-------
Naticnal Diitr-iixrricn
TABLE 11
cf ?Os Ircineraticn FacHici
Tfetal Kb. cf
No. of
^s Facilinss
(1)
* Nurisr c^
12
XS-I CT 1 * '
k">^ . " 1 II *
So* Calif.
Caiorads
Chia
« 1
Ml 1
_ T_
- 1
_ 1
Arkar-sas - 1
/",i ; .*,.,_,• ., „ i
V—.,
Chia
_ 1
,1 ,• J ; , . i
29
-------
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.
Transportation
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
-------
Decontamination
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.
33
-------
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
35
-------
Marking
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
Inventory:
Transformers
Large Capacitors
v Articles
_-w Ecuipirsnt
TOTALS
3
2,700
25,000
25,000
55,450
Transportation
and Labor Costs
20
40,000
42,890
Total
Containers
Storage Areas
Vehicles
2,700
27
20
1,500
1,000
370
4,200
1,027
390
23
42,700
25,000
25,000
98,340
37
-------
Table 13
Electrical Ecuianent Users' Total Marking Cos
for the Year Er.dir.g Cecsnier 31, 1373
(in (dollars)
Trarsportaeicn
Label Ccsts and Later Costs
To-t:
fTHT. ,>•!«»<.
rr-r-t-a •» rn»r-s
Storage Areas
Vehicles
Large Low Voltage
Capacitars
Large High Voltage
Capacitors
Trans-forcers
PTH Capacizors
TOTALS
Contsir-ars
Storage Araas
Vehicles
Large Lew Voltage
Capacitors
Large High Voltage
Capacitors
Transforrers
cm casa/r — ^
TOTALS
Pasidential:
Ccntainsrs
Storage Areas
Vefc-i,-lo<;
Large Low Volcage
Capacitors
Large High Voltage
Capacitors
Transformers
HID Capacitors
34,780
215
200
27,000
760, 000 )
22,680)
10 , 300
905,575
130,350
269,785
610
513,000
300,000
15,120
258,120
2,046,985
-0-
-0-
-0-
-0-
HD-
^3-
1,080
1,080
100,000
7,960
3,700
1,000,000
8,396,481
120,000
9,623,141
350,000
4,956,020
11,300
9,500,000
2,000,000
340,000
2,363,000
20,565,320
-0-
-0-
-0-
-0-
-o-
-0-
12,000
12,000
134,730
3,175
3,900
1,027,000
9,179,161
130,300
10,533,316
540,330
5,25= ^05.
—
10,013,000
2,300,000
255,120
3,125,120"
22,612,305
-0-
• -o-
-0-
-o-
-0-
: c
12,'CSO
2,953,740
30,205,461
-------
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.
39
-------
TA8L£ 14
-*--.-]/-ar Squi-msn-e Users' total Marking Casts
fas ths Year" Ending Cecsnfaer 31, 1373*
(in dollars}
Utilities:
Containers
Storage Areas
Vehicles
Large Lew Voltage
Capacitors
Large High Voltage
Trans fcsners
HID Capacitors
TOTAL
Containers
Storage Areas
Vehicles
Large Low Voltage
Capacitors
Large High Voltage
Capacitors
Transfornars
E2U Cacacitars
TOTALS
Residential:
Containers
Storage Areas
Vehicle
Large Lew Voltage
Cacacitars
Large Sigh Voltage
Capacitors
Transformers
HID Capacitors
TOTALS
GSAND TOTALS
*Cose estimates are based en
(e-un-i-f ia.1 \ e* i Sf-rKJi 1 ,
Lata?I Casts
84,780
81,000
200
. 13,500
123,120
1,361
10,300
314,761
130,350
139,000
610
256,500
6,430
307
253,120
901,967
-0-
H3-
-0-
H3-
-0-
-0-
1,080
1,080
1,217,308
the assurnticn, that lar
a.pti tait-'l -parrerjiM f-~sa.
and Labor Casts
100,000
3,000,000
3,700
250,000
2,280,000
25,200
120,000
5,773,300
350,000
3,500,000
11,300
4,750,000
120,000
50,400
2,363,000
11,549,700
-0-
• -o-
-0-
-0-
-0-
-0-
12,000
12,000
17.440,500
ga casacitcrs and
ser/ica and hance
Total
134,780
3,081,000
3,300
263,500
2,403,120
26,551
130,300
5,093,551
540,350
3,539,000
11,910
5,005,500
126, 4&v.
51,307
3,126,120
12,551,557
-0-
-0-
-0-
-0-
-0-
_o-
13,050
13,080
13,559,408
trans farrsrs
gathered fcr
40
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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.
41
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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:
42
-------
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
Marking
New PCHs 0.1
Existing ?C2s
Option 1 (Proposed regulation) 33.3 5
Cpticn 2(5) 17.3 5
Storage
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
43
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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.
45
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FOOTNOTES
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.
46
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ADDENDUM TO PART II, ECONOMIC CONSEQUENCES, OF THE SUPPORT
DOCUMENT FOR PCS RULEMAKING
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
facilities.
47
-------
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.
48
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III. OFFICIAL RECORD OF RULEMAKING - PCS MARKING AND DISPOSAL REGULATIONS
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
49
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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
Agenda
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
50
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2. Public Participation Meeting, Monday, January 24, 1977
Agenda
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,
D.C.
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
Regulation.
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.
51
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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.
52
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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
Substances.
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.
CPA-76-3/b."
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.
Undated.
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.
53
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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.
54
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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.
55
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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. .
1976.
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.
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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.
Undated.
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."
57
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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)."
53-
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