EPA 560/4-76-003
INDUSTRY VIEWS ON THE USE OF
POLYCHLORINATED BIPHENYLS
TRANSFORMERS AND CAPACITORS
JUNE 1976
OFFICE OF TOXIC SUBSTANCES
U.S. ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
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This Document is available to the public through the
National Technical Information Service,
Springfield. Virginia 22151
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
SUBJECT: OTS Reports DATE: 8/4/76
FROM: V.J. DeCarlo, Chief
Monitoring & Information Systems Branch
TO: Libby Smith
Librarian
Enclosed is a copy of "Industry Views on the Use of Polychlorinated
Biphenyls in Transformers and Capacitors" for your library.
EPA Form 1320-6 (Rev. 6-72)
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EPA 560/4-76-003
INDUSTRY VIEWS ON THE USE OF
POLYCHLORINATED BIPHENYLS
IN TRANFORMERS AND CAPACITORS
Prepared by the
OFFICE OF TOXIC SUBSTANCES
U.S. ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
JUNE 1976
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PREFACE
In January 1976, EPA Administrator Russell Train
met with manufacturers and users of PCB products.
As a result of those two meetings, three industry task
forces were formed and the findings of the task
forces were presented to the Administrator at a
meeting in May 1976.
This report is a compilation of the statements made
by industry leaders at the three meetings.
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TABLE OF CONTENTS
Preface i
Table of Contents ii
January 14, 1976 Meeting
Richard Rollins
Electronic Industries Association 1
Herbert Appleton, President
M c'G raw - Edi son 5
F. J. Fitzgerald, Vice President
Monsanto Chemical Company 6
John F. Welch, Vice President
General Electric Company 8
D. M. Sauter, Vice President
Westinghouse Electric 10
Richard L. Hauser, President
Electrical Utilities Company 13
January 22, 1976 Meeting
John P. Belong, Director
Power Systems Operations, Tennessee Valley Authority 15
W. B. Behnke, Executive Vice President
Commonwealth Edison Company 18
May 13, 1976 Meeting
R. E. Uptegraff
Transformer Manufacturers Task Force 21
Clifford Tuttle
Capacitor Manufacturers Task Force 25
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May 13, 1976 Meeting (cont.)
Harry Onishi
Utilities Task Force 28
J. Coleman Weber
Monsanto Industrial Chemicals Company 31
Ronald Kasper
Industrial Risk Insurers 33
Arthur Speigelman
American Insurance Association 34
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Richard Rollins
Vice-President, Jard Company
Representing the Electronic Industries Association
January 14, 1976
PCB' s IN CAPACITOR APPLICATIONS
Mr. Train, Ladies and Gentlemen:
On behalf of the Electronic Industries Association and the manu-
facturers of PCB-filled AC capacitors, I appreciate this opportunity
to present our views on PCB capacitors and possible alternatives
for PCB's.
The manufacturers have almost exclusively used PCB's in
capacitors for the fluorescent and mercury vapor lighting, air-
conditioners, television sets and power factor correction applica-
tions since World War II.
This capacitor is thus near you a high percentage of the time.
Manufacturers are very cognizant of their responsibilities in pro-
viding a capacitor that will operate satisfactorily in these applica-
tions, providing a long life and high reliability at a reasonable cost.
With these requirements in a competitive marketplace, the conse-
quence is that these components must constantly be reevaluated to
increase life, increase reliability, decrease size and decrease
cost. We, as manufacturers, see these pressures for improvements
every day.
Why, therefore, hasn't the U. S. capacitor industry developed
suitable alternatives to PCB's in 40 years? One of the answers
lies in the nonflammability of the PCB material. Because of appli-
cations, such as lighting, where personnel and equipment safety
are paramount, capacitors must be manufactured such that they
not only fail infrequently, but also fail safely. In an application
such as the World Trade Center in New York where 250, 000 fluo-
rescent lights are installed, it is obvious that high reliability and
a nonflammable capacitor characteristic are mandatory. A capaci-
tor which fails violently and contains a flammable fluid could create
a serious problem, especially in densely populated buildings, giving
visions of a "towering inferno". The Consumer Products Safety
Commission, as an example, have shown considerable concern over
television set fires and have requested Underwriters Laboratories
to develop standards for safety for television receivers.
A second reason lies in the reliability of the product as it is
known today. Presently the capacitors our companies manufacture
have a survival rate per year greater than 99.9988%. The
requirements that more than 95% of our capacitors must survive
after 13 years of normal application conditions must also be met.
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The test time and amount of product tested necessary to guarantee
the above reliability is mind-boggling to say the least. Many thou-
sands of units and millions of unit hours at or referred to applica-
tion conditions are required to satisfy our statisticians that any
change in product will perform to these present day standards.
Even with the large amount of previous testing and history on
the PCB containing capacitor, there have been instances which,
despite all controls in existence, caused consumer concern due to
extreme failure rates (greater than 10%). The first occurred in
1957, when a variation in the quality of PCB fluid, as synthesized,
produced a highly unstable capacitor. Standard analytical tests in
use at the time could not detect the quality difference. The result
was a large number of capacitors failing in a very short period of
application life. The consequence was the requirement, by the
customer, that the capacitor manufacturer not only provide compen-
sation for the cost of the capacitor but the cost of the equipment
which contained the capacitor plus the labor charge for replacing
the equipment in installation. The total replacement cost to the
manufacturer thus became 100 times the original price of the
capacitor.
A second instance of numerous failures occurred six years later
involving this time the capacitors from most manufacturers. In
this circumstance, reduced-size capacitors were tested and
approved by industry-accepted accelerated life testing and the new
sizes were shipped to customers. Approximately one year later,
up to 15% of these capacitors began failing in some applications. A
subsequent modification in the accelerated life testing, based upon
the findings in field failure analyses, now provides proper screen-
ing which eliminates the chance of this problem recurring.
The AC capacitor industry is therefore very sensitive to the
possible effects of changes and insists upon very extensive screen-
ing before releasing new designs or using new materials.
As previously mentioned, alternates have been considered ever
since the introduction of PCB's. Now the substitutes must not only
be a satisfactory dielectric fluid providing acceptable life, reliabil-
ity, and safe failure modes, but, in addition they must not cause
environmental problems.
Our experiences with PCB's have demonstrated that some
material will escape into the environment through processing, etc.
Therefore, alternate fluids must be evaluated on this basis. The
effects on man and his environment must be evaluated before the
product is introduced.
It would be a very serious error to inadequately evaluate and
prematurely replace capacitor grade PCB's with a fluid which
eventually becomes a greater threat to man and/or his environ-
ment.
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Non-PCB alternatives are now being offered or suggested,
some are new and some have been available for many years. The
industry's position on these is as follows:
1. Mineral Oil is a flammable fluid, which was replaced
by PCB's in the 1930's. Capacitors using it are 50 to
100% larger, much less reliable and much less safe
than those using PCB's. The substitution of mineral
oil would necessitate redesign of equipment to utilize
the larger capacitors, would require an increase in the
capacitor manufacturing facilities and would result in
increased use of basic materials which are presently
in short supply.
2. Modified synthetic hydrocarbon oils have been devel-
oped which, while flammable, would allow capacitors to
approximate today's sizes. Samples have been distrib-
uted for testing, but the material is not commercially
available.
3. Phthalate Ester, also a flammable fluid with biodegra-
dability problems, it should be noted, has been used in
certain restricted applications where conditions of
limited temperature requirements exist. The unknown
factors of reliability and safety in the broad consumer
use areas such as lighting now prevent its use. Evalu-
ations, however, are continuing.
4. Substituted Aromatic Compounds are possible candi-
dates and one has been proposed that has less fire
resistance than PCB's, and is suggested to be a good
dielectric fluid, but only for high voltage power factor
correction applications. This to our estimation repre-
sents only 17% of the PCB usage in closed systems,
and leaves completely unanswered any alternative(s)
for the remaining 83% of the applications. Although
some material has been produced, the fluid has not
been made commercially available. When samples
become available, the time-consuming testing can
begin. It has been estimated that approximately three
years are required for final commercial use after ini-
tial testing of a change in capacitor fluids.
Also, proposed for limited applications is the use of a plastic
film replacing the kraft paper dielectric in the AC capacitors.
Although evaluations for small industrial capacitors with this mate-
rial have been underway for more than two years, the reliability
of the product is only I/20th of the present capacitor in most appli-
cations. Significant additional testing is required to determine the
cause of the poor reliability.
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In summary, there are no commercially available fluids which
today can be considered a totally acceptable substitute for PCB' s
in the broad range of AC capacitors. Nor, in fact, are there sub-
stitute dielectric systems which would satisfy the requirements of
reliability and safety in most applications.
Finally, our industry believes we should work together with
the EPA to promote mutual understanding and to attempt a coopera-
tive effort for solving our mutual problem with polychlorinated
biphenyls.
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Herbert M. Appleton
Vice-President, McGraw Edison Company
January 14, 1976
Thank you, Mr. Train, for your invitation to meet with you
to discuss polychlorinated biphenyls.
We believe there is no question that PCB's eventually
must be eliminated from all products going into the
marketplace. The only question can be, "When? No other
position is defensible.
As a major manufacturer of power capacitors,
McGraw-Edison Company has recognized the PCB prob-
lem. We have a modern plant and control our emissions
carefully, but we can't control the ultimate destination of
millions of pounds of PCB's shipped in our products,
which someday will be entering the environment.
Believing this to be a major concern, four years ago
we sought, with the help of Dow Chemical, to find a non-
toxic, biodegradable substitute for PCB's in high voltage
power capacitors. We have succeeded and are offering a
diphenyl oxide formulation to the power capacitor industry.
It can be substituted in present designs, using existing
process equipment.
This diphenyl oxide capacitor fluid is up to 20 times
less toxic, far more biodegradable and easier to dispose of
than PCB's. Electrically, it is equal to or better than
PCB1 s in our tests.
Flammability in power capacitor imp regnant is not a
major issue, we believe, since most units use less than
three gallons. The National Electric Code allows this to be
installed without a vault in a building. The flash and fire
points are better than mineral oil although not as good as
PCB's.
Someday there may be developed a better, cheaper,
universal liquid for capacitors, transformers, ballasts,
etc., but we do have an answer now for capacitors. Dow
Chemical promises to have production quantities available
by mid-1976 and in large quantity by the end of 1976.
Manufacturers can get sample quantities now to begin their
tests.
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F. J. Fitzgerald
Vice-President, Monsanto Chemical Company
January 14, 1976
Good afternoon, my name is Jack Fitzgerald. I am a vice
president of Monsanto Company, a member of its Corporate
Administrative Committee and managing director of Monsanto In-
dustrial Chemicals Company, an operating unit of Monsanto Com-
pany.
Since I am responsible for the operating unit which manufac-
tures poly chlorinated biphenyl dielectric fluids, John Hanley, our
president, has asked me to represent him today and reaffirm to
you Monsanto's commitment to continue working with the EPA and
the electrical industry in finding solutions to the PCB issue.
Let me state at the outset that Monsanto agrees wholeheartedly
with EPA1 s desire to work toward the goal of eventually eliminating
aU uses of PCB's.
Monsanto has already taken several steps designed to restrict
the entry of PCB's into the environment.
First, Monsanto began restricting the use of PCB's solely to
closed electrical systems, for which no viable alternates existed,
back in 1970. It should be noted that this voluntary program was
fully implemented prior to the completion of the study done on
PCB's by a Federal Interagency Task Force in 1972.
Secondly, Monsanto has been working for a number of years on
non-PCB replacement products. These materials, designed to
replace PCB fluids in capacitors and transformers, are currently
being evaluated by the major electrical manufacturers in the United
States.
While the PCB issue is a tough one to handle, the difficulty does
not nor will not in the future stem from any lack of cooperation on
the part of Monsanto. The problems that we face, collectively, are
rather rooted in the unique characteristics of PCB's and the ir-
replaceable role they have served in our electrical-industrial envi-
ronment for the past 45 years. The challenge: Replacing them
in an orderly manner without creating another hazard of equal or
potentially greater consequence, while at the same time avoiding
serious power and transportation disruptions.
Let me emphasize that we have no desire to remain in the PCB
manufacturing business any longer than is necessary. By this I
mean as soon as we are satisfied that the electrical power supply
industry's needs for usable, acceptable alternate dielectric fluids
have been met by whomever, Monsanto will voluntarily shut down
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its PCB manufacturing unit. In the interim, we will continue to
work with industry and government to ensure that the restrictive
measures and controls we implemented in the early 1970's remain
in force and are diligently pursued.
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John F. Welch
Vice-President, General Electric Company
January 14, 1976
General Electric welcomes the opportunity to participate in
today's proceedings and wishes to compliment Mr. Train and the
EPA for the constructive manner in which they have approached
this very complex PCB issue. A cooperative effort between gov-
ernment and industry can avoid the delays brought about by adver-
sary proceedings and should truly benefit the public at large.
As the leading industrial user of PCB's in the manufacture of
capacitor and transformer products, we have pursued a parallel
course both to reduce the PCB discharges from our manufacturing
plants and to find an acceptable substitute for their use in electrical
apparatus.
The public record shows that we have made excellent progress
in lowering PCB discharge levels at all related manufacturing
sites. Our technological developments have positioned these facili-
ties to achieve discharge levels in the ounces-per-day range. How-
ever, progress has been more difficult in the search for a PCB
substitute.
General Electric for the past 30 years has attempted to find a
suitable substitute. In the early years, this effort was directed to
improving the economy and performance of its electrical apparatus,
but in the past several years, the emphasis has been to provide a
more environmentally acceptable substitute. We have tested over a
hundred fluids representing the full spectrum of chemical sub-
stances, and although there are promising leads, they all require
additional long-term testing for reliability, safety and environmental
compatability.
For example, in capacitors, all known potential substitutes,
unlike PCB's, are flammable. This characteristic presents a sig-
nificant problem to the users of capacitors: the appliance, lighting
and several other consumer-related industries.
Consumer product safety is just one of the many complex
issues which have to be resolved in evaluating a PCB substitute.
Environmentally, as a minimum, we must be satisfied that any sub-
substitute considered is a significant improvement over PCB's.
As we stated at the outset. General Electric is most willing
and indeed anxious to cooperate with EPA in their goal of finding
a satisfactory substitute for PCB's in electrical apparatus. How-
ever, we urge that the complexity of this issue and the potential
consequences of precipitous action be thoroughly and thoughtfully
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considered. Industry and government have the opportunity to
demonstrate, on this highly visible PCB issue, that they can work
together in solving environmental questions in the best interest of
the public.
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D. M. Sauter
Vice President, Westinghouse Electric Company
January 14, 1976
Westinghouse very much appreciates the opportunity to make
these comments at this conference. It is the hope of Westinghouse
that this meeting will be devoted to the safety aspects of electrical
equipment. Westinghouse recognizes that environmental effects are
one of the many elements that affect human safety. The production,
use and operation of electrical equipment must not increase the
danger to humans.
Since the early 1970's, when scientific studies indicated that
polychlorinated biphenyl mixtures presented some hazard in the
environment, Westinghouse has expended considerable money and
effort to reduce the amount of Aroclors 1016 and 1242 that might
escape into the environment. Measures that have been employed
are: sealing drains in manufacturing areas where Inerteen is used;
(note - Westinghouse uses the term Inerteen for Aroclors 1016 and
1242); utilizing specially designed incineration facilities for the
destruction of scrap Inerteen and special scientific landfills for the
disposal of Inerteen contaminated material; instructing operating
personnel and our customers regarding the need for care, and that
special waste disposal is required; and reducing the number of
pounds of Inerteen for each rating of transformers and capacitors.
Most of these measures were implemented prior to the enactment
of the Federal Water Pollution Control Act Amendments of 1972.
Westinghouse recognized that these measures could not prevent
the total elimination of Inerteen escaping into the environment.
Therefore, concurrent with the above measures, we have conducted
extensive evaluation programs designed to utilize those mixtures of
polychlorinated biphenyls having low persistence and high biode-
gradability in the environment. By February 1968, Westinghouse
determined that a mixture of polychlorinated biphenyls, sold by
Monsanto as Aroclor 1242, would be satisfactory as Inerteen for
transformers. Aroclor 1242 contains about 91% of the lower iso-
mers (containing 4 chlorines or less) that more readily biodegrade
in the environment. This material has been used by Westinghouse
since that time with the understanding that over 90% of any small
amounts that did enter into the environment would have relatively
low persistence.
Monsanto subsequently developed a new material from Aroclor
1242 which contained more of the lower chlorinated isomers and
marketed this material as Aroclor 1016. By the first quarter of
1972, this material was introduced by Westinghouse into the manu-
facture of all capacitors. This material contains 99% of the more
biodegradable isomers (4 chlorines or less) so that less than 1% of
this material that might escape into the environment might be more
resistant to biodegradation.
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The industry, Monsanto, our own research of the scientific lit-
erature and most kf the papers presented at the EPA Conference
in Chicago have indicated that the lower chlorinated mixtures of
polychlorinated biphenyls are more biodegradable and do not pre-
sent the same long term toxic environmental problems as those
which contain the higher chlorinated isomers. It is interesting to
note in this regard, that not only have Environment Protection
Agency researchers found a significant difference between the
effects of Aroclor 1242 and Aroclor 1016 on rats, but also
Dr. Robert W. Riseborough and Dr. Ian Nisbet concluded that
there were significant differences between the various mixtures and
that comments concerning the higher chlorinated mixtures should
not be associated with the lower chlorinated mixtures.
Because of the long term nature of biodegradable and toxLcity
tests, limited data is available on Aroclor 1016 and Aroclor 1242.
We hope the government is gathering test data on biodegradability,
toxicity and flammability of 1016 and 1242. Otherwise, industry as
it develops alternate fluids will have no sound basis for compari-
son.
To gather data to evaluate alternate fluids, Westinghouse after
40 years of experience, has found these steps necessary:
1. Check the fluid for possible harmful effects to the
environment.
2. Check the electrical characteristics.
3. Check for safe handling.
4. Check for availability, wide use and economic feasibil-
ity.
5. Make small model capacitors and transformers and
check for system compatability.
6. Perform accelerated life tests on small model capaci-
tors and transformers.
•
If a fluid passes step one through six it becomes a candidate
for full scale tests.
Westinghouse instituted development programs to evaluate var-
ious fluids as possible impregnants for high voltage power capaci-
tors and transformers using these six steps over five years ago.
These programs were first aimed at consideration and testing of
several known existing impregnating fluids and, secondly, to seek
out and test new fluids as possible impregnants. This effort has
been carried out at both Research and Development Laboratory
levels and plant engineering levels.
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In the first phase of this program, it was determined that none
of the known available capacitor impregnants were a satisfactory
replacement for Aroclor 1016 either due to poor electrical perform-
ance at the high voltage stresses required, or due to poor flamma-
bility characteristics. Similar results were found when testing for
substitutes for 1242 which is used in power transformers.
In the search for new fluids, a large number of raw material
suppliers of chemicals and petrochemicals have been contacted.
Among these have been Dupont, Dow Chemical, Dow Corning, Mon-
santo, Sunoco, Exxon, Pilot Chemical, Union Carbide, Nippon Oil,
Prodelec, Pittsburgh Chemical and USS Chemicals. Many tests
have been carried out with materials supplied by most of the above
suppliers, some tests on the fluids themselves and others using the
more promising fluids in both small model capacitors and in full-
size capacitors units. Although none of these fluids have flamma-
bility characteristics equal to that of 1016 fluid, some have adequate
electrical performance sufficient to consider them as possible
replacements for Aroclor 1016 should this action become necessary.
In the transformer area, no economical substitute for Aroclor 1242
could be found with adequate flammability characteristics either.
The electrical characteristics of mineral oil obviously are suitable
for power transformers if flammability could be ignored.
Precipitous action to replace electrical equipment would result
in billions of dollars spent by utilities, industrial plants and com-
mercial installations. While this could increase orders for electri-
cal manufacturers it would be a disaster for customers who would
have to replace equipment prematurely and rebuild their electrical
systems. The Government is meeting with utilities and will learn
of capacitor replacement problems. Industrial and commercial
customers are the primary users of askarel power transformers.
They should be included in government meetings since they will be
faced with unreasonable costs for replacements also.
In conclusion, Westinghouse believes the U. S. Government and
the scientific community should determine the biodegradability,
toxicity and flammability of Aroclor 1016 and 1242. The tests and
results for these two askarels can then serve the electrical industry
as standards that should be improved upon. By putting forth scien-
tific data and performing suitable tests on alternate fluids, the U.S.
Government can assist the electrical industry in selecting alternate
fluids which potentially are less dangerous to man and his environ-
ment.
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Richard L. Hauser
President, Electrical Utilities Company
January 14, 1976
Mr. Train, my name is Richard Hauser. I am President of
the Electrical Utilities Company in La Salle, Illinois. My company
manufactures capacitors used in air conditioners, television
receivers, lamp ballasts, and many other types of equipment.
As is the case with similar capacitors made by other manufac-
turers in the United States, they are almost all impregnated with
polychlorinated biphenyl, known as Monsanto Aroclor 1016. In com-
mon with other aroclors, this material is non-flammable in the
usually accepted sense.
In the pursuit of the goal of phasing out PCB's in the United
States, I believe it is imperative that we take into consideration not
only the adverse environmental effects we are trying to minimize,
but also the safety impact of these actions.
One consideration which must be faced squarely is the matter
of flaminability. There are literally hundreds of millions of small
industrial capacitors impregnated with non-flammable polychlori-
nated biphenyl (PCB's) in service today. I am not concerned about
their contribution to fire hazard in these existing installations.
However, an additional 50 to 75 million of these capacitors are
being placed in service each year.
The materials the Electrical Utilities Company has tested may
be more environmentally acceptable than PCB's, and they have
other characteristics which make them reasonable candidates for
use in industrial capacitors; however, they have flammability char-
acteristics as dangerous as those of ordinary mineral oil. I am
aware that there have as yet been no serious fire problems attrib-
utable to capacitors in Japan since they switched from PCB' s to
other impregnants. I am aware that pressure interrupting devices
in some applications or electrical fuses can be used to reduce the
possibility of case ruptures or fire when a capacitor fails. These
safety devices, while reasonably reliable, are by no means com-
pletely effective. There also may not yet be many non-PCB capa-
citors in service in Japan. Failures are more likely to occur in
application when the capacitors are older. Unless some other com-
ponent in equipment fails first, or capacitors are removed from
service for other reasons, all small industrial capacitors will
eventually fail in service.
Because of the large number of capacitors being put into serv-
ice, if they contain a flammable dielectric, it is my opinion that it
will not be long before the first failure occurs resulting in a fire.
The Electrical Utilities Company has already had a fire in our fac-
tory while experimenting with non-PCB' s.
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If our industry agrees to phase out PCB's, EPA should agree
to help us coordinate the introduction of non-PCB's with those
organizations and agencies that will be concerned with flammable
capacitor dielectrics. Underwriters Laboratory, the Consumer
Product Safety Commission, and insurance companies using the
National Electric Code will be some of the organizations concerned.
Also, my company has no wish to jeopardize its own survival,
as well as peoples' lives and property, by producing a product
which is not as safe as capacitors are today. If we are forced to
use flammable dielectrics, some type of government sponsored
indemnification for potential damages could greatly aid users of
non-PCB capacitors and reduce the risk to capacitor manufacturers
potential damages pose.
I hope that in our mutual search for reasonable alternatives to
PCB' s you will take these suggestions into account.
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John P. DeLong
Director, Power System Operations, TVA
January 22, 1976
TVA POWER SYSTEM
USE AND CONTROL OF
POLYCHLORINATED BIPHENYLS (PCS' s) ASKAREL
There are two uses of askarel on the TVA system in quantities
of any significance. This is in transformers and capacitors. We
have slightly over 700 gallons of askarel in storage among 10 store-
rooms. In addition there are thousands of small capacitors and
relays, but each of these has only an ounce or less of askarel. We
also have a few hundred motors which contain starting capacitors
with just a few ounces in each.
Transformers filled with askarel do not burn or sustain fire
under conditions of internal electrical arcing. Various Federal,
state, and local conditions require use of askarel in transformers
for use in locations where electrical fires present the greatest
potential danger to life and property.
We have approximately 1, 350 transformers filled with askarel
that are installed in hydro, steam, and nuclear generating plants for
indoors, vaults, or special applications where fire protection is
important. The total quantity of askarel used in these transformers
is about 850, 000 gallons. These transformers, depending upon the
rating, each contain some 50 to 1,000 gallons of askarel. Out of all
the askarel-filled transformers at the plants the only failures in the
last 20 years have been the small high-voltage precipitator trans-
formers. We have experienced over the last few years two or three
of these failing a year. Each of these holds 50 to 100 gallons of
askarel. In the past these transformers were repaired in an area
of our central service shop where, if a spill had occurred, the
askarel would not have entered a door drain but would have drained
into a catch sump area. For future repairs this is being discon-
tinued. The transformers and associated filtering equipment will
be repaired and handled inside a steel curbed pan with a volume
that will hold the full amount of askarel that the transformers con-
tain. This will result in a completely sealed system and eliminate
the danger of spillage. The soiled rags and solids will be collected
in a sealed tank and held for future disposal.
Capacitors are used on the electrical transmission and distri-
bution system as devices to control voltage and by correcting power
factors reduce system transmission and distribution losses. We
have approximately 82,000 capacitors totaling 5, 595, 000 kvar's in
use on the TVA system. These capacitors vary in size from 15 kvar
for the older ones up to 200 kvar for the new ones. The new ones
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are not much larger physically than the old style, so the whole
group would average 2 to 21/2 gallons of askarel per capacitor.
This will give a total of 160 to 200 thousand gallons in all capa-
citors.
Approximately 2/3 of the capacitors are installed in TVA sub-
stations mounted on steel structures, over graveled area, and
inside a security fence. The other approximately 1/3 are located
on TVA power distributor systems usually in clusters of 3 to 12
capacitors mounted on a pole structure primarily in rural areas.
Our major disposal problem has been with the failed or retired
capacitors. On an average, 250 fail each year and another 50 are
retired due to obsolescence. Since each capacitor is protected by
an individual fuse, seldom does a failure result in a ruptured case
and loss of askarel. From the above totals, you can see that we
would have a total of approximately 1,050, 000 gallons of askarel in
use on the TVA system.
In the early 1970's TVA considered storing failed capacitors
and solid material containing askarel until a standard disposal pro-
cedure was approved by the Federal government. However, it was
felt that the storage and shipment of failed and obsolete capacitors
(approximately 300 per year) would be a hardship and, therefore,
the American National Standard Institute "Guidelines for Handling
and Disposal of Capacitor and Transformer Grade Askarels Con-
taining Polychlorinated Biphenyls" were adopted. These guidelines
state that failed capacitors should be disposed of only in dry land-
filled sites which met all applicable state standards. All waste
liquid askarel should be disposed of by incinerator at a suitable
facility. TVA has plans to send all waste askarel to the Monsanto
Chemical Company for disposal when sufficient quantities are avail-
able. Until then it is being stored in glass-lined tanks. All solid
waste which had been saturated with askarel was disposed of in a
dry landfill that met state requirements.
In late 1975 TVA reviewed its guidelines for disposing of failed
units and PCB's because of problems incurred with storage, col-
lection, and transportation to the various sites. It was desirable to
develop a standardized method of handling failed or obsolete units
within TVA and to effect the final disposition of these units. It was
felt that landfilling was probably not acceptable as a permanent
solution. A decision was thereby reached to cease the practice of
disposing of defective capacitors in dry landfilled areas. The deci-
sion was made to return all defective capacitors to a storage ware-
house where they will be held until an appropriate method of dis-
posal is determined. Units which might leak during transit are to
be drained into a suitable closed and sealed container. Drained
units are to be protected from rainwater to prevent leaking askarel
into the environment. These returned units are being accumulated
and stored until an environmentally satisfactory method of disposal
is found or developed. No units are presently being discarded in
landfills.
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TVA's Solid Waste Management Staff, of the Division of Envi-
ronmental Planning, is working on an environmentally and econom-
ically satisfactory method of disposing of these PCB materials.
This staff is investigating in cooperation with EPA and others the
adequacy of Chem-Dyne Corporation's incinerator recently placed
in service in Ohio. This incinerator can operate at 2,200 degrees
Fahrenheit with a residence time of 3 1/2 seconds which is suf-
ficient temperature and residence time to destroy PCB's. The
corporation has expressed an interest in testing this method of dis-
posal of capacitors and solid waste material soaked with askarel.
If this method of disposal is environmentally satisfactory, TVA
will probably develop plans to ship accumulated askarel mate-
rials to the Ohio facility.
The Division of Environmental Planning is also coordinating
within TVA the following actions:
1. Inventory of transformers containing askarels; review
of procedures for collection, storage, and disposal or
reuse of small amounts of waste liquid askarel, trans-
former components contaminated with askarels, and
solid waste materials soaked with askarel.
2. Development of a contingency plan based upon the
existing Spill Prevention, Control and Countermeasure
Plan for transporting transformers filled with askarel
to and from the service shops.
3. Development of engineering design plans for contain-
ment of askarels to avoid the escape or discharge of
PCB's into water courses as part of the ongoing work
related to the National Pollutant Discharge Elimination
System permit program activity.
4. Review of procedures for storing obsolete -capacitors
and containers of askarel to avoid escape or accidental
discharge of PCB's into the environment.
5. Issuance through TVA's Hazard Control Compliance
Staff of a hazard awareness bulletin for the purpose
of protecting employees' health and safety. TVA's
Industrial Hygiene Branch and Safety Engineering Staff
will inspect the work places periodically to ensure that
the control measures identified in the bulletin are
implemented.
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W. B. Behnke
Executive Vice President, Commonwealth Edison Company
January 22, 1976
MANAGEMENT OF PCB's ON UTILITY PROPERTIES
Because of their non-flammable and extremely stable chemical
characteristics, PCB liquids such as Askarel have been used in
capacitors and certain indoor transformers on utility systems for
many years. Until the late 1960's, even though these fluids were
regarded as safe industrial chemicals, the need for following good
housekeeping practices in handling Askarel has long been
apparent to the utilities. Aside from environmental concerns, it is
essential that such insulating materials be protected from contami-
nation by water, dirt, or other liquids. The environmental con-
cerns with PCB's identified in the late 1960's added further empha-
sis to the importance of careful handling of PCB liquids. These
concerns called for the control of Askarel to a much greater extent
than of other insulating liquids, and led the American National
Standards Institute to issue Standard C-107, guidelines for handling
and disposing of transformer grade Askarels. Commonwealth Edi-
son participated in drafting this standard and we are complying
with its requirements. We recognize that, in the light of EPA's
more recent concerns, more must be done. The following are the
good housekeeping principles we feel are most important.
Inventories of PCB liquids must be closely controlled. Equip-
ment containing PCB's should be inspected for leaks upon receipt
and again when permanently installed. Small quantities of Askarel
are needed each year to make up for losses and replace contami-
nated liquid.1 Askarel is shipped in sealed five-gallon cans which
are clearly labeled to identify their contents, and should be
inspected for leakage upon receipt. Storage of these cans should
minimize the risk of accidental puncture and avoid the possibility of
any environmental contamination through sewers or seepage. Used
Askarel should be accumulated and safely stored pending disposal.
Askarel should be only used for approved purposes and unused
quantities returned to stock. Accountability records should be
maintained.
Commonwealth Edison, we have about 1.0 million gallons of
Askarel in use. Last year we purchased 2,100 gallons for
make up and returned 2,000 gallons to Monsanto for disposal.
The returned portion consisted of contaminated fluids plus
drainage from junk capacitors. Some additional fluid in
Askarel-saturated materials was also returned. Actual losses
to the environment, while difficult to quantify, were very
small.
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Handling procedures in the shop as well as the field should
avoid release of PCB liquids to the environment. It is important to
avoid any possibility of introducing PCB's into regular insulating
oil handling systems and oil-filled equipment. For example, hoses
and pumps used for regular transformer oil should not be used to
handle Askarel. When filling or draining Askarel from electrical
apparatus, steps should be taken to keep accidental spills from
entering floor drains or seeping into the ground. Used Askarel and
Askarel-contaminated materials such as rags, solvents, and sweep-
ing compounds, should be collected and stored in sealed containers
pending shipment to approved disposal facilities.
Disposal of Askarel and Askarel-saturated materials requires
special attention. Commonwealth Edison's practice is to seal them
in steel drums and return them to the manufacturer for high-
temperature incineration. Disposal of Askarel-insulated apparatus
also imposes special problems. It is virtually impossible to com-
pletely decontaminate the insulation in Askarel-filled transformers
and capacitors. Therefore, it is necessary to dispose of them in a
manner which will prevent the release of Askarel to the environ-
ment. Ordinary salvage practices are not sufficient. There are
several companies qualified to handle the disposal of Askarel-
contaminated capacitors and transformers.
There is no way to eliminate the risk of accidental Askarel
spills. They can occur as. a result of handling accidents or equip-
ment failures. In order to minimize the environmental impact of
such mishaps, it is important that utilities have spill control plans.
These plans should provide for prompt recovery of any Askarel re-
leased to the environment and the safe disposal of all contaminated
materials.
Finally, utility procedures should provide for control of
Askarel-contaminated clothing. At Commonwealth Edison, workers
who handle Askarel are instructed to wear face shields, gloves, and
plasticized coveralls. The use of non-absorbant disposable clothing
eliminates the problem of Askarel contamination from laundry
water. Solvent is provided in which workers can rinse their hands.
The ANSI C-107 drafting group is now reviewing the Standard
in response to EPA's concerns and expects to make appropriate
revisions in the near future. EPA has identified the need to tighten
the requirements concerning handling and cleaning of workers'
clothing, disposal of laundry water, and requirements for solid
waste disposal. We believe there are practical solutions to these
concerns which can be incorporated into the Standard.
We are hopeful that within the next few years environmentally
acceptable non-flammable substitutes for PCB fluids will be devel-
oped and used in all newly-manufactured equipment. Unfortunately,
the flammable characteristics of those identified so far are inferior
to Askarel. Even when a substitute is found, a large amount of
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Askarel-filled equipment will still be in service. Replacement of
this equipment is not economically feasible or environmentally
desirable. It will be difficult, if not impossible, to flush enough
PCB from existing transformers to avoid contamination of a sub-
stitute insulating material. Since capacitors are in sealed cans,
there is no practical way to change the insulating fluid. Obviously,
the handling and disposal of so much equipment on an accelerated
schedule will greatly increase the risk of accidental spills, and the
cost would be prohibitive. Therefore, the only practical approach
is to limit the use of Askarel to existing facilities and those new
installations where substitutes are unavailable. Or at the same
time, maintain procedures for the control of Askarels to be up-
graded wherever feasible in order to minimize future release of
PCB's to the environment.
It is important for utility management to understand the prob-
lems associated with the use of Askarel and develop procedures for
dealing with it. It is equally important that these procedures be
properly implemented. Personnel training is an essential element
in proper implementation, but indication of top management con-
cern and insistence that Askarel control procedures be followed is
equally important. I believe that the presence of top utility manage-
ment at this meeting is strong evidence of their recognition of the
problems and their commitment to solving them. We are convinced
that good PCB housekeeping procedures will assure that the utili-
ties can continue to use PCB insulating liquids in transformers and
capacitors without adverse impact on the environment.
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R. E. Uptegraff
Transformer Manufacturers Task Force/
National Electrical Manufacturers Association
May 13, 1976
PROBLEMS ASSOCIATED WITH THE BAN ON THE USE OF
PCB's (ASKARELS) IN TRANSFORMERS
In attempting to analyze the extremely complex problems that
would result from a ban on the use of PCB's in transformers, it is
logical to first consider the various sectors that would be affected:
1. Manufacturers of new transformers;
2. Transformer service and repair companies;
3. Architects and construction consultants;
4. Buyers, such as contractors, industrials, govern-
mental agencies, utilities, etc.;
5. Users, such as apartment owners, commercial build-
ing owners, hospital administrators, shopping center
owners, etc.;
6. Regulatory agencies, such as the Environmental Pro-
tection Agency, Department of Transportation, U. S.
Coast Guard, Underwriters Laboratories, National
Electrical Code, etc.;
7. Insurance companies, as regards fire hazards and gen-
eral insurability of locations where substitute liquids
may be used; and
#8. The courts, as regard litigation for settlement of
claims.
Some of the concerns of the transformer sectors are as fol-
lows:
1. The inability of certain users or owners to obtain
askarel-filled transformers or some equivalent where
the location or space is limited in existing buildings or
buildings currently under construction.
* Not in official presentation to EPA
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2. The fire hazards associated with the ill-considered use
of oil-filled transformers in locations that presently
call for the use of nonflammable transformers.
3. The technical or engineering problems associated with
the use of oil-filled transformers in locations that
presently call for the use of nonflammable trans-
formers.
4. The fire hazard and insurability problems associated
with the use of relatively untried substitute materials.
5. The technical and engineering problems that could
arise in using dry type transformers as replacements
for a ska r el-filled units.
6. The serious consequences, both technical and finan-
cial, that would result if an entire transformer system
had to be changed because of inability to replace or
modify any part of an existing askarel transformer
system.
7. The inability of the transformer manufacturer to honor
express or implied warranty on askarel-filled units in
the event that no equivalent liquid is available.
8. The problems associated with retro-filling existing
askarel units with replacement liquids should the PCB
ban make this become a requirement. It is our opinion
that large scale retro-filling with other liquids should
be avoided as the environmental hazards of such a pro-
gram would be greater than if the askarel-filled trans-
formers were allowed to remain in service throughout
their useful life.
9. The possibility that some substitute fluids may also
present future environmental hazards. We feel that
before the transformer industry adopts any replace-
ment for askarel, some form of official sanction should
come from EPA.
10. The problems, both technical and financial, associated
with the cleanup of existing manufacturing, transport,
and service facilities that have been handling askarels.
We recommend that ANSI Standard C-107.1 "Guidelines
for Handling and Disposal of Capacitor and Trans-
former Grade Askarels Containing PCB's" be given
official sanction by EPA so that askarel users have
clear guidance in dealing with the cleanup problem.
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11. The severity of fines for accidental spills and dis-
charges of PCB's into the environment, as called for
in 40 CFR Part 116-119, in the event EPA finds "gross
negligence . "Gross negligence" is not specifically de-
fined and does not appear to be established in guide-
line rules or regulations, violation of which would
imply 'gross negligence".
12. The possibility of problems arising regarding the dis-
position of askarel-filled transformers already manu-
factured, both in service and in storage, when and if
these were to be banned.
In analyzing all of these concerns of the various transformer
sectors, there is one major and overriding key issue; and that is
the timing of the implementation of a ban on the use of PCB's. A
corollary key issue, associated with timing, is that effective dates
be broadly communicated to all of the transformer sectors.
Adequate specific timing and communication will enable the
transformer users, buyers, manufacturers, and other concerned
sectors:
1. To intelligently plan an orderly withdrawal of PCB's
from commerce with minimum economic impact;
2. To obtain and technically evaluate substitutes;
3. To obtain environmental qualifications on substitutes;
4. To attempt to resolve problems dealing with the
National Electrical Code, Underwriters Laboratories,
and other fire code writing bodies such as local muni-
cipalities;
5. To attempt to clarify general insurability of installa-
tions using substitute" materials that are somewhat
more flammable than askarel; and
6. To formulate policy dealing with manufacturers' liabil-
ities under warranty.
Recognizing the importance of these timing and communication
problems, we feel that real progress in solving them can only be
made:
1. By there being a definite date for stopping the sale or
purchase of askarels for new transformers;
2. By EPA establishing a definite, later date, for the cut-
off of sale of askarels to transformer service and
repair shops; and
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3. By EPA broadly disseminating at the proper time, a
comprehensive analysis of the PCB ban, including
alternative or remedial procedures, to all architects,
construction consultants, federal, state, and local
governmental agencies, transformer manufacturers,
service shops, utilities, fire underwriters, profes-
sional technical organizations, and others. This anal-
ysis should specifically spell out the timing on a ban,
its restrictions, and its alternatives; and most impor-
tantly, there should be precise definitions of terms,
such as "use", "transport", "process", "distribute in
commerce", and other similar terms.
We recognize the fact that the timing aspects of the PCB ban
are spelled out in the proposed "Toxic Substances Control Act,
S-3149"; and we feel that we can effect an orderly withdrawal of
PCB's within this time frame. In summary, it should be noted that
askarel-filled transformers represent perhaps less than 5% of the
dollar value of the total transformers sold; and because of this and
the fact that other types of transformers will be made in lieu of
askarel transformers, we do not see any undue hardship resulting
from an intelligently planned and implemented total ban on the usage
of PCB's.
We, as responsible members of the business community, share
the concerns of everyone regarding environmental hazards; and we
pledge our wholehearted support in helping solve the PCB problem.
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Clifford Tuttle
Capacitor Manufacturers Task Force/
Electronic Industries Association
May 13, 1976
Mr. Train, my name is Clifford Tuttle, I am president of
Aerovox Industries and I am speaking under the auspices of the
the Electronic Industries Association for the manufacturers of
alternating current (AC) capacitors on polychlorinated biphenyls.
Perhaps it would be illuminating if I briefly outlined the market and
function of an AC capacitor.
The total capacitor market in the U. S. is approximately
$600 million of which the Department of Commerce reports only
$500 million since some AC segments of the market do not fall
under a capacitor SIC code. Of this $600 million, $450 million is
direct current (DC), primarily electronic. We are only associated
with the AC sector which totals approximately $150 million. This
can roughly be divided into three equal parts: $50 million of large
(utility type) capacitors, $50 million of lighting (small) capacitors,
and $50 million of motor run and other small capacitor applications.
Frequently, people not connected with the industry try to make
comparisons between the use of AC capacitors in the U. S. and the
practices followed in other countries. This is not possible since
the U. S. is relatively unique. In many countries, the distribution
circuits are 220 volts and capacitors are applied across the incom-
ing voltage, providing power factor correction only. In the U.S.
we use a 110 volt system, but we put our capacitor in the circuit
with a transformer or a motor winding to gain significantly greater
efficiency and use less current. The result is that U. S. capacitors
see voltages of from 300-500 volts versus the 220-250 volts typical
in other countries.
As a result of these higher voltages and the resultant corona,
we do not believe that the referred to "dry construction" - metal-
lized film - will be a viable method of manufacturing AC capacitors
until the 1980's and still then only for a segment of the market.
Presently, this process and resultant product is simply too unreli-
able and much must be done to improve performance before dry-
designs will satisfy U. S. requirements; therefore, for the remain-
der of this decade, we feel paper/foil capacitors, with some type of
impregnant, are the only way that we can supply the needed AC
capacitors in the U. S.
Without capacitors, our fluorescent and mercury lights would
require nearly twice as much electric power for the same light out-
put. The same is true for AC motors and, in the case of most air
conditioning compressors, the units would not even operate on the
110 volt line current without capacitors. The present use in the
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U. S. of an AC capacitor in television is primarily for the benefit of
the consumer in that the constant voltage transformer insures that
the picture size will not decrease with changes in line voltages. It
also significantly reduces the amount of current needed for televi-
sion sets, but this is not the reason the capacitor is currently being
installed in about 25% of the U. S. sets.
Looking forward to 1980, TV sets will undoubtedly have to have
capacitors since the Federal Energy Policy and Conservation Act
mandates energy consumption reduction on virtually all appliances
and other items that are significant users of electricity. For
example, room air conditioners now use shaded pole motors on the
fans; these must change to split capacitor motors in order to meet
this mandated reduction. We believe that compliance with this
recently passed legislation will increase by 1980 the small capaci-
tor market in the U.S. from its present $100 million to between
$150 million and $175 million in terms of today's dollar.
I just learned yesterday that the State of California is holding
hearings on legislation that would immediately require the addition
of capacitors on virtually eve'ry appliance.
Now that we have identified the function and market for an AC
capacitor, let me bring you up to date on our progress in searching
for alternate liquid impregnants to replace Aroclor 1016. At pres-
ent, it appears that manufacturers of small capacitors may gener-
ally employ phthalate esters which are less efficient than PCB's.
There is some concern about a segment of the applications of these
products where operating temperatures are in the 85° C to 100 °C
range. The manufacturers of large utility type capacitors do not
have unanimity in the selection of alternate materials. Some are
going to phthalate esters, others hydrocarbons and a few to entirely
different materials. Both types of manufacturers will probably be
able to meet a 24-30 month phase-out which provides a very limited
amount of time for testing and customer acceptance. The transi-
tion is going to pose a special hardship on about half of the manu-
facturers of small capacitors who had hoped to use a modified
hydrocarbon that was being proposed by Monsanto. The availability
of this fluid has been withdrawn and therefore these companies are
starting today from ground zero on phthalate ester research.
There are other problems associated with the transition. First, I
must emphasize that in a short period of two years we have to
change from a material on which we have a 40 year history to brand
new untried alternates. There are many risks involved because we
may be unsuccessful. Therefore, the product liability that rests
upon us, as manufacturers, is most significant. Secondly, there is
no doubt that the product made with alternate materials will have a
somewhat poorer performance and be significantly less reliable
than those made with Aroclor 1016. Also, we are still concerned
about the environmental acceptability of these alternates and hope
we are not trading one problem for another. Finally, and most
important, all of these alternates are flammable,, posing a signifi-
cant safety hazard to both life and property. We do have methods
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of protection available, but unfortunately they are most unreliable.
All the user groups with which we met are practically paranoiac
about this problem.
Now I would like to address myself to EPA1 s directive efforts
to force those of us discharging to streams to hold effluents to one
part per billion. We do not believe that pretreatment has been
proven technically and the cost appears to be extremely high. Fur-
ther, we are having even greater difficulty in responding to EPA
pressure that discharges to municipal sewers be low. Here, we
apparently must treat the raw sewage before we can even start the
treatment for PCB's. This is going to be very expensive and again,
the end results are unknown. Frankly, we are concerned that the
cost will be prohibitive to many of the capacitor manufacturers. We
think, during this last 2 year phase-out period, maximum dis-
charges of 1-3 ounces per day, per plant and 4 pounds a day for
the entire industry is acceptable. By your own admission, this is
an infinitesimal amount compared to the PCB's going into the envi-
ronment by other means. We question the edict to go lower than
1-3 ounces per day when we know that from the date in which pre-
treatment could be installed we will probably use PCB' s for only
6-12 months. Therefore, it appears the necessity for this signifi-
cant expenditure will be removed almost immediately after it is
made. We hope that EPA will understand our position on this mat-
ter.
In summary, phasing out the use of Aroclor 1016 in 24-30
months forces the manufacturers of AC capacitors to take major
risks from a consumer safety and a product liability standpoint. We
will be making the transition with totally insufficient experience.
Let me review our major concerns:
1. The modified product would be considerably less reli-
able;
2. The new product will be more costly;
3. The new product will be larger;
4. We do not know the environmental impact of the alter-
nate materials;
5. Finally, and most important, any known alternative
material will be flammable and a potential hazard to
people and property. We hope the U. S. Government is
truly facing the potential magnitude of this problem.
As you can see, Mr. Train, we sincerely question the advisa-
bility of ceasing the use of Aroclor 1016 and changing to flammable
alternatives. Perhaps, considering all aspects, controlled use of
Arochlor 1016 in capacitors would be better.
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Harry Onishi
Utilities Task Force
May 13, 1976
PROGRESS ON PCB CONTROL
Mr. Train, as a result of your meeting with representatives
of the electric utility industry in January concerning the problem of
PCB's, a Task Force has been formed under the auspices of the
Edison Electric Institute to focus voluntary action of the utility in-
dustry in cooperation with EPA in controlling the handling and dis-
posal of PCB's.
The Task Force has had several meetings with EPA represent-
atives and we have prepared an Industry Position Statement. Cop-
ies of this statement are available and have been released to your
staff. Today, I would like to briefly summarize our concerns with
the phase-out of PCB's and the use of substitute fluids in electri-
cal equipment.
Looking first at existing equipment (which are primarily trans-
formers and power capacitors), we believe such equipment should
remain in service for its useful life. Our reasons for this position
are as follows:
1. Past experience has shown that transformers and
capacitors are very reliable devices. During normal
operation of this equipment, PCB losses to the envi-
ronment have been minimal. I might mention that this
finding is also supported by the Independent Study
(PCB's in the United States Industrial and Environ-
mental Distribution) conducted for EPA.
2. It is not possible to completely drain equipment of all
PCB's. If we attempted to retrofill transformers, the
substitute fluids would be contaminated with PCB's and
the transformer would still have to be handled as PCB
containing apparatus. For capacitors, the units are
hermetically sealed with no provisions for adding or
removing fluid.
3. Substitution of non-PCB fluids in existing equipment
would create severe handling, transportation and dis-
posal problems. For example, for disposal of PCB's,
there are limited facilities for incineration, and there
are a limited number of chemically secure landfill
sites for disposal of non-burnable PCB wastes and
equipment. Moreover, we believe undertaking such a
program would significantly increase the probability of
PCB releases to the environment.
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4. If it were required that all PCB containing equipment
be replaced in total, there would be a tremendous
replacement cost, insurmountable disposal problems,
and we believe such a move could also impair the qual-
ty of electric service.
For these reasons we believe existing PCB containing equip-
ment should remain in service and that our efforts should be
directed toward maintaining records of all PCB equipment and
establishing procedures and methods for the containment, clean-up,
handling, and disposal of PCB1 s in accordance with guidelines as
stated in the ANSI Standard C-107. You may be interested in know-
ing that utilities are disposing of PCB's by incineration and in
approved landfill sites. As I mentioned previously, there are at
present a very limited number of chemically secure landfill sites.
Geographically they are located in California, Idaho, Nevada, Tex-
as, New York, and Illinois. Because of this limitation, in some
instances, utilities are stockpiling capacitor units until suitable
disposal arrangements can be made. Utilities are also in the pro-
cess of developing and implementing procedures for control and
proper clean-up of inadvertent PCB spills should they occur.
We expect that PCB containing equipment will be part of elec-
tric utility systems for many years into the future. Phase-out of
the manufacture of PCB's would not impact existing capacitor
installations because there are no make-up fluid requirements. It
would require, however, that acceptable substitute capacitor fluids
for replacement units be available. For existing transformers,
unavailability of PCB's would be an inconvenience, but the nomi-
nal make-up fluid requirements could be provided by reclaiming
askarel from transformers removed from service.
Moving on to replacement and new equipment, there are
numerous proposed substitute fluids; however, there are today no
direct replacement fluids that have the equivalent properties of
askarel. We note in pending legislation that the proposed timetable
for phase-out of PCB use in electrical equipment is 21/2 years.
We think this is overly optimistic. We believe further research,
development, demonstration and evaluation are necessary to deter-
mine long term electrical characteristics and operating reliability.
It is also important that we have EPA assurance that the substitute
fluids are environmentally acceptable so that normal handling and
disposal methods may be employed.
For transformers, we believe further testing is required to
establish that substitute fluids do not constitute an undue fire risk
and further, the appropriate code-making agencies must indicate
they are acceptable from a fire risk standpoint. On new trans-
former installations, utilities are taking steps to minimize or elim-
inate requirements for PCB transformers by using alternative
designs where practicable. However, for replacement units at
existing locations, there may be no feasible alternatives. At some
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locations it is essential that replacement transformers have a fire-
resistant insulapion. Based on the development, testing, and evalu-
ation still remaining, we believe the phase-out of PCB use in
transformers will be in the range of 5 years, rather than 21/2
years.
For power capacitors, it appears substitute fluids having ade-
quate insulating properties are available; however, no adequate
assessment of their operating performance or reliability has been
made. Assuming these fluids are environmentally acceptable, and
there are no other unforeseen difficulties, the phase-out of PCB us<
in capacitors could be accomplished within 3 years.
In conclusion, the utility industry is concerned that PCB16 are
properly controlled and we are prepared to take practical measures
to ensure that PCB's from electrical equipment do not enter the
environment. We are pleased that we have the opportunity of work-
ing with EPA in moving toward a voluntary solution to this difficult
problem. In view of the progress on control of PCB's and the
intention of utilities to conform with provisions of ANSI C-107, v/e
believe it is unnecessary to specifically legislate the control of
PCB's such as is proposed by the Nelson Amendment. We would
urge that this be a significant consideration in your discussions with
Congress on PCB legislation.
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J. C. Weber
Monsanto Chemical Company
May 13, 1976
Good afternoon, my name is Cole Weber. I am manager of
product acceptability for specialty chemicals, including polychlori-
nated biphenyls (PCB) dielectric fluids, manufactured by Monsanto
Industrial Chemicals Company, a unit of Monsanto Company.
When Jack Fitzgerald, a Monsanto vice president and managing
director of this operating unit, met with you in January, he assured
you that Monsanto had no desire to remain in the PCB business any
longer than necessary. He also stated that as soon as Monsanto
was satisfied that the electrical power supply industry's needs for
usable, acceptable alternate dielectric fluids had been met by
whomever, Monsanto would voluntarily shut down its PCB manu-
facturing unit.
I am here today representing Monsanto to reaffirm this posi-
tion and to give you a brief update on the status of development
work on possible replacement products. I'll also comment on the
phase-out timetable.
Based on customer feedback, the transformer industry is
apparently leaning towards silicones, which are readily available,
as the leading askarel (PCB) replacement candidate. We do, how-
ever, still sense some reservations on the part of our transformer
customers with regard to the fire resistance of all current replace-
ment candidates and are awaiting further clarification programs.
In the meantime, we have shelved all development work on our
transformer fluid alternates because they simply did not appear to
be able to compete on a cost/performance basis with other viable
alternates.
In the capacitor segment, the trend is currently towards com-
modity type solutions which are widely available in large quantities
such as phthalate esters. If this approach proves satisfactory, it
will obviously preclude further consideration of specialty solutions
such as Monsanto's MCS 1238-type technology which is a proprie-
tary blend specially designed as a capacitor dielectric. Conse-
quently, we are very close to terminating our development efforts
in this area as well.
If the capacitor industry determines that commodity fluids are
indeed the most expedient way to satisfy their cost/performance
criteria, we believe that Monsanto may have viable candidates to
assist them in this approach.
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Regarding the phase-out timetable, we are already involved in
the transformer fluid phase-out. Since we announced our intentions
to exit the business, demand for PCB-filled transformers has de-
clined substantially. Our transformer fluid sales in 1976 will be
less than half the toal recorded in 1975.
When the capacitor makers complete their evaluation work and
tell us they are satisfied that they have viable alternates in hand,
we will cooperate fully in an industry-wide changeover and proceed
with the orderly termination of all PCB production, including
Aroclor 1016, the current capacitor industry standard.
Monsanto is often asked, and indeed pressed, to establish a
firm exit date. We are as anxious as anyone to settle on a firm
timetable so we can complete our exit plan and begin applying these
considerable resources to ongoing programs. However, to unilat-
erally set an exit date would be inconsistent with our long-standing
pledge to work with the electrical industry to replace PCB' s in an
orderly manner. So, to reiterate, Monsanto is fully prepared and
indeed most anxious to exit this business at the earliest possible
date. We will establish and begin executing a firm phase-out time-
table as soon as we receive a consensus judgement that viable
alternates are in hand.
Thank you.
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Ronald J. Kasper
Industrial Risk Insurers
May 13, 1976
CURRENT POSITION OF THE INDUSTRIAL RISK INSURERS
REGARDING THE USES OF PCB's IN ELECTRICAL SYSTEMS
It has been common practice to use askarel-insulated trans-
formers as one of the counter measures against the fire and explo-
sion hazards of oil-insulated transformers. Recently, however,
recognition of the environmental hazards of askarels (polychlori-
nated biphenyls or PCB's) has become a matter of concern to
many. As a result, this Association is reevaluating the suitability
of askarel-insulated transformers.
As an industrial property insurer, we are interested in the
development by industry and/or government agencies of substitutes
for askarels that are satisfactory from a fire protection standpoint.
Otherwise it may be necessary that we evaluate installations to
determine if additional fire protection is needed. Oftentimes, auto-
matic deluge waterspray systems, fire barrier walls, fire resistive
vaults, or combinations thereof are recommended to protect build-
ings, adjacent transformers, and outdoor storage where combusti-
ble liquid-immersed units introduce exposures.
Currently, silicone oils are being considered as one substitute
for askarels in transformers. Although our experience with sili-
cone oils is limited, their use has been accepted by us on a limited
case-by-case basis. Hopefully, additional research, testing, and
service experience will eventually demonstrate that silicone oils as
well as some other dielectrics are acceptable substitutes for
askarels in transformers.
Although silicone oils have shown considerable promise for use
in transformers, this does not currently appear to be the case for
their use in capacitors. Other dielectrics are currently in the
developmental stage and will be tested for suitability. Hopefully,
researchers will soon be able to agree on a number of dielectric
fluids for use in capacitors that are relatively non-combustible and
equivalent electrically to the PCB's.
In summary, having recognized the adverse ecological and tox-
icological problems associated with PCB1 s and the impact of cur-
rent EPA regulations, this Association urges that precautionary
measures be developed to reduce the potential hazards of existing
installations and utilized until such time as the availability of suit-
able substitutes having low orders of combustibility makes it pos-
sible to eliminate PCB's from our environment.
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Arthur Spiegelman
American Insurance Association
May 13, 1976
My name is Arthur Spiegelman. I am the Vice President for
Engineering and Safety in the American Insurance Association. I
am a registered professional engineer in the State of New York and
and have graduated from the The Cooper Union with a Bachelor of
Science Degree in Chemical Engineering. During the past 31 years
I have been associated with the insurance industry in positions such
as Director of Research, Manager of Engineering and now in rny
present position.
The PCB's or polychlorinated biphenyls came to our attention
in the early 1950's as a fire retardant substitute for oil insulated
transformers. At that time, this fire problem was important to
our industry. A preliminary survey of our industry indicates that
there was a decrease in this hazard after the PCB's (or askarels)
were introduced.
The insurance industry has an overall interest in the total loss
control aspects of multi-faceted hazards. In this sense, the PCB's
fit into the category of a product which alleviates a serious fire
hazard but produces an environmental hazard of major proportions.
I am submitting to you a copy of our latest publication on this sub-
ject, Chemical Hazard Bulletin C-17 Polychlorinated Biphenyls
(April 1976). This publication will serve to acquaint you with the
extent of our concerns and also indicates the Loss Control meas-
ures which we advocate.
In this publication, we have not addressed the two problems
facing the EPA at this point of time:
1. The implications of prohibiting further production of
PCB's; and
2. The implications of outlawing their use within a period
of 2 1/2 years.
It was my understanding that you wished us to discuss these
questions from the standpoint of the economic impact on our indus-
try and on those of our insureds.
A prohibition of further production of PCB's appears to be
inevitable. The preponderous evidence as to the toxicity and the
apparent environmental problems would certainly cause you to act
in this direction. From a fire protection standpoint, this will re-
quire some readjustments. It would be easier for us to make the
changes if we had an acceptable substitute for the PCB's. How-
ever, those materials which have been suggested to date, such as - -
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Diisonyl Phthalate, Dichlorobiphenyl (plus alpaline Derivative),
Polydimethyl Siloxane, and Butylated Monochlorodiphenyl Oxide
have all been tried. There seems to be some problems associated
with each product and we would have to adjust our thinking to the
degree and type of problem which each one presents.
For instance, if the fire hazard were increased through the use
of a substitute material in the transformers, it might require relo-
cation of the transformers and the use of fire resistive enclosures
and water spray protection systems. All of this would be an addi-
tional expense and in some cases provide difficulties in finding
acceptable space to locate the redesigned transformers. How many
of the 125,000 transformers would require this treatment? How
much money would be involved? All of these questions and others
cannot be evaluated until we know what substitute material has been
selected and to what degree the fire protection will be changed.
The second question which involves the time period for outlaw-
ing the use of PCB's is one which involves a serious financial
responsibility on your part. The removal of the PCB's from the
existing 125, 000 transformers and the changing of 780 million capa-
citors places a burden on the users of this equipment which could
run into many millions of dollars. To this must be added the cost
of discreet and safe waste disposal of the existing PCB's. This
will require an educational program of major proportions.
We in the insurance industry will cooperate with you in inform-
ing our insureds of your decisions in this matter. We are inter-
ested in producing a safe and healthy environment. The target
dates depend on the availability of a substitute for the PCB's and
the practical aspects of changing the materials and equipment.
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TECHNICAL REPORT DATA
Incase read Instructions on the reverse before completing}
1. REPORT NO.
EPA 560/4-76-003
4. TITLE AND SUBTITLE
Industry Views on the Use of Polychlorinated
Biphenyls in Transformers and Capacitors
3. RECIPIENT'S ACCESSION NO.
5. REPORT DATE
June 1976
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
Office of Toxic Substances
9. PERFORMING ORGANIZATION NAME AND ADDRESS
U.S. Environmental Protection Agency
Office of Toxic Substances
401 "M" Street, SW
Washington, DC 20460
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
Office of Toxic Substances
401 "M" Street, SW
Washington. DC 20460
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
Statements presented by representative manufacturers and
users of PCB's and PCB containing products at meetings with the
EPA Administrator have been compiled. Industry outlines its
plans for discontinuing the use of PCB's, but presents summariza-
tions of the problems with the phasing out of capacitor and
transformer manufacture. The report represents a consultative
step in meeting the EPA goal of banning the use of PCB's in all
new products.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS
c. COSATI Held/Group
Polychlorinated Biphenyls
PCB's
Capacitors
Transformers
Electrical Industry
13. DISTRIBUTION STATEMENT
Release Unlimited
19. SECURITY CLASS (This Report)
Unclassified
20. SECURHY CLASS (This page)
Unclassified
21. NO. OF PAGES
48 pages
22. PRICE
EPA Form 2220-1 (9-73)
•6 U.S GOVERNMENT PRINTING OfFICfc 1976- 210-fllOAX
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