBs that had been suggested in 1930 proved
 to be successful.  PCBs were used as heat transfer liquids in critical appli-
 cations such as food processing  (Smith, 1955; Coulson,  1957),  in various elec-
 trical applications (Clark, 1962), in sealants (Skrentny,  1971),  in carbonless
 copy papers (Masuda, 1972;  Lister, 1972), and in paint  (Young,  1974).  Poly-
 chlorinated terphenyls were suggested as a carrier for  insecticides (Tsao,
 1953; Sullivan, 1953).  A Monsanto marketing guide to PCBs which was published
 in the late 1960s also described their possible use as  expansion media in tempera-
ture sensing bellows devices,  as liquid sealants for furnace roofs, as sealers for
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gaskets, as dedusting agents, in insecticides, in casting waxes, in abrasives,
in lubricants and cutting oils, in adhesives, in polishing waxes and impregnat-
ing compounds, in coatings, in inks, in mastics, in sealing and caulking com-
pounds, in tack coatings, and as plasticizers in plastics, paint, varnish, and
lacquer.   (Monsanto, undated).  In addition, a number of other uses of PCBs
had been patented over the years  (for a list of patents see:  Interdepartmental
Task Force on PCBs, 1972, pp. 70-74).
     The available data on the toxicity of PCBs was first summarized in an
article published in 1931  (Smyth, 1931).  Skin problems attributed to PCB
exposure were later reported to be associated with various industrial pro-
cesses including PCB manufacturing  (Jones, 1936), capacitor manufacturing
 (Mayers, 1936), industrial painting  (Birmingham, 1942), and electrical cable
insulating  (Good, 1943).  Systemic effects of exposure to mixtures of chlorinated
organic compounds including PCBs were also noted during the 1930s  (Drinker, 1937)
and were evaluated by animal exposure studies  (Bennett, 1938; von Wedel, 1943;
Miller, 1944.)  In much of this early work, the toxicity studies used
commercial mixtures which included chlorinated naphthalenes, and the effects of
PCBs were not conclusively demonstrated  (Drinker, 1939).  Animal exposure tests
eventually defined the toxicity of PCBs  (Treon, 1946; Mclaughlin, 1963; American
Industrial Hygiene Assoc., 1965), and reports of worker health problems became
limited to unusual situations  (i.e., Meigs, 1954).  Information on the toxicity
of PCBs led the investigation of PCBs as a possible cause of chick edema disease
 (McCune, 1962; Flick, 1965) which was later demonstrated to be caused by con-
tamination of feed with chlorinated dibenzodioxins.
     During the early 1960s interest increased concerning the biological effects
of environmental levels of chlorinated pesticide residues such as DDT and chlordane.
Measurement of low levels of these compounds in biological samples required the
development of sensitive analytical procedures that could both separate the
pesticides from each other and from similar compounds and measure the amount of
each compound present.  The technique that was developed to perform this
analysis was gas chromatography.  In this method, a small amount of sample is
introduced into a long heated tube which is packed with a material that has
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 different adsorption characteristics  for the different compounds in the
 sample.  The tube is then flushed with an inert gas, and the different com-
 pounds are swept out of the tube at different times past a detector that is
 sensitive to the presence of chlorinated organic compounds and that gives a
 response proportional to the amount of chlorinated material in the stream of
 inert gas.  The time required for each compound to move through the tube depends
 on the temperature, the type of packing, the rate of flushing with inert gas,
 and the characteristics of the particular compound.  Therefore, the identifica-
 tion of the compounds in the environmental sample depends on knowing the reten-
 tion time of the compounds and the response of the detector to each compound.
 This requires that known compounds be run through the column and detector, and
 as a result, only known compounds can be identified.  Gas chromatography proved
 to be a very useful method for determining the concentrations of low levels of
 pesticides in environmental samples, but the detector usually recorded the
 presence of a number of chemicals that could not be identified by comparison
 with known pesticide chemicals.
      In 1966, Soren Jensen attempted to identify the unknown compounds that
 were being recorded during routine pesticide analyses.  In order to determine
 when the unknown compounds first appeared in biological samples, be analyzed
 feathers,  fron eagles that had been taken for museum collections.   He found
 the unknown materials in feathers collected as  early as 1944,  before the wide-
 spread use of chlorinated pesticides,  and so concluded that the unknown materials
 were not pesticides or degradation products of  pesticides (Jensen,  1972).  By
 testing chlorinated materials  that were in wide use before 1944, he eventually
 identified commercial PCBs as  the source of the unknown compounds,  and published
 this finding in late 1966 (Jensen,  1966).
     A  full discussion of the presence of  PCBs  in pesticide analyses was
published  in 1967  (Widmark, 1967), and this  set off a number of investigations
to determine the extent of environmental contamination by PCBs.  The discovery
that PCBs were cannon in the environment in  sufficient concentrations to  affect
the reproduction of wild birds was published in 1968 (Risebrough, 1968).  This
article was picked up in the press which started the widespread concern about
possible human health effects from PCBs in the  environment.
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                                                                      PLEASE RETURN TOJ
                                                                   NCIC/OTS  CHEMICAL LIBRARY.
                                                                    401 M ST., S.W., TS-793
                                                                    WASHINGTON, D.C. 20460
     The Yusho incident that  occurred in Japan during the summer of 1968 added
to the public concern over  the toxicity of PCBs.   This was a case of  widespread
PCB poisoning caused by contamination of cooking  oil.  The PCBs were  used
a heat transfer  liquid on the high temperature side of a heat exchanger used
to pasturize the oil.  Over 1000 people were seriously affected by eating con-
taminated oil  (Kuratsune, 1971).  The resulting concern over PCBs led to regula-
tory activity and  increased research throughout the world.  In July of 1971, a
similar incident in the United States contaminated a considerable quantity of
chicken feed as  the result  of leakage of PCB heat transfer fluid.  The U.S.
Food and Drug Administration  eventually destroyed thousands of chickens and
eggs that were fed this contaminated feed (Pichirallo, 1971).  Starting in 1970,
Monsanto voluntarily  limited  sales of PCBs to closed electrical equipment
applications  (Wood, 1975) and recommended that existing PCB-filled heat
transfer systems be drained and refilled with non-PCB fluid  (Monsanto, 1972).
This voluntary ban was completed by the end of 1973.  Monsanto closed the
Anniston, Alabama, manufacturing plant at this time.
     By 1972, a  great deal  of research had been completed on PCBs and was
summarized  in various review  articles covering their toxicity  (Kimbrough, 1972;
Kimbrough,  1974),  environmental impact (Peakall,  1972; Hammond, 1972), environ-
mental distribution (Nisbet,  1972), uses  (Broadhurst, 1972), presence in food
 (Fries, 1972)  and chemical analysis  (Reynolds, 1971).  The basic information
on PCBs was later compiled in the monograph "The Chemistry of PCBs"  (Hutzinger,
1974).  The amount of published information on PCBs has continued to grow
rapidly since  the early 1970s and is now most accessible through published
literature  surveys (Fuller, 1976; Kbrnreich, 1976) and annotated bibliographies
 (Quinby, 1972; Office of Water Resources Research, 1973; Office of Water
Research and Technology,  1975; Cavagnaro, 1978).
      2.2  PCB Use Restrictions and Government Regulations
          The  Yusho incident created considerable concern in the U.  S. over
possible contamination  of food by PCBs.  The U. S. Food and Drug Administration
started routine sampling of foods for PCBs in 1969, and soon found that PCBs
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were present in fish from the Great Lakes, that there was PCB contamination of
milk caused by use of PCBs as a solvent in pesticide sprays and as a compo-
nent of sealants used in farm silos, and that there was contamination of
chickens resulting from PCBs introduced into the feed as a component of ground
bread cartons and wrappers.  It has since become apparent that the presence of
PCBs in fish is a problem that has existed since at least 1964  (Hartsough, 1965),
although PCBs were not identified as the cause of the problem until 1971
 (Aulerich, 1971; Aulerich, 1973).
     From 1969 through 1971, the FDA established action levels for PCBs in food
at 0.2 ppm in milk, 5 ppm in edible flesh of fish, 5 ppm in poultry, and  0.5
ppm in eggs.  In 1970, the FDA prepared a surrmary of the available information
on the chemistry and toxicity of PCBs  (U. S. Department of Health, Education,
and Welfare, 1970).  In 1972, the FDA published a notice of proposed rulemaking
 (Federal Register, 37FR 5705).  The U. S. Department of Agriculture also
prepared a report on ways that it could act to limit PCB contamination of Food
 (U. S. Department of Agriculture Ad Hoc Group on PCBs, 1972.)  In 1973, the
FDA formally established limits for PCBs in food and animal feed  (Federal
Register/  38FR  18096).  The FDA proposed a revision of these limits in
1977  (Federal Register, 42FR 17487) , but no action has yet been taken on
this proposal.
     During 1970, the Council on Environmental Quality  (CEQ) studied regulatory
approaches to the problem of toxic chemicals in the environment.  In its  report
"Toxic Substances" published in 1971, CEQ identified PCBs as a major problem
 (Council on Environmental Quality, 1971).  The initial response of the respon-
sible agencies was to establish a task force to review the available informa-
tion on PCBs and recommend regulatory alternatives  (Interdepartmental Task
Force on PCBs, 1972).
     During 1973 and 1974, the EPA proposed the establishment of water quality
criteria for PCBs in industrial discharges as part of a program for establish-
ing such criteria for a larger group of pesticides.  However, PCBs were not
covered in the effluent standards that were eventually promulgated.
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     The Occupational  Safety and Health Administration adopted the standards for
PCB exposure in  industrial air that had previously been established by the
American industrial  Hygiene Association.  The National Institute of Occupational
Safety and Health conducted a major review of available data and an extensive
program of industry  assessment in the mid 1970s,  and the final report recom-
mended that the  allowable concentration of PCBs in the work place be reduced
 (NIOSH, 1977).   However,  OSHA has not yet taken action on this recommendation.
          Government actions restricting the use of PCBs were not limited to
 the United  States.  Japan banned the manufacture and use of PCBs in the early
 1970s because of public pressure following the Yusho incident.  Sweden banned
 the use of  PCBs at about the same time.  International actions were also taken
 to reduce the risk of food contamination by PCBs during the early 1970s  (OCED,
 1973;  OECDCouncil,  1973; The Council of the European Communities, 1976).
 3.0  CONTRACT SUPPORT OF EPA ACTIONS ON PCBS

      3.1   Support of  Office of Toxic  Substances
            During 1974 and 1975,  the Office of Toxic Substances sponsored a
  series of  review studies to identify  regulatory alternatives for various
  specified  toxic substances.  Contract 68-01-3259  was  awarded by the EPA to
  Versar on  June  26,  1975, to support similar work on additional chemicals.
  The  first  task  on this new contract was assigned by the EPA Technical
  Project Officer, Mr.  David Garrett, on June 27, 1975.  This task required
  the  contractor  to study  the role of PCBs  in the U.S. economy and prepare
  a draft report  by October 31,  1975, identifying and screening alternative
  regulatory and  non-regulatory control options:  Study of Regulatory Alterna-
  tives for  PCBs;  Draft Interim Report - Task I, October 31.   (Unpublished -
  Superceded by "PCBs in the United States...  .";)
           As  part of  the review of PCBs,  the Office of Toxic Substances
  sponsored  a national  conference on PCBs in Chicago on November 19 thru
  21,  1975.
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The Technical Coordinator of this conference was Mr. Thomas Kbpp of the Office
of Toxic Substances.  Several major articles on the environmental effects of
PCBs that appeared in the popular press shortly before the conference  (Boyle,
1975a; Boyle, 1975b) caused considerable public interest in the conference and
a number of demands that EPA regulate PCBs.  Dr. Robert Durfee of Versar parti-
cipated in this conference and presented a paper summarizing the background on
PCBs as presented in the draft report (Durfee, 1975).
     Because of the increasing importance of PCBs to the activities of the
Office of Toxic Substances after the conference, the EPA assigned Mr. Kopp
as Technical Project Officer on the contract and had the contractor expand
the draft interim report and prepare four special reports under Task I.
The Versar Program Manager in charge of this work was Dr. Robert Durfee.  The
following reports were submitted in response to this directive:
          The Handling and Disposal of Electric Transformers;  Special Report,
          Task I  (December 5, 1975).  Non-proprietary sections included in
          "PCBs in the United States	"
          Results from Review and Analysis of 308 Letter Responses on PCB Manu-
          facturing, Usage, and Disposal in United States Industry:  Special
          Report  (December, 1975).
       *  Toxicological Studies Conducted Under Task I:  Special Report  (February
          19, 1976).  Incorporated in "PCBs in the United States..." as Appendix F.
       *  Development of an Economic Analysis Methodology for Evaluating Regula-
          tory Alternatives for PCBs:  Special Report, Task 1  (March 9, 1976).
          Unpublished.
       *  PCBs in the United States:  Industrial Use and Environmental Distribution
          Final Report, Task I (February 25, 1976).  EPA 560/6-76-005.  NTIS
          PB 252 012.
     At about the same time that Task I \ias expanded, the EPA directed the con-
tractor to perform two additional tasks.  Task II was a study of wastewater treat-
ment technology that could be used to reduce the concentration of PCBs in industrial
effluents.  This work was supported by Clark, Dietz Associates who performed the
industrial economic analysis under subcontract from Versar as provided by Modifica-
tion 1 to the contract.  Task III was a plan for an assessment of the use of PCBs
     summary of report in Appendix C.

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in the investment casting industry and the resulting environmental
impacts.  Versar program managers were Mr. Donald Sargent on Task II and Dr.
Robert Durfee on Task III.  The following reports were submitted in response
to these work directives:
       *  Assessment of Wastewater Management, Treatment Technology, and
          Associated Cost for Abatement of PCBs Concentration in Industrial
          Effluents;  Final Report, Task II.(February 3, 1976).EPA 560/6-
          76-006.  NTIS PB 251-433/AS.
       *  Development of a Study Plan for Definition of PCBs Usage, Wastes, and
          Potential Substitution in the Investment Casting Industry:  Final
          Report, Task III.   (January, 1976)  EPA 560/6-76-007.  NTIS PB 251-842.
     Based on these three tasks and on other work performed within the Environ-
mental Protection Agency, the EPA published recommended disposal procedures for
PCBs  (Federal Register, 41 FR 14134) and proposed effluent standards for PCBs
in the water discharges from PCB manufacturers and from capacitor and transformer
manufacturers that used PCBs  (Federal Register, 41 FR 30468).
     Senator Gaylord Nelson introduced an amendment to the Toxic Substances Control
Act  (TSCA) on March 26, 1976.  This amendment required the EPA to establish label-
ing and disposal requirements for PCBs and mandated an eventual ban on the manu-
facture and processing of PCBs.  This amendment was incorporated into TSCA as
Section 6 (e) and became a legislated requirement when TSCA was signed into law
on October 11, 1976.  The effective date of TSCA was January 1, 1977.
     On July 15, 1976, EPA modified the contract to support additional studies
on several aspects of PCBs.  EPA technical supervision of this work was the
responsibility of Mr. Kbpp.  Under this contract modification  (Mod. 4), four
formal tasks were established and two additional reports were prepared for
internal EPA use.  The Versar program manager for this work was Mr. Robert Westin,
with each report being the responsibility of a Versar Task Manager who was as
the principal author of the report.  The following reports were submitted in
response to the requirements of this contract modification:
*See summary of report in Appendix C.

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       *  PCBs Involvement in the Pulp and Paper Industry:   Final Report, Task IV.
          EPA 560/6-77-005, NTIS PB 271-071/6WP.  February 25, 1977.

       *  A First Order Mass Balance Model for the Sources, Distribution, and
          Fate of PCBs in the Environment;  Final Report,  Task V.'
          EPA 560/6-77-006, NTIS PB 270-220.  July,  1977.

       *  Assessment of the Environmental and Econcmic Bnpacts of the Ban on
          Snports of PCBs:  Final Report, Task VI.  EPA 560/6-77-007, OTIS
          PB 270-225.  July 1977.

       *  Assessment of the Use of Selected Replacement Fluids for PCBs in Elec-
          trical Equipment:  Final Report, Task VII.  EPA 560/6-77-008, NTIS No.
          forthcoming.  April, 1979.

          Environmental Discharges of PCBs Associated with the Manufacture and
          Use of PCBs and PCB-Containing Equipment?  (Contains EPA proprietary
          Information, submitted to EPA Enforcement Division.)  October 29, 1976.

          Usage of PCBs in Open and Semi-Closed Systems and the Resulting losses
          of PCBs to the Environment.  (Contains EPA proprietary information,
          submitted to EPA Enforcement Division).  September 30, 1976.

     3.2  Supportjjf the Criteria and Standards Division

          Versar provided support to the Criteria and Standards Division of

EPA under three separate contract modifications.  All of the work involved support

of the effluent standards for PCBs by performing additional technical and economic

analysis of the feasibility and costs of various pollution abatement technologies.

The EPA Technical Program Manager on this work was Mr. Thomas Kopp, and the EPA

Task Manager was Mr. Ralph Holtje of the Criteria and Standards Division.  The

Versar Program Manager was Mr. Donald Sargent.  The contract modification require-
ments and the reports submitted were as follows:

          Modification 2  (Feb. 27, 1976):  Provided for the analysis of the
             economic impacts of the proposed regulation by Jack Faucett
             Associates under subcontract from Versar and for the review of
             the Final Task II report by Versar.
*See summary of report in Appendix C.
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      *  PCBs Water Elimination/Reduction Technology and Associated Costs:
         Manufacturers of Electrical Capacitors and 'Transformers;  Addendum
         to Final Report, Task II.  EPA 440/9-76-020.  July 2, 1976.

         Recommendations as  to PCB Sampling  Sites and  Sampling Points  at
         Industrial Sources:  Special  Report.  August  17,  1976.

      *  Economic Analysis of Proposed Toxic Pollutant Effluent  Standards
         for Polychlorinated Biphenyls;  Transformer,  Capacitor, and PCB~
         Manufacturing.   (Prepared by  Jack Faucett Associates) EPA 230/1-
         76-068.  October, 1976.

      Modification 3  (June 10, 1976):  Provided for additional assessment
         of wastewater management and  treatment technology and support of
         EPA during formal hearings and rulemaking proceedings.

         Costs  for U.V.  - Ozonation Process:  Addendum to  Final Report,
         Task II.  September 27,  1976.Unpublished.=

       *  Detailed Cost Estimates  for Alternative PCBs  Treatment Technol-
         ogies  Applied to Hypothetical Large arid Medium Sized PCB Capacitor
         and Transformer Manufacturing Plants.  Addendum to Final Report,
         Task II.  October 15, 1976.   Unpublished.

         Cost for Equalization Basin Based on Bentonite Clay Liner Special
         Renort, October, 1976.   Unnublished.

       *   Impacts of  Substitutes  for PCBs on  Fire Hazards  in Commercial and
         Residential Buildings;   (Draft) Special Report.   October,  1976.
         Unpublisned.

       *  Recent Advances in PCBs Detoxification in Wastewater:   Supplement
         to Final  Report, Task II.  January  18, 1977.  Unpublished.

       *  PCB  Levels  in Non-Contact Cooling Waters  and  Other Effluents  from
         Capacitor and Transformer Production Facilities;  Supplement  to
         Final  Report, Task II.   January 18, 1977.   Unpublished.

       *  Refinement  of Alternative Technologies and  Estimated Costs for  Re-
         duction of  PCBs in Industrial Wastewaters from the Capacitor  and
         Transformer Manufacturing Categories.  January 19, 1977.   Unpublished.

       *  Costs  Associated with Installing  Production Equipment for Use of
         Nbn-PCB Dielectric Fluids in Transformer  and  Capacitor Manufacture;
         Supplement  to Final Report,  Task  II.January 19, 1977-Unpublished.


*See summary of report in Appendix C.
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          On February 2, 1977, the EPA promulgated effluent standards restricting
any discharges of PCBs in the wastewaters fron manufacturers of PCBs or from
capacitor and transformer manufacturing plants that used PCBs after February 2,
1978  (Federal Register, 42 FR6531).
     3.3  Support of PCS Work Group - Disposal and Marking Regulations
          Section 6 (e) (1) of the Toxic Substances Control Act required the EPA
to regulate the labeling and disposal of PCBs by July 1, 1977.  On December  8,
1976, the EPA announced the formation of a PCB Work Group to write the proposed
rules.  The contractor provided staff support to this work group,  providing a
number of special reports as requested,  performing the economic impact analysis
of the proposed regulation,  and providing testimony at the rulemaking hearing.
The contract was modified on March 25, 1977,  (Mod. 6)  to authorize this addi-
tional technical and economic support.  The EPA Project Officer for this work
was Mr. David Wagner, and Mr. Thomas Kopp remained the Technical Project Officer
in charge of the total contract.  The Versar Program Manager was Mr. Robert
Westin.  The following reports were submitted in support of the development of
the PCB Marking and Disposal Regulations:
          Assessment Methodology for labeling and Education to Assure the
          Proper Disposal of PCBs;  Special Report.  November, 1976.
          Analysis of the Economic and Technological Constraints on the Disposal
          of PCBs:  Special Report.  November 22, 1976.
          PCB Disposal Regulations;  Problem Areas and Regulatory Alternatives:
          Special Report.  December 10,  1976.
          Estimated Usage of Electrical Equipment Containing PCBs:  Special
          Report.  December 23, 1976.'
          Recommended Label Requirements and Suggested label Formats:  Special
          Report.  January 12, 1977.
          Draft Notice of Public Meeting - PCBs.  January 10, 1977.
          Garments on PCB Definitions to Subcommittee on Manufacturing Bans.
          January 14, 1977.
 frSee summary in Appendix C.
                                  -12-

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          Draft Notice of Proposed Rulemaking, Preamble, and Labeling and
          Disposal Regulations;  Special Report.  January 21, 1977; revised
          February 4, 1977.
          Labeling and Disposal Regulations;  Revised Draft.  January 27, 1977.
          Draft Preamble to PCB Disposal Regulation.  December 29, 1976:
          revised January 12, 1977; revised February 4, 1977.
          Economic Impact - Summary and Conclusions;  Special Report.  March 14,
          1977.
          Statement of Economic Consequences of the Rule:  Special Report.
          April 12, 1977.
        *  Microecononic Impacts of the Proposed Marking and Disposal Regulations
          for PCBs.  April, 1977.  EPA 560/6-77-013, NTIS PB 267-833.

           EPA formally proposed the rules for marking and disposal of PCBs on
May 24, 1977 (Federal Register, 42 FR 26564).  Rulemaking hearings were held
on June 24, 27, 28, and 29.  Mr.  Westin of Versar presented testimony on the
economic impacts of the proposed regulation at the hearings on June 29.  The
EPA promulgated the PCB Disposal and Marking Regulations on February 17, 1978
(Federal Register, 43 FR 7150) and issued corrections on August 2, 1978  (Federal
Register, 43 FR 33918).  The effective date of the regulations was April 18,
1978.
     3.4  Support of PCB Work Group - PCB Ban Regulations
          Sections 6(e)(2) and 6(e)(3) of the Toxic Substances Control Act
banned the manufacturing, processing, distribution, and use of PCBs after
January 1, 1978, except in a totally enclosed manner; completely banned the
manufacture of PCBs after January 1, 1979; and completely banned the process-
ing and distribution in commerce of PCBs after July 1, 1979.  However, the Act
also authorized the EPA  to exempt those activities involving PCBs that did not
present an unreasonable risk of injury to health or the environment provided
*See summary in Appendix C.
                                 -13-

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that good faith efforts were made to develop an adequate substitute for PCBs
in that use.  On June 27, 1977. the EPA announced the formation of a PCB work
group to develop proposed regulations implementing these provisions of the act,
and announced public meetings on the subject to be held in Washington,  D.C. on
July 19, 1977  (Federal Register, 42 FR 32555).
          EPA modified the contract on June 26, 1977,  (Mod. 7)  to provide for
support during the development of the proposed ban regulations.   EPA Project
Officers continued to be Mr. Wagner and Mr. Kopp.  Versar's work  was supervised
by Mr. Westin.  Versar prepared briefing papers for the work group prior to
the public meetings and submitted them to the work group as the special report:
Potential Impacts of the Bans on PCB Manufacturing, Processing, and Use;
PCB Activity Analysis Papers  (July 11, 1977).*  Following the public meetings,
the work group prepared a draft of the proposed regulations (August 30,  1977),
and the contractor submitted a formal report on the economic impacts of these regular
tions:  Microeconomic Impacts of the Draft "PCB Ban Regulations":   Draft
Report (September 18, 1977).  Formal proposal of the ban regulations was
delayed while the Work Group prepared the final version of the Disposal  and
Marking Regulations, and on December 30,  1977,  EPA announced that  it would  not
enforce the January 1,  1978 ban on open system activities involving PCBs until
after formal ban regulations were promulgated (Federal Register, 42  FR  65264 ).
          The work group continued to revise the draft proposed regulation,
and Versar submitted a major revision of the economic impact analysis reflect-
ing the changes in the proposed regulation and including appendices character-
izing the U.S.  waste oil industry and presenting a formal microeconomic  analysis
of the supply and demand effects of the PCB Ban on the electric equipment indus-
try:   Microeconomic Impacts of the Draft "PCB Ban Regulations":  Revised Draft
Report (March 8,  1978).*
     3.5  Support of EPA Office of Planning and Management - PCB Ban Regulations
          In early 1978,  the EPA transferred responsibility for the analysis  of
the economic impacts of the PCB ban regulations from the PCB Work  Group to  the
 *See  surrttiary in Appendix C.
                                   -14-

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Office of Planning and Management.  On .April 19, 1978, the EPA awarded contract
number 68-01-4771 to Versar for additional economic analysis, preparation of a
revision of the previously submitted draft economic impact report, and support
during the public hearings on the proposed regulations.  The EPA Technical Pro-
ject Officer was Mr. Steven B. Malkensen, Office of Planning and Management.
The Versar Program Manager was Mr. Robert Westin.  In May, 1978, the contractor
submitted the revised report:  Microeconomic Impacts of the Proposed "PCS Ban
Regulations"* that was issued in support of the proposed regulations as EPA
Report No. EPA-560/6-77-035.

          The EPA formally proposed the PCB Ban Regulations on June 7, 1978
 (Federal Register,  43 FR 24801).   Public Hearings  were held in Washington,
D. C., from August  21 through September 1, 1978.  Mr. Westin of Versar pre-
sented testimony on the economic impacts of the proposed regulations on Sep-
tember 26, 1978.
          Following the hearings, EPA continued to revise the ban regulations.
On November 1, 197 8, EPA published interim procedural rules for filing and
processing petitions for exemptions from tha January 1, 1979 bans on manufactur-
ing of PCBs  (Federal Register, 43 FR 50905;.  On Januarv 2, 1979, *T>A Announced
that  it would not enforce the prohibitions on PCB manufacturing, processing,
distribution in commerce, and use until after formal promulgation of the PCB
Ban Regulations  (Federal Register, 44 FR 108).
          On November 15, 1978, Versar submitted a draft report on the economic
impacts of the draft ban regulations:  PCS Manufacturing, Processing, Distribu-
tion  in Commerce, and Use Ban Regulation:  Economic Impact Analysis;  Draft
Final Report.  A major revision of this report was submitted on December 22,
1978.  On December  27, 1978, EPA modified contract 68-01-4771 to extend the
duration  of the contract and to fund further revisions of the economic impact
analyses  as required by additional changes to the  draft regulation.  Mr.
Stephen Weil was assigned to be the EPA Technical  Project Officer for this
contract  modification.  The contractor submitted the  final  revision of this
 *See summary in Appendix C.
                                   -15-

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 report on March 30,  1979.*  EPA issued  the  final  regulations on April 19,  1979.
 Formal promulgation  of  the regulations  through  the Federal Register was expected
 to occur by the end  of  May, 1979.
*See summary in Appendix C.
                                  -16-

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References

   American Industrial Hygiene Association  (1965).  "Chlorodiphenyls
   (containing 42% and 54% chlorine)."  Hygienic Guide Series, Jan-Feb.

   Aulerich, R.J.- Ringer, R.K.;  Seagron, H.L.; Youatt, W.G.  (1971).   "Effects
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   Aulerich, R.J.- Ringer, R.K.;  Iwamoto, S.  (1973). "Reproductive Failure
   and Mortality  in Mink Fed on Great Lakes Fish."  Journal of Reproduction
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   Bennett, G.A.; Drinker, C.K.;  Warren, M.F.  (1938). "Morphological Changes
   in the Livers  of Rats Resulting from Exposure to Certain Chlorinated
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   No. 2  (February), pp. 97-123,  (Feb. 1938).

   Birmingham, D.J.  (1942).   "Occupational Dermatology:  Current Problems."
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   Boyle, R.H.  (1975a). "Of PCB ppms from GE and a SNAFU from EPA and DEC,"
   Audubon, Vol.  77, No. 6  (Nov.  1975), pp. 127-133.

   Boyle, R.H.   (1975b).  "Poisoned Fish, Troubled Waters."  Sports Illustrated,
   Sept. 1, 1975, pp. 14-17.

   Broadhurst, M.G.  (1972). "Use  and Replaceability of Polychlorinated Biphenyls,"
   Environmental  Health Perspectives, Vol.  2, pp. 81-102.

   Cavagnaro, D.M.  (1978).  Polychlorinated Biphenyls in the Environment
    (A Bibliography with Abstracts).Springfield, Va:National Technical
   Information Service (NTIS/PS-78/0893/4WP) August, 1978.

   Clark, F.M.  (1934).  "The Development and Application of Synthetic Liquid
   Dielectrics."  Transactions of the Electrochemical Society, Vol. 45, p. 59.

   Clark, F.M.  (1937).  "Nonflammable Dielectric Organic Compounds."  Industrial
   and Engineering Chemistry, Vol. 29, p. 698.

   Clark, Frank M.   (1962)-  Insulating Materials for Design and Engineering
   Practice, New York:  John Wiley and Sons, Inc.

   Coalson, H.; Sellers, K.W.  (1957).  "Modern Potato Chip Production."
   Taylor Technology, Spring, 1957, pp. 14-18.

   Council on Environmental Quality  (1971).   Toxic Substances,  Washington,  D.  C.
                                  -17-

-------
References (Continued)

   Drinker, C.K.  (1939).   "Further Observations on the Possible Systemic
   Toxicity of Certain of the Chlorinated Hydrocarbons with Suggestions for
   Permissible Concentrations in the Air of Workrooms."  The Journal of
   Industrial Hygiene and Toxicology, Vol.  21, No.  5 (May), pp. 155-159,

   Drinker, C.K.; Warren,   M.F.;  Bennett, G.A.  (1937).  "The Problem of
   Possible Systemic Effects from Certain Chlorinated Hydrocarbons."  The
   Journal of Industrial Hygiene and Toxicology, Vol. 19, No. 7 (September),
   pp. 283-311.

   Durfee, R.L. (Versar Inc.).  (1975).   "Production and Usage of PCBs in the
   United States."  Conference Proceedings:  National Conference on Poly-
   chlorinated Biphenyls  (Report No.  EPA-560/6-75-004).   Washington,  D.  C.:
   Office of Toxic Substances, U.S. Environmental Protection Agency.  March,
   1976, pp. 103-107.

   Flick, D.F.; O'Dell, R.G.; Childs, V.A.   (1965).  "Studies of the Chick
   Edema Disease.  3. Similarity of Symptoms Produced by Feeding Chlorinated
   Biphenyls."  Poultry Science,  Vol. 44, No.  6, p. 1460-1465.

   Fries, G.F.  (1972).  "PCB Residues:   Their Significance to Animal
   Agriculture."  Agricultural Science Review, 3rd Quarter, pp. 19-24.

   Fuller, B.; Gordon, J.; Kornreich, M. (MITRE Corp.).  (1976).  Environmental
   Assessment of PCBs in the Atmosphere.  Springfield, Va.:  National Technical
   Information Service (NTIS PB-274 115/5WP).

   Good, C.K.; Pensky, N.    (1943).  "Halcwax Acne  (Cable Rash)."  Archives of
   Dermatology and Syphilogy, Vol. 48, p. 251.

   Hammond, P.B.; Nisbet,  C.T.;  Sarofim, A.F.; Drury, W.H.; Nelson, N.  (1972).
   "Polychlorinated Biphenyls - Environmental Impact, A Review by the Panel on
   Hazardous Trace Substances."   Environmental Research, Vol. 5, pp. 247-362
   (Sept. 1972).

   Hartsough, G.R.   (1965).  "Great Lakes Fish Now Suspect as Mink Food."
   American Fur Breeder,  Vol. 38,  p.  25.

   Hutzinger, 0.; Safe, S.; Zitko, V.   (1974).  The Chemistry of PCBs, Cleveland,
   Ohio:  CRC Press.

   Interdepartmental Task Force on PCBs.   (1972).  Polychlorinated Biphenyls
   and the Environment.  Springfield, Va.:   National Technical Information
   Service (Report No.  NTIS CCM-72-10419).

   Jenkins, R.L.;  McCollough, R.;  Booth, C.F.    (1930).  "Syntheses in the
   Diphenyl Series."  Industrial and Engineering Chemistry, Vol. 22, p. 31.

   Jenkins, R.L.;  Foster,  R.N.  (1931).   "Compatibility Relationships of
   Aroclors in Nitrocellulose Lacquers."  Industrial and Engineering Chemistry,
   Vol. 23, No. 12 (Dec.  1931),  pp. 1362-1365.


                                  -18-

-------
References  (Continued)

   Jensen, Soren.   (1966).  "Report of a New Chemical Hazard."  New Scientist,
   Vol. 32, p. 612.

   Jensen, Soren.   (1972).  "The PCB Story."  Ambio, Vol. 1, No. 4, (August,
   1972) pp. 123-131.

   Jones, J.W.; Alden, H.W.   (1936).  "An Acneiform Dermatergosis."  Archives
   of Dermatology and Syphilogy, Vol. 33, pp. 1022-1034.

   Kimbrough, R.D.   (1972).   "Toxicity of Chlorinated Hydrocarbons and Related
   Compounds."  Archives Environmental Health, Vol. 25, pp. 125-131.

   Kinibrough, R.D.   (1974).   "The Toxicity of Polychlorinated Polycyclic
   Compounds and Related Chemicals."  CRC Critical Reviews in Toxicology,
   January, 1974, pp. 445-498.

   Kbrnreich, M.; Fuller,  B.; Dorigan, J.; Walker, P.; Thomas, L.   (Mitre Corp.)
    (1976).  Environmental  Impact of Polychlorinated Biphenyls.  Draft Report.
   ERDA Contract No. E (40-1)  - 4993.  McLean, Va:  The Mitre Corporation
    (Report No. MTR-7006).

   Kuratsune, M.; Yoshimura,  T.; Matsuzaka, J.; Yamaguchi, A.   (1971).  "Yusho,
   a Poisoning Caused by Rice Oil Contaminated with Polychlorinated Biphenyls."
   HSMHA  Health Reports, Vol. 86, No. 12, pp. 1083-1091.

   Lister, R.E.; Bennett,  N.J.M.  (1972).  "PCBs in Copying Paper,"  Nature
    (London), Vol. 237, p.  414.

   Masuda, Y.; Kagawa, R.   (1972).  "Polychlorinated Biphenyls in Carbonless
   Copying Paper."  Nature (London), Vol. 237 (5/5), pp. 41-42.

   Mayers, M.R.; Silverberg,  M.G.   (1938).  "Skin Conditions Resulting from
   Exposure to Certain Chlorinated Hydrocarbons."  The Journal of Industrial
   Hygiene and Toxicology, Vol. 20 p. 244.

   McCune, E.L; Savage, J.E.; O'Dell, B.L.   (1962).  "Hydropericardium and
   Ascites in Chicks Fed a Chlorinated Hydrocarbon."  Poultry Science, Vol.
   41,  p. 295.

   McLaughlin, J.; Marliae, G.P.; Verrett, M.J.; Mutchler, M.K.; Fritzlaugh,
   O.G.  (1963).  "The Injection of Chemicals Into the Yolk Sac of Fertile
   Eggs Prior  to Incubation as Toxicity Test."  Toxicol. Appl.  Pharmacol.,
   Vol. 5, pp. 760-771.

   Meigs, W.J.; Alborn, J.J.; Kartin, B.L.   (1954).  "Chloracne from an Unusual
   Exposure to Aroclor."   Journal of the American Medical Association, Vol.
   154, pp. 1417-1418.

   Miller, J.W.   (1944).   "Pathologic Changes in Animals Exposed to Commercial
   Chlorinated Diphenyl."  Public Health Reports, Vol. 59, pp.  1085-1093,
    (August 18, 1944).

                                  -19-

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References (Continued)

   Monsanto Chemical Co.  (undated).   The Aroclor Compounds, St. Louis, Mo:

   Monsanto Industrial Chemicals Co.   (1972).   Therminol Conversion Bulletin
   SP/TC-1.  St. Louis, Mo.:   January,  1972.

   NIOSH.  (1977).   Criteria for a Recommended Standard.  Occupational Exposure
   to Polychlorinated Biphenyls (PCBs).   DHEW (NIOSH)  Publication No. 77-225.
   Washington, D.C.:  U.S.  Government Printing Office.

   Nisbet, C.T.; Sarofim, A.F.  (1972).   "Rates and Routes of Transport of
   PCBs in the Environment."   Environmental Health Perspectives.  Exp. 1,
   pp. 21-38.

   OECD.   (1973).  Polychlorinated Biphenyls;   Their Use and Control.  Paris,
   France:  Environmental Directorate from the Organization for Economic
   Cooperation and Development.

   OECD Council  (1973).  "Protection of the Environment by Control of Poly-
   chlorinated Biphenyls:  Decision  Adopted 13 February, 1973."  as cited in:
   OECD and the Environment.   Paris:  Organization for Economic Co-operation
   and Development, 1976, pp.  17-24.

   Office of Water Resources  Research,  U.S.  Department of the Interior (1973).
   PCS in Water - A Bibliography.  Springfield,  Va.:  National Technical
   Information Service (NTIS-PB-217-859).

   Office of Water Research and Technology,  U.S. Department of the Interior,
   (1975).  PCB in Water:  A Bibliography, Vol.  2.   Springfield, Va.:  National
   Technical Information  Service (NTIS-PB-248-141).

   Peakall, D.B.  (1972).  "Polychlorinated Biphenyls:  Occurrence and
   Biological Effects."  Residue Review,  Vol.  44, pp.  1-21.

   Penning, C.H.  (1930).  "Physical Characteristics and Commercial Possibili-
   ties of Chlorinated Biphenyl.   Industrial and Engineering Chemistry, Vol.
   22, p. 1180.

   Pichirallo, J.  (1971).   "PCBs:   Leaks of Toxic Substances Raise Issue of
   Effects, Regulation."  Science, Vol.  173,  p.  899.  (Sept. 3, 1971).

   Quinby, G.E.   (1972).  Polychlorobiphenyls (PCBs) and Related Chlorophenyls;
   Effects on Health and  Environment -  I:  Bibliography — 1881-1971.
   Springfield,  Va/:  National Technical Information Service (NTIS PB-209-944).

   Reynolds,  L.M.  (1971).   "Pesticide  Residue Analysis in the Presence of
   Polychlorobiphenyls  (PCBs)."  Residue Reviews, Vol. 34, pp.  27-57.

   Risebrough, Robert W.; Reiche,  P.; Peakall, D.B.; Herman, S.C.; Kirven, M.N.
   (1968).  "Polychlorinated  Biphenyls  in the Global Ecosystem."  Nature,
   (London),  Vol. 220,  (Dec.  1968),  pp.  1098-1102.
                                  -20-

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References  (Continued)

   Schmidt, H., and Schultz, G.   (1831).   "Uber Diphenylbasen."  Annalen Chem.,
   Vol. 207, pp. 338-344.

   Skrentny, R.F.; Hemken, R.W.;  Dorough,  H.W.;  (1971).   "Silo Sealants as a
   Source of Polychlorobiphenyl  (PCS) Contamination of Animal Feed."   Bulletin
   of Environmental Contamination and Toxicology, Vol. 6, No. 5, pp.  409-416.

   Smith, H.L.; Freeman, W.E.   (1955).   "Automatic Remote Heating  Cures Frying
   Faults."  Food Engineering, March, 1955, pp. 60-62, 205.

   Smyth, H.F.   (1931).  "Toxicity of Certain Benzene Derivatives  and Related
   Compounds."  The Journal of  Industrial  Hygiene and Toxicology,  Vol.  13,
   pp. 87-96.

   Sullivan, W.N.; Hornstein, I.   (1953).   "Chlorinated  Polyphenyls to Improve
   Lindane  Residues."  Journal of Economic Entomology, Vol.  46, No. 1,  pp.
   158-159.   (February,  1953).

   The Council of the  European Communities (1976).  "Council Directive of
   27 July, 1976."  Official Journal of  the European Communities,  No.  L 262,
   p. 201-203  (Sept. 27, 1976).

   Treon, J. F.; Cleveland, F.P.; Cappel,  J.W.; Atchley,  R.W.   (1956).
   "The Toxicity of the Vapors of Aroclor  1242 and Aroclor  1254."  American
   Industrial  Hygiene  Association Quarterly,  Vol. 17, No. 3, PP- 204-213.

   Tsao, Ching Hsi; Sullivan, W.N.;  Hornstein, I.   (1953).   "A Comparison of
   Evaporation Rates and Toxicity to House Flies of Lindane and Lindane-
   Chlorinated Polyphenyl Deposits." Journal of Economic Entomology,  Vol.
   46, No.  5,  pp. 882-884  (October,  1953).

   U.S. Department of  Agriculture Ad Hoc Group on PCBs  (1972).  Agriculture's
   Responsibility Concerning Polychlorinated  Biphenyls  (PCBs).  Washington,
   D.C.:  Office of Science and  Education,  U.S. Department  of Agriculture.

   U.S. Department of  Health, Education, and  Welfare   (1970).   Supplement 1 -
   Status Report on the Chemistry and Toxicology of Polychlorinated Biphenyls
   (PCS) of Aroclors"!  Washington, D.C.:   Bureau of Foods,  Food and Drug
   Administration, Public Health Service.

   Von Wedel,  H.; Holla, W.A.; Denton, J.   (1943).  "Observations  on  the Toxic
   Effects  Resulting from Exposure to Chlorinated Naphthalene and  Chlorinated
   Phenyls with Suggestions for  Prevention."   The Rubber Age, Vol.  53,  No. 5,
   pp. 419-426  (August, 1943).

   Widmark, G.   (1967).  "Possible Interference by Chlorinated Biphenyls."
   J. Assoc. Off. Anal. Chem., Vol.  50,  p.  1069.
                                  -21-

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References (Continued)

   Wood, David (Monsanto Industrial Chemicals Co.)  (1975).  "Chlorinated
   Biphenyl Dielectrics - Their Untility and Potential Substitutes."  Conference
   Proceedings:  National Conference on Polychlorinated Biphenyls  (Report No.
   EPA-560/675-004).   Washington, D.C.:   Office of Toxic Substances, U.S.
   Environmental Protection Agency, March, 1976, pp. 317-324.

   Young, D.R.; Heesen, T.C.;  McDermott, D.J.; Smoklev, P.E.   (1974).  "Marine
   Inputs of Polychlorinated Biphenyls and Copper from Vessel Antifouling
   Paints."  Southern California Coastal Water Research Project, TM 212,
   (May, 1974).
                                 -22-

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               APPENDIX A
FEDERAL REGISTER NOTICES REGARDING PCBs

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                                                                  A-l
Environmental Protection Agency

     Effluent Limitations (§ 307a Clean Water Act)
     Date
Vol. Pacres
     July 6, 1973   38  18044-5
     Sept 7, 1973   38  24342-4
     Dec 27, 1973   38  35388-95
Subject

Proposed List of Toxic Pollutants,
  Including PCBs.
Promulgated List of Toxic Pollutants,
  Including PCBs.

Proposed Water Effluent Standards,
  Including PCBs.
     Mar 5, 1974    39  8325-6     Public Hearings on Effluent Standards.
     Mar 21, 1974   39  10603-4    Correction - Effluent Standards.

     Jul 23, 1976   41  30468-77   Proposed Effluent Standards.

     Feb 2, 1977    42  6531-55    Effluent Standard Regulations.
     Spill Reporting Requirements (§ 311,  Clean Water Act)
     Date
Vol. Paaes
Subject
     Feb 16,  1979   44  10266
                Definition of "Discharge" under Clean
                  Water Act.
     Feb 16,  1979   44  10271-84   Defines Reportable Quantities of PCBs
                                     Spilled into Waterways, Reporting
                                     Requirements and Fines.

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                                                              A-2
Disposal and Marking Regulations  (§ 6el) Toxic Substances Control Act
Date
Apr 1, 1976
Dec 8, 1976

Jan 5, 1977
Jan 19, 1977
Apr 21, 1977
Vol. Pac
 41  14134-36
 41  53692

 42  1067
 42  3701-2
 42  20640-44
May 24, 1977    42   26564-77
Jul 15, 1977    42   36484-85
Subject
Recommended Disposal Procedures.
Panel Discussion/Formation of PCB Work
  Group.

Rescheduling of Meeting.
Notice of Jan. 24, 1977 Public Meeting.
Proposed Procedures for Rule-Making under
  Sect. 6 of TSCA.
Proposed Marking and Disposal Regulations.
Deadline for Reply Comment Period.
Feb 17, 1978
Jul 18, 1978
Aug 2, 1978
Aug 25, 1978
Oct 26, 1978
Dec 20, 1978
 43  7150-64
 43  30882-3
 43  33918-20
 43  38087-88
 43  50041
 43  59432-3
Promulgated Marking and Disposal Regulations.
List of Approved PCB Disposal Facilities.
Corrections to Marking & Disposal Regulations.
List of Approved PCB Disposal Facilities.
List of Approved PCB Disposal Facilities.
List of Approved PCB Disposal Facilities.
Mar 12, 1979   44  13575
                 Request for Comments on Citizens' Petition to
                   Give Regional Administrators Authority to
                   Approve Alternate Disposal Methods.

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                                                             A-3
Ban Regulations  (§ 6e2, 6e3, etc.) Toxic Substances Control Act
Date
Jun 27, 1977
Dec 30, 1977
Vol. Pages      Subject
 42  32555      Notice of July 19 Chicago Hearing.
 42  65264      Notice that EPA Would Not Enforce Ban on
                  Uses in "Other Than a Totally Enclosed
                  Manner."
Jun 7, 1978    43
Jun 7, 1978    43
Aug 25, 1978   43

Sept 22, 1978  43
Nov 1, 1978    43
     24802-17
     24818
     38057

     43048
     50905-07
Jan 2, 1979    44  108-109
May '-',/, 1979   44
Proposed Ban Regulations.
Requires Notification of Intent to Export.
Incorporates Hearing Record of  Effluent
  Standard Regulations  into Hearing Record
  for Ban Regulations.
Notice of Cross-Examination of  Versar.
Interim Rules:  Applications for Exemption
from PCB manufacturing  ban.
Notice that enforcement is postponed until
regulations are promulgated.
Promulgated Ban Regulations

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Food and Drug Administration
                                                                  A-4
     Date
     1972
Vol. Pages         Subject

 37  5705-5707     Notice of Proposed Rule-Making.
     Jul 6, 1973    38  18096-103     Limits of PCBs in Foods, etc., Aug. 8
                                        Corrections.
     1975
 40  11563-66
     Apr 1, 1977    42   17487-94
PCBs in Paper/Food Packaging Material.
                   PCBs in Food - Proposed Changes.
National Cancer  Institute
     Date
Vol. Paaes
     Apr 21, 1978    43   17060
Subject

Carcinogenicity of Aroclor 1254.

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             APPENDIX B
VERSAR REPORTS TO EPA RELATED TO PCBs

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                                                                  B-l
 Contract 68-01-3259 - EPA;  Mr. Thomas Kbpp, EPA Technical Project Officer

      Office of Toxic Substances

 Durfee,  R.  L.; Contos, G. Y.; and Whitmore, F. C.  "Study of Regulatory Alterna-
    tives for PCBs," Draft Interim Report, Task I.  October 31, 1975.  Unpublished.
    (Superseded by PCBs in the United States...")

 Westin,  R.  A. "The Handling and Disposal of Electric Transformers," Special Report,
    Task I,  EPA Proprietary Data.  December 5, 1975.  Unpublished.   (Non-proprietary
    parts included in "PCBs in the United States...")

*Pallotta, A. J. "Toxicological Studies Conducted Under Task I:  Special Report."
    Washington, D. C.:  Office of Toxic Substances, U. S. Environmental Protec-
    tion Agency, February 19, 1976.   (Included in "PCBs in the United States..."
    as Appendix F).

*Durfee,  R.  L.; Contos, G. Y.; Whitmore, F. C.; Barden, J. D.; Hackman, E. E.;
    and Westin, R. A. "PCBs in the United States:  Industrial Use and Environ-
    mental Distribution," Final Report, Task I (EPA 560/6-76-005).  Springfield,
    Va.:   National Technical Information Service  (NTIS PB 252-012), February 25,
    1976.

*Mosbaek, E.  (Jack Faucett Associates), "Development of an Economic Analysis
    Methodology for Evaluating Regulatory Alternatives for PCBs," Special Report,
    Task I.  March 9, 1976.  Unpublished.

 Contos,  G. Y. and Durfee, R. L. "Results from Review and Analysis of 308 Letter
    Responses on PCB Manufacturing, Usage, and Disposal in United States Industry."
    (EPA Proprietary Information, submitted to EPA Enforcement Division)  November,
    1975.  Unpublished.

*Contos,  G.; Durfee, R. L.; Hackman, E. E.  (Versar, Inc.), and Price, K.  (Clark,
    Dietz and Associates).  "Assessment of Wastewater Management, Treatment
    Technology, and Associated Cost for Abatement of PCBs Concentration in
    Industrial Effluents," Final Report, Task II  (EPA 560/6-76-006).  Springfield,
    Virginia:  National Technical Information Service  (NTIS PB 251-433/AS),
    February 3, 1976.

*Barden, J. D. Durfee, R. L. "Development of a Study Plan for Definition of
    PCBs Usage, Wastes, and Potential  Substitution in the Investment Casting
    Industry," Final Report, Task III  (EPA 560/6-76-007).  January, 1976.
    Springfield, Va.:  National Technical Information Service  (NTIS PB 251-842).

*Carr, R. A.; Contos, G. Y.; Durfee, R. L.; Fong, C. C.; and McKay, E. G. "PCBs
    Involvement in the Pulp and Paper  Industry" Final Report, Task IV
    (EPA 560/6-77-005).  Springfield, Virginia:  National Technical  Information
    Service  (NTIS PB 271-071/6WP), February 25, 1977.
 *Summary included in Appendix C.

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                                                                  B-2
*Whitmore, F. C. "A First Order Mass Balance Model for the Sources, Distribution,
    and Fate of PCBs in the Environment," Final Report, Task V.   (Report No.
    EPA 560/6-77-006),  Springfield, Va.:  National Technical Information Service
    (NTIS PB 270-220),  July, 1977.
*Burruss, R. P. "Assessment of the Environmental and Economic Impacts of the
    Ban on Imports of PCBs," Final Report, Task VI.   (Report No. EPA 560/6-77-007),
    Springfield, Va.: National Technical Information Service  (NTIS PB 270-225),
    July, 1977.

*Westin, R. A. "Assessment of the Use of Selected Replacement Fluids for PCBs
    in Electrical Equipment," Final Report, Task VII.   (EPA 560/6-77-008),
    Springfield, Va.:  National Technical Information Service  (NTIS No. forthcoming),

 Carr,R. A.; DeFries, R.; and Fensterheim, R. "Environmental Discharges of PCBs
    Associated with the Manufacture and Use of PCBs and PCB-Containing Equipment."
    (Contains EPA Proprietary Information, submitted to EPA Enforcement Division)
    October 29, 1976.  Unpublished.

 Dentel, S., and Kuniansky, S. "Usage of PCBs in Open and Semi-Closed Systems
    and the Resulting Losses of PCBs to the Environment," Draft Final Report.
    (Contains EPA Proprietary Information, submitted to EPA Enforcement Divi-
    sion) .  September 30, 1976.  Unpublished.

      Office of Water Planning and Standards:  Mr. Ralph Holtje, Criteria
        and Standards Division

 Sargent, D. L. "An Approach to Zero Water Usage and Runoff Control for First
    Tier PCB User Industries," Extension to Task II, June, 1976.  Unpublished.

*Sargent, D. L. and Contos, G. Y. "PCBs Water Elimination/Reduction Technology
    and Associated Costs:  Manufacturers of Electrical Capacitors and Trans-
    formers," Addendum to Final Report, Task II.   (EPA 440/9-76-020) Washington,
    D. C.:  Criteria and Standards Division, U. S. Environmental Protection Aaency,
    July 2, 1976.

 Contos, G. Y. "Recommendations as to PCB Sampling Sales and Sampling Points at
    Industrial Sources," Special Report.  August 17, 1976.  Unpublished.

*Mosbaek, E.  (Jack Faucett Associates, Inc.) "Economic Analysis of Proposed
    Toxic Pollutant Effluent Standards for Polychlorinated Biphenyls:  Trans-
    former, Capacitor,  and PCB Manufacturing."  Washington, D. C.:  U. S.
    Environmental Protection Agency (Report No. EPA 230/1-76-068), October 1976.

*Contos, G. Y. "Costs for U.V.-Ozonation Process," Addendum to Final Report,
    Task II.  September 27, 1976.  Unpublished.

*Sargent, D. L. and Contos, G. Y., "Detailed Cost Estimates for Alternative PCBs
    Treatment Technologies Applied to Hypothetical Large and Medium Sized PCB
    Capacitor and Transformer Manufacturing Plants," Addendum to Final Report,
    Task II.  October 15, 1976.  Unpublished.
 ^Summary included in Appendix C.

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                                                                  B-3
*Contos, G. Y. "Cost for Equalization Basin Based on Bentonite Clay Liner,"
   Special Report.  October, 1976.  Unpublished.

*Westin, R. A. "Impacts of Substitutes for PCBs on Fire Hazards in Commercial
   and Residential Buildings," Draft Special Report.  Washington, D. C.: Criteria
   and Standards Division, U. S. Environmental Protection Agency, October, 1976.
   Unpublished.

*Durfee, R. L. and Hackman, E. E.  "Recent Advances in PCBs Detoxification  in
   Wastewater," Supplement to Final Report, Task II.  Washington, D. C.:
   Criteria and Standards Division, U. S. Environmental Protection Agency,
   January 18, 1977.  Unpublished.

*Durfee, R. L. and Carr, R. A. "PCB Levels in Non-Contact Cooling Waters and
   Other Effluents from Capacitor  and Transformer Production Facilities,"
   Supplement to Final  Report, Task II.  Washington, D. C.:  Criteria and
   Standards  Division,  U. S. Environmental Protection Agency, January 19,  1977.
   Unpublished.

*Durfee, R. L.; Sargent, D. H. and Contos, G. Y. "Refinement of Alternative
   Technologies and Estimated Costs for Reduction of PCBs in Industrial Waste-
   waters from the Capacitor and Transformer Manufacturing Categories."
   Washington, D. C.:  Criteria and Standards Division, U. S. Environmental
   Protection Agency, January 19, 1977.  Unpublished.

*Durfee, R. L. and Westin, R. A. "Costs Associated with Installing Production
   Equipment  for Use of Non-PCB Dielectric Fluids in Transformer and Capacitor
   Manufacture," Supplement to Final Report, Task II.  Washington, D. C.:
   Criteria and Standards Division, U. S. Environmental Protection Agency,
   January 19, 1977.  Unpublished.

     PCB Disposal and Marking Work Group;  Mr. David Wagner, EPA Project Officer

"Assessment Methodology for Labeling and Education to Assure the Proper Disposal
   of PCBs."  (Outline of the technical assessment that would be required to
   support the regulations for the labeling of PCBs)   November 1976.   Unpublished.

"Analysis of the Economic and Technological Constraints on the Disposal of PCBs,"
   Special Report, November 22, 1976.   Unpublished.

"PCB Disposal Regulations:  Problem Areas and Regulatory Alternatives."
   December 10, 1976.   Unpublished.

"Estimated Usage of Electrical Equipment Containing PCBs."  December 23, 1976.
   Unpublished.

"Recommended Label Requirements and Suggested Label Formats."  January 12,
   1977.  Unpublished.

"Draft Notice of Public Meeting - PCBs."  January 10, 1977.   Unpublished.
*  Summary included in Appendix C.

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                                                                      B-4
"Garments on PCB Definitions to Subcommittee on Manufacturing Bans."
   January 14,  1977.   Unpublished.

"Draft Notice of Properse Rulemaking,  Preamble, and Labeling and Disposal
   Regulations" (Revised 2-4-77).   January 21, 1977.  Unpublished.

"Labeling and Disposal Regulations" Revised Draft.  January 27, 1977.
   Unpublished.

"Draft Preamble to PCB Disposal Regulation."  December 29, 1976,  (Revised
   January 12, 1977,  February 21,  1977).   Unpublished.

"Econonic Impact - Summary and Conclusions,"  (Early Draft of Marking and Dis-
   posal Economic Impact Report).   March 14, 1977.  Unpublished.

"Statement of Economic Consequences of the Rule"  (Draft Section for Preamble
   to Marking and Disposal Regulation).   April 12, 1977.  Unpublished.

*Westin, R.A.; Fourt, L.; Drabkin,  M.; Guinan, D.; Berkey, D.; Frankel, I.;
   and Sood, D.  "Microeconomic Impacts of the Proposed Marking and Disposal
   Regulations for PCBs,"   (EPA 560/6-77-013).  Springfield, Va.:  National
   Technical Information Service (NTIS PB-267-833), April 1977.

*"Potential Impacts of the Bans on PCB Manufacturing, Processing, and Use:  PCB
   Activity Analysis Papers," Special Report.  July 11, 1977.  Unpublished.

 Westin, R.A.; Fourt, L.; Drabkin,  M.; Berkey, D.; Woodcock, B.; and Sood, D.
   "Microeconomic Impacts of the Draft PCB Ban Regulations," Draft Report,
   (based on August 30, 1977 draft of regulations).  September 28, 1977.
   Unpublished.

*Westin, R.A.; Fourt, L.; Berkey,  D.;  and Woodcock, B., "Microeconomic Bnpacts
   of the Draft PCB Ban Regulations,"  (Includes Appendices C:  "Characterization
   of U.S. Waste Oil Industry," and D:  "Supply and Demand Effects of PCB Ban on
   the Electric Equipment Industry.").  March 8, 1978.  Unpublished.

Contract 68-01-4771

     Office of Planning and Management:  Mr. Steven Malkenson, Mr. Stephen Weil,
                                         EPA Technical Project Officers

*Westin, R.A.; Fourt, L.; Berkey,  D.;  and Woodcock, B. "Microecononic Impacts
   of the Proposed PCB Ban Regulations"  (EPA 560/6-77-035) Springfield,
   Virginia:  National Technical Information Service  (NTIS PB-281 881/3WP),
   May, 1978.

*Westin, R.A.; Woodcock, B., "PCB Manufacturing, Processing, Distribution  in
   Commerce, and Use Ban Regulation:  Economic Impact Analysis,"  (EPA 230-
   03/79-001).  Washington, D.C.:   Office of Planning and Management, U.S.
   Environmental Protection Agency.
*Suntnary included in Appendix C.

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                                                                      B-5
Other Contracts

Whitmore, F.C. "Destruction of Polychlorinated Biphenyls in Sewage Sludge
   During Incineration" Final Report  (EPA Contract 68-01-1587) Springfield,
   Virignia:  National Technical Information Service  (NTIS PB-258 162), 1975.

Sargent, D.H.; Carr, R.A.; and Vogel, G.A.  "PCBs Removal in Publicly-Owned
   Treatment Works," Final Report, Task 13.  EPA Contract 68-01-3273, Washing-
   ton, D.C.:  Criteria and Standards Division, Office of Water Planning and
   Standards, U.S. Environmental Protection Agency, December 15, 1976.

Versar, Inc., "Gross Annual Discharge to the Waters in 1976 - Polychlorinated
   Biphenyls," Revised Report No. 16, Task  II.   (EPA Contract 68-01-3852)
   Washington, D.C.:  Monitoring and Data Support Division, Office of Water
   Planning and Standards, U.S. Environmental Protection Agency, 1978.

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                  APPENDIX C
SUMMARY OF MAJOR VERSAR REPORTS REGARDING PCBs

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                                                                   C-l
               TOXICOLOGICAL STUDIES CONDUCTED UNDER TASK I
                    Special Report    February 19, 1976
        (Included in "PCBs in the United States..." as Appendix F)
     This study presents the results of two general areas of effort concerned
with PCBs:  the toxicology of PCBs and the testing of potential substitutes for
PCBs.
     The toxicological aspects of PCBs are sunmarized, with emphasis placed on
potential human health hazards caused by widespread use of PCBs in the United
States.  Tests have been conducted on the toxicity and carcinogenicity of PCBs
in a variety of animals including rats, dogs, rabbits, and monkeys.  In addi-
tion, there was an incident in Japan where approximately 1,000 people consumed
rice oil that was contaminated with PCBs.
     Reviewing the results of these studies led to several important conclusions.
PCBs tend to localize in certain tissues and do not break down easily in the
body, leading to cumulative or chronic toxicity.  Early toxicological evidence
concerning the chronic adverse health effects of PCBs from experimental animals
such as mice and rats and from observational data in humans has more recently
been supplemented by additional experimental findings in monkeys.  A close
 correlation exists for PCBs between the symptoms noted in humans and those
 noted in monkeys, suggesting that the dose/response relationships and meta-
 bolic and excretion phenomena in humans are similar to those in monkeys.
 According to some pathologists, PCB exposure can cause cancerous liver lesions.
 Evidence from short-term (several months) exposure and chronic exposure in
 animals and humans demonstrates that PCBs are a significant health hazard.
      Following the review of the toxicological potential of PCBs,  a study was
 made of the procedures necessary for evaluating the potential hazards from
 possible PCB substitutes.  Preliminary information necessary for a thorough
 investigation of a substance includes:
      1)  Physical and chemical properties
      2)  Manufacturing processes and possible losses
      3)  Chemodynamics, environmental alteration, and bioaccumulation.

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                                                                   C-2
                      PCBs IN THE UNITED STATES:
             INDUSTRIAL USE AND ENVIRONMENTAL DISTRIBUTION
                          FINAL REPORT, TASK I
                           February 25, 1976
                            EPA 560/6-76-005
                            OTIS PB-252-012

                            TABLE OF CONTENTS
SECTION                           TITLE                                  PAGE
I              Introduction                                                 1
II             Summary                                                      4
III            Conclusions and recommendations                             25
IV             Chemical and physical properties of PCBs                    31
V              Industrial characterizations                                54
VI             Waste treatment technologies                               145
VII            Production and distribution                                198
VIII           Substitutes for PCBs                                       220
IX             PCBs release and cumulative environmental loads            286
X              Inadvertent ambient reactions as routes of entry of
               PCBs into the environment                                  297
XI             Movement of PCBs in the environment - general
               distribution model                                         314
XII            Regulatory actions on PCBs                                 322
Ap. A.         PCB adsorption testing by XAD-4 resin                    A-l/A-3
Ap. B          Macroreticular resins from Rohm and Haas Co.             B-l/B-7
Ap. C          Non-carbon adsorbtion and other research stage
               PCB treatment technologies                               C-l/C-18
Ap. D          Mass balance model for PCB distribution                  D-l/D-46
Ap. E          Background data used to construct the model for
               PCBs in Lake Michigan                                    E-l/E-21
^P* F          Toxicological Studies                                    F-l/-

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                                                                   03
     This report summarizes the production, use, and distribution of poly-
chlorinated biphenyls  (PCBs) in the United States.  The information was obtained
by detailed studies of the production of PCBs, the use of PCBs by first tier
user industries, the past and present generation and disposition of PCB-contain-
ing wastes, environmental transport and cumulative loads, potential alternatives
to PCB usage, inadvertent losses to and potential formation of PCBs in the
environment, and current regulatory authorities for PCBs control.
     It is estimated that approximately 1.5 billion pounds of PCBs have been
sold for industrial use in the U. S. since initiation of production around 1930.
Of this amount, at least 95 per cent is still in existence; most is in service
in capacitors and transformers, but about 290 million pounds are believed to
reside in landfills and dumps and about 150 million pounds are believed to be
"free" in the environment.  The magnitude of these values indicates that there
is a strong future threat from PCBs in land disposal sites.
     In 1974, U. S. use of PCBs sold by Monsanto, the sole domestic producer,
was distributed between capacitor manufacture  (22 million pounds) and transformer
manufacture  (12 million pounds).  Imported materials amounted to about one per
cent of U. S. industrial purchases of PCBs in 1974; about 400,000 pounds  (of
decachlorobiphenyl) were used in investment casting, and an estimated 50,000
pounds of new material were used in specialized heat transfer systems.
     Although PCB content in industrial wastes can be reduced through various
approaches  (treatment, substitution, etc.), the large amounts of PCBs already
contained in land disposal sites present a severe hazard for the future.
Further study of this and other aspects of the PCBs problem, and determination
of ways to minimize the hazard, are recanmended.

     MDnsanto and portions of the electrical equipment industry which use PCBs
have greatly reduced PCB releases to water and land over the past few years,
primarily through improvement of plant housekeeping, improved waste collection
and handling, and disposal of liquid wastes through incineration.  Waterborne
effluents from PCBs production and first-tier use currently release amounts to
the environment which are very small in comparison to the amounts entering land

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                                                                   C-4
disposal sites fron these industries.  However, these effluents can have severe
local impacts, as evidenced by the current PCB problem in the Hudson River.

     There is no plant-scale process used at present for the specific purpose
of removing PCBs from industrial wastewater.  The best available treatment tech-
nology for removal of PCBs from wastewater is carbon adsorption after removal  of
solids, oil, and grease.  Carbon treatment can produce end-of-pipe  PCBs
concentrations of one ppb or less.  Other adsorbents, such as resins, also
appear effective to this extent.  The most promising method of those water
treatment technologies under development for PCBs destruction is ultraviolet-
catalyzed ozonation.  "Zero discharge" to water of PCBs from production and
first-tier use is available only through extensive water reuse plus extensive
incineration of lightly contaminated wastewaters.
     Incineration is an effective method of disposal for liquid PCBs.   Land-
filling is the only generally available disposal method for PCBs-contaminated
solid wastes, but incineration of these wastes is technically feasible.
     Significant amounts of solid PCB  (decachlorobiphenyl, or deka)  wastes are
stored or disposed of on land by the investment casting industry.   Air  emissions
of deka may also be significant in amount, but no evidence of potential health
hazards from this material has been reported.
     The total present use of PCBs for open and semi-closed applications is
not known but is believed to be small  in comparison to closed electrical system
use.  A few capacitor manufacturing plants report recent use of PCBs in vacuum
pumps, and a significant amount of carbonless copy paper containing PCBs must
still be in inventory and in files.

     PCBs are uniquely suited to the requirements of capacitors for A.  C. service.
Although a number of potential substitues for this application are  under devel-
opment and test, they are all more flammable than Aroclor 1016 and  neither their
performance in service nor their potential toxicity to man and other species
have been evaluated sufficiently to allow a definitive comparison with.  1016.

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                                                                    C-5
     Alternatives to PCB  use in new transformers are available.  In addition,
 testing of promising substitute fluids (termed "self-extinguishing") is under
way; these fluids may gain industry-wide acceptance within three years as sub-
stitutes for PCB fluids.  At present,  choice of PCB-filled transformers
appears to be based primarily on cost considerations.
     No technical barriers to substitution for PCBs  (deka) in investment cast-
ing waxes are apparent.   Several potential alternatives have been previously
used by this industry.
     Atmospheric fallout  is a major  source of PCB  input to freshwater systems.
In Lake Michigan, the PCB: contribution at present  appears to be much larger
than the total PCB inputs fror.  point sources such  as minicipal  sewage treat-
ment and paper recycling.
     The importance of atmospheric transport of PCBs relative to other potential
inputs to water indicates that  the availability of environmental sinks from
PCBs is limited, possibly due to short  residence times to evaporation in sea
water.
     Chlorination of waste biphenyl  in  industrial  wastewaters discharged into
municipal  sewers is a potential mechanism for inadvertent production of PCBs.
     At present, regulatory authority over PCBs in the United States is not
  sufficient to significantly reduce  future PCB inputs to the environment, although
 inputs directly to the waterways from industrial sources can be reduced from
their present level.  Current disposal  practices,  except for incineration, tend
to delay instead of prevent the PCB'  entry into the "free"  (available to the
biota) state, and these practices are regulated only minimally.

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                                                                    C-6
              DEVELOPMENT OF AN ECONOMIC ANALYSIS METHODOLOGY
              FOR EVALUATING REGULATORY ALTERNATIVES FOR PCBS
                 Task I, Special Report    March 9, 1976
     (Prepared by Jack Faucett Associates under Subcontract to Versar)
                                Unpublished
      This report presents factors to be taken into account when evaluating
alternatives to PCBs to arrive at fair and reasonable time restrictions
on the use of PCBs.  Also included are a critique of previous estimates
of the cost of regulating PCBs, suggestions for improving such estimates,
and a survey of the technological aspects of PCB controls.
      The following regulatory alternatives are considered:
      1)  Regulation based primarily on chlorine content of Aroclor
      2)  Regulation based primarily on type of use
      3)  Regulation based on responsibility of user
      4)  Regulation of new PCBs
      5)  Regulation of phase-out for PCBs currently in use
      6)  Regulation oriented toward control of waste
      7)  Regulation oriented toward protection of population from
          exposure to PCBs
      After possible regulatory options were identified, a study was made of the
 information required to evaluate the various alternatives.  It was decided that
 comprehensive information in each of the following areas was needed:
      1)  Present manufacturing and use
      2)  Future substitutions and product changes
      3)  Methods of release to the environment and transport and fate in the
          environment
      4)  Toxicity, including exposure levels and results of past incidents
      5)  Effect, legality, and options for regulation
      Covered under the study of technological aspects of PCB controls are:
      1)  Current and suggested regulations for reducing exposure to PCBs
          currently in the environment

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                                                             07


2)  Waste disposal control

3)  Effects of phasing out PCB use

4)  Limitations on the use of new PCBs in investment casting wax, small
    capacitors, large power factor capacitors, and electrical transformers

Factors that were analyzed for each of the products above are:

1)  Risks from continued use

2)  Present alternatives

3)  Effect that timing of a ban would have on cost and availability of
    alternatives

4)  Benefits from use of alternatives

5)  Cost of ban of PCBs

This report reaches the following conclusions:

1)  A total ban on PCBs will have only a minor effect on the current
    environmental problem but will be necessary in the long run.

2)  The smooth transition to PCB alternatives is unlikely because of
    uncertainty about the rationale for and probability of a PCB ban.

3)  Many of the opinions and cost estimates uncovered in this research
    indicate that there has been more preparation for debate than for
    orderly changeover

4)  Estimates of costs and benefits should be clearly explained to provide
    incentive for every accurate data supply.

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                                                                       C-8
       ASSESSMENT OF WASTEWATER MANAGEMENT, TREATMENT TECHNOLOGY.-
        AND ASSOCIATED COSTS FOR ABATEMENT OF PCBs CONCENTRATIONS
                         IN INDUSTRIAL EFFLUENTS
                          FINAL REPORT, TASK II
                            February 3, 1976
                            EPA 560/6-76-006
                             NTIS 251-433/AS

                            TABLE OF CONTENTS
SECTION                             TITLE                                 PAGE
I        Introduction                                                        1
II       Summary and conclusions                                             4
III      Recommendations                                                    15
IV       Water use and waste characterization                               18
V        Selection of pollutant parameters                                  79
VI       Wastewater treatment technologies                                  84
VII      Cost of treatment and control technologies                     138/227
Ap. A    Plant 106's position statement on Dew's SFX-4169
         capacitor dielectric liquid                                    A-l/A-2
Ap. B    PCB adsorbtion testing by XAD-4 resin                          B-l/B-3
Ap. C    Description of macroreticular resins from Rohm
         and Haas Co.                                                   C-l/C-6
Ap. D    Non-carbon adsorbtion and other research stage
         PCB treatment technologies                                     D-l/D-18

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                                                                       09
     This report presents the findings of a  study of available wastewater
management and treatment technology  for the  purpose of determining toxic pollu-
tant effluent concentrations and daily load achievable in three industrial
categories:  polychlorinated biphenyls  (PCBs) manufacturing; capacitor manu-
facturing; and transformer manufacturing.  All plants in these categories have
PCB discharges to either waterways or sewage treatment plants, under normal
operating conditions.  All plants have discharges to storm sewers or directly
to waterways under heavy rainfall conditions.
     Extensive survey of wastewater  treatment technologies and cooperative
laboratory work with several suppliers of treatment equipment and research
facilities confirmed that carbon adsorption  technology is the best current can-
didate  for successful removal of PCBs from the wastewaters.  Uv-ozonation was
considered as an alternative.  This  technology is still in the research stage;
however, it offers potential of complete destruction of PCBs all the way to C02,
water,  and HC1.
     Another adsorbent technology now in the development stage, AMBERLITE
polymeric adsorbents, has demonstrated a PCBs removal efficiency that was roughly
equivalent to carbon during laboratory tests.  Further testing is needed with
this adsorbent to accurately assess  its potential .
     For scrap oils  and burnable solid wastes generated at these plants, high
temperature, controlled incineration offers  a straightforward method of destruc-
tion, whereas scientific landfilling appears to be the best suited mode of
disposal for nonburnable contaminated solids.
     Zero discharge  objectives can be best achieved by eliminating discharge
streams and developing recycle systems.  All non-contact cooling water would
be pretreated.   The portion of the pretreated water which would be used in the
plant would be treated with carbon, while the excess water would be incinerated
in a specially designed system which would allow for energy recovery.
     Supporting data, rationale for  the selection of above recommended treatment
technologies and associated costs are contained in this report.

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                                                                      010
               DEVELOPMENT OF A STUDY PLAN FOR DEFINITION
             OF PCBs USAGE, WASTE,  AND POTENTIAL SUBSTITUTION
                    IN THE INVESTMENT CASTING INDUSTRY
                         FINAL REPORT, TASK III
                              JANUARY, 1976
                           EPA 560/6-76-007
                             NTIS PB 251-842
     This report summarizes the use of decachlorobiphenyl  (deka) and poly-
chlorinated terphenyls (PCTs) as wax fillers in the investment casting indus-
try and develops a detailed study plan of the industry.  Significant information
gathering efforts would be required to establish a complete picture of the
practices, processes, and products of this industry, which in this instance, is
taken to include casting wax manufacture as well as wax usage in foundries.
Definition of the waste streams and emissions from the processes used will
require sampling and analysis and gathering available process data from the
industry.
     An approach to determining the most suitable alternatives to decachloro-
biphenyl and PCTs is presented.  Filler substitutes and the use of unfilled
waxes are the two general alternatives to be studied.  At present there appear
to be no technical barriers to discontinuation of deka and PCTs as fillers,
although use of alternatives may increase product cost on the order of 10 per-
cent.  In determining the most premising alternatives, product and process
oriented technical factors must be evaluated, but potential environmental and
human health effects may prove to be the most important factors in selection.
An approach to comparison of alternatives based on technical factors and toxi-
cology data is presented.  However, it is anticipated that toxicological data
on most alternatives, and also on the currently used materials, will be sparse.
     The success of information gathering and in-plant sampling efforts is
expected to depend heavily on use of Section 308  (FWPCA) authority.  Air
emission sampling would be very important to the establishment of an overall
process material balance and definition of process losses to the environment.

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              PCBS INVOLVEMENT IN THE PULP AND PAPER INDUSTRY
       FINAL REPORT, TASK IV    February 25, 1977    EPA 560/6-77-005
                                                     NTIS PB-271 017/6WP

      This paper discusses in detail the sources, distribution, and losses of
 PCBs in the U. S. pulp and paper industry.  The major use of PCBs in the indus-
 try was as an ink solvent in carbonless copy paper that was manufactured by
 various paper mills for NCR from 1957 to 1971.  Since 1977, PCB levels in
 recycled paper have diminished rapidly but PCBs are still present in the
 effluent water from companies that recycle waste paper.
      Arcclor 1242, a PCB mixture containing 42% chlorine,  was used as a solvent
 for color reactants which were then microencapsulated and  applied to one side of
 the carbonless copy paper.  The microspheres ruptured and released the dye under
 high pressure, such as would be applied by a pen or pencil.  44,162,000 pounds
 of Aroclor 1242 were used for this purpose during the period 1957-1971.  The
 average content of PCBs in the paper was 3.4%.  A minor use of PCBs in the
 paper industry/, was in inks,  which consumed approximately  50,000  pounds of  PCBs
 from 1968 to 1971.
      Recycling of wastepaper is a large part of the paper industry.  Wastepaper
 is the third most important source of pulp behind pulpwood and forest product
 wastes.  19% of the annual output of finished paper is recycled each year.   There
 are 230 paper mills that produce pulp completely derived from wastepaper and
 550 other facilities that use 10-15% secondary fiber in their pulp production.
      PCB concentrations in paper products, paper mill effluents, and sludges
 have declined sharply since the use of PCBs in carbonless copy paper was ter-
 minated in 1971.  Concentrations in paper products are now in the 0-1 ppm range.
 Sludges have been in the < 1 to 24 ppm range which is common for municipal
 sewage treatment plants.  The major reasons behind this sharp reduction in PCB
 concentrations are the elimination of PCB use and the disposal each year of
 81% of the annual, paper production via incineration or landfillinar together
these removed approximately 80% of the PCBs fron the paper cycle each vear.
A small amount of PCBs is added to paper products each year because of the

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                                                                      012
presence of PCBs in plant influent water, but this contribution does not appear
to be significant at present.
     Prediction of PCBs in paper mill effluent and products by using a mathemati-
cal model of the industry indicates that PCB concentration reached its peak
during 1970-71 and is declining to pre-1957 levels because amounts of PCBs in the
recycled wastepaper stream are also declining.
     Qn-site measurements and laboratory experiments have shown that PCBs are
attracted to the fibers rather than to the water in which they are carried.  Dis-
charge of PCBs from a paper mill appears to be by way of suspended solids and
removal of these suspended solids should substantially reduce PCB effluents.
     The paper industry as a whole is continuing to develop and install water
recycling technology in order to minimize waste treatment costs and recover
chemicals, heat, and raw materials.  New treatment systems also offer the pro-
mise of reduced PCB discharges.  Some data indicate, that PCBs are being re-
moved from influent streams and are becoming fixed in the paper products, there-
by producing a net reduction in PCBs which are free in the environment.  However,
these PCBs could be re-released when the paper products are disposed of.
     It is believed that essentially all of the PCBs used in the production of
carbonless copy paper have been released to the environment.  Half are believed
to reside in landfills and the remainder have been dissipated.

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                                                                      C-13

              A FIRST ORDER MASS BALANCE MODEL FOR SOURCES,
            DISTRIBUTION, AND FATE OF PCBs IN THE ENVIRONMENT
                          FINAL REPORT, TASK V
                               JULY, 1977
                            EPA 560/6-77-006
                             NTIS PB 270-220

     The work presented here, an extension of that reported in the Task I
report, is an attempt to answer the question, "How did it cone about that
a compound, such as the PCBs, is so widespread an environmental contaminant?"
The work involves the construction of several descriptive mathematical models
made necessary by the lack of historical data and the absence of a large base
of reliable contemporary measurements.  The work is necessary since the measure-
ments that do exist strongly suggest that the PCBs are a persistent menace to the
biosphere and hence that actions to control them cannot be delayed while a truly
adequate data base is obtained.
     The basic model is constructed on a mass balance principle; that is, all
the PCB input to a restricted region of the lithosphere may be accounted for by
solution, by uptake on suspended solids, and by uptake within the biota, with the
remainder of the input PCBs being carried off by the "loss" processes consisting
of surface co-distillation, carrybff by outflowing streams, and entrapment within
the sediments.
     The model is somewhat complicated by the necessity of an analytic expres-
sion for the PCB input rate as a function of time; i.e., the driving function.
In the absence of a sufficient amount of data, a model has been constructed to
account for the losses to the environment, for the free or "wild" PCB lead, and
for the atmospheric reservoir of PCBs.  The actual relationship of the various
parts of the model are shown in Figure I.
Environmental Load Model
     Appendix C and Appendix D attempt to determine the magnitude of the total
environmental load, the free environmental load, and the atmospheric reservoir
of PCEs, all as functions of time.

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                                                                            C-14
                                        Figure I

            Schematic Showing Relationship of the Various Sections of Eeport*
   Environmental
   Load Model
       (C)
      Free PCB
    Load Model
        (0
    Atmospheric
      Reservoir
       Model
         (C)
       Surface
  Co-Distillation
       Model
         (3)
Lake Michigan
    Model
    (2) (3)
   Fish Uptake/
    Clearance
      Mode
       (6)
Great Lakes
   Model
    (4)
1  Continental  '
1  Atmospheric  I
I     Model     I
                                                                       l_
                 Sediment
                 Suspended
                  Solids
                  Model
                  (B) (3)
*The number or letter associated with each block refers to section dealing directly with
 the subject matter.

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                                                                      C-15
     The results of this analysis are:
     a.   In 1975, the total environmental PCB load is estimated to be 3.76 x
         108 Ibs. within the continental United States.
     b.   In 1975, the total free or mobile PCB load in the continental
         United States is estimated to be 8.31 x 107 Ibs.  The remainder
         of the total environmental load is thought to be encapsulated in
         one form or another (in landfills, for example).
     c.   As of 1970, the cumulative atmospheric reservoir contained some
         6 x 107 Ibs. of PCB indicating a rather rapid exchange between the
         total mobile PCBs and the atmospheric reservoir.
     d.   As of 1975, the PCB concentration in the air near Lake Michigan
         was of the order of 10 yg/m3.
     e.   The estimated half life for fallout from the atmospheric reservoir
         is 0.9 years.
     f.   The average chlorine number for environmental PCBs is of the order
         of 4.32.
Results  of Mass Balance Model Applied to Lake Michigan
     The results of this analysis are :
     a.   A plausible scenario indicates a present-day PCB concentration (water
         plus suspended solids) of the order of 7-10 ppt.
     b.   Atmospheric fallout constitutes the major input of PCBs to Lake
         Michigan.
     c.   Surface evaporation or co-distillation  (the exact nomenclature
         is not known because the process is incompletely understood)
         constitutes a significant PCB loss mechanism.
     d.   The presence of suspended solids within the water column can be
         expected to have a dominant effect on the actual  (filtered)
         aqueous concentration.

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                                                                      C-16
     e.  The sediments should act as a significant sink for the removal of
         PCBs from the water column.
     f.  Even though there is considerable uncertainty as to the proper value
         for some of the important parameters, the sheer bulk of the water
         mass makes the aqueous concentration essentially independent of these
         parameters over wide ranges.
     g.  70 years would be required to reduce the present PCS concentration by
         one-half in the absence of all external sources.
Results of Mass Balance Model Applied to the Entire Great Lakes System
     a.  A plausible scenario leads to an estimate of aqueous PCB concentrations
         within the range of measured values, i.e., less than 40 ppt.

     b.  The estimated average PCB concentration in the sediments of lake
         Erie and Lake Ontario fall within an order of magnitude of other
         estimates.
     c.  The estimated fallouts in 1974 onto Lake Erie and Lake Ontario both
         fall within a few percent of other estimates.
     d.  Point source inputs, when introduced into Lake Erie and Lake Ontario,
         led to PCB concentrations in the aqueous phase as well as within the
         sediments which are within a factor of 2 or 3 of direct observation.
     e.  The lifetime of the present PCB loads in the absence of all sources
         can be estimated.
Other Results
     Other results obtained somewhat incidentally to the main effort include:
     a.  An estimate of the bioconcentration rates of PCBs for a trout
          (about 4 x 106)-
     b.  An estimate that, for the trout, the uptake of PCBs from contaminated
         food is 50 times greater than from respiration.

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                                                                 C-17
c.  The MacKay and Vfolkoff model for co-distillation is apparently not
    applicable in the situation where infalling PCB complicates the situa-
    tion.
d.  The significant difference in activity of PCBs in bulk solution
    compared to that in the surface layer is probably the driving force
    for the creation of a surface concentration gradient.
e.  A formulation is developed that suggests the possibility of an analy-
    sis of the continental PCB atmospheric reservoir.

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                                                                      C-18
             ASSESSMENT OF THE ENVIRONMENTAL AND ECONOMIC
                IMPACTS OF THE BAN ON IMPORTS OF PCBS
                         FINAL REPORT, TASK VT
                               JULY 1977
                           EPA 560/6-77-007
                            NTIS PB 270-225

     This report summarizes an investigation into the uses of imported PCBs
in the United States and a determination of the economic impacts which may
occur as a result of the impending ban on importing PCBs.   Imported PCBs are
currently used only for the maintenance  of two types of mining machinery
produced in the past by Joy Manufacturing Co.   PCBs may also be a significant
contaminant in polychlorinated terphenyls (PCTs) which wax manufacturers
import for use in tooling compounds  and  investment casting waxes.  However,
the sole U.S. distributor of PCTs  is currently guaranteeing that such con-
tamination is less than 0.05%.
     PCE fluids were used as coolants  in minina machinery because of their
low combustability, low electrical conductivity, and inertness which mini-
mizes system corrosion even at continuous high operating temperatures.  The
two types of mining machinery manufactured by Joy which use PCBs are loaders,
of which there are approximately 350 and which were last produced in 1973,
and continuous miners, of which there  are approximately 50 and which were
last produced in 1970.  Converting the motors in the loaders to air cooling
would cost about $6,200 per loader.  Converting the continuous miners would
require replacement of the cutting heads and would cost about $65,000 per
miner.  As a result of the Toxic Substances Control Act, owners of the
machinery which use PCB fluids have three options:
     1)   Petition  for an exemption to the Act.
     2)   Bear the  cost of converting the machinery motors  to air-cooling.
     3)   Scrap the machinery.
     PCTs are used in wax formulations known as tooling compounds, which
are used to provide support to thin walled objects so that they may be

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                                      OFFICE OF TOXIC SUBSTANCES       c~19
                                           CHEMICAL LIBRARY

machined without being damaged.  After machining, the tooling compound is
removed either by melting or by using an aqueous acid solution.  The sole
producer of tooling compounds which contain PCTs is M. Argueso & Co. of
Mamaroneck, N.Y.
     Investment casting  is  a method of producing metal castings which may
have complex  shapes and  which  have a surface  finish and dimensional toler-
ance which cannot be matched by other casting processes.   It involves first
making a pattern out of  wax,- the pattern is then covered, or  "invested,"
with a refractory coating which hardens at room  temperature.  The wax is
then melted and/or burned out  of the mold.  The  metal is then poured in and
allowed to harden.  Investment casting is  best suited to the production of
a large volume  of small, intricate parts made of metals which are difficult
or impossible to machine.
     PCTs are used in investment casting waxes for several reasons.  They
make the wax  harder at all  temperatures below the melting point; they cause
the wax to harden faster by improving thermal conductivity; and they reduce
the coefficient of thermal  expansion of the wax, resulting in improved di-
mensional accuracy in the finished casting.   Detailed data on PCT loss to
the environment is not available, but possible sources of loss include mold
production, mold dewaxing,  mold firing and preheating, and wax reclamation.
There are eleven manufacturers of investment  casting waxes in the United
States; three currently  use PCTs in their  formulations, and three others
did in the past but no longer  do so.  All  three current users of PCBs receive
them from the same distributor.
     The following points with respect to  PCT use in tooling compounds and
investment casting waxes are noted:
     1)  PCT  containing  casting waxes cost 15C to 25C per pound more than
         non-PCT containing waxes and comprise less than half of the total
         sales  of manufacturers who sell them.
     2)  Of the three manufacturers of PCT containing waxes who ceased using
         PCTs in their waxes within the past  decade, none seems to have been
         placed in an unfavorable competitive position.

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                                                                 C-20
3)   One investment casting foundry, General Electric, has ceased using
    PCT waxes.  They have apparently found adequate substitutes for use
    in casting turbine blades,  an application which is critically de-
    pendent upon high dimensional accuracy and extremely fine surface
    finish.
4)   From 2 and 3 above, it appears that acceptable substitutes for PCT-
    containing waxes are available.
5)   If imported PCTs are found to contain PCBs in excess of 0.05%, the
    EPA can take action to ensure adequate quality control.
6)   If PCTs are found to "present an unreasonable risk of injury to
    health or the environment," they may be banned.

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                                                                 C-21
            ASSESSMENT OF THE USE OF SELECTED REPLACEMENT FLUIDS FOR
                         PCBs IN ELECTRICAL EQUIPMENT
        Final Report, Task VII,  April  1979            EPA 560/6-77-008
                                                       NTIS No.  Forthcoming.
     This report discusses the use of PCBs as dielectric liquids in trans-
formers, motors, electromagnets, and capacitors.  The performance criteria
for replacement liquids are summarized and alternative technologies are
reviewed.
     The major alternatives to the use of PCBs in tranformers are:
     •   Dry type transformers, including gas-filled and cast coil construc-
         tion
     •   Oil-filled transformers located in safe locations or installed in
         a vault
     •   High fire point liquid dielectric-filled transformers,  including
         silicone, paraffinic hydrocarbon, and synthetic hydrocarbon liquids
     •   Non-PCB askarel liquids based on chlorinated benzenes
     PCB filled electromagnets may be replaced with available oil-filled,
high-fire point liquid-filled, or dry type units.  Dry air-cooled motors are
also available for most of the previous applications using PCB-filled elec-
tric motors.
     Alternative capacitor liquids are:
         Phthalate esters
         AUcylated monochlorodiphenyl oxide
         Isopropyl biphenyl
     Other possible capacitor dielectric liquids are also discussed, and
the status of dry film capacitors is reviewed.

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                                                                     C-22
   PCBS WATER ELIMINATION/REDUCTION TECHNOLOGY AND ASSOCIATED COSTS,
        MANUFACTURERS OF ELECTRICAL CAPACITORS AND TRANSFORMERS
                   ADDENDUM TO FINAL RETORT, TASK II
                             JULY 2, 1976
                           EPA 440/9-76-020
     The general potential for reduction of water use in the electrical
equipment manufacturing industry is favorable, since water has to be carefully
excluded from the internals of both transformers and capacitors for the units
to meet product and performance specifications.  Newer plants in these
categories, particularly those of smaller size, use much less water per unit
of PCS use than the older plants.  However, the existing plants would require
a combination of process and plant modifications and wastewater treatment and
recycle to achieve a goal of no discharge of PCB-contaminated waters.  This
addendum to the Task II report summarizes the quantities and sources of the
wastewaters; describes the available alternative technologies for reducing
or eliminating the discharges on a source-by-source basis; and tabulates the
estimated costs for achieving such reduction or elimination.
     Section 2.0 of this report addresses the point sources from the capaci-
tor and transformer manufacturing industry with the absolute goal (with a
single exception from one plant)  of no point-source discharges of any waters.
Extensive applications of process changes  (from wet to dry unit processes or
unit operations), of water segregation practices, of water treatment and re-
cycle practices, and of water-quantity reduction practices were investigated.
The residual contaminated wastewaters not eliminated by these practices were
then hypothesized to be "incinerated," e.g., heated to a sufficiently high
temperature for a sufficiently long time to ensure destruction of PCB con-
taminants.
     Section 3.0 presents the technologies and costs for eliminating PCB
contamination of rainwater runoff from manufacturing plants in this industry.
     Section 4.0 presents the technical basis and estimated costs for three

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                                                                     023
alternative approaches to PCBs reduction in the direct discharges from this
industry to waterways.  The technology and costs presented are based on
those of Reference 1 and Sections 2.0 and 3.0 of this Addendum.  The ap-
proaches were selected to offer a range of PCBs control at various levels
of costs.
     The estimated costs are as accurate as was possible within the scope of
work.  Based on previous experience in this area, we feel that the least re-
liable costs tabulated are those for waste stream segregation.  Costs for
segregation are highly variable from plant to plant, and accurate estimation
is-only possible as a result of detailed study of plant layout, piping, etc.,
which was beyond the scope of this study.

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                                                                     C-24
            ECONOMIC ANALYSIS OF PROPOSED TOXIC POLLUTANT EFFLUENT
                   STANDARDS FOR POLYCHLORINATED BIPHENYLS;
                 TRANSFORMER, CAPACITOR,  AND PCB MANUFACTURERS
           October 1976                           EPA 230/1-76-068
       (Prepared by Jack Faucett Associates Under Subcontract from Versar)

     This report presents an assessment of economic impacts from PCB effluent
controls.  Because of the cost of required effluent controls, it is estimated
that a minimum of nine and maximum of all eleven direct discharging plants
will stop using PCBs depending on the particular regulation issued.  Accord-
ing to industry opinion, the estimated minimum is very unlikely because
additional PCB controls would encourage stopping use of PCBs.  Decisions
against investment in control equipment does not mean, however, that the impacts
of these regulations are zero.  Company decisions to cease PCB use will have
impacts,  particularly with regards to the timing of the decision to stop
using PCBs.  The earlier the switch to substitutes the more likely that pro-
duct prices and performance will change in the transition.
     There is evidence that some industries will cease PCB use prior to imple-
mentation of Section 307(a) controls.  That evidence is based on investment
analysis of probable effects on company profits, announced decisions such as
those by General Electric and Monsanto, and capacitor/transformer users'
preparations for PCB substitutes.  These decisions are significant in light
of the range of government alternatives that were considered.  A major force
in government controls affecting PCB use is the Toxic Substances Control Act,
which will prohibit the use of PCBs in capacitors and transformers by 1980.
The EPA proposed toxic pollutant effluent standards for PCBs in July 1976,
and EPA is scheduled to promulgate regulations in January 1977.  Depending on
the final standard, the affected plants which continue PCB use are likely to
install one of the treatment technologies presented below.  Circumstances at

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                                                                      C-25
each plant could cause deviations in technology costs from the following
sutmiaries:
Government
Regulatory
Options
A
B
C
Zero
Discharge
Potential Technology
Process Change & Carbon Treatment
Maximum Carbon Treatment
Minimum Carbon Treatment

Process Change and Recycle
Average Investment
Cost/Plant
$ 527,000
$1,207,000
$ 392,000

$ 555,000
The cost of each of the technologies varies considerably among plants, but
the above costs are an average of investment costs for model plants that
were considered.
     Since few if any plants will actually install effluent control equipment
in response to Section 307  (a) directly, economic impacts can be viewed as
emanating from timing of decisions.  Monsanto's voluntary ban on PCB produc-
tion and the new Toxic Substances Control Act will effectively terminate PCB
use by 1980 independent of Section 307  (a) provisions.
     Total investment costs and total annual costs for each of the four
treatment technologies are given in the table below.  Our analysis focuses
on the 11 direct discharging plants of the 37 plants that manufacture PCB
transformers and capacitors.
     The following sunmaries are based on analysis of investment, i.e., in-
vestment to meet only federal effluent controls under Section 307 (a), for
model plants.  Conclusions on whether companies with plants similar to each
model would actually install the specified treatment are based on a com-
parison of present costs of the equipment.

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               INVESTMENT AND ANNUAL COSTS FOR DIRECT DISCHARGING TRANSRDRMER
                                    AND CAPACITOR PLANTS
                                    (Millions of Dollars)
    Number of Plants  that would
       Install Treatment:
          Transformer
          Capacitor
 0
 1
                                                    Required Treatment
                                                    B             C
 0
 0
  0
  2
                                       Zero Discharge
  0
  1
    Total Investment:
       Transformer
       Capacitor
                      a
0.0
.26
0.0
0.0
0.0
.23
0.0
.31
    Total Annual  Cost:
       Transformer
       Capacitor
0.0
 .14
0.0
0.0
0.0
.10
0.0
.19
a)  Investment analysis  indicates an acceptable return on investment.
                                                                                                    to
                                                                                                    a\

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                                                                      C-27
                         Alternative A Treatment Costs
     EPA standards which would lead firms to invest in Alternative A would
cause 5 direct discharge capacitor plants and all 5 direct discharge trans-
former plants to stop using PCBs in January 1978 rather than by 1980 as
would otherwise occur.  The one remaining direct discharging capacitor man-
ufacturer could comply with the regulation by installing the necessary treat-
ment equipment.  These early curtailments in production would reduce industry-
wide production capacity of PCB capacitors by about 35 percent and of PCB
transformers by about 50 percent.  Industry-wide investment for control equip-
ment would be $ .26 million with annual costs of $ .14 million.
                         Alternative B Treatment Costs
     EPA standards which would lead firms to invest in Alternative B would
cause all capacitor and transformer plants among the direct discharges to
stop using PCBs in January 1978 rather than by 1980 as would otherwise occur.
These early curtailments in production would reduce industry-wide production
capacity of PCB capacitors by about 45 percent and of PCB transformers by
about 50 percent.
                         Alternative C Treatment Costs
     EPA standards which would lead firms to invest in Alternative C would
cause 4 direct discharge capacitor plants and all 5 direct discharge trans-
former plants to stop using PCBs in January 1978 rather than by 1980 as would
otherwise occur.  The two remaining direct discharging capacitor manufactur-
ers could comply with the regulation by installing the necessary treatment
equipment.  These early curtailments in production would reduce industry-
wide production capacity of PCB capacitors by about 30 percent and of PCB
transformers by about 50 percent.  Industry-wide investment for control
equipment would be $ .23 million with annual costs of $ .10 million.

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                                                                      C-28
                         Zero Discharge Treatment Costs
     EPA standards which would lead firms to invest in zero discharge would
cause all but 1 direct discharge capacitor plant and all 5 direct discharge
transformer plants to stop using PCBs in January 1978 rather than by 1980 as
would otherwise occur.  The one remaining direct discharging capacitor manu-
facturer could comply with the regulation by installing the necessary treat-
ment equipment.  These early curtaiLnents in production would reduce industry-
wide production capacity of PCB capacitors by about 35 percent and of PCS
transformers by about 50 percent.  Industry-wide investment for control
equipment would be $ .31 million with an annual cost of $ .19 million.
     The following economic impacts for the eleven direct discharge plants
are based on industry trends as well as data collected from transformer
and capacitor users and producers directly.
     Average transformer price increases due solely to PCB effluent controls
will be minimal because (1)  PCBs used by direct discharge plants represent
less than 10 and possibly only 5 percent of total transformers and (2)
other expected controls and voluntary bans will already have caused a
further shift to non-PCB units.  The price adjustment for the less effective
non-PCB transformers could be significant, but little of this increase can
objectively be attributed to Section 307 (a) controls.
     The dollar value of all transformer sales is likely to increase more
because of higher costs with PCB substitutes than they decrease because of
demand response to higher prices.  However, recent data indicate that an
increase in imports could easily offset any increase from higher prices,
leaving domestic producers with slightly lower dollar sales.
     Industry-wide capacitor price increases due solely to changes resulting
from PCB effluent controls are likely to be less than 5 percent in 1977 and to
decrease to less than 2 percent as PCB substitute technology improves by
1980.  All environmental controls combined can generate up to a 20 percent
increase in average capacitor prices.  However, only part of that increase

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                                                                      C-29
can be attributed to Section 307  (a) effluent controls which will affect
only six specific plants in the entire 19 plant capacitor industry.  The
remaining plants will be covered by a future regulation, however.
     There are no significant effects on energy consumption, balance of
payments, or employment.  The announced and apparent shifts to non-PCB units
and the expected demand for capacitors and transformers are likely to increase
rather than decrease sales and industry-^wide employment.  However, to pre-
vent losses to foreign competition, domestic producers might have to absorb
some cost increases in lower profits.  Since all of the affected plants
are either part of a much larger company or have a reasonably good PCB al-
ternative, reduced profits will not necessarily lead to significant reduc-
tions in employment.  There will be no reductions if sales in fact do in-
crease and if similar numbers of people are needed to manufacture non-PCB
units.

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                                                                      C-30
                      COSTS FOR UV - OZONATION PROCESS

       Addendum to Final Report, Task II          September 27, 1976

     The costs presented in the Task  II Final Report were reevaluated based
on new tests that determined that complete removal of the organic content
in wastewaters is not required prior  to removal of the PCBs.
     Comparison of the terminal treatment capital costs  of UV-ozonation
systems with carbon adsorbtion systems  for reducing the  concentration of
PCBs in effluent waters  to below 1 ppb  indicated  a greater than 50% higher
cost for ozone system over the carbon system.   However,  combining the pre-
treatment costs with the terminal  treatment costs results in  UV-ozonation
system costs about 5 to  10 percent higher than the carbon system costs.

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                                                                      031
                 DETAILED COST ESTIMATES FOR ALTERNATIVE PCBs
   TREATMENT TECHNOLOGIES APPLIED TO HYPOTHETICAL LARGE AND MEDIUM SIZED PCB
                CAPACITOR AND TRANSFORMER MANUFACTURING PLANTS

         Addendum to Final Report, Task II            October 15, 1976


The three treatment alternatives for which costs were estimated are:

     A)  Process and plant modifications and pretreatment of process water.
     B)  Maximum use of carbon adsorption.
     C)  Minimum treatment.

The estimates for these three alternatives are:
                                                Plant          Medium Plant
                                       2,500,000 Ibs. PCB    500,000 Ibs. PCB
                                            use/yr.              use/yr.

Alternative A     Capital Investment        $1,997,900          $647,000
                    Annual Cost                528,900           164,700
Alternative B     Capital Investment         3,811,400           935,500
                    Annual Cost                922,900           222,300
Alternative C     Capital Investment         1,588,400           575,500
                    Annual Cost                374,000           138,200

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                                                                           C-32
                COST FOR EQUALIZATION BASIN BASED ON BENTONITE CLAY LINER

                      Special Report                     October 1976

          The capital  cost for the equalization basin with a bentonite clay lining
     is shown below.   This cost was  estimated based on  a basin volume of three
     tines the design  flow,  24 hour  residence time/ and $5.00 per cubic yard of
     excavation cost consistent with the Task II  report basis for the reinforced
     concrete equalization basin.  The report also summarizes total installed
     costs, maintenance  costs, and operating  costs, and compares these costs to
     those estimated for concrete storage basins  described in the Task II Final
     Report.

     Bases:    1.   24 hour  retention
              2.   3  times  normal flow
                                                                             2
              3.   Bentonite lining at 80 tons/acre and  lining cover @ $0.3/yd
              4.   12 ft  depth
              5.   10 ft  water depth
              6.   L/W  -  2.0
Flow  (gpn)
Liquid Vol.  (1000 gal)
Width  (ft)
Length  (ft)
Excavation Cost
   ($1000)
Lining & Cover Cost          0.5      0.7      1.3      2.3      4.1     7.6   18.4
   ($1000)
Total Basin Cost             3.1      5.8     11.5     22.8     45.1    89.6   236.4
   ($1000)
Pumps & Sump  ($1000)         20       20       21       22       27       32      42

Total Basin & Pump Cost    23.1     25.8     32.5     44.8     72.1   121.6   278.4
   ($1000)
20
36
24
48
2.6
40
176
34
68
5.1
80
345
48
96
10.2
160
690
68
136
20.5
320
1380
96
192
41
640
2760
136
272
82
1700
7340
222
444
218

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                                                                       C-33
          IMPACTS OF SUBSTITUTES FOR PCBs ON FIRE HAZARDS IN COMMERCIAL
                          AND RESIDENTIAL BUILDINGS
                (Draft) Special Report     October, 1976

     This report reviews the technologies that were being developed for the
replacement of PCBs as dielectric liquids in transformers and capacitors.  All
of the potential substitute liquids are more flammable than PCBs, and this
flarnmability presents a potential fire hazard.  The report reviews the changes
in design and the effects of changing fire codes and insurance underwriter's
requirements on limiting the potential hazard resulting from the use of sub-
stitutes for PCBs in electrical equipment.
     The report concludes that there is no basis to assume that properly
engineered and tested equipment would result in an increase in risk.  Any
safety problems that occur may be the result of inadequate testing and evalua-
tion prior to commercial introduction of the electrical transformers and
capacitors that use the substitute materials.

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                                                                      C-34
              RECENT ADVANCES IN PCBs DETOXIFICATION IN WASTEWATER
                     Supplement to Final Report, Task II
                               January 8, 1977

     This report summarizes a brief study made to update information on methods
 (other than adsorption) for removing or detoxifying PCBs present in industrial
wastewater.  Information was obtained from Westgate Research and Houston Research
on UV-catalyzed ozonation, from Envirogenics Systems Company on catalyzed re-
duction, and from Environment Canada and others on biodegradation.
     In the area of UV-ozonation, both Westgate Research and Houston Research
have run tests in which the level of PCBs has been reduced almost to the detec-
tion limit of 0.1 ppb.  Both companies have stated that they can provide an
operational operating costs for a 640 gpm system at $1,750,000 and $120,800/yr.,
respectively.  The decomposition products of UV-ozonation of PCBs are not
known at this tiite.  The catalyzed reductive declorination process being
developed by Envirogenics has been tested on PCBs.  A 75 ppb concentration of
the PCB isomer 4,4;-dichlorobiphenyl was reduced to about 1.0 ppb.  The Enviro-
genics process is currently being used at the Velsical Chemical Corporation
plant in lyfemphis where it was put into service in mid-May.  It is expected that
a contamination level of 1000-15000 ppm of heptachlor and 500-700 ppm of endrin
will be reduced to less than 1 ppb of total contaminants.  Envirogenics is
expecting a grant to set up a plant-scale system to handle PCBs at one of the
GE plants.  Decomposition products of this process are being investigated.
     The work being conducted on biodegradation by Environment Canada has pro-
duced a bacterial strain which subsists solely on PCBs.  However, this process
is not yet ready for commercial scale demonstration because the lowest PCB
concentration reached  (as of August, 1976)  is 19 ppb.

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                                                                      C-35
                      PCB LEVELS IN NCN-CONTACT COOLING
                   WATERS AND OTHER EFFLUENTS FROM CAPACITOR
                     AND TRANSFORMER PRODUCTION FACILITIES
                     Supplement to Final Report, Task II
                              January 19, 1977

     This work provides a tabulation and analysis of the current status of
non-contact cooling water waste streams from the capacitor and transformer
production facilities which use PCBs.
     Data on PCB levels in 1974-75 and 1976 samples from cooling water effluents
from PCB capacitor and transformer manufacturers were obtained for ten streams
at six different facilities.  All but one of the 1976 levels were below 10 ppb
total PCBs, and five were at 2 ppb or lower.  These levels are compared to
combined plant effluents and rainfall runoff samples at four plants.  The
highest and most variable PCB levels occurred in runoff samples, and the
lowest and least variable occurred in the cooling water effluents.  In general,
one to two ppb appears to be a typical PCBs level for non-contact cooling
water in this industry for plants which practice good plant-housekeeping and
segregate their cooling water.

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                                                                      036
            REFINEMENT OF ALTERNATIVE TECHNOLOGIES AND ESTIMATED
                 COSTS FOR REDUCTION OF PCBs IN INDUSTRIAL
              WASTEWATER FROM THE CAPACITOR AND TRANSFORMER
                      MANUFACTURING CATEGORIES
                    Supplement to Final Report, Task II
                             December 16,  1976

     This report augments and refines the  available information on technology
and estimated costs for abatement of PCB discharges from the capacitor and
transformer manufacturers who use PCBs in  their products.  It includes:
     1)  A description of modifications being performed at
         two GE plants to reduce PCB effluents;
     2)  An updated cost estimate for UV-ozonation;
     3)  A cost estimate for the use of bentonite-lined equalization
         basins;
     4)  A general review of the current industry trends towards abatement
         of PCB discharges.
     As of September, 1976, GE had reduced PCB discharges from 8 to 9 pounds per
day to one pound per day at their Fort Edward and Hudson Falls manufacturing
plants.  This was accomplished by:
     1)  Segregating wastewater;
     2)  Preventing spills and leaks from  contaminating clean water;
     3)  Decreasing wastewater volume;
     4)  Eliminating batch dumping;
     5)  Treating sanitary wastewater at Fort Edward.
     Additional projects intended to reduce PCB discharge to less than 1 gram
per day were underway and were scheduled for implementation by April or May, 1977.
     These include:
     1)  Recirculating non-contact cooling water;
     2)  Consolidating discharges and impoundment basins;
     3)  Treating impounded water at Fort  Edward.

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                                                                      C-37
     The cost of constructing and operating an equalization basin based on the
use of a bentonite clay lining was calculated and conpared with figures which
had been previously derived for a concrete lined basin.  It was determined
that the annual operating cost for a bentonite lined basin was approximately
half that for a concrete basin the same size.  In actual practice, however,
the bentonite lined pond would be much larger than a concrete lined basin in
order to reduce the frequency of pond dredging and cleaning.  Thus, the costs
for the two alternatives will be more nearly equal.
     Vfestgate Besearch Corporation's continuing UV-ozonation development pro-
gram has produced some system simplifications which made it necessary to re-
estimate the cost of removing PCBs in a UV-ozonation treatment plant.  The new
treatment costs ranged from $16.00/1000 gal. for a 20 gpm plant to $1.50/1000
gal. for a 1,700 gpm plant.  Typical costs for PCB removal using activated
carbon range from $4.47/1000 gal. for 20 gpm capacity to $1.18/1000 gal. for
1,700 gpm.
     An examination of current industry trends towards abatement and disposal
of PCBs revealed several things.  Calgon is furnishing GE with carbon adsorption
technology and generally agreed with the technical conclusions and cost estimates
determined by Versar.  There are at least three PCB users which have no discharge
of process water or non-contact cooling water to waterways or PCTWs.  Segrega-
tion of cooling water streams appears to be well in hand or underway in five plants.
Three potential suppliers of incinerators for waste PCB-containing liquids in-
dicated that they could supply incinerators within 6 to 18 months of receiving
an order.

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                                                                      C-38
                 COSTS ASSOCIATED WITH INSTALLING PRODUCTION
                  EQUIPMENT FOR USE OF NON-PCB DIELECTRIC
                FLUIDS IN TRANSFORMER AND CAPACITOR MANUFACTURE

       Supplement to Final Report, Task II             January 19, 1977

      This report summarizes the costs associated with the expected changeover
from polychlorinated biphenyls (PCBs)  and PCB-containing askarels to substitute
(non-PCB) dielectric fluids in the manufacture of transformers and capacitors.
      The approach taken was to contact industry representatives at the various
meetings of industry comnittees dealing with disposal of obsolete PCB-contam-
inated equipment and waste oils.   In addition, discussions were held with other
industry personnel from whom information on similar matters had been obtained
in the past.
      The results indicated that no significant process changes would be
required of any producer to convert to a PCB substitute.  However, minor to
extensive retooling will be required for most capacitor producers that produce
their own containers and/or utilize their product capacitors in assemblies
(ballast assemblies, for example).  Design, testing, and other activities re-
quired by the product changes will also result in costs associated with the
changeover but not with process changes.  In addition, clean-up and disposal
costs will be borne by all firms.

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                                                                      C-39
            MICROECCNQMIC IMPACTS OF THE PROPOSED MARKING
                     DISPOSAL REGULATIONS FOR PCBs
                            FINAL TASK REPORT
                               April 1977
                            EPA 560/6-77-013
                           NTIS PB 267-833/3WP
     This study evaluates the economic impact of the draft regulations for the
marking and disposal of PCBs.  The report includes estimates of the quantities
of PCBs and equipment containing PCBs that will be affected, present and future
required availability of PCBs, PCS disposal facilities, secondary costs (in-
cluding storage), recordkeeping, transportation, and the cost of the actual
marking.  The economic analysis includes estimates of additional costs by
year and economic sector, effects on price, investment requirements, and
employment.  Finally, the effects of compliance on energy requirements and on
the availability of strategic materials are estimated.
     The basic disposal requirement for all PCBs is controlled use and storage
followed by high temperature incineration.  The proposed regulations are very
specific on what is to be done and how it is to be done.  Consideration of the
present lack of incineration facilities and the high costs which would be
incurred by requiring removal and special handling of fluorescent light ballasts
and small capacitors have resulted in the following exemptions from the basic
requirements of incineration:
     1)  Until July 1, 1979, non-liquid PCB mixtures, PCS capacitors, and PCB
         fluorescent light ballasts may be disposed of in chemical waste
         landfills.
     2)  PCB containers may be decontaminated by triple rinsing.
     3)  PCB transformer may be rinsed and disposed of in chemical waste
         landfills.
     4)  Small PCB capacitors in electrical equipment do not have to be
         removed before disposal of the equipment.
     5)  Small capacitors and fluorescent light ballasts used in private
         homes may be disposed of as municipal solid waste.
     6)  Material or equipment containing less than 500 ppm of PCBs will
         not require special handling or disposal.

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                                                                      C-40
     Most storage areas, required by the regulations will be established by
office and commercial buildings, electrical repair shops, and small industrial
buildings for the storage of small capacitors and fluorescent light ballasts
removed during normal maintenance.  Cost of establishing a small storage area
is estimated at $145 with an annual operating cost of $95/year.  It is suggested
that these costs may be reduced by using unused space and establishing the area
during a time of slack labor demand.  A larger area, such as required by utilities
and transformer repair shops is estimated to cost $1,000-$5,000 to establish
and $2,125 to operate annually.
     The draft regulations require that chemical waste landfills used for the
disposal of PCBs be approved by the EPA Administrator for that purpose.  At
present there are sixteen chemical waste landfills in the U.S., but none have
been approved for PCB disposal.  Average cost for disposing of materials in
these landfills, including freight and state fees, is estimated at $3.00 per
cubic foot of material.
     There are currently nine commercial incinerators with the capacity to
destroy liquid PCB waste.  In addition, three of these facilities have the
capacity to destroy PCBs contained in solid wastes.  Charges at these facilities
are 7-14C/ib. for liquid waste and $40/drum for solid waste.  Estimated operating
cost of a unit capable of shredding and disposing of capacitors is 52£/lb.  It
may also be possible to dispose of PCB liquids in cement kilns and power boilers.
Shipping charges for liquid PCB wastes in 55 gallon drums range from $1.14 to
$6.24 per hundred pounds depending upon the number of drums and the shipping
distance.  In addition, there may be a charge of $2.85 per platform handling
for each drum.  There will also be additional recordkeeping charges of $2 to
$5 per item.
     For estimating the total cost to industry which will be incurred in
complying with the draft disposal regulations, three options were identified.
Option 1 assumes that all PCB capacitors are removed from equipment before it
is scrapped.  Option 2 assumes that 2/3 of all small appliance capacitors, HID
capacitors,  and fluorescent light ballast capacitors are not removed from the

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                                                                      C-41
equipment but are disposed of as municipal solid waste while the remaining
1/3 are incinerated.  Option 3 allows the disposal of fluorescent light ballasts
in chemical waste landfills.
     Associated with each of these regulatory options are aggregate, industry-
wide costs for decontamination, storage, landfill and incineration costs,
transportation costs, and recordkeeping costs.  The maximum expected cost for
decontamination of askarel filled transformers is $365,000 per year.  The cost
for storing PCBs prior to disposal is estimated to be $8.2 million the first
year  (including cost for setting up storage areas) and $4.2 million per year
in subsequent years.  The maximum expected cost for disposal in chemical land-
fills is expected to be $5.5 million.  The estimated incineration costs range
from $134 million per year for Option 1 to $39 million per year for Option 3.
Estimated transportation costs for incinerating PCBs vary from $7.4 million
to $13.2 million per year, depending on how many incinerators are assumed with
the various disposal options.  Recordkeeping costs are estimated to be $8 million
initially plus $4.0 million per year thereafter.
     m addition to the economic impacts which will result from the disposal
regulations, there will also be substantial costs incurred due to the marking
regulations.  Manufacturers will be faced with major retooling costs, on the
order of $25,000 each, in order to comply with the proposed regulations.  The
majority of the marking cost, however, will be borne by the present users of
PCS electrical equipment who need to mark existing equipment.  The total cost is
estimated to be $33.2 million.
     Ihe aggregate effects which the proposed marking and disposal regulations
will have on the electrical pricing, energy consumption, and strategic materials
are slight.  The price of electricity will increase by an average of 0.06%.
The upper bound estimate for increased energy consumption is 17,700 Bbl/day.
Rsclamation of copper windings from transformers may be inhibited but the
total amount affected would be less than 1% of the total copper  reclaimed every
year in the U.S. and is an insignificant portion of the copper consumed  each
year.

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                                                                      C-42
   POTENTIAL IMPACTS OF THE BANS ON PCB MANUFACTURING, PROCESSING, AND USE
              Special Report, PCB Activity Analysis Papers
                                July 11, 1977

      This report describes the current uses of PCBs in the United States and
draws particular attention to those uses which present environmental hazards
or problems of a regulatory or economic nature.
      At the present time the only uses of PCBs in the United States are in
capacitors, transformers, and the maintenance of a number of mining machines
formerly manufactured by Joy Manufacturing, Inc.  Capacitor and transformer
manufacturers and transformer maintenance shops currently receive their PCBs
from Monsanto, the sole U.S. producer of PCBs.   Monsanto intends to stop
manufacturing PCBs by August 1977, and will cease shipment from inventory as
of October 1977, even though the Toxic Substances Control Act permits the
manufacture of PCBs for use in a totally enclosed manner through January 1979.
Small custom chemical companies may be attracted to this market, requiring
definition of allowable manufacturing processes and/or air and water emission
regulations.  Another possible source of PCB "manufacture" which may arise
is the reclamation of used askarels from transformers.  This may create some
regulatory difficulties.
      It appears that either presently or in the near future, GE and Westinghouse
will be the only companies who will service PCB transformers.  With the sole
domestic producer of PCBs about to cease production, GE and Westinghouse will
be forced to decide whether to import PCBs before January 1, 1977, in order to
meet an anticipated upward trend in PCB use by the transformer service industry.
GE has indicated that in no event will they stockpile more than a 1 or 2 year
supply.
      In any event, the transformer repair industry will remain a potential
source of PCB emissions for the immediate future.  PCB air emissions from the
repair shops may need to be monitored and regulated.  The majority of documented
PCB releases attributable to the transformer repair industry have occurred

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                                                                      C-43
while transporting filled transformers by truck.  Draining of transformers
before they are shipped would alleviate this problem.
      Retrofilling of all PCB transformers with silicone based oil is possible
but is not justified on either economic or environmental grounds.  The cost
would be $45,000-$50,000 each for the largest units, and the increased risk of
spills makes this environmentally unattractive.  Generally, when a transformer
is retrofilled, some of the PCBs remain trapped in the windings.  However, it
may be possible to remove nearly all the remaining PCBs by periodically
filtering the new transformer fluid through activated carbon until the PCBs
are reduced to an acceptable level.
      The users of PCB equipment may be categorized as utility, commercial-
industrial, and residential.  It appears unlikely that PCBs used in residences
 (low voltage capacitors) present any great danger because only small amounts
of PCBs are present in any residence and there is little chance that one of
these capacitors will rupture upon failure.  There is a much greater danger
from utilities and commercial-industrial users.  Spills or losses are known
to occur from, damaged equipment and through improper handling of PCB liquids.
It is estimated that 78,295 pounds of PCBs will be released into the environ-
ment each year from utility transformers and capacitors.
      It may be possible for PCBs to enter the environment as a contaminant
in another chemical or as a by-product of some chemical process.  PCB has been
reported as a low-level contaminant in some cases where water containing
biphenyl is chlorinated.  PCBs already free in the environment may become more
of a hazard if contaminated sewage sludge is used as a soil conditioner.
      Unless carefully worded, regulations to enforce the ban on "distribution
in commerce" could have adverse effects on inventories, equipment resale, and
maintenance.  Strict enforcement could result in the scrapping of large inven-
tories of capacitors without any decrease in the potential for environmental
damage.  Another question to be considered is that raised by the disposal of
PCB wastes in a landfill.  That is, when the title to the material passes from
the original owner to the landfill operator, does this constitute "distribution
in commerce"?

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                                                                       044
                        IMPACTS OF THE DRAFT "PCB RAN REGULATIONS"
                     (Draft Report)     March 8, 1978

     This report analyzed the economic impacts of an early draft of the pro-
posed PCB ban regulations.  The draft report was used by EPA in preparing the
final proposed regulations.  The material in this report was superseded by
the report of the same title published in May, 1978, except that this draft
report included two appendices that did not appear in the published version.
     Appendix C of the draft report, "Characterization of U.S. Waste Oil
Industry," described in detail the uses of waste oil and characterized the
structure of the waste oil collecting and re-refining industry.
     Appendix D of the draft report, "Supply and Demand Effects of PCB Ban,"
presented a formal microeconomic analysis of the supply,  demand,  and price
effects of the increased demand expected for substitutes for PCBs.  The purpose
of this exposition was to correct an error in a similar analysis previously
published by Ashford and Murry of MIT^ ' .
 (1)  Ashford, Nicholas A.,  Murry, Albert E.  (1976)  The Impact of Governmental
     Restrictions on the Production and Use of Chemicals:  A Case Study on
     Polychlorinated Biphenyls  (Report No. CPA-76-3/b).Cambridge, MA:Center
     for Policy Alternatives, Massachusetts Institute of Technology, April  30,
     1976.

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                                                                      C-45
      "MICROECONCMIC IMPACTS OF THE PROPOSED "PCB BAN REGULATIONS"
                                MAY 1978
                             EPA 560/6-77-035
                           NTIS PB 281  881/3WP
     The purpose of this study was to evaluate the economic impacts of the
proposed "PCB Ban Regulations."  These regulations were prepared by the Office
of Toxic Substances of the U.S. Environmental Protection Agency with the
technical support of the Interagency PCB Work Group.  These regulations implement
the bans on various PCB activities which were established by Congress in Section
6(e) of the Toxic Substances Control Act - Public Law 94-469.
     The economic costs reported are those directly and indirectly attributable
to those changes in future PCB activities which would be caused by implementa-
tion of the proposed regulations.  From the wording of Section 6(e) , it is clear
that the "intent of Congress was to ban the manufacture of PCBs after .^December
31, 1978, and to ban the distribution of polychlorinated biphenyls (PCBs) after
June 30, 1979.  Therefore, the long-term costs of using substitutes for PCBs
will be a consequence of this legislated ban on the manufacture of PCBs and
not a consequence of discretionary regulatory actions taken by the Environmental
Protection Agency.
     This analysis of the proposed regulations considered both the direct costs
of complying with the requirements and the indirect effects of these requirements
on price levels, capital  needs, employment, energy consumption, and the avail-
ability of strategic materials.  The calculated economic impacts were the
incremental impacts of the proposed regulations on a base of 1976 practices
as modified by the previously promulgated PCB effluent standards and the marking
and disposal regulations.  The costs of these other PCB regulations were con-
sidered during their development and are not considered to be a result of these
proposed ban regulations.
     The expected transitional and long term costs resulting from  the proposed
regulations are summarized in the following tables.   The report also estimated
employment effects and other economic consequences.

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                                                     Table  1
                    Transitional  Cost Inpacts of  Proposed PCS Ban Regulation
 I ton (Chapter)
 rCU Transformers:
    Manufacturer cl
    nan on Rebuilding (4)
      Fbregone Savings

      lost Service Tiine

    Transformer Service (5)
      Lost Wages
      Spill Prevei
    locomotive Tr,
      Retrofill Program
      Processing Program
      final Analy
      Deporting
      Spill Preva
 PCD Capacitors
      Equipment H
      Inventory 01
 Oil Filial Transformers (7)
 Mining Machines (8)
     Rebuild loader's
     Scrap Continuous Miners
     Reporting Costs
     Spill Prevention Plans

$ Million Per Year

Succeeding $ Million
1979 Years 'total
in up costs (16)
1(4)
|3

$ .1
0 $ .1
14.3 3.4% less 420
per
year
une 2.4 3.4% less 75

ce (5)

>n Plan
bniiars (6)
•am
irain
for PCBs

m Plan
iign(15)
escence (3)
era (7)
d Disposal
per

1
1

7
0 2.7
0 .1
.005
.02
*
1

year

0 1
0 1

0 7
(2 years) 5.4
(1983) .1
0 .005
0 .02

0 1

24 3.4% less 700
per year
Conplete by Dec.  31, 1981
COiplete by Dec.  31, 1901
  .02                  0
  .04                  0
.6
.02
.04
                                                                                                      Estimated
                                                                                                     Reliability
                                                                                                      of -mtal
                                                          -50% 1500%

                                                          ±50%

                                                          150%


                                                          1100%
                                                          ±1004

                                                          120%
                                                          120%
                                                          120%
                                                          1100%
                                                          150%


                                                          1100%

                                                          130%
120%
±50%
1100%
150%
*Data not available to su(>porL estimate; probably small cost intact.
n
,t>
CTi

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                                                    Table 1
                Transitional Cost Impacts of  Proposed  PCS  Ban  Regulation  (Continued)
  I tail  (Cliaptcr)

  Uectranagnets (9)

    Replacement Cost
     Report ijtg
  Cnipressora (12)
  Reclaimed Oil



19)
lost
or Costs
IDS (10)
lachi nes
>1 Sampling

sntion Plans
ition
ic Systems
it ion
Interruptions
lystans (11)
0
tost of Synthetic Road
rial
)ost of Road Oil
rtion of Reclaimed
a Fluid
Pitjnnntis (14)
inges

$ Million


1979
$ 3.5
.5

.8
.2
.5
7.3

3.6

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                                                                      C-48


                                   Table 2

           long Term Cost liipacts of Proposed PCB Ban Regulations^

Transformers:  (Chapter 16)

     Increased cost of non-PCB transformers           $0 to 10 million/year
     Increased fire losses                            Data not available

Capacitors:  (Chapter 15):

     Increased cost of non-PCB 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

Dairylide Yellow Pigment (Chapter 14)

     Increased cost of substitute pignnents            $10 to 25 million/year

                       TOTAL                          $23 to 56 million/year

                       Present value of long term cost iirpacts assuming 10%
                       discount rate = $230 to 560 million

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                                                                       C-49
       PCB MANUFACTURING, PROCESSING, DISTRIBUTION IN COMMERCE-, AND
               USE BAN REGULATION:  ECONOMIC IMPACT ANALYSIS
                               FINAL REPORT
                                MARCH 1979
                             EPA 230-03/79-001
                           NTIS No. forthconing

      This report is a revision of the report "Microecononic Hinpacts of the
proposed PCB Ban Regulations."  The report summarizes the economic impacts
of the promulgated ban regulations and incorporates the information made
available during the rulemaking hearings on the proposed regulation.  The
total economic costs and estimated pounds of PCBs diverted from the environment
by the regulation are summarized the following Table.

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                             Economic Costs of the PCB Ban Regulation
Chapter
Number   Item
                          Total Cost
                          $  Million
  3


  3
  5


  5



  6


  7



  8


  9
                   Pounds PCBs Diverted
                   from the Environment

                           500
                          Cost per Pound
                          of PCBs	

                          $  2,000
Scrap Spare PCB                1
Capacitors

Remove PCB Capacitors       1,000                  5,360               $187,000
from Equipment in        These costs will be  significantly reduced or eliminated  if EPA
         Inventory
                         grants exemptions  from the  "distribution in coirmerce" ban.
         Ban Rebuilding         397 to 771 (30 yrs)    47,000 to 925,000
         Askarel Transformers
Retrofill Railroad
Transformers to 6%
Retrofill Railroad
Transformers from
6% to .1%
6.7


5.15
Require Incineration of   96 to 510 (30 yrs)
Transformer Oil
Special Storage Areas        *
at Transformer Service
Stops

Retrofill/Ban PCB Miner   2.6 to 4.3
Motors
**(3.76 million Ib)
       total

**(80,240 Ib. total)



     200,000
Ban Rebuilding Electro-
magnets
  .96
? (27,500 Ib total)


  200 to 2,000
$429 to $16,400


**(>$!.75)


**(>$68)



$480 to $2,550
?  (>$94 to $155)


$480 to $4,800
  *Information not available in record to make estimate.
 **Figure represents total amount of PCBs in this use.  Information not available in record to
  make an estimate of amount diverted from the environment.
                                                                                                     o
                                                                                                     Ul
                                                                                                     o

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           ECONOMIC COSTS OF THE PCB BAN REGULATION (Continued)
Chapter
Number
10

11

12
13

14
14
15

16
16
17
Total Cost Pounds PCBs Diverted
Item $ Million from
Decontaminate Hydraulic 21.4 to 25
Systems
Decontaminate Heat 12.8 to 17.2 1,
Transfer Systems
Decontaminate Compressors .2
Ban Use of Waste Oil on 0 to 31.7/year
Roads
Phthalocyanine Blue pigments .425/year
Diary lide Yellow Pigments ,478/year
Spill Materials (50-500ppm) -
to Chemical Waste Landfill *
Ban New Large PCB Capacitors 5.5 to 11/year
Ban New Small PCB Capacitors 6.6 to 18.9/year
Ban New PCB Transformers 0 to 10/year
the Environment
470 to 2,390

872 to 2,496

*
8,073/year

544/year
4 4 I/year

*
14,200
6,930/year
12,000/year
Cost per Pound
of PCBS
$6,000 to $53,000

$6,870

*
$0 to $3,925

$781
$1,084

$182
$387 to $775
$950 to $2,730
$0 to $833
*Information not available in the record to make  estimate.
                                                                                                    n
                                                                                                    en

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BIBLIOGRAPHIC DATA 1. Report No. 2.
SHEET EPA 560/6-79-004
4. Tide and Subtitle
Polychlorinated Biphenyls 1929-1979: Final Report
7. Authors)
Robert A. West in
9. Performing Organization Name and Address
VERSAR, Inc.
6621 Electronic Drive
Springfield, Virginia 22151
12. Sponsoring Organization Name and Address
Office of Toxic Substances
U. S. Environmental Protection Agency
Washington, D. C. 20460
3. Recipient's Accession No.
5. Report Date
Ifev 16, 1979
6.
3. Performing Organization Repc.
No. 474. 5F
10. Project/Task/Work Unit No.
11. Contract/Grant No.
63-01-3259
13. Type of Report & Period
Covered
Final Report
14.
15. Supplementary Notes
EPA Program Manager: Mr. Thomas E. Kopp
16. Abstracts
   The primary emphasis of this report  is a summary of the work that Versar
   performed in support of the EPA's regulatory activities involving polychlori-
   nated biphenyls over the past four years.   The report  includes summaries of
   24 reports on PCBs that Versar submitted to EPA during this period.  Also
   included are a summary of the uses of  PCBs from 1929 through 1979, a review of
   much of  the early literature on the  uses and toxicity  of PCBs, and a discussion
   of the various regulatory activities that limited human exposure to PCBs and
   eventually banned their manufacture, processing, and use.
17. Key Words and Document Analysis.  17a. Descriptors

   Polychlorinated biphenyls
   PCBs
   Regulations
   Water Pollution Abatement
   Economic Analysis
   Toxic Substances Control Act
   Toxicity
   Environmental Transport
   Effluents

I7b. Identifiers /Open-Eaded Terms
17c. COSAT! Fie id/Group
18. Availability Statement
      19.. Security Class (T'nis
         Report)
           UNCLASSIFIED
                                                           20. Security Class (This
                                                              Page
                                                                UNCLASSIFIED
21. No. of Pages
     90
                             22. Price
FORM r»Tis-39 iREv. 10-73)   ENDORSED SY ANSI AND UNESCO.
THIS FORM MAY 3E REPRODUCED
                                                                                  USCOMM-QC 328S-P7

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