United States         Office of
          Environmental Protection     Pesticide and Toxic Substances
          Agency           Washington, DC 20460
          Office of Pesticide and Toxic Substances
EPA      PCS Marking and
          Disposal Regulations
          Support Document




       (40 CFR Part 761)

        ' (OTS - 068005)

    Toxic Substances Control

Poiychlorinated Sipnenyls  (?C3s)



  i.     Introduction                                                          i

  I.     Background                                                            1

 II.     Economic  Consequences                                                12

        General                                                              12
        Disposal  Costs                      '                                 14
        Chemical  Waste  Landfill  Costs                                        17
        Liquid  Incineration                                                  21
        Solid Waste Incineration                                            23
        Transportation                                                       30
        Decontamination                                                     32
        Storage for Disposal                                                 33
        Marking                                                             36
        Records and Monitoring                                              38
        Summary of Economic  Impacts                                         41

        Addendum                                                            46

III.     Official  Record of Rulemaking - PCS Marking and Disposal
        Regulations                                                         48

        A.   Proposed Regulation                                             48
        3.   Support Documents                                               43
        C.   Public Comments                    •                              48
        D.   Publicly Announced Meetings or Hearings                         ^9
            1.   Public Participation Meeting, Dec. 20, 1976                 49
            2.   Public Participation Meeting, Jan. 24, 1977                 50
            •3.   Work Group Meetings                                         50
                a.  Non-Federal Register.  EPA statements                   50
                b.  Communications                                          30
            4.   Reports                                             •        50
        E.   Other  Information                      •                         56
            1.   Federal Register Notices                                    56
            2.   Development Plan                                            57

  IV.     ADpendix:  Toxic Pollutant Effluent Standards;                      58
                   Standards  for Polychlorinated
                   Biohe.nvls  (?C3sh~ Final Decision


                                    This  Support  Document  for PCS  Marking  and  Disposal
                          Regulations  provides  information and data  that expand  the  basis  for  this
                          rulemaking contained  in the  Preamble.  This  Document provides  a  history
                          of  events'leading  to  EPA's  initiation of this  rulemaking.   This  Document
                          also  includes  a reference to the very detailed discussion  of the health
                          and environmental  effects of ?C3s presented  in the preamble to the
                          toxic pollutant effluent standards for PCBs  which were promulgated by
                          EPA on February 2,  1977, under the authority of  Section 307(a) of the
                          Federal  Water  Pollution Control  Act.  Those  standards  are  attached
                          to  this  Document as an  Appendix.
                                    This  Document also includes a  discussion of the  economic
                          consequences of the proposed regulations.   The discussion  is derived
                          from  a report  entitled  Microeconomic Impacts of  the Proposed Marking
                          and Disposal Regulations for PC3s submitted  to EPA under contract
                          by  Versar, inc., of Springfield, Virginia (a research and  consulting
                          firm) in April  1977.
                                    Finally, this Document includes the Official Record of
                          Rulemaking --  Marking and Disposal Regulations.


        Polychlorinated  biphenyls  (PC3s)  are  mixtures  of  the  chemical
 compounds  formed  by  the chemical  bond  of two benzene  molecules
 (biphenyl)  with varying numbers  of chlorine  atoms  attached  to  the
 biphenyl molecule.   The biphenyl  molecule has ten  positions  to  which
 chlorine can  be attached.   There are  209 theoretically possible
 isomers;. that is,  there are 209  different ways in  which  one  to  ten
 chlorine atoms may replace hydrogen ions on  the biphenyl molecule.
 About 100  different  chlorobiphenyl isomers are found  in  commercial
 PCBs.  The pure  isomers of chlorinated biphenyls are  crystalline at
 normal  temperatures.
        PCBs are  among the  most stable organic compounds  known  and
 exhibit other properties that render them extremely advantageous
 for use as dielectric and  heat transfer fluids.
        The synthesis of PCBs was reported as long ago as 1831.
 Successful commercial production of ?C3s in the United States  began
         1 /? /
'in 1929.--  With minor exceptions, the Monsanto Industrial  Chemicals
 Corporation has  been the sole U.S. producer of Aroclors" for several
 years.   Some domestic equipment manufacturers either modify Aroclor
 themselves or have Monsanto prepare special  formulations for them.  These
 have been  marketed and used in their products under the vairous traae
 names 1isted below:
 *  Registered Trademark.   (This will not be  footnoted further  in  "he
    .text, either separately or in  conjunction with a  soecific
    Aroclor, such as  1016/1242, 1243, 125^,  1250, or  1252.

                    Name:              •       Manufacturer

                    Aroclor*                  Monsanto
                    Aroclor  3*                Mallory
                    Asbestcl*                American
                    Askarel**                Hevi-Outy
                    Askarel**                Ferranti-Packard
                    Askarel**                Universal  Mfg.
                    Chlorextol*              Allis-Chalmers
                    Chlorinol*                Sprague  Electric
                    Clorphen*                JARO
                    Oiaclor*                  Sangamo  Electric
                    Dykanol*                  Cornell  Oubilier
                    Elemex*                   McGraw Edison
                    Eucarel*                  Electric  Utilities
                    Hyvol*                   Aerovox
                    Inerteen*                Westinghouse Electric
                    No-Flamol*                Wagner Electric
                    Pyranol*                  General  Electric
                    Saf-T-Kuhl*               Kuhlrnan  Electric
                    Pydraul1'                  Hydraulic  Fluids
                    Therminol*                Heat Transfer Fluids

        *  Registered trademark

       **  Generic name used  for nonflamacle insulating liquids in
           transformers and  capacitors.

          Other domestic usage  depends on imoorted ?C3s  known to originate

in [taly and France.  Some ?C3s may be imported from other countries, but

this  has not been definitely ascertained.  Qecachlorobiphenyl is imported

from  Italy for use  in investment casting wax, and trie various ?C3s
imported rrom France are used in the ccol'ng systems at mining machinery.

          An estimated 55 to 70 percent of domestic sales of ?C3s  is to

manufacturers of alternating current liauia  imoregnaLed capacitors, anc

the remainder to manufacturers  of transformers.-   Transformers, whicrt

contain 2,000 to 2,500 pounds of ?C3s on the average (normally  = mixture

of 50  to 70 percent ?C3s and 30 to -0 oercent tricnlorooenzane) are

primarily used to modify voltages during the distribution of electrical  power.
Approximately five percent of the transformers in service in this country
contain PCBs .  Most transformers now contain mineral oil instead of PCBs.
Capacitors containing PCBs  are of two general types:  small capacitors
that are built into electrical equipment such as fluorescent lights, TV
sets, and small motors;  and large capacitors that are used as separate
units in electrical power distribution systems and in large industrial
equipment, such as electrical motors and welding machines.   PCSs are used
in about 95 percent of U. S.-produced liquid-impregnated capacitors  (most
small capacitors in radios and other electronic equipment are non-PCB-
containing solid state units). —
          Over the past four years the domestic production  and use  of
polychlorinated biphenyls  (PC8s~)  has been  approximately  constant at 40
million Ibs/year.—   Figure  1 summarizes the distribution  of domestic and
imported  PCBs .  -/
          Estimates developed  for  total  PCBs production  and use in the
U.  S.  since  their  introduction to  industry  in 1929-30 are presented in
Table  1. —    These data define the estimated  proportions  of ?C3s used  in
various applications, and  an  accounting,  based  on  available data plus
estimates, of  the  current  distribution  of this  material.  Of the roughly
1.25  billion  pounds  purchased  by  U.  S.  industry,  it  is  estimated that  only
53  million pounds, or 4.4  percent, have  been  destroyed  by incineration  or
by  degradation  in  the environment.   About 60  percent of the total domestic
sales  is  still  in  service  --  almost  all  in  capacitors  and transformers.
The remainder,  about  4iQ  million  pounds,  is in  the environment.-   It  is
estimated that 290 million pounds  are  in  landfills or dumos and  150 million
 pouncis are  "free"  in  the  general  environment (air, water,  soil,  sediments)

             Figure 1
-ISV. -*SV» «0-»3"

/ SIMIt A't TO 1 V '
\AHOCLOH" 1242 | -TO'A


-•«SV» ^S3*/«


40X10* LB/YEAH
U il-JOV,





*• so V.

> UN




     SUMMARY OVER  1972-75

                                    Table  1
                    Estimates  of  Cumulative  pC3s  Production,  Usage,
               and  Gross  Environmental  Distribution  in  the  United  States
               Over the Period 1930-1975  in  Millions of Pounds
,S. res Production
b&il U.S. rC3 Import!
!.S. PC3 Qmtic Ul*9«
but U.S. PO Dieorta
C3 by U« Catvpary:
j f«trol«ua Addttiwrs
M««t Transfer
«lse. LnSuseriAl
Cutcnl««s C^Y Paper
Hydraulics irri lixiciomej
CUwr Pl'icicizer U»«
fhM OOMT «h» ei«trie.l
^3 winrjdc^ or t/cii>eratfld:
' Ls wid PO&J In CU^PSt
Ov*^r t^*pwc. pljucic* 0c~.1
rr^tf ^~ "•** ^i U^c Cri wi^^nr^w t
(soil. «it«Ti »ix. »Bdir»»ieJ
: rat*!



• InhueriiJL
PUT3%»3»» O( PCS


PCi» Currently
in Service


PCSf Currently

• PCSi


o( Vilur.
* 5» .
t 301
t :oi
i SOt
t 781
I lfl»
t Ml
t 401
t 301

Source:   Versar Inc.

and presumably available to the biota.
          The amount of  PC3s  in landfills and dumps is about two times the
amount of PC3s  already free in the environment.  The material in land
disposal sites may be considered likely to become widely dispersed over a
long period of time.  The length of time required can only be speculated,
but it is probably short in comparison to the time required for degradation
of  PC3s  by natural processes.  Thus, release of  PC3s  from landfills by slow
volatilization and leaching could compound an already severe environmental
problem. J i/
          A material balance for  ?C3s production, sales, distribution, and
production- wastes  in 1974 is presented in Table 2- —  —   The reliability
of the values was  estimated by the same methods used in Table 1.  The
amounts listed under "scrap  PC3s  incinerated" are based on all of the ?C3s
incinerated (at the recommended temperature-time  conditions of 2000 degrees
and 2 seconds dwell time) in the U. S. during 197-.
          A tabulation of the best available estimates of the amount of ?C3s
presently in use.  in electrical equipment  is  included in Table 3. —   These
data reflect what  is currently estimated  co  be  in  service and the normal 1;
expectancy of a new article or equipment.
          The failure rate of electrical  transformers and capacitors is very
low --  less than  one percent per year.  Further,  the likelihood of loss-of
?C3s  as a result  of equipment failure is less  than one-tenth of the "ai'ura
rate because transformers and capacitors  are~ccristructed using sealed
containers of high quality.  These containers can  be damaged  in accidents
which result in the loss of  PC3s .   Transformers  and capacitors are usual"/

                           Table 2
Estimated Production, Usage, and Losses of  PC3s  in the United
               State During 1974 in Millions of Pounds

Da-rtie netette
^DCA! 1m i ITS
Kantmto CnrmJG S4ln*
IxCOC^ $u mjppli^d by induicry. n»t »/vil)riM Jor ?G3« ccreentritien* in in3u«tri»l'
v«rrr»«it«r» AT* praMaly not sort Accurate Uvui 1 54 p*r cenc.
 iiourca:   Versar Inc.

                                Table 3

     Estimated Current Uses of Electrical Equipment Containing ?C3s

Transformers, (5% of all liquid filled transformers) (40 year life)

     140,000 @ 2150 Ib PCS (3000 Ib liquid) = 300.000,000 lb ?C3s

               60% utility
               20% office, apartment, commercial buildings
               20% industrial buildings

Large High Voltage (Power  Factor) Capacitors (20 year life)

     8,000,000 units 9 25  lb PCS = 200,000,000  lb  ?C3s

               95% utility
                5% industrial

Fluorescent Light Ballasts (15 year life)

     300,000,000 @ .1  Ib  PCS = 30,000,000  Ib ?C3s.

               95% large  buildings
                5« homes

High intensity _.Light Ballasts  (20 year  life)

     25,000,000 9 2  Ib PCS = 50,000,000  Ib  PC3s

                3% utility
               77% hiahway dept.
               20% buildings

Small Apol icance .Caoaci tors  (TV, microwave  ovens,  rcotn  air  conditioners)  (15
                                                                   year  life)

removed from service due to obsolescence rather than because of failure.    •"•

          In 1966, PCBs  were found in fish in the Baltic Sea.-*-   These

chemicals then were discovered in birds and other animals.  PCBs

have now   been demonstrated to be globally distributed. -   In 1969, PCBs

were determined to be the causative agent in an outbreak of a disease in

Japan now called "Yusho" or "rice-oil" disease, which stemmed from PC3-

contaminated cooking oil.—

          Thus, in a relatively short period of time,  a man made  comoounc

which was introduced into commerce for a relatively narrow  purpose,  a

contained use, was broadened through new applications and distributed into

the environment, and then discovered to be hazardous to  animals,  birds,

fish,  and man.

          In  1971, there was concern that  ?CSs apoeared to  be  an ever-

expanding problem whose potential  limits were  essentially unknown.—   Sy

mid-1971, Monsanto had  voluntarily terminated  sales of  Aroclors  (PCBs)

and polychlorinated  terphenyls  (PCTs)  for all but  closed electrical  system

uses.   At the  same time, Monsanto offered to  incinerate  all  liquid

waste  PCSs, and terminated  production of the  most highly chlorinated

Aroclors.-  •

           In  December  of  1971,  the U.S.  Qeoartment  of  Health,  Education,  and

Welfare convened  a two-day  open meeting  to discuss  the  widespread use  anc

dispersion  of ?C3s .   The  meeting  was  broadly attended  by scientists anc

administrators from  throughout  the world who  were  concerned with  this


          During 1972 and 1973, the Food and Drug Administration established

limitations on PC3s concentrations which were designed to eliminate the in;.

state transportation of a number of PCS-contaminated foodstuffs and the use of

PCB-containing food packageing materials.-  —

          In November 1975, EPA, in cooperation with other  Federal agencies,

held a National Conference on Polychlorinated Siphenyls  (PC3s)  which
discussed the latest findings about these chemical substances.-

          Limitations on discharges of  toxic pollutants  like  ?C3s  from

wastewater streams are authorized by Section 307(a) of the  Federal Water

Pollution Control Act (P.I. 92-500; 33  U.S.C. 1317(a)).  Such a limitation,

in the form of a standard, has been promulgated  for electrical  caoacitor

manufacturers and electrical  transformer manufacturers (40  C.F.R.  129,

published  in  the Federal Register on February 2,  1977  (42 FR  5532}).

           The discussion of the adverse environmental  and health  effects

of  ?C3s  contained  in the  preamble  to  those  effluent standards

is detailed and  inclusive.  That discussion  is  included  in  the  Apoendix

to  this  document.


]_/    USEPA  -.GTS.   ?C3s  in  the United States:   Industrial Use  and  Environ-
      mental Distribution.   Feb. 25,  1976.   Yersar,  inc.

2/    Hutzinger,  0., Safe, S.,  Zitko,  7.  The  Chemistry  of ?C_53_ •   137-1.
      CRC Press.

3/    USEPA-OSWMP.   Preliminary Assessment of QC3  Oisoosal  in  Municipal
      Landfills  and  Incinerators.   Uncatea.

 4/    USEPA  -OTS.  National  Conference  on  Polychlcrinatad  ::':neny's.  ')ov.
      19-21,  1975.   Chicago,  [11.   March  i975.

 5/    USEPA-OTS.   Micrceconomic  Imoact3 of the  P^ocosed  .Var'<:'ng  and  Oiscosa'
      Regulation  fcr PC3s.   EPA  560/5-77-013.  -cr-i i  1977.  Versar,  .nc.

6/   National  Swedish Environment Protection Board.  PC3 Conference 5eo.
     29,  1970.   Stockholm.   Dec. 1970.

7_/   Interdepartmental  Task Force on PCBs.  Polychlgrinated Biphenyls
     and the Environment.  May 1972.  Washington, O.C.

8/   Monsanto Co.  Presentation to the Interdepartmental Task Force on
     PC3s.  May 15, 1972.  Wasnington, O.C.

9/   US-DHEW, NIH, National Institute of Health Sciences.  Environmental
     Health Perspectives, Environmental Issue, No. 1, April 1972.

TO/  38 F.R. 13096 (July 6, 1973).



          The  proposed  regulations  cover:*   the  marking  of  newly

manufactured PC3s and PCS-containing equipment; and the marking, storage for

disposal, disposal, and recordkeeping requirements for existing PC3s and

manufactured items which contain PC3s.  The proposed effective date of these

regulations is January 1, 1978.  The SPA has funded an independent analysis

of the economic  impacts of these regulations.   The results of this study

were reported in the Task Report Microeconomic  Impacts of  the Proposed

Marking and Qi'soosal Regulations for PCSs.-   Limited numbers of this

report are currently available from the Office  of Toxic Substances, and

the report will  shortly be published through the National  Technical

 Information Service (NTIS).  The following paragraphs and  tables which

sutnmarize the estimates  of the economic impacts of the proposed regulations

are taken from this report.

          The Toxic Substances Control Act requires that PCSs not be used

after January 1, 1978, except  in a totally enclosed manner.  Electrical

 equipment manufacturers have indicated that there will probably be no

 PCS-containing transformers or large capacitors manufactured after 1977,

 and only  two manufacturers of  small capacitors  have indicated that they

may continue  to  use PCSs in their  products during 1973.  Therefore, the

 proposed  rules will have minimal impact on new  PCSs.

          The major impact of  the  rules will apoly :o the  owners and user" 3;

 currently operating ?C3 capacitors and transformers.  These  Persons will be

 affected  by increased costs due to the special  mark-ing, storage, disposal,

 and racordkeeping  chat *ill be reauired for tnis equipment.

 *  See Addendum

          For purposes of analysis,  existing PCS electrical  equipment

has been classified in accordance with the following categories:

          PCS transformers @:

                         2150  Ib PCSs
                         3000  Ib liquid
                         6500  Ib drained weight
                         40 year average life

          Large High Voltage Capacitors (LHV) (?:

                         25 Ib PCSs
                         120 Ib Total
                         20 year average 1 i fa-

          Large Low Voltage Capacitors (LLV) @:

                         3.5 Ib PCSs
                         20 Ib Total
                         15 year average 1i fe

          High Intensity Discharge Lighting Capacitors (HID) ?:

                         2 Ib PC3s
                         8 Ib Total
                         20 year average 1 ife

          Small Appliance  Capacitors  (SA) @:

                         1 Ib PC3s.
                         5 Ib Total
                         15 year average  1 ife

           fluorescent Lighting  Ballasts  (PL) @:

                         0.1 Ib  PCSs
                         3.5 Ib  Total
                         15 year average  1ife

          The  total  numbers of  electrical  items  containing  ?C3s  is sum-

 marized in  Table  -.
                                       1 7

 Disposal  Costs

           The estimated  amount  (in  pounds)  of  ?C3  electrical  equicment

 requiring disposal  in  1978  is  surnmarized  in Table  5.

           The proposed  regulation  requires  that  all  of  this  material  be

 incinerated  with  the  following  exceptions:

           Transformers  may  be  disposed  in chemical  waste landfills  if
           they  are  flushed  to  remove  at least  98"  of the ?C3s;

           Capacitors  may be disposed  in chemical waste  landfills  until
           July  1,  1979;

           Small  aopliance  capacitors and fluorescent light  ballasts  in
           private  residences may be disposed in  sanitary landfills;  and

           Small  capacitors  (including fluorescent  light ballasts  and
           HID capacitors)  need  not  be removed  "rom equipment wnicn  is
           disposed  in  sanitary  landfills.

           Because  of  the higher costs of incineration,  it may be  assumes

 that few capacitors will be incinerated until  after July 1,  1979.   rne

 uoper estimates of  incineration requirements are snown  below in ocf'on  1

 wnicn assumes  tnat  all  PCS-containing caoacitors are removed from ec
                                                     TABLE  4

                                            Hmnbar of PCU Itana  Jn  Servlco
Transformers IJfV
04,000 7,600,000
20,000 400,000
140,000 0,000,000
500,000 5,000,000
25,000,000 50,000,000

                          TAULE  5

Diapoaal Requlruitintu for PCD Electrical Equipment  in  1978,
                     mllliona of. pounds
Sourcxs pen Liq. Solvent Trans.
Utilities 6.3 4.7 13.6
Ollaixjo Ileaidential 2.1 1.6 4.6
and Cumtircial
Jnduu trial 2.1 1.6 4.6
Private - -
'total 10.5 7.9 22.0
Flu Light
UIV Uallasta
2.4 29
40 170
Hi Intensity
Light Ball.
Large Low

differs from option 2 only in that it allows  the continued  disposal  of
fluorescent light ballasts in chemical  waste  landfills.
          The disposal  requirements after July 1, 1979,  are summarized
in Table 6 for each of these three options.  The disposal  requirements  are
expected to decrease by about 7 percent per year.  Only  5  percent of the
PC3s  presently in use will still  be in use 42 years from  now.
          The effect of the various options on the disposal of the PC3s
is summarized in Table 7.

Chemical Waste Landfill Costs_
          There are sixteen landfill sites in the U.S. which have been
identified as secure or chemical wasta landfills by the Office of Solid
Waste,  EPA.  A preliminary survey  shows that fifteen of the landfills
will accept PCS-con-aminated solid waste such as capacitors and trans-
former  internals.  However, some of  the sites in California serve only a-
limited locale.  The sixteen sites are scattered throughout the country:
nine Class 1 landfill  sites  in  California-, one  in  Idaho; one in  Illinois;
one in  Missouri; one in Nevada; two  in iNew York; and one in Texas.  These
landfills  range  in  size from 32 acres  to 330  acres, with most  estimating
operating  lifetimes  greater  than  10  years.  There  are no Class 1  landfills
in  Puerto  Rico or  any  other American possessions or tarn tones.
           Costs  for  disoosal in chemical waste  landfills are highly variable
depending  on location  and  area  serviced.   Landfills in  California are
county  operated  to  service specific  nearly locales; they  impose  relatively
low charges  plus  additional  state  fees.  Sites  which  service a number  of

                                                          •mm E  6
                                       Annual PCft t/julpnont Disposal Requirauenta,
                                        after July 1, 1979;  iitLllioiui of pounds


              4.7       13.6

              1.6        4.6
Option I1
CM a-' Incin
Option 2a
Cwii;% Ine.in
2 - 47.0
3 - 60.2
4 - 25.1
4 - 0.511
3 - 132.0
Option -
100.3 4Q.9
25.4 10.1
155.3 59.0
73. U
SU-'   =  Sanitary I-andfili
CWII-'  ^  Clujiuical Waste
Incin =  Jncineralti
'inchwivalft all anoept  for retiidential.  SFF(reiiidtuiticil) : All except  10'i of large low voltaye
  cupucttor:; (MD'.UI run.,  air onnditioner, etc.)  icaioued  for replaeeiitait by service s
2.SU' --•  2/.i or l:lt»  liah  iiU^[)i>  (central air  oond. , nioloru, ate.)

                                                               TAIUIJ  7
                                           ial  of K.'H CU^nlcal ikihr.laitfx;  In K'.l\  I2i|ui|ii(int ,
                                             aftoi ,luly 1,  10/9:  million

I'll vat o


Sll-'    - iiiuillary l.uKlfl 11
UVIJ'  - tlMiiiUcal W.iiite landfill
1 nciii — liu:iin;i alti


1)1 H[X

CWir Iiyiln
nijjjiosal Option 2
Sir CMP Incln
0.00 - 9.74
J.J5 - 3.43
1.06 ~ 3.1U
4.12 - 0.1
9.3(1 16.45
(36i) (64%)
Disposal C\>tion 3*
sir Criie incin
1.40 2.03
0.29 2.89
1.69 14.76
(7*) (57%)
 Ini-'iiiei.iUi  all CXL.\J|)L for  itj.sl(Vy>l lal.
  Sili-' (ic.'iiiloaiial) :   Ml except 101 of laicjo lex; vollngo cra  (itntoc  nm, air
  tile.)  iiiiiD'jisl for  rcpliitxiiiLsnt ly  siuvlcxs  iilu.)i>s.
*!Jir:   2/3 ul  flu llijhL l^llnstu, 111!) and uiiall i>lityiiw,-o cai>acltor3
 iiicin:   All 111V and  laryo  I.Vil/3  (flu liijhla t 111!) I tiicoH a
'fill'':  tiUUi  ilil ({>!. i(>k 2
 iWi'i  1/3 flu ll«jl>l-  Ixillasls
 Iiicin;   Ml UIV and  larye  I.Vll/3  (1I1O I uiivil I appl.)

States'typically charge from $1.00 to $10.00 per cubic foot of material

disposed, excluding freight or State fees.  The lower costs are largely

found in California and the West where climate and soil type allow

location of Class 1 landfill sites close  to the counties which ara serviced.

The facilities in the East service the Eastern States and parts of Canada,

and must provide impermeable liners and more stringent monitoring and

leachata controls, thus making disposal more expensive.

          During 1973, 275 million pounds of capacitors and miscellaneous

equipment at 150 pounds per cubic foot, and 22.3 million pounds of trans-

formers at ICO pounds per cubic  foot may  require disposal in chemical

waste landfills.  This amounts to 1,320,000 cubic feet of landfill

capacity necessary for capacitor disposal and 223,000 cubic feet  for

transformer disposal.  These requirements will drop as land discosal of

capacitors is phased out during  1979.

          Total costs for chemical waste  landfill in  1973 ara  estimated at

2,053,000 cubic feet x 53.00 per cubic foot = So.17 million, olus trans-

portation costs of 50.02 pe^ pound (J.GO mile average  trip) x 293 mil "ion

1bs = 55.36 million.  The total  chemical  waste landfill disrosa" costs

will be  312.13  million.  However,  this method of disposal  is currently

specified by the American National Standards  Institute (ANSI)  voluntary

standard ror  'C3s  -, and is employed by  most utilities and large incus-

trial users.  Thus, as much as 50 million ibs of equipment migr.t :e

disposed of in chemical waste  landfills,  even if tnis  regulation ^ere not

prcmulgated.  The additional costs incurred cy the orooosed regulation for

chemical  waste landfill  therefore will  be less  than  S10 million  in  1973,  36  mil-
lion in 1979, and about one million dollars per year thereafter  under options
1  and 2,  since only transformers and containers (such as emcty drums) will
be authorised for chemical  waste landfill disposal  after July 1, 1979.
This projected demand for chemical waste landfill  is not expected to have
a  significant effect on either the availability or price of such service.
          Under option 3, chemical waste landfill  would be required by an
additional 393,000 cubic feet of fluorescent light capacitors,  increasing
the chemical  waste landfill costs to about 32.2 million per year.

Liquid Incineration
          Most DC3-containing'liquids are currently disoosed of by  inciner-
ation.  The major  incinerators ooerated  by Monsanto and the General  Electric Co
will cease operation before 1973.
          Chem-Trol  has a  patented  orocess of  disposal  of  ?C3s  by  mixing
?C3  liquids with waste solvents  and other  hydrocarbons  and using the
mixture as a  fue-1  in cement kilns  for the  manufacture  of special cements.—
A report  on  the  burning  of PC3s  in a  cement  kiln  of the St.  Lawrence
Cement Co., Mississauga, Ontario,  Canada,  is encouraging,  in  that  it has
been demonstrated  that the waste liquid  ?CSs  can be  ccmoletely destroyed
(greater  than  99.99" destruction efficiency) while,  at the same time,  the
KC1  liberated  in  the destruction reaction  neutralizes  undesiraole  excess
alkali in  the  cement oroduct.   This  liquid ?C3 waste  destruction acoroach
shows  great  promise  and  a  survey is  being  made by Versar  to  cetermine the
potential  use of tnis  process  in the  United  States.

          The Florida Power and Light Comcany has conducted tests to

determine the feasibility of PCS destruction in a power boiler.  However,

the results are considered preliminary.  According to a representative of

the company, combustion temperature and dwell time meet the proposed EPA

disposal regulations.

          A review of test data indicates that destruction of  liquid  °C3s

by co-incineration with sewage sludge is not desirable, in that the average

combustion temperatures achieved in this operation (950 degrees K,  150 degrees

F) are  insufficient  to insure 99.99% ?C3 destruction efficiency.-   Criteria

for destruction of  PC3s   in sewage sludge at levels of approximately 25  acm,

dry basis, are discussed  in the Federal Register of Thursday,  June  3, 1975,

Part  IV,   i F.P.. 22531).

          A total demand  for incineration of PCS-containing liquids, in-

cluding solvents from flushing of transformers,  is expected to be aoproxirrc

13,000,000 lb/'year (10,500,300 ib/yr of PCS liquids and 7,900,000 ib/yr of con-

taminated solvents).  Sufficient incineration capacity is available to -ancle this"

volume  of  ?C3s  at a cost of about 30.15 per oound, oius perhaos an additional

30.15 oer ocund  for  containers and transportation, for a total economic

imcact  of 35.- million per year.  However,  since tne costs of  disposal of

the  PC3s  would be incurred by industry ooerating  in accordance with the

ANSI  standard, they  cannot be attributed to  the  requirements of  *ne orccosec

regulation.  Total costs  of liquid incineration  due to t.ie regulation *i':~

therefore be accroximately 32.2 million per year scent to  incinerate tna

contaminated solvents resulting from flusning transformers to  recuce tr.ai-

content of  ?C3s  bv  98% orior to discosal in cnemical waste ' ar.cf"'' 1 s.

Solid Waste Incineration

          Versar estimates that beginning in the middle of 1979, between

74,000,000 and 253,000,000 Ib per year (see Table 6} of capacitors containing

PC3s will have to be disposed of by incineration in the United States,

depending on the final PCS disposal regulations.  The following section

sunmarizes information of the technical and economic factors which can

affect disposal of these materials in light of the proposed new incineration

regulations .'

          Sased on the latest -PA national  survey of cotnnercial hazardous

waste incineration facilities, there are approximately twenty  liquid waste

incineration operations which will net or do not have  the capability of

handling  solid PCS wastes.  There are  three installations which presently

have  the  capability of handling both solid  and  liquid  PCS-containing wastes

and which  have the presently  required  environmental aoprovals.  Additionally,

tnere are  two  installations which  have liauid PCS  incineration capability

and one  installation  with both solid and  liauid  PCS waste  incineration

capability which  are  awaiting  state operating permits.   There  is  one  facility,

presently shut down,  which  has state authorization  (as of  1974)  to  dispose  of

liquid  PCS wastes.  The  two  liquid  PCS waste  incineration  operations

carried  on by  industry  -- General  Electric  at Pittsfield,  Massachusetts,

and  Monsanto  at  Sauget,  Illinois  — will  be shut down  well  before the

prooosed disposal  regulations take  effect.

           The  three currently operating  incineration  facilities with  botr,

liquid  and solid  PCS  disposal  capabilities  are  all  owned by Sol!ins

 Environmental  Services,  Inc.   These  units  are  .ocatec  in Logan Tcwnsr.ij,  '<.•„'.;

 Baton Rouge,  Louisiana;  and Houston,  Texas, anc eacr,  serves a  five  to  six

stats area.  Data from a recent cast burn of shrsddad capacitors at  the

Houston facility indicatad chat this unit processed approximately  7CO-3GO

pounds per hour of shredded capacitors containing 20"  PC3s .  This burn

resulted in a PC3 destruction efficiency of greater than 99.99".-    The

residue from the burn contained approximately 0'. 1 ppm  PC3s.  Total  dwell

time was 2.5 seconds and combustion temperature  ranged from 2,000 tc  2,400

degrees F.  Number 2 fuel oil was  used for a heat supply and  a  fuel  oil/

solid ?C3 waste ratio of aporoximately 1.3 gal.  oil/lb  solid  PCS waste

was required.  A test burn was also conducted on whole  cacaciccrs.   PCS

levels in  cne gaseous emissions was less than 3.001 gm/!
 containing activated carbon treatment.  Equipment  for this purpose would
 include a fixed bed system containing activated carbon and suitable
 filtration equipment to  remove  particulates  from  the  feed  to  the  carbon bee.
 The spent carbon would be  incinerated in  the  rotary kiln unit  after
 suitable dewatering.
          A preliminary  estimate for the  cost of a  complete shredded
capacitor disposal  unit  based on the Houston design is  $5.0 million
installed.   This unit is believed by Rollins to be  capable of processing
3000 Ib/hour of shredded capacitors.  The same unit could handle 500-1000
Ib/hour of liquid PCS wastes as a blend in the fuel feed to the incinerator.
A breakdown of the investment cost for the dual purpose unit is shown in
Table 8.  The annual casts of operation have been determined based on data
from the Houston facility test burn of shredded capacitors and  engineering
estimates, and are tabulated in Table 9.   All costs are shown in 1S77
          The unit cost of  52c/lb for solid and liquid PCS waste disposal
reoresents an uoper limit for  this  cost.   The major cost  item  involved,
fuel, can be averaged down through the use of  inexpensive waste  solvents
which are currently used  by the  commercial  incineration facilities.
          The total annual  operating costs  for  PC3s disposal  by  inciner-
ation,  depending on the final  EPA disposal  regulations, are tabulatac  in
Taole 10.
          3ased  on  the  estimated  national  distribution of  solid PCS
wastes,  a preliminary assessment  nas been  made  of  the  aoorooriata  cistri;-
ution of the new incineration  facilities which  woulc De neecec  in  1379.
This distribution  is  tabulated in Table  11.

      TABLE S

"prfn-*—I <-»»-'  t*sr*--ir«jaf «k r;r a rX"*"-3 1  "^"l
*^.-™. _Q—,**«  ^-...ij *-iinjiji.- *• 'C— >-™—. V^ *> ti W^Sii'il.inijtl  — <-M
         ?lait£ Cacacity:   3000  Lb/hr sarscdad rC3 cacadtcrs
                            500 ib/nr ?G2  liquids
C ^*^lf-*f
     ""'"-• ••"', H-eis a^d Fiit^rat^icn.  3vs"c
Pi^i-r^ and  VaJLvss  5  25%
  nt-ir.car.cv •* 201
                                       Insrglled Cc


                                             270, COO/
                                           4,1,45, COG

                          TABLE 9
   Annual Ccaratirc: Costs far ?C3 Capacitcr Ir.cir.eraticr.

Plarrt_ Capacity :   3,000 Ib/hr of shredded PCS capacitors
                    500 IVbr of ?C3 -liquids
Cceratir.c Factrr ;  7300 hcurs/yr
Capi4-*! Irvestrrar.i:;                                       55,000,000
VarJRble .Casts
Fuel Oil  (J2)  21,900,000 gal,  @  40C/cal                   3,760,000
Diracr Cpsrati^c1 labcr, 2 rr^rV shift. § 53/hr                 137,000

Activatsi Caricr. Systan                                      122,000
ifei^tananca § 20% cf capital inveswssr.*                   1,000,000
PCV.HT, 100,gjDO k-^h « 3c/kwh                                   3,000
Secslisj  and Analysis                                        100,000
       Dispssal, 5,000  T?Y   8 S10/t=n                         90,000
                             T^stal Variable Ccs^s         10,311,CCC

                            TA8LE 10
E?A Cstlcn
tttal Annual ?C2
+»*^ Tr»£«-i •* 
Naticnal Diitr-iixrricn
                            TABLE  11

                             cf ?Os Ircineraticn FacHici
Tfetal Kb.  cf
                      No.  of
                        ^s Facilinss
* Nurisr c^

                                                          XS-I  CT 1 * '
                                                          k">^ .  "  1  II *

                                                          So* Calif.

                            « 1

                            Ml 1

                            _ T_

                            - 1

                            _ 1
                                                               Arkar-sas   - 1
                                                               /",i ; .*,.,_,• .,  „ i

                                                                      _ 1
                                                                 ,1 ,• J	; , . i


          Incineration costs would be reduced somewhat by operating fewer
but larger incineration plants.  However, reduction of the number of incin-
erators would increase transportation costs for waste  PC3s .
          It is estimated that the net effect on the labor force starting
in 1979 (after aliminating the labor needs of chemical landfill  operations)
would be an increase of Q-3Q jobs, depending on the final PCSs  disposal
regulations adopted.

          For distances averaging 400 miles and for truck loads or less-
than-truckload shipments from 500 Ibs uo, shipping costs for PCS-containing
equipment may vary from 3.Q15/lb to  3.05/1-b.  At greater or lesser distances
costs vary proportionately to mileage.  Since lesser distances are associat
with larger waste amounts (because incinerators are located near centers of
population),  5.05/10  is a safe upper limit for costs of transporting PC3-
containing products and mixtures.  At 300 million Ibs/year the total trans-
port cost would be 515 million.
          3y establishing storage at user sites ana/or at intermediate
collection centers, i; would be possible to lower the sum of extra storage
and transport costs below this upper bound but not drastically, unless a
number of new incinerator sites are  optimally located.  The siting of new
incinerators would .^-cuira the further trade-off between caoita" recovery
costs of the incinerators and  transoortation ccst reductions.  Several
additions beyond  trie  tnree incinerators tnat accent bctn solid and liquid

PCS waste now in operation may be required to handle the annual  disposal
of materials containing ?C3s .
          The construction of additional  incinerators would make the
assumption of a 400 mile average trip very reasonable and would push the
S.OS/lb maximum for transportation costs  alone down to the 3.03 level as
an upper limit, but would do so at the expense of greater capital recovery
costs for the new incinerators.  New incinerators will require at least a
year to construct after all approvals are obtained', however, certain
existing incinerators might be modified to handle  ?C3s  at lesser caoital
recovery rates.
          Although incineration of  ?C3s  will be a declining business because
of the elimination of the  source of new  ?C3s  , investment  in incinerators
that can handle  PC3s  as well  as other toxic  substances should be an
attractive  growth business, because more  and  more  chemicals  in industrial
use are  proving  to be toxic and may require  incineration under similar
conditions.   Investment  in  incinerators with  capabilities  to recover
copper and  other metals  from  transformers will become  increasingly  attractive,
because  of  the  increasing  costs of metallic  resources.
          Net transportation  costs will  depend upon  the particular
response of industry  to  the  requirements  for  incineration  capacity,  but
S.05/lb  for transportation  costs  seems to be  a reliable uoper  limit  wit.n
attractive  trade-off  oossibilities  for net  reductions  in  total  costs.
                                       o i

          Because of the potential for accidental spills of ?C3s  during
decontamination and resultant liability, we do not foresee widespread use
of this alternative disposal method.  There will be some need for decon-
tamination of tank cars, tank trucks, and production machinery as produc-
tion of new  ?CBs is phased out.  This will not be a major economic
impact.  Any decontamination performed after this initial period may
result in a slight decrease in the costs shown for incineration, but the
effect is not expected to be significant because the decontaminating
solvent will require incineration under the same kinds of conditions.
          Effective decontamination of drums and small containers has
been reported for pesticides  by  triple rinsing of the containers with
solvents which contain less than  0.05% of pesticide but have a solubility
of  5*  or more  for the pesticide,  tach  rinsing uses a volume of solvent
approximately  10% of the volume of  the  container, and the rinsing must be
accomplished by  repeated contact  of  the  internal surfaces of the container
with the solvent.   The efficiency of decontamination depends in part on  the
degree of  solvent contact and on  the condition of the container surfaces
being  cleaned.   After each  rinse, the solvents are collected and incineracad.
This procedure  is believed  to be  readily adaptable for ?C3 containers.
          Complete  decontamination of askarel transformers does not apoear
feasible because of their cesign.  However, a hi en degree (greater than
98%) of decontamination of  askarel transformers which are being taken out
of  service  is required.  This can be accomplished by thoroughly ariining

the askarel  fluid from the transformer, followed by refilling and re-
circulating for several hours with a solvent such as mineral spirits.  The
solvent is then drained and incinerated.  Preliminary results of a test
which was performed by Westinghouse for the Federal Railway Administration
and based on the above procedure show a 99" reduction in the quantity of
PCBs  in the transformer.  Transformers so treated may then be disposed of
in a chemical waste landfill.
          Askarel transformers which are kept in service, but retro-filled
with a silicone or other oil, should be thoroughly drained  of askarel oil
prior to refilling with replacement oil. Subsequent drain ings and refill ings
of such transformers will require treatment of  the previous retro-fill oil.
In the case of silicone oil, Oow Corning reported  that treatment with
activated carbon will  remove the  PC3s   and permit  reuse of  the oil.   In the
case of mineral oil, the  initial retro-fill must be incinerated.  Subsequent
mineral oil  retro-fills must also be incinerated if the level of PCS  is
greater than 500 ppm.

Storaae  for  Oisoosal
           When  this  regulation  becomes  effective,  large  costs  will  be
 incurred  by  several  categories  of  industrial  and  coranercial  users  of PCS
 capacitors.   Each  commercial  or industrial  building  (or  complex),  and  eac.i
 repair center will  be  required  to  establisn a special  storage  center  for
 PCS  articles.

          Most such storage areas will  be quite small.   These will  be

required by the proposed regulations for office and commercial  buildings,

electrical repair shops, and small industrial  operations to store the

small  capacitors and fluorescent light ballast which are removed during

normal  maintenance.  Such storage requirements for large buildings, or

complexes operated by one real estate manager, will be significantly larger.

For instance, the World Trade Canter in New York City has 250,000 fluorescent

light ballasts; replacement of failed ballasts .nay result in the requirement

to store several hundred ballasts per week prior to disposal.

          If the small storage areas for accumulation of small  capacitors/

ballasts are indoors and accommodate only one 55-gallon drum at a time,

no special flooring, diking, or  recordkeeping  will be required.  The cost

of establishing such an area will be the cost of procuring a DOT Spec 5,

58, or  17C opanhead drum, marking the drum and the area, establishing a

local  policy, and policing the collection and storage of the units.  Total

costs will be about 310 (one man-hour) for drum labeling and setting up anc

maintaining  the storage location; 325 for the initial purchase of one drum-,

and SI 5 per year for purchase of a statistical 0.5 of one drum  in sub-

sequent years;  330 for  first year administrative expenses; and 350 for

subsequent years.  The  small area required by one drum (about 10 sq. feet)

will require a  non-cash allocation of about 330 per year (S3 per sq. footN

for equivalent  rental value of the soace.  Thus, individual costs "or s.~a:'

storage areas *culd be on the order of 31^5 for the first year and less -or

subsequent years, approximately  3105 per year.

          Special  indoor storage facilities which may not now exist will

be required by utilities and large industrial  and commercial  building

complexes which may store quantities of used capacitors or repairable

PCS transformers.   Such storage area will require impermeable floors and

dikes.  Two thousand such areas, utilizing about 200 sq. ft.  per area,

would require engineering and construction costs of about 32,000 each

for modification of existing storage areas.  Equivalent rental costs of

S3.00 per sq. ft.  still apply, and drum costs would be about 3225 per

year.  Labor costs are estimated at 31,000 per year, and administrative

costs at 3300.  Indoor storage costs will  total about  34,125 for the first

year, and 32,125 in subsequent years.

          Major facilities, devoted only  to the repair of PCS transformers

are expected to be far fewer  (probably about 20), and  are believed  to be

in existance.  Therefore, we  do not believe that any further economic

impact for  such facilities  will result from the proposed regulation.

          Total estimated costs of  storage areas will  be:

               First year:

               Small 3145 x 1,000,000  facilities =  3145,000,000

               Large 4,125  x  2,000  facilities    .=     3,250.000

                                  Total             3153,250,000

               Succeeding years:

               Small 3105 x 1,000,000  facilities =  3105,000,000

               Large 2,125  x  2,000  facilities    =     ^,250.000

                                  Total             3109,250,000

          The proposed regulations specify marking of both new  PC3s  and ?C3
equipment, and of existing  PC3s .   The impact of the regulations on the
manufacturers and users of new  PC3s  and new PCS equipment will be small
because the amount manufactured after 1977 will be small.  The  two capacitor
manufacturers who have indicated that they may continue  to make ?C3 capacitors
in 1978 will be faced with about $25,000 in tooling costs to mark the
capacitors, and the equipment manufacturers who use these capacitors will
also be faced with some marking costs.  The total economic impact of the
marking regulations on the manufacturers of electrical equipment should be
less than SI00,000, as summarized  in Table 12.
           The major costs of complying with the proposed- marking regulation
will be incurred by the users of existing ?C3 electrical equipment.  The
costs of  complying with the  proposed marking regulations can be divided
into two  categories:   (1) the cost of the specified labels, and (2) the
costs of  applying the  labels.   The estimated upper bound costs  of complying
with the  proposed marking regulation are summarized in Table 13.
          Estimated label costs are based upon manufacturers'  retail prices
for  lots  of  1,000.  Unit costs  for labels will be extremely small if aju
labels  are manufactured by a few companies rather than many; i.e., the
economies of  scale will give rise  to decreasing average  costs.  Costs
associated with applying  the labels, transportation and  labor  costs, are
maximum estimates based on a full-time labeling program.  Such  costs will
be  greatly  reduced  if  users'  ?C3 electrical equicment  is marked during

                                TABLE 12
            Electrical Equipment Manufacturers'  Total Marking Costs
                      For the Year Ending Decercer 31, 1978
                                    (in collars)
                              Label Costs
   Large Capacitors
  v Articles
 _-w Ecuipirsnt
                  and Labor Costs
Storage Areas

    Table  13
Electrical Ecuianent Users'  Total Marking Cos
     for the Year Er.dir.g Cecsnier 31, 1373
                  (in (dollars)
             Label Ccsts         and Later Costs
fTHT. ,>•!«»<.
rr-r-t-a •» rn»r-s
Storage Areas
Large Low Voltage
Large High Voltage
PTH Capacizors
Storage Araas
Large Lew Voltage
Large High Voltage
cm casa/r — ^
Storage Areas
Large Low Volcage
Large High Voltage
HID Capacitors
760, 000 )
10 , 300


5,25= ^05.

• -o-
: c

routine maintenance operations.  For example, it would be more economical
for a utility company to have its crews mark the various units during tneir
routine visits to substations for periodic checks, servicing, monitoring,
etc., rather than sending crews- to equipment sites for the sole purpose of
marking PCS electrical equipment.
          Several utilities have suggested that, additional labeling of
transformers and large high voltage capacitors presently in service will
not result in improved spill handling.  They claim that their present
procedures and policies have been adequate in the past, and that continuing
education would enable employees to recognize PCS units even  though the
units will not have a standard identification or warning label.  It is
difficult to judge the effectiveness of such a program over 40 years, at
the time when PCS units become rare in service.  However,  if  satisfactory
spill response could  be assured without special labeling,  the application
of the labels could be delayed until PBC  transformers and  capacitors are
removed from service.  Table 14 summarizes total marking costs under this
scenario.  This  revision of  the proposed  regulation  would  reduce users'
1978 marking costs by approximately 48.2  percent.

Records and  Monitoring,
          The  recordkeeping and  monitoring  costs  for incinerators  and
chemical  waste  landfills have  been  implicitly  included  in  the estimated
^disposal  costs  for PC3s  by those  methods.  The  proposed regulation  does
not  impose  any  record keeping  requirements  on  the  million  small  storage
areas  which  handle only  small  capacitors.

                TA8L£  14

-*--.-]/-ar Squi-msn-e Users' total Marking Casts
fas ths Year" Ending Cecsnfaer 31, 1373*
              (in dollars}

Storage Areas
Large Lew Voltage
Large High Voltage
Trans fcsners
HID Capacitors
Storage Areas
Large Low Voltage
Large High Voltage
E2U Cacacitars
Storage Areas
Large Lew Voltage
Large Sigh Voltage
HID Capacitors
*Cose estimates are based en
(e-un-i-f ia.1 \ e* i Sf-rKJi 1 ,
Lata?I Casts
. 13,500
the assurnticn, that lar
a.pti tait-'l -parrerjiM f-~sa.

and Labor Casts
• -o-
ga casacitcrs and
ser/ica and hance
126, 4&v.
trans farrsrs
gathered fcr

          The 2,000 large storage areas will  be required to maintain a
perpetual  inventory of all  items or containers in storage.  Since the
record for each item must include its weight, origin, and date of entry
into the area, clerical costs of perhaps two dollars per item might be
expected in addition to a cost of $200 per area to establish the record-
keeping procedures.  It would therefore be expected that initial costs  of
$400,00]plus- an additional  one million dollars per year associated with
large capacitors and transformers and an additional one million dollars
per year associated with containers might be expected.  In addition, the
reports will require about one man week per facility or $2,000,000  total).
Thus, total  recordkeeping  costs for storage areas might reasonably be
estimated at $400,000  initially, plus $4,000,000 per year  thereafter.
          In addition, owners of transformers and  large capacitors  must
maintain records as to their location, estimated date of retirement, and
date of disposal.  Based on a current usage of 140,000  transformers and
8,000,000 large high voltage capacitors at 400,000  locations, and assuming
a cost of $5 per transformer or capacitor location,  the initial record-
keeping costs may  be expected to be  $2,700,000 the  first year,  with
record maintenance and reporting costs of perhaps  an  additional million
dollars per year.
          Total  recordkeeping  costs  are  therefore  estimated  at $3,100,000
initially plus  $5,000,000 per year.   This will result  in an  equivalent
increase  in clerical employment of over 300  jobs.   The  costs  will be
widely  distributed among utilities and  industrial  concerns,  and should
have little imoact on  prices or market  structure.

Summary of Economic. Impacts
           Estimated capital costs and annual operating costs are summarized
in Table 15.  The capital investment requirements of the proposed regulations
as written are estimated to be about $15 to $45 million for incineration
facilities and $4 million for storage facilities.  These requirements
would be reduced to $5 million for incineration facilities if the less
expensive options identified in this analysis are adopted.
           Annual operating costs for disposal, transportation, record-
keeping, and marking, in accordance with the proposed regulation, are
estimated to be from $54.3 million in 1978 and from $97 million per year
thereafter.  In addition, annual operating costs of storage areas are
estimated to be $149 million in 1978 and $109 million in 1979.  If the
suggested lower cost disposal and marking options were adopted, operating cr
for disposal, transportation, recordkeeping and marking would range from $3b.
million to $45.3 million in 1978 and from $53 million to $55 million in 1979.
The total operating costs will decrease approximately 7% each year after 1979.
           The proposed  regulations will not result in a significant increase
in energy demands.  Even if all the incinerators were fueled with ?2 fuel oil,
and the kerosene or fuel oil used to flush the transformers was not used to
fuel PCS  incinerators, the  total energy demand would be equivalent to about
20,000 barrels of oil per day.  This is significantly below the trigger •
level of  25,000 bbl/day  which is considered a significant energy demand.
           The regulations  do not directly have any significant effect on
the supply or consumption of any strategic materials.  However, strict:


                                  Table  15

              Sunnary of Economic Impacts,  Millions of Dollars
                                       Canital Costs         Annual Cseratlr.? Costs

                                                             1978        1979 and late:
   ipj-sri i Cpticn 1
   Incinerator                                45
   Chem Waste IT                                               51
   Incineration      .                                                         134

Disposal Cpticn 2     (Probable response to proposed regulation)
   Incinerator                                IS
   Chem Waste IP                                               51
   Incineration                                                                 S9

Disposal Option 3(  '

   Incinerator                                 5
   Chem Waste LF                                               52
   Incineration  '                                                               39

V  _,osal Transportation

   Cpticn  1                                                   IS                15
   Cpticn  2,3  (Probable response to proposed regulation)      g                 8

Secord Keeping                                                 8         .        4

   New PCHs                                    0.1
   Existing  ?C2s
      Option  1      (Proposed  regulation)                       33.3               5

      Cpticn  2(5)                                              17.3               5

                                              4              149               109
 (1)   Inci.i.  all
 (2)   2/3 srall cap.  to 3LF
 (3)   1/3 of n. light Ballasts to GOTT
 (4)   all initially
      when reicved fron service

controls on the disposal of transformers may discourage development of
reclamation technology for the copper in transformer windings as the GE
incinerator will shut down soon and there are no others able to handle
copper windings.  Mot all transformers have copper windings; many of the
newer transformers use  aluminum conductors.  There are an estimated
100,000 copper/askarel transformers in service, each containing 1,000
pounds of copper.  The disposal of these transformers over 40 years
would result in the loss of 2,500,000 Ibs of copper per year into land-
fills rather than into reclamation systems.  This is considerable less
than 1% of the  total amount of copper reclaimed each year in the U.S.
and is an insignificant portion of the total amount of copper consumed
each year.
          The impact of the regulations on any specific industry will be
proportional to the amount of electricity used, except for electrical
contractors, transformer repair shops, appliance reoair shoos, etc.
          The proposed regulations will result in substantial compliance
costs for the electric utilities, as this industrial segment has the most
intensive use of PCSs  capacitors and transformers.  The utilities would
generate about  353 of the demand for incineration of  capacitors   (see
Table 15, disposal option 2)  resulting  in a cost to the utilities of 527
mill ion per year.
           In addition, much of the cost of complying with the record"
keeping and marking requirements will be incurred by the utilities.  Total
attributable costs to the utilities may be  in  the range of $30 million per

year beginning in 1978.  The costs will be included as a component of the
cost basis on. which the electric rates are established by State regulatory
agencies and will therefore be recovered from the consumer of electric
power.  Based on total annual U.S. electrical sales of $53,462,864,000 in
1976, the proposed marking and disposal regulations will cause an average
increase in the  price of electricity of about 0.06 percent.
          Among  small business, perhaps as many as 20 transformer repair
businesses wi-11  either have to stop handling askarel transformers or  install
special diked work and storage areas.  Because most askarel  transformers
are handled by GE and Westinghouse and because most transformers  are  oil
filled, there should  be little loss of business even  if  the  small  indepen-
dent  repair shops stop servicing  askarel transformers.
          The regulations may  result  in the  development  of collection and
storage services to  reduce  storage and transportation charges  from  numerous
small  generators of  PCS wastes.   This  would  result  in increased  business
opportunities for numerous  small  labor intensive  service businesses,
resulting  in  an  increase  in  small  business opportunities and employment.
           Conceivably the  incinerator business  could  be  dominated by
Rollins,  which  has  a sister business  in  trucking, Mack!in Trucking.
Mack!in  or Rollins  might  very well  franchise collector  and  storage oper-
ations in areas  that Macklin  and  Rollins  could  service.   This would also
 increase  small  business  opportunities by  making regulatory  expertise
 available to  small  operations.   Rollins  could thus  be more 'confident  of
 a steady supply for their incinerator business  and  be more  willing to
 undertake the investments required for new sites.

V   USEPA-OTS.  Microeconomic Impacts of the Proposed Marking and Disposal
     Regulations for PCB's.  April 1977.Versar," Inc.

21   ANSI.  American National Standard Guidelines  for Handling and Disposal
     of Caoacitor-and Transformer-Grade Aska'reIs  Containing Polychl'gr'inatsd
     Slohenyls.  ANSI-C107.1-1974.

3/   McCord, Andrew T., et al. Chemtrol, U.S. Patent 4,001,031.
     Jan. 4, 1977.

4/   USEPA.  Destruction of  Polychlon'nated Biphenyls in Sewage  Sludge
     During.Incineration.  NTIS PB 258 152 1976.   Versar,  Inc.

5/   USEPA-OSWMP.  PCS Capacitor Burn.  Unpublished report.

           The Economic Ana-lysis presented in the Support Document for
PCS Rulemakino does not fully reflect the regulation as proposed.  The
Versar study Microeconomic Impacts of the Proposed Marking and Disposal
Regulations for PCBs evaluated certain regulatory options that
included disposal requirements for some or all fluorescent light ballasts.
The Versar study indicated, however, that much of the economic impact of
the draft regulations was due to the storage of fluorescent light bal-
lasts prior to disposal.  In addition, due to wide dispersion of these
items of.PC3 equipment, over 1,000,000 building maintenance and service
organizations would be affected by regulations requiring  special storage
and disposal by  incineration or chemical waste landfill.  While recognizing
the importance of the magnitude of the PCB problem contained  in fluorescent
light ballasts,  the EPA concluded that special requirements for  fluorescent
light ballasts could not  be practically enforced and deleted  those  require-
ments from  the proposed  regulations.  The  estimated  total costs  of  comply-
ing with  the  revised regulations were therefore  lowered.
            The capital  costs  associated with  compliance are now  $9.1  mil-
lion  (from  S19.1  million)  as  a  result of  a two-thirds  decrease  in tne
needed  incineration capacity.   The  incineration  capacity now  required is
the  same  as that required in  Option  3, where  none  of the fluorescent light
ballasts  go to  incineration.   The  capital  costs  are broken  down  as
 follows:   $5 million  for new  incineration capacity,  $0.1 million for
marking equipment and  labels,  and  $4 million  for the required storage

          Operating costs associated with compliance in 1978 are expected to
total not more than $58.3 million.  The decrease from $203.3 million is due
entirely to revision of the costs of providing storage prior to disposal.  The
lower cost is the result of having no storage requirements for fluorescent light
ballasts, eliminating all of the "small" storage facilities and therefore
reducing costs by $145 million in 1978 (see Storage for Disposal in this Support
Document).  Annual costs are broken down as follows:  $5 million for chemical
waste landfill changes, $8 million for disposal transportation charges, $8 million
for recordkeeping, $33.3 million for marking, and $4 million for maintaining
storage facilities.  Note that 1978 marking costs are probably conservative
since a small portion of those costs are associated with fluorescent light ballasts.
           Operating costs  in  19/9 are expected to  total $61 million.
The decrease  from $196 million  is due to  the elimination of  storage  costs
from  "small"  storage facilities  and a reduction  in  incineration charges
($30  million).   As with  capital  costs, the  incineration  charges will be
the  same  as  for  Option 3  as  presented in  the Support  Document.  The
costs in  1979 include  $1  million for chemical  waste landfill charges,
$39  million  for  incineration charges, $8  million  for  disposal  transporta-
tion, $4  million for recordkeeping,  $5 million for  marking,  and $4 mil-
lion  for  storage.   After 1979,  annual operating  costs  are  expected to
decrease  approximately 7 percent per year as  PC3s  are removed  from service.
            These cost  estimates  are  conservative.   The actual  reduction
 is  likely to be  somewhat greater than  that discussed  above because trans-
 portation and recordkeeping costs, which  are not included  in the  above
 analysis, will  also decrease as a result  of less  flow of material  to
 incineration facilities  and the consequent lessening  of transportation
 costs and recordkeeping  requirements  for the facility operators.

      A.   Proposed Regulation
              Part 761  - Polychlorlnatad Biphenyls (PCBs)
      8.   Support Documents
              PCS Marking and Disposal Regulations - Support Document
      C.   Public Comments
              State of Wisconsin/Department of Natural Resources   Dec. 20, 1976
              Mobil Oil Corp.                                      Dec. 27, 1976
              American Electric Power Service Corp.                Jan.  6, 1977
              Dow Corning Corp.                                    Jan. 18, 1977
              Lorraine Pappas                                      Jan. 19, 1977
              ACBE Comment                                         Jan. —, 1977
              General Electric Co.                                 Jan. 19, 1977
              General Electric Co.                                 Jan. 21, 1977
              Edison Electric  Inst.                                Jan. 28, 1977
              Westinghouse Electric  Corp.                          Jan. 28, 1977
              National  Fisheries  Inst.                             Jan. 28, 1977
              Environmental  Defense  Fund         .                  Jan. 28, 1977
              Mallory  Capacitor  Co.                                Jan. 31, 1977
              Prodelec                     '                        Jan. 31, 1977
              Japanese  Materials                                   Feb. —, 1977
              State  of  Michigan/Department of  Natural  Resources    Feb.  1, 1977
              deary,  Gottlieb,  Steen 4 Hamilton                   Feb.  4, 1977
              Stripers  Unlimited                                   Feb. 21, 1977
              Monsanto  Co.                                         Mar.  3, 1977
              Department of  Water and Power,  City of Los  Angeles   Mar.  3, 1977
              The Institute  of Electric and Electronics
               Engineers, Inc.                                      Mar. 18, 1977
               FMC Corp.                                            Apr. 25, 1977

01 W ST SW /To-/    Documents Submitted at Public Meeting, January 24, 1977

          '3Q44       statement of Judy Good, La Lache League International.

                      Testimony-of Lee R. Ivey for USEPA Public Hearing on PCS
                     • Disposal, Washington, O.C., Jan. 24, 1977.

                      Statement of Lyle R. Salmela, Northern States Power Co.

                      Statement for Public Meeting by David Usher, Marine
                      Pollution Control, on behalf of Amcord, Inc.

                      Comments by American Federation for Labor and Congress of
                      Industrial Organizations Dealing with Proposed Rule
                      Making by the Environmental Protection Agency on Disposal,
                      Labeling and Use of Polychlorinated Biphenyls, Jan. 24,
                      1977.  Submitted by Russell M. Bargmann.

                      Comments Related to Marking and Disposal of PCBs Submitted
                      by N. Ray Clark, on behalf of PCS Ad Hoc Committee of
                      Electronic Industries Association.

                      List of Attendees

           0.   Publicly Announced Meetings or Hearings

                1• Public Participation Meeting, December 20, 1976


                   41 F.R. 53692, December 8, 1976.  "Polychlorinated Biphenyls
                   (PC8s):  Formation of PCS Work Group; Notice of Public Meetings;
                   Solicitation of Comments."

                   USEPA.  Stenographic Transcript of Hearings in the Matter of
                   Polychlorinated Siphenyls:  Panel Discussion.  December 20, 197a
                   Washington, O.C.

                   Documents Submitted at Public Meeting, Dec. 20, 1976

                      Submittal of John Hess, Michigan Oept. of Natural Resources

                      Submittal of Andrew Melechinsky, Tivian Laboratories,  Inc.

                      Statement of Nathan Ray Clerk, Universal Manufacturing Corp.'

                      Sufamittal of J. Coleman Weber, Monsanto Co.

                      List of  Panel Members

                      List of  Attendees


2. Public Participation Meeting, Monday, January 24, 1977


      42 F.R. 1067, January 5, 1977.  "Polychlorinated Biphenyls
      (PCBs):  Rescheduling of Public Meeting."

      Polychlorinated Biphenyls (PCBs):  Public Meeting;
      Solicitation of Comments.

      USEPA.  Stenographic Transcript of Hearings in the Matter of:
      PCSs Public Hearing.  Use, Labeling and Disposal of
      Polychlorinated Biphenyls.January 24, 1977. Washington,

 3. Work Group Meetings

       This file contains Agenda,  Minutes, and all pertinent material
       of PCB Work Group Meetings.

       a. Non-Federal Reaister EPA Statements
          USEPA.  Polychlorinated Biphenyls (PCBs) Schedule for

          USEPA.  Polychlorinated Biphenyls (PCBs):  Regulation
          Outline.  PCB Interagency Meeting.  February 10, 1977.

          USEPA, Toxic Substance Section.  Polychlorinated Biphenyls
          (PCBs) Regulation.  March 1977.

       b. Communications

          Intragovernment memoranda, letters, and other correspondence.

          Other letters.

 4.  Reports

          ANSI.  American National  Standard Guidelines for Handling  and
          Disposal of Caoacitor-and Transformer-Grade Askarels  Containing
          Polychlorinated Bipnenyis.   ANSI-C107.1-1974.

          ANSI.  Letter Ballot on Approval of^Revision of ANSI  Publication
          C-107.1-1974 - Guiaellnes for .Handling and Disposal of  Capacitor"-
          and Transformer-Grade-A-Askarels Containing Polychlorinated
          Bionenyls.  Final  Draft.Sep.  24,  1975.

          Department of the Environment,  U.K.   Waste Management Paper
          No. 6.   Polychlorinated  Blphenyl  (PCB)  Wastes.  "A  Technical
          Memorandum on Reclamation,  Treatment  & Disposal  Including  a
          Code  of  Practice.   London,  England.


Dow Chemical Co.  "Dow's New Capacitor Fluid - A Case Study
in Product Stewardship."  In:  ASTM Synposium on Aquatic
Toxicology, Memphis,  Tenn.   Oct. 25-26, 1976.

Environment Canada.  Petroleum and Industrial Organic
Chemicals,  Water Pollution  Control Directorate, Abatement
and Compliance Branch.  Burning Waste Chlorinated Hydrocarbons
in a Cement Kiln.  Feb. 3,  1977.

Environment Canada, Health  and Welfare Canada.  Background
to the Regulation of Polychlorinated Biphenyls (PCS) in
Canada.  A Report of the Task Force on PCS, April 1, 1976
to the Environmental ContaminantsCommittee of Environment
Canada and Health and Welfare Canada.  Technical Report 76-1.

Fii/.lun, Lawrence.   "Toxicity of Chlorinated Biphenyls."
Annual Reviews of  Pharmacology, 1_4 (1974).

Florida  Power and  Light Co.  Critical Assessment of  the
Feasibility of  Biqdegradlnq Polychlorinated  Sipnenyls
(PCS)  to Non-Toxic  Derivatives.  Contract  RF3392.  Texas
A&M University.

Florida  Power and  Light Co.  Phase I-Alternative Disposal
Prpcesses_for Liquids  and Solids Contaminated with Poly-
chlorinated Slohenyls.Aug. 12, 1976.Turner, Mason  &
Solomon, Consulting  Engineers.

Florida  Power and  Light Co. Report  on  PC3 Emissions from
Sanford  Unit No. 4.   May  1976.

Fort  Howard Paper  Co.   Before  the  Senate  Committee on
Natural  Resources,  Assembly Committee on  Environmental
Quality, Assemoly  Committee on  Natural  Resources:   In
the Matter  of Creating Chapter  NR  212 of  the Wisconsin
Administrative  Code Related to  Effluent Standards  for
Polychlorinated Slohenyls  (PCBsj

General  Electric Co.   Wastewatar Monitoring Program  and
Evaluation  of Control  Measures, for Polychlorlnatad  Slonenyls
 (PC8).  Discharges to the  Hudson  River.   Phase  I  Report.
Jun.  1975.  Clark, Oietz  and Associates,  Engineers,  Inc.

Hutzinger,  0.,  S.  Safe, and V.  Zitto.   The Chemistry of
 PC3s.  1974.   CRC  Press.

 Interdepartmental  Task Force on  PC3s.   Polychlorinated
Biphenyls  and  the  Environment.  May  1972.   Wasnington, O.C.

Kimbrough,  Renate  0.   "Toxicity of Polychlorinated  Polycyclic
Compounds  and  Related Chemicals."  Critical  Reviews  in
Toxicology, 2(4):  445-498,  1974.   CRC Press, Inc.

Mallery & Co., Inc.  Economic Impact of a Ban on PCS In
Capacitors.  (With cover Tetter to Mr! Robert A. Westin,
Versar Inc., Springfield, Va.).  Aug. 10, 1976.

Manufacturing Chemists Assoc.  Guide to Precautionary
Labeling of Hazardous Chemicals, Manual1 L-l.  1970.
Seventh Ed.

Manufacturing Chemists Association.  Study of the  Potential
Economic Impacts of the Proposed Toxic Substances  Control
Act as Illustrated bv Senate Bill S. 776.	Fahrimry ?0.
June 26, 1975.  Foster 0. Snell, Inc.

Michigan Oept. of Public  Health.   Evaluation of Changes
of  the Level  of  Polychlorinated Bi'gnenyls  (PC3) in. Human
Tissue.  Final Report!FDA Contract 223-73-2209.

Midwestern Governors'  Conference,  Indianapolis, Indiana,
July  25-28,  1976.   Policy Statement on Hazardous Toxic

MIT Center for Policy Alternatives.  The Impact of Govern-
mental  Restrictions on the Production and  Use of Chemicals.
A Case  Study on  Polychlorinated Biohenyls.  Apr. 30,  1975.

Monsanto Co.  "Monsanto to Shut Down PCS Unit, Exit Business
by  Oct.  31,  1977."  Monsanto News.

Monsanto Co.  Presentation to the Interdepartmental Task
 Force on  PCBs.  May 15, 1972.  Washington, O.C.

NIOSH.   Draft Criteria Document, for Polychlorinated Biohenyls.

 National  Swedish Environment Protection Board.  PCS Conference
 Sep.  29,  1970.  Stockholm.  Dec. 197b.

 National  Marine Fisheries Service.  Estimation of Economic
 Impact of PCBs in Great Lakes Commercial  Fish.  Dec. 18,  1975.

 Organization for Economic Co-operation and  Development.
 Environment Directorate.  Polychlorinated Biohenyls, Their
 Use and Control.  1973.  Paris, France.

 Panel on Hazardous Trace Substances.  "Polychlorinated
 Biphenyls-Environmental  Impact.  A  Review by the  Panel  on
 Hazardous  Trace Substances.  March  1972."   Environment
 Research,  5(3) Sep. 1972.  Academic Press,  Inc.

 State of Michigan.  Enrolled House  Bill No.  5619.  78th
 Legislature Regular Session of  1976.

Stata of New York, Department of Environmental Conservation.
Interim Opinion and Order in the Matter of AllegedViolations
of Sections 17-0501, 17-0511 and 11-0503 of "t'h'e'Env'ironniental
Conservation Law of the Stata of New York by:  General
Electric Company. File No. 2833.  Trial Memorandum and
Memorandum of Law on the  Issue of Respondent's Violation
of Law.  Dec. 24, 1975.

State of New York, Department of Environmental Conservation.
In the Matter of Alleged  Violations of SS17-Q501, 17-0511,
and  11-0503 of  the State  of New York by:  General Electric
Co., File No. 2833.  Undated.

 State  of Wisconsin,  Department  of  Natural  Resources.
 Latter to  Dr.  A.  D.  Schmidt,  Commissioner of Foods  and
 Drugs,  Dept.  of Health,  Education  and  Welfare:   In  Reply
 to:   3210-3.   Apr.  28, 1S76.

 State  of Wisconsin,  Department  of  Natural  Resources.   Notice
 of Proposed Rulemaking.   Discharge of  Polychlorinatad
 Sipnenyls  (RGBs)  Into  the Waters^of the State.   July  14, 1976.

 State  of Wisconsin,  Department  of  Natural  Resources.   Notice
 of Public Hearings,  Management  of  PCSs and Products Containing
 PC3s.   Feb. 9,  1977.

 State of Wisconsin,  Department  of  Natural  Resources.   The
 PCS Problem in Wisconsin.  Undated.

 State of Wisconsin,  Department  of  Natural  Resources.   State-
 ment for Public Hearings on NR  212 Held by the Assembly
 Environmental  Quality Committee with the Senate and Assemb1y
 Natural	Resources Commitee on September 21,  1975 at 1:30 P.M.,,
 Madison, Wise.

 USOA.   Agricultural  Research Service,  Pesticides Regulation
 Division.  PR Notice 70-25:  Notice to Manufacturers,
 Formulators, Distributors, and  Registrants of Economic
 Poisons.Oct. 29, 1970.

 US-OHEW.  Final Report of the Subcommitteeon Health  Effects
 of Polychlorinated Blohenyls.  July 1976.

 US-OHEW, Public Health Service.  PCSs  in Mother's Milk;
 Transcript of Proceedings.  Sept.  23,  1976.   Setnesda, Md.

 US-OHEW, FOA.  Draft Environmetal   Impact Statament.  Notice
 of Proposed Rule Making  Polychlorinatad Blohenvis.May 8,
 WT.	   	'—

 US-OHEW, FOA.  Final  Environmental Impact Statement Rule
 Making on Polychlorinated Bighenyls.  Dec.  13,  1972.

US-OHEW, FDA.  In the Hatter of Polychlorinated Biohenyls
(PCBs) in Paper Food-Packaging Materials.  Docket No. 75N-
0013.  Prepared Testmony of;  (1) Paul £. Trout,(2) Seymour
G. Gilbert,(3) J. Rodney Edwards,   (4) Paul E. Corneliussen
(5) E. Bruce Brookfaank, Jr., (6) Peter L. Oliver,  (7) Donald
R. Russell,  (8) Nathan Mantel,  (9)  A. T. Luey,  (10) Robert
Long,  (11) Moreno Keplinger,   (12) Eiiiar Wulfsberg,
(13) Albert C. Kolbye, Jr., M.D.,   (14) Charles F. Jelinek,
PhD.,  (15) Elizabeth 0. Campbell,  (16)  Herbert 81umenthal,
PhD.,  (17) James  R. Allen,  (18) Renate 0.  Kimbrough, M.D.,
(19) John R. Wessel.  Affidavit of:   Edward  K.  Mullen.

US-OHEW,  NIH   Meeting  on  Breast Milk.  Transcript of
Proceedings.   Aug.  27,  1976.   Washington,  D.C.

•US-OHEW,  NIH,  National  Institute of Health  Sciences.
Environmental  Health  Perspectives.  Environmental  Issue
No.  1.  April  1972.

USEPA.   Destruction of Polychlorinated Biohenyls  in  Sewage
Sludge  During Incineration'.   1976.   Versar,  Inc.

USEPA.   Environmental  Assessment of PC8s in  the Atmosphere.
April  1976.   Mitre Corp.  MTR-7210,  Rev. 1.

USEPA.   "For Release After 11:00 A.M. Monday, Dec.  22, 1975:
Train Announces Plan to Control PCBs."  Fnvirnnmpntal News.

 USEPA.   Memorandum to:  All  Regional  Administrators, From:
 Assistant Administrator for Enforcement and General  Counsel.
 Subject:  Policy on PCBs.  Apr. 19,  1972.

 USEPA.   PCS Sampling and Analyses  at Selected Sanitary
 Landfill Sites.May 25, 1976.  SCS  Engineers, Consulting
 Engineers, Inc.

 USEPA, Office of Federal Activities.  Letter to the Hearing
 Clerk, US-OHEW:  Re:  Draft Environmental Impact Statement
 and Proposed  Rule Making on Polychlorinated Biphenyls (PCBs)
 of May 8, 1972.

 USEPA, Office of Water Program Operations.  Study of  the
 Distribution  and  Fate of Polychlorinated Biphenyls  and
 Benzenes after Spill of Transformer  Fluid.  Jan. 1976.

 USEPA.   Predicting Organic Contaminant  Removal by Clay
 Minerals ana  Waste Materials.  Grant No. 804684010,  1st
 Quarter  Report, Oct. 6,  1976 to Jan.  6,  1977.

 USEPA-OSWMP.  Destroying Chemical  Wastes in Commercial
 Scale Incinerators.  Apr. 1977.  Preliminary Draft.
 Rollins Environmental  Services.

 USEPA-OSWMP.  Hazardous Waste Management "acil_ities  in the
 United States.  Current Reoort en  Solid Waste Manaoement.
 Fed. 1976.

USEPA-OSWMP.  Facilities in the United States.  A Current
Report on Solid Waste Management.  Feb. 1976.

USEPA-OSWMP.  Polychlorinated Biohenyl Capacitor Test Burn.
(unpublished report).

USEPA-OSWMP.  Preliminary Assessment of PCB Disposal in
Municipal Landfills and Incinerators'Undated.

 USEPA,  OTS.   Assessment of Wastewatsr Management  Treatment
 Technology,  and Associated Costs  for Abatement of PC3s
 Concentrations  in Industrial  Effluents:   Task II.   Feb.  3,
 1976.Versar,  Inc.

 USEPA,-OTS.   Criteria Document for PCSs.   July 1976.  Mass.
 Audobon Society.

 USEPA,  OTS.   Development of a Study Plan for Definition of
 PCSs Usage.  Wastes,  and Potential Substitution in the
 Investment Castinqjndustry::  Task IIj.   Jan. 1976. Versar,
 Inc.              '

 USEPA,  OTS.   Industry View on the Use of Polychlorinated
 Siphenyls in Transformers and Capacitors.  Jun. 1976.

 USEPA,  OTS.   Microeconomic Impacts of the Proposed Marking
 and Disposal Regulationsfor Pol/chlorinated SiDhenyls.
 April 1977.Versar, Inc.

 USEPA,  OTS.  National Conference on Polychlorinated Sishenyls.
 Nov. 19-21, 1975.  Marcn  1976.  Chicago, 111.

 USEPA, OTS.  PC3s in the  United  States:  Industrial Use
 and Environmental Distribution.  Feb. 25, 1975.  Versar,  Inc.

 USEPA, OTS.  Preliminary  Assessment of Suspected Carcinogens
 in  Drinking Water:   Report to Congress.  Dec.  1975.

 USEPA, OTS.  Review  of PC3 Levels in  the Environment.  Jan. .

 USEPA, OWPS.   Quality  Criteria for  Water.  July  26,  1976.

 USEPA, OWPS.   Economic Analysis  of  Proposed  Toxic .Pollutant
 Effluent Standards  for Polychlorinated  Sionenyls:   Trans-
 •former,  Capacitor,  and  PC3 Manufacturers.   Oct.  1976.

 USEPA,  OWPS.   PC3s  Water  Elimination/Reduction Technology
 and Associated Costs,  Manufacturers  of  electrical  Capacitors
 and Transformers...Addendum  to  Final  Report:   Task ii.
 Versar,  Inc.

           USEPA, OWPS.  Supplement to Development Document Hazardous
           Substances Regulations Federal Water Pollution Control Act
           as Amended 1972.Nov. 1975.

           USEPA, Region V.  Statement of Karl E. Bremer, USEPA, Region
           V, Chicago. 111., Before the Minnesota House Natural  Resources
           and Environmental Protection Committee on House 811.1  Number
           2492 Related to Prohibition of Sale, Manufacture, and Use
           of Polychlorinated Biphenyls  (PCBs).Mar. 4, 1976.

           USEPA, Region V.  Statement of Karl E. Bremer, USEPA, Region
           V, Chicago, 111., Before the House Environment Energy
           and Natural Resources Committee Related to Legislation  •
           Regulating Use of Polychlorinated Biphenyls  (PCBsK'
           Springfield, 111.Apr. 27, 1976.

           USEPA, SSAD.  Sampling Survey Related to Possible Emission
           of Polychlorinated Biphenyls  (PCSs) from the  Incineration"
           of Domestic Refuse.  Oct.-Nov. 1975.

           US ERDA.  An Appraisal of Tests and Standards for the
           Evaluation of Electrical Insulating Fluids.   Final  Report.
           May 14, 1975.National Bureau of Standards.

           US ERDA.   Environmental Impact of Polychlorinated Biphenyls..
           May 1976.  Mitre Corp. MTR-7006.

           Westinghouse Co.  Economic  Impact of  Alternatives to  PCBs.

           Wisconsin  Association  of Manufacturers and Commerce and
           the Wisconsin Paper  Council.  Statement  Before  the  Senate
           Natural Resources Committee and Assembly  Environmental
           Quality Committee Relating  to Proposed NR  212.   Sep.  21,  1976.

            USEPA-OTS.   Microeconomic  Impacts  of  the Proposed  Marking  and
            Disposal  Regulation  for  PCBs.   E?A 560/6-77-013.   April  1977.
            Versar,  Inc.
E.   Other .Information

    1.   Federal  Register Notices
            41  F.R.  14123-14136, April  1, 1976.  "Polychlorinated Biphenyl
            Containing Wastes:  Disposal  Procedures.  PTV."

            41  F.R.  23225, June 9, 1976.   "Chloralkylene Fluids:  Opinion
            Regarding Use as Dielectric Fluids."

            42 F.R.  6532-6555, February 2, 1977.  "Toxic Pollutant Effluent
            Standards:  Standards for Polychlorinated Biphenyls (PCBs);
            Final Decision."

     41 F.R. 53692, December 8, 1976.  "Polychlorinatad Siphenyls
     (?C8s):  Panel Discussion."

     41 F.R. 23225, June  9, 1976.   "Polydimethylsiloxane:  Opinion
     Regarding Use as  Coolants  for  Use in  Transformers."

     42 FR. 17487-17494,  April  1, 1977.  "Unavoidable Contaminants
     in Food and  Food  Packaging Materials:   Polychlorinated  Biphenyls
     (PCBs)."  USOHEW  21  CFR Part 109.  Docket No.  77n0080.

2. Development Plan

   "Request for Approval of a Development Plan to Initiate the
   Regulatory Process for Polychlorinated Siphenyls (?C3s)."