May 2002
DTSC R-02-02
EPA 600/R-02/042
Environmental Technology
Verification Report
Cooper Power Systems
Envirotemp®FR3 ™
Vegetable Oil-Based
Insulating Dielectric Fluid
Prepared by
@Cal/EPA|
California Environmental Protection Agency
^^^^^^^^^^^^^^^^
Department of Toxic Substances Control
Under a cooperative agreement with
u.S. Environmental Protection Agency
ET1/ET1/ET1/
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May 2002
Environmental Technology Verification
Report
Cooper Power Systems
.TM
Envirotemp^FRS
Vegetable Oil-Based Insulating
Dielectric Fluid
By
California Environmental Protection Agency
Department of Toxic Substances Control
Office of Pollution Prevention and Technology Development
Sacramento, California 95812-0806
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Notice
The information in this document has been funded in part by the U.S. Environmental Protection
Agency (EPA) under a Cooperative Agreement number CR 824433-01-0 with the California
Environmental Protection Agency (CalEPA), Department of Toxic Substances Control (DTSC).
The Pollution Prevention and Waste Treatment Technologies Center under the U.S. EPA
Environmental Technology Verification (ETV) Program supported this verification effort. This
document has been peer reviewed by the EPA and recommended for public release. Mention of
trade names or commercial products does not constitute endorsement or recommendation by the
EPA or the Department of Toxic Substances Control (DTSC) for use.
This verification is limited to the use of the Cooper Envirotemp®FR3™ Vegetable Oil-Based
Insulating Dielectric Fluid for use in electrical apparatus such as distribution transformers as an
alternative to mineral oil-based dielectric fluids. EPA and DTSC make no express or implied
warranties as to the performance of the Cooper Envirotemp®FR3™ Vegetable Oil-Based
Insulating Dielectric Fluid technology. Nor does EPA and DTSC warrant that the Cooper
Envirotemp®FR3™ Vegetable Oil-Based Insulating Dielectric Fluid is free from any defects in
workmanship or materials caused by negligence, misuse, accident or other causes.
June 2002
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Foreword
The U.S. Environmental Protection Agency (EPA) is charged by Congress with protecting the
Nation's air, water, and land resources. Under a mandate of national environmental laws, the
EPA strives to formulate and implement actions leading to a compatible balance between human
activities and the ability of natural systems to support and nurture life. To meet this mandate, the
EPA's Office of Research and Development (ORD) provides data and science support that can
be used to solve environmental problems and to build the scientific knowledge base needed to
manage our ecological resources wisely, to understand how pollutants affect our health, and to
prevent or reduce environmental risks.
The Environmental Technology Verification (ETV) Program has been established by the EPA to
verify the performance characteristics of innovative environmental technologies across all media,
and to report this objective information to the permitters, buyers, and users of the technology,
thus substantially accelerating the entrance of new environmental technologies into the
marketplace. Verification Organizations oversee and report verification activities based on
testing and quality assurance protocols developed with input from major stakeholders and
customer groups associated with the technology area. There are now six ETV technology
centers, which include the original twelve ETV technology areas. Information about each of the
environmental technology centers covered by ETV can be found on the Internet at
http://www.epa.gov/etv.htm.
Effective verifications of pollution prevention and treatment technologies for hazardous waste
are needed to improve environmental quality and to supply cost and performance data to select
the most appropriate technology. Through a competitive cooperative agreement, the California
Department of Toxic Substances Control (DTSC) was awarded EPA funding and support to plan,
coordinate, and conduct such verification tests, for "Pollution Prevention and Waste Treatment
Technologies" and report the results to the community at large. Information concerning this
specific environmental technology area can be found on the Internet at
http://www.epa.gov/etv/03/03_main.htm.
The following report reviews the performance of the Cooper Envirotemp®FR3™ Vegetable Oil-
Based Insulating Dielectric Fluid. Envirotemp®FR3™ fluid is used as an insulating dielectric fluid
for electrical apparatus such as distribution transformers as an alternative to mineral oil-based
dielectric fluids.
June 2002 iii
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Acknowledgment
DISC wishes to acknowledge the support of all those who helped plan and implement the
verification activities, and prepare this report. In particular, a special thanks to Ms. Norma
Lewis, Project Manager, and Ms. Lauren Drees, Quality Assurance Manager, of EPA's National
Risk Management Research Laboratory in Cincinnati, Ohio.
DTSC would also like to thank Mr. Jay Wells and Mr. James Tolosano of Artwel Electric, Inc.,
Mr. Tony Borba of Western Utilities, and Mr. David Pais of Texas Instruments for their support
and for providing the facility and necessary resources to conduct the verification field test.
Additionally DTSC would like to thank Mr. John Luksich and Mr. Patrick McShane of Cooper
Power Systems for their participation in this Environmental Technology Verification Pilot
Project.
June 2002 iv
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THE ENVIRONMENTAL TECHNOLOGY VERIFICATION
PROGRAM
EPA OCal/EPAl
California Environmental Protection Agency I
U.S. Environmental Protection Agency ^^^^^^^^^^^^^^^^^^^^^^J
ETV JOINT VERIFICATION STATEMENT
TECHNOLOGY TYPE: VEGETABLE OIL-BASED INSULATING DIELECTRIC
FLUID
APPLICATION: VEGETABLE OIL-BASED INSULATING DIELECTRIC
FLUID FOR USE IN ELECTRICAL APPARATUS REQUIRING
A LIQUID DIELECTRIC COOLANT
TECHNOLOGY NAME: ENVIROTEMP®FR3™INSULATING DIELECTRIC FLUID
COMPANY: COOPER POWER SYSTEMS, INC.
ADDRESS: 1900 EAST NORTH STREET PHONE: (800)643-4335
WAUKESHA, WISCONSIN 53188 FAX: (262)524-4654
WEB SITE http://www.cooperpower.com
EMAIL: cooper@cooperpower.com
The U.S. Environmental Protection Agency has created the Environmental Technology Verification
(ETV) Program to facilitate the deployment of innovative or improved environmental technologies
through performance verification and information dissemination. The goal of the ETV Program is to
further environmental protection by substantially accelerating the acceptance and use of innovative,
improved, and more cost-effective technologies. The ETV Program is intended to assist and inform those
individuals in need of credible data for the design, distribution, permitting, and purchase of
environmental technologies.
ETV works in partnership with recognized testing organizations to objectively and systematically
document the performance of commercial ready environmental technologies. Together, with the full
participation of the technology developer, they develop plans, conduct tests, collect and analyze data, and
report findings. Verifications are conducted according to an established workplan with protocols for
quality assurance. Where existing data are used, the data must have been collected by independent
sources using similar quality assurance protocols.
EPA's ETV Program, through the National Risk Management Research Laboratory (NRMRL), has
partnered with the California Department of Toxic Substances Control (DTSC) under an ETV Pilot
June 2002 v VS-R-02-02
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Project to verify pollution prevention, recycling, and waste treatment technologies. This verification
statement provides a summary of performance results for the Cooper Power Systems Envirotemp®FR3™
Vegetable Oil-Based Insulating Dielectric Fluid.
TECHNOLOGY DESCRIPTION
Cooper Power Systems (Cooper) has developed a vegetable oil-based dielectric fluid comprised of
>98.5% vegetable oil and <1.5% additives. Envirotemp®FR3™ fluid is used in liquid-filled electrical
apparatus such as transformers to act as an electrical insulating medium. Envirotemp®FR3™ fluid is
currently used in pole, padmount, network, and small and medium power transformers with a voltage
rating of 35 kV and a maximum rating of 10 MVA. Other electrical apparatus include loadbreak
switches, cables, electromagnets, klystron modulators, power supplies, and bushings. To date,
approximately 475 transformers currently use Envirotemp®FR3™ fluid.
EVALUATION DESCRIPTION
The evaluation consisted of:
Developing a Technology Evaluation Workplan by DTSC to independently evaluate the technology
with respect to the identified performance objectives for general performance, aquatic
biodegradability, flammability, acute toxicity, chemical composition, and protection of worker health
and safety;
Implementing the Technology Evaluation Workplan by DTSC and Cooper at their manufacturing
facility in Waukesha, Wisconsin. Field sampling has also been performed at transformers located at
San Mateo High School in San Mateo, California, and Texas Instruments in Santa Cruz, California.
The field sampling included collection of 12 samples from three different unused (virgin) product
lots at Cooper's facility, and four samples from four different in-service transformers (one sample per
in-service transformer).
Analyzing virgin product samples for general performance parameters (fire and flash point, dielectric
breakdown, dissipation factor, neutralization number, interfacial tension, viscosity, pour point, and
water content), aquatic biodegradation, aquatic toxicity using the California sample preparation
method, fatty acid content, phenolic antioxidants, SVOCs, and metals. In-service transformer sample
analyses included general performance parameters (fire and flash point, dissipation factor, water
content, conductivity, neutralization number, and interfacial tension,), fatty acid content, phenolic
antioxidants, SVOCs, and metals;
Reviewing supporting documentation on Envirotemp®FR3™ fluid including ASTM data, an acute
toxicity report, aquatic biodegradability data, and material safety data sheets (MSDSs).
VERIFICATION OF PERFORMANCE
Performance results of Cooper Power Systems' Envirotemp®FR3™ Vegetable Oil-Based Insulating
Dielectric Fluid are as follows:
• General Performance. Envirotemp®FR3™ fluid met Cooper's performance specifications for
dielectric breakdown (minimum and gap), pour point, viscosity at 40°C and 100°C, water content,
interfacial tension, and neutralization number. Envirotemp®FR3™ fluid also met the ASTM, IEEE,
and IEC specifications for dielectric breakdown (minimum, gap, and impulse) and met the ASTM
D3487, IEEE, and IEC specifications for the neutralization number. However, all samples had
higher dissipation factors at 100°C than past samples tested by Cooper. Envirotemp®FR3™ fluid also
had an average dissipation factor at 25 °C that did not meet the Cooper specification listed in Table 1.
The high dissipation factors may be due to contaminants introduced during product storage, sample
collection, sample preparation, or sample testing.
June 2002 vi VS-R-02-02
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Table 1. Summary of Virgin Product Sampling Results
Performance Parameters
Specification Standards1
Cooper
ASTM
D3487
ASTM
D5222
IEEE
C57.121
IEC
1099
Sampling Results
Lot 01D1
VFR3-01
Lot 01C6
VFR3-05
VFR3-07
Lot 01P2
VFR3-10
Average*
Dielectric Properties
Dielectric Breakdown (kV)
minimum
gap
impulse
Dissipation Factor (%)
@ 25°C
@ 100°C**
>30
>20
-
<0.15
--
>30
>28
>145
N/A
N/A
>42
>30
NA
N/A
N/A
> 25-30
> 20-30
-
N/A
N/A
-
>23
-
-
N/A
45
36
170
0.127
2.70
45
37
168
0.159
3.17
45
34
164
0.157
3.23
46
39
168
0.127
2.46
45 ±1
37 ±3
168 ±4
0.143 ±0.029
2.89 ±0.59
Chemical Properties
Interfacial Tension (dyne/cm)
Neutralization Number (mgKOH/g)
Water Content (ppm)
>18
<0.07
<75
N/A
<0.03
N/A
N/A
<0.01
N/A
N/A
<0.03
N/A
-
<0.03
<200
28
0.03
53
27
0.03
59
28
0.02
57
28
0.03
52
28 ±1
0.03 ±0.01
55 ±5
Physical Properties
Pour Point (°C)
Viscosity (cSt) @ 100°C
@ 40°C
@ 0°C
<-18
<8.5
<35
-
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
-
N/A
-
-7S
8
32.63
188.01
-18
7.88
32.67
187.14
-18
7.9
32.79
187.53
-18
7.95
32.74
187
-18
7.9 3 ±0.09
32.71 ±0.11
187.42 ±0.72
Note: Sampling results values in bold indicate these values met all the specification values listed for a given performance parameter. Italicized
values met only the Cooper specification value. Underlined values meet all but one specification value.
Data variability was calculated at 95% confidence using a two-tailed T-test assuming normal distribution.
:*Cooper does not have specification value for the dissipation factor at 100°C. Cooper does not routinely test for the dissipation factor at
100°C but reported three past samples had values ranging 1.4% to 1.9%.
Acronyms and Abbreviations:
- = No specification value available
ASTM D3487 = American Society for Testing and Materials (ASTM) standard specification for mineral insulating oil used in electrical
apparatus
ASTM D5222 = ASTM standard specification for high fire-point electrical insulating oil (high molecular weight hydrocarbon
specification)
cm = centimeter
Cooper = Virgin product specification for Envirotemp®FR3™ fluid developed by Cooper Power Systems
cSt = centistoke
IEC 1099 = International Electrochemical Commission (IEC) Specifications for Unused Synthetic Organic Esters for Electrical Purposes
IEEE C57.121 = Institute of Electrical and Electronic Engineers (IEEE) 1998 IEEE Guide for Acceptance and Maintenance of Less
Flammable Hydrocarbon Fluid in Transformers (silicone oil specification)
kV = kilovolt
mgKOHYg = milligrams of potassium hydroxide per gram
N/A = Not applicable since these specification values were developed for fluids with different physical and chemical characteristics than
Envirotemp®FR3™ fluid.
ppm = parts per million
For in-service transformer samples, the dissipation factor, neutralization number, interfacial tension,
conductivity and water content met the Cooper and IEC 1203 specifications for in-service fluid (see
June 2002
VII
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Table 2). Based on the historical data for the oldest in-service transformers, Envirotemp®FR3T
appears to have degraded little over the service life of the unit.
Table 2. Summary of In-service Transformer Sampling Results
fluid
Performance Parameters
Dissipation Factor (%) @ 25°C
Water Content (ppm)
Interfacial Tension (dyne/cm)
Neutralization Number (mgKOH/g)
Conductivity @ 25°C (pS/m)
Specification
Standards
Cooper
<1.0
<400
>18
<2.5
~
IEC 1203
<0.8
<400
—
<2.0
>1.1
Sampling Results
ISFR3-01
0.139
98
26
0.03
10.6
ISFR3-02
0.196
56
26
0.02
17
Note: Sample results in bold indicate these values met the both specifications listed in this
ISFR3-03 ISFR3-06
0.120 0.146
33 41
24 23
0.01 0.08
12.75 13.6
table. Envirotemp®FR3™
was compared to the IEC 1203 specification since its in-use performance is similar to synthetic oil.
1. ISFR3-01 and ISFR3-02 were collected from two separate transformers owned by Cooper Power.
2. ISFR3-03 was collected from one transformer owned by Texas Instrument.
3. ISFR3-06 was collected from one transformer owned by San Mateo
Acronyms and Abbreviations:
- = No specification value available
cm = centimeter
High School.
Cooper = In-service fluid specification for Envirotemp^FRS™ developed by Cooper Power Systems
IEC 1203 = International Electrochemical Commission (IEC) Synthetic Organic Esters for Electrical
Guide for Maintenance of Transformer Esters in Equipment
mgKOH/g = milligrams of potassium hydroxide per gram
ppm = parts per million
pS/m = picosiemen per meter
Aquatic Biodegradability. The average biodegradability of Envirotemp®FR3™ fluid was 120% ±33%
after 28 days using OPPTS Method 835.3110. The higher than expected biodegradability is due to
possible CO2 leaks from the control samples. The average biodegradation rates for
Envirotemp®FR3™ fluid and mineral oil based on literature data are presented in Table 3.
Table 3. Aquatic Biodegradation Rates
Compound
Envirotemp® FR3™
Mineral oil
HMWH
Biodegradation Rates
Cooper ETV1
120% ±33%
after 28 days
—
—
Universite de Liege2
—
70% after 40 days
—
CONCAWE3
—
28% after 28 days
—
USAGE45
—
42-49% after 28 days
—
TERC67
98% after 28 days
30. 5% after 28 days
2 1.3% after 28 days
'U.S. EPA, Environmental Technology Verification Report ABB Inc. BIOTEMP® Vegetable Oil-Based Insulating Dielectric Fluid, 2001 .
2Cloesen,C. & Kabuya, A, Research RW N° 21 74 Physical and chemical properties of environment friendly lubricants, no date.
Conservation of Clean Air and Water-Europe (CONCAWE), Lubricating OilBasestocks, pp. 20-22, June 1997.
4U.S. Army Corps of Engineers (USAGE), Engineering and Design Environmentally Acceptable Lubricating Oils, Greases, and
Hydraulic Fluids, April 1997.
USAGE, Engineering and Design Environmentally Acceptable Lubricating Oils, Greases, and Hydraulic Fluids, February 1999.
6 Thomas Edison Research Center, The Biodegradation ofEnvirotemp®FR3™, Univolt 60, andR-Temp Transformer Fluids, April 1999.
7The mineral oil used in the TERC study was Univolt 60 while the high molecular weight hydrocarbon (HMWH) oil was R-Temp.
June 2002
Vlll
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Based on the information above, the virgin Envirotemp®FR3™ fluid appears to biodegrade more
readily than mineral oil. Although Envirotemp®FR3™ readily biodegrades per this test, releases to
water should be prevented. The product's ability to degrade in the environment is dependent on site-
specific factors such as climate, geology, moisture, pH, temperature, oxygen concentration, dispersal
of oil, the presence of other chemicals, soil characteristics, nutrient quantities, and populations of
various microorganisms at the location.
Flammability. The flash and fire point for the virgin and in-service fluid were consistently above the
minimum values listed in the ASTM D3487, D5222, and Cooper performance specifications
presented in Table 4. The fire point results obtained also agreed with values reported by
Underwriters Laboratories.
Table 4. Flash and Fire Point Results for Virgin and In-Service Samples
Product Lot No./
Transformer SN
Flash Point (°C)
Specification Criteria
Cooper
ASTM
D3487
ETV
Result
Fire Point (°C)
Specification Criteria
Cooper
ASTM
D5222
ETV
Result
Virgin Product
01D1
01C6
01P2
Average
>320
>320
>320
>320
>145
>145
>145
>145
328
333
318
328 ± 11
>350
>350
>350
>350
304-310
304-310
304-310
304-310
362
363
362
363 ±2
In-service Transformer Fluid
ISFR3-01
ISFR3-02
ISFR3-03
ISFR3-06
>320
>320
>320
>320
>145
>145
>145
>145
338
328
330
340
>350
>350
>350
>350
304-310
304-310
304-310
304-310
362
364
364
364
Note: Data variability was calculated at 95% confidence using a two-tailed T-test assuming a normal
distribution.
SN = Sample Number
Acute Toxicity. The average LC50 for virgin Envirotemp®FR3™ fluid was less than 250 mg/L. This
low LC50 value is thought to reflect the physical impacts on fish due to oil coating the gills and
preventing oxygen exchange. The average LC50 indicates the spent (or waste) Envirotemp®FR3™
fluid may exhibit a hazardous characteristic when tested under California regulations (California
Code of Regulations, Title 22, Section 66261.24(a)(6)). This determination is based on a limited set
of data for the virgin product and may not apply in states other than California where hazardous
waste criteria and test methods may differ. End-users should characterize their spent
Envirotemp®FR3™ fluid at the time of disposal since changes to the oil may occur due to use,
storage, or age. End-users should also consult their appropriate local, state, or federal regulatory
authority on applicable waste characteristic definitions and available disposal options.
Chemical Composition. The AOAC results for the virgin Envirotemp®FR3™ samples showed the
virgin and in-service fluid agreed closely with Cooper's formulation. The virgin product consisted of
23.8% ± 0.1% monounsaturated fatty acids, 59.9% ± 0.1% polyunsaturated fatty acids, and 15.7% ±
0.1% saturated fatty acids. The in-service transformer fluid consisted of 22.0% to 23.8%
monounsaturated fatty acids, 59.8% to 62.4% polyunsaturated fatty acids, and 15.2% to 16.3%
saturated fatty acids.
June 2002
IX
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Antioxidant concentrations in the virgin Envirotemp®FR3™ samples ranged from 2,787 ppm ± 834
ppm. Antioxidant concentrations in the in-service transformer samples ranged from 3,550 ppm to
4,595 ppm. The antioxidants detected agreed with ingredients list provided by Cooper.
For the 65 standard SVOC compounds analyzed by the DTSC Hazardous Material Laboratory, none
were detected in the virgin product samples. Bis- (2-ethylhexyl) phthalate, butyl benzyl phthalate,
and di-n-butyl phthalate were detected in the in-service transformer samples. These compounds were
suspected to be contaminants introduced from the sampling equipment and deionized water used.
Other tentatively identified compounds were various sterols normally found in vegetable oils.
All the virgin product samples and two in-service samples contained barium and zinc between 25
mg/kg and 36 mg/kg, and between 11 mg/kg and 24 mg/kg, respectively. Cadmium and molybdenum
were also detected in one in-service transformer sample at 0.42 mg/kg and 2.6 mg/kg, respectively.
The barium and zinc might have been introduced during the processing of the basestock oil,
degassing of the oil, or storage in the finishing tank.
• Worker Health and Safety. Based on the MSDS information, Envirotemp®FR3™ fluid appears to
have similar PPE requirements compared to select mineral oil-based transformer fluids.
Envirotemp®FR3™fluid had less stringent PPE requirements when compared to select silicone oil-
based transformer fluids. Envirotemp®FR3™ fluid has a slightly higher nuisance particulate OSHA
PEL than mineral oil. Envirotemp®FR3™ fluid does not contain listed IARC confirmed carcinogens
or teratogens. The select mineral oil-based transformer fluids listed a hydrotreated light naphthenic
petroleum distillate, which is an IARC confirmed carcinogen. The silicone based transformer oils
listed dimethyl polysiloxane as the primary ingredient, which is a teratogen in animals. Although the
product appears to contain ingredients with less serious health effects, the end-user must comply with
all applicable worker health and safety regulations when using this product.
• Estimated Cost of Using Envirotemp®FR3™fluid versus Mineral Oil. The initial purchase cost of a
new transformer unit containing Envirotemp®FR3™ fluid is approximately 1.2 to 1.3 times more than
that of a comparable mineral oil transformer. When comparing the price per gallon of
Envirotemp®FR3™ fluid to mineral oil, the difference may be between $5 to $8 more per gallon
depending on the volume purchased. Based on historical accelerated aging test results, the estimated
life expectancy of an Envirotemp®FR3™ transformer is estimated to be 20 years, which is comparable
to mineral oil-based transformers.
Results of the verification/certification show that the Cooper Power Systems Envirotemp®FR3™
Vegetable Oil-Based Insulating Dielectric Fluid is a readily biodegradable, vegetable oil-based dielectric
fluid with a flash and fire point above 300°C. The product has dielectric breakdown voltages comparable
to mineral oils, silicone oils, synthetic esters, and high molecular weight hydrocarbons.
Envirotemp®FR3™ samples from in-service transformers had flash and fire points above 300°C, and
showed no signs of oil degradation due to use for the oldest transformers, which were in-service for 4.8
years. The LC50 results for virgin Envirotemp®FR3™ fluid indicate the spent Envirotemp®FR3™ fluid
may exhibit a hazardous characteristic per California's hazardous waste characteristic definition. This
interpretation is based on a limited set of test data. The end-user should characterize the spent
Envirotemp®FR3™ fluid at the time of disposal since changes may occur to the oil due to use, storage, or
age.
Although Envirotemp®FR3™ fluid is a vegetable oil-based product, end-users are still subject to the
federal oil pollution prevention regulations under 40CFR112. End-users should contact their appropriate
local, state, or federal regulatory authority regarding the management of Envirotemp®FR3™ fluid and
Envirotemp®FR3™ spills.
June 2002 x VS-R-02-02
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Original signed by: Original signed by:
E. Timothy Oppelt 5/15/02 Kim F. Wilhelm 5/8/02
E. Timothy Oppelt Date Kim F. Wilhelm, Acting Chief Date
Director Office of Pollution Prevention
National Risk Management Research Laboratory and Technology Development
Office of Research and Development Department of Toxic Substances Control
United States Environmental California Environmental Protection Agency
Protection Agency
NOTICE: Verifications are based on an evaluation of technology performance under specific,
predetermined criteria and the appropriate quality assurance procedures. EPA and Cal/EPA make no
expressed or implied warranties as to the performance of the technology. The end-user is solely
responsible for complying with any and all applicable federal, state, and local requirements. Mention of
commercial product names does not imply endorsement.
June 2002 xi VS-R-02-02
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Availability of Verification Statement and Report
Copies of the public Verification Statement and
Verification Report are available from the following:
1 U.S. EPA
Web site: http://www.epa.gov/etv/library.htm (electronic copy)
2. Department of Toxic Substances Control
Office of Pollution Prevention and Technology Development
P.O. Box 806
Sacramento, California 95812-0806
Web site: http://www.dtsc.ca.gov/sciencetechnology/etvpilot.html
http: //www. dtsc. ca.gov/sciencetechnology/techce rt_index .html
or http://www.epa.gov/etv (click on partners)
(Note: Appendices are not included in the Verification Report
and are available from DTSC upon request.)
June 2002 xii VS-R-02-02
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TABLE OF CONTENTS
Notice ii
Foreword iii
Acknowledgment iv
Verification Statement v
Glossary of Terms xviii
Section 1. Introduction 1
Section 2. Description of Technology 4
Section 3. Field Sampling Verification Objectives 6
Section 4. Verification Activities and Results 7
4.1 Verification Activities 7
4.2 Results: Objective 1, General Performance 11
4.3 Results: Objective 2, Aquatic Biodegradability 20
4.4 Results: Objective 3, Flammability 23
4.5 Results: Objective 4, Acute Toxicity 26
4.6 Results: Other Verification/Certification Objectives 28
Section 5. Regulatory Considerations 34
5.1 Regulation of Virgin Envirotemp®FR3™ Dielectric Fluid 34
5.2 Waste Characterization/Disposal Requirements 35
5.3 Spill Management 37
Section 6. Conclusions 39
6.1 Objective 1, General Performance 39
6.2 Objective 2, Aquatic Biodegradability 39
6.3 Objective 3, Flammability 39
6.4 Objective 4, Acute Toxicity 40
6.5 Other Verification/Certification Objectives 40
Section 7. Vendor's Comment Section 42
References 43
June 2002
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TABLES
Table 1. Summary of 1992 PCS Waste Generation - Electric Utility 2
Table 2. Envirotemp®FR3™ Samples and Analyses 8
Table 3. Equipment Information on Sampled Transformers 10
Table 4. Performance Results for Virgin Envirotemp®FR3™ Samples 12
Table 5. Performance Results for In-Service Envirotemp®FR3™ Samples 18
Table 6. Aquatic Biodegradability Results 21
Table 7. Flash Points for Virgin and In-service Envirotemp®FR3™Samples 23
TableS. Fire Points for Virgin and In-service EnvirotempRFR3 Samples 24
Table 9. Fish Bioassay Results for Virgin Envirotemp®FR3™ Samples 26
Table 10. AOAC Results for Virgin Envirotemp®FR3™ Samples 28
Table 11. AOAC Results for In-Service Envirotemp®FR3™ Samples 29
FIGURES
Figure 1. Transformer Cross Section 4
Figure 2. Tank Sampling 9
Figure 3. Sampling Spigot 9
Figure 4. Transformer Sampling performed at SMHS and TI 10
Figure 5. Transformer Sampling at Cooper 10
Figure 6. Trends for In-Service Transformer Parameters 17
Figure 7. Flash Point Trend for Transformers Sampled 25
Figure 8. Fire Point Trend for Transformers Sampled 25
June 2002
xiv
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APPENDICES
Appendix A: Cooper Field Test Results
Appendix A-l: Select ASTM Test Methods: Objective 1
Appendix A-2: Aquatic Biodegradability Test Method: Objective 2
Appendix A-3: Flammability ASTM Test Method: Objective 3
Appendix A-4: Acute Toxicity Test Method: Objective 4
Appendix A-5: Worker Health and Safety Assessment: Other Verification/Certification
Objectives
Appendix A-6: AOAC Test Methods, EPA Test Method 8270 (SVOCs), and EPA Test
Appendix B: Cooper Field Test Plan
Technology Evaluation WorkPlan (Cooper), May 16, 2001; Department of Toxic
Substances Control, Office of Pollution Prevention and Technology Development.
Note: Appendices are not included in the Verification Report and
are available upon written request to DTSC at the following address:
Department of Toxic Substances Control
Office of Pollution Prevention and
Technology Development
P.O. Box 806
Sacramento, California 95812-0806
June 2002 xv
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List of Abbreviations and Acronyms
Qcm ohm-centimeter
ANSI American National Standards Institute
AOAC Association of Analytical Chemists
ASTM American Society of Testing and Materials
Ba(OH)2 barium hydroxide
BHA butylated hydroxy anisole
BHT 3,5-di-tert-butyl-4-hydroxytoluene
°C degrees Celsius
CAA Clean Air Act
CAS Chemical Abstracts Service
CCR California Code of Regulations
CFR Code of Federal Regulations
cm centimeters
CONC AWE Conservation of Clean Air and Water-Europe
CO 2 carbon dioxide
Cooper Cooper Power Systems
cSt centistokes (millimeter squared per second or mm2/s)
CWA Clean Water Act
DEHA bis-2-ehtylhexyl hexanedoic acid
DI deionized
DL detection limit
DO dissolved oxygen
DTSC California Department of Toxic Substances Control
EPA United States Environmental Protection Agency
EPCRA Emergency Planning and Community Right-to-Know Act
ETV Environmental Technology Verification
FDA Food and Drug Administration
FMRC Factory Mutual Research Center
FRP facility response plan
g gram
HML Hazardous Materials Laboratory
HMWH high molecular weight hydrocarbons
HSC Health and Safety Code
IARC International Agency for Research on Cancer
LEG International Electrochemical Commission
IEEE Institute of Electrical and Electronic Engineers
KOH potassium hydroxide
kPa kilopascals
KV or kV kilovolts
ka kilovolt amperes
LCso lethal concentration for 50% of the test population
LD50 lethal dose for 50% of the test population
mg/kg milligrams per kilograms
June 2002 xvi
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mg KOH/g milligram of potassium hydroxide per gram
mg/L milligrams per liter
ml milliliter
mmHg millimeters of mercury
MSDS material safety data sheet
MVA megavolt amperes
NEC National Electrical Code
NIOSH National Institute for Occupational Safety and Health
NRMRL National Risk Management Research Laboratory
OECD Organization of Economic Cooperation and Development
OPPTD Office of Pollution Prevention and Technology Development
OPPTS Office of Prevention, Pesticides and Toxic Substances
ORD EPA's Office of Research and Development
OSHA Occupational Safety and Health Administration
QA/QC quality assurance/quality control
PCBs polychlorinated biphenyls
PEL permissible exposure limit
PPE personal protective equipment
ppm parts per million
pS/m picosiemens per meter
psi pounds per square inch
psig pounds per square inch gauge
RCRA Resource Conservation and Recovery Act
SIRI Safety Information Resources, Inc.
SOP standard operating procedure
SMHS San Mateo High School
SPCC spill prevention, control, and countermeasures
SVOCs semivolatile organic compounds
TBHQ mono-di-tert-butyl hydroquinone
TCLP toxicity characteristic leaching procedure
TERC Thomas Edison Research Center
TI Texas Instruments
TOCC total organic carbon content
TSCA Toxic Substances Control Act
TWA time weighted average
UL Underwriters Laboratory
USAGE U.S. Army Corps of Engineers
U.S. EPA United States Environmental Protection Agency
WET waste extraction test
June 2002
xvii
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Glossary of Terms
Dielectric breakdown
(ASTMD1816;gap)
The dielectric breakdown voltage indicates the fluid's ability to
resist electrical breakdown at a power frequency of 60 Hz and is
measured as the minimum voltage required to cause arcing
between two submerged convex electrodes, 0.04" or 0.08" apart, in
the fluid. This test is recommended for virgin product acceptance
testing and evaluation of in-service fluids. The method is
considered more sensitive to the adverse effects of moisture in the
oil in insulating systems.
Dielectric breakdown
(ASTMD3300;
impulse)
The impulse dielectric breakdown voltage indicates the fluid's
ability to resist electrical breakdown under transient voltage
stresses such as lightning and power surges and is measured as the
voltage required to cause arcing between submerged electrodes
under prescribed conditions.
Dielectric breakdown
(ASTM D877;
minimum)
The dielectric breakdown voltage at a 60 Hz test voltage indicates
the fluid's ability to resist electrical breakdown under prescribed
test conditions. It is measured as the minimum voltage required to
cause arcing between two submerged planar electrodes, 0.1" apart,
in the test fluid. This test is recommended for virgin product
acceptance testing.
Dissipation Factor
(maximum)
This factor is a measure of the dielectric losses in the fluid. A low
dissipation factor indicates low dielectric losses and a low
concentration of soluble, polar contaminants.
Diunsaturated fatty
acids
Fatty acids consisting of several carbons with 2 carbon-carbon
double bonds (e.g., Cl8:2).
Fire point
Flash point
Interfacial tension
The lowest temperature at which the fluid will sustain burning for
5 seconds.
The lowest temperature corrected to a barometric pressure of 101.3
kPa (760 mmHg) where a test flame causes the test fluid's vapor to
ignite.
The measure offeree required to draw a planar ring of platinum
wire, located below the water surface, across the oil/water
interface.
June 2002
XVlll
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Kinematic viscosity
The amount of the time for a volume of liquid to flow under
gravity through a calibrated glass capillary viscometer.
Linoleic acid
Linolenic acid
A diunsaturated acid found as a triglyceride in high oleic oils.
has 18 carbons and 2 carbon-carbon double bonds (C18:2).
It
A triunsaturated acid found as a triglyceride in high oleic oils. It
has 18 carbons and 3 carbon-carbon double bonds (C18:3).
Monounsaturated
fatty acids
Fatty acids consisting of several carbons with 1 carbon-carbon
double bond (e.g., CIS: 1).
Neutralization
number
This number is a measure of the acidic or basic substances in the
oil and is used as a quality control indicator. An increase in the
value of the neutralization number may indicate degradation of the
oil due to increased water content. This value is measured by
dissolving the oil sample in a mixture of toluene, isopropyl
alcohol, and a little water. A color indicator, />-naphtholbenzein, is
added to this mixture and then titrated with potassium hydroxide
until an orange (acid) or green-brown (base) color change occurs.
Oleic acid
A monounsaturated acid found as a triglyceride in many natural
oils such as sunflower, olive, and safflower oil. This compound
has 18 carbons with one carbon-carbon double bond (C18:l).
Polar contaminant
A polar contaminant in a dielectric fluid ionizes and imparts
electrical conductivity to the solution. Examples of polar
contaminants in dielectric fluids include water, dirt, and metals.
Polyunsaturated fatty
acids
Fatty acids consisting of diunsaturated and triunsaturated fatty
acids (i.e., several carbons with 2 or more carbon-carbon double
bonds, respectively such as C18:2, C18:3)).
Pour Point
The lowest temperature at which the movement of the oil is
observed. An average electrical power distribution application will
require a dielectric fluid to have a pour point below -20°C.
Saturated fatty acids
Fatty acids consisting of several carbons and no carbon-carbon
double bonds (e.g., C18:0).
June 2002
xix
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Stearic acid
A saturated acid found as a triglyceride in high oleic oils. It has 18
carbons and no double carbon bonds (C18:0).
Triunsaturated fatty
acids
A triunsaturated acid found as a triglyceride in high oleic oils. It
has 18 carbons and 3 carbon-carbon double bonds (C18:3).
Water content
The concentration of water in the oil expressed in milligrams per
kilogram (mg/kg) or parts per million (ppm). Water in a vegetable
oil-based insulating oil will increase the breakdown rate of fatty
acid esters and leads to the formation of polar contaminants. This
breakdown rate is proportional to the amount of water present in
the oil. A significant increase in the value of the neutralization
number is an indicator this reaction is occurring due to the
increased acidity of the fluid. Compared to conventional mineral
oils, vegetable oils have a much higher water content saturation
point, typically well over 1,000 ppm at room temperature. The
recommended range for post-processed vegetable oil is 2 to 5% of
the saturation level (25 to 50 ppm).
June 2002
XX
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Section 1. Introduction
Background
Electric power utilities use electrical transformers for a variety of applications, including power
distribution. The transformers generate significant amounts of heat, and must contain
cooling/insulating (dielectric) mediums to prevent gas formation, electrical shorts, fire or
explosion, and transformer damage. The media can be a solid, liquid such as mineral oil, high
molecular weight hydrocarbons (HMWHs), synthetic oils such as silicone, or a gas such as sulfur
hexafluoride. Most transformers currently use some type of mineral oil as the cooling fluid;
however HMWHs and synthetics (less-flammable fluids) are used in transformers that must
operate in safety-related applications (near or inside buildings). Recently, transformer fluid
vendors have developed vegetable seed oil-based dielectric fluids. These fluids have been
certified as meeting "less-flammable" safety-related requirements by organizations such as
Underwriters Labs or Factory Mutual.
Typically, liquid-containing distribution class transformers store from 30 to 1,000 gallons of oil.
Spills from transformers are potentially an environmental concern because even small amounts
of oil can contaminate bodies of water, possibly deplete oxygen, coat plant and animal life, be
toxic or form toxic products, affect breeding, produce rancid odors, or foul shorelines or other
habitats. Effects on soils are not as well characterized.
Polychlorinated Biphenyls (PCBs) are still used but no longer produced because of their high
toxicity - they are regulated under the federal Toxic Substances Control Act (TSCA). According
to Title 40 Code of Federal Regulations Section 261.8 (40CFR261.8), dielectric fluids and
electric equipment with dielectric fluids regulated under TSCA are not regulated under the
federal Resource Conservation and Recovery Act (RCRA). Non-PCB transformer fluids
generally do not meet the requirements for regulation as hazardous waste under RCRA; however,
mineral oils that have been in service for approximately 10 years may have exceeded California's
acute toxicity levels for copper due to leaching from the transformer coils.
Mineral oil transformer fluid spills to the soil are presumed to be hazardous until the
contaminated soil has been tested. The clean-up levels for these spills vary depending on the
responsible State and local regulatory authority overseeing the clean-up.
Facility owners and operators that handle, store, or transport oils (e.g., petroleum oils, vegetable
oils, animal fats, etc.) are required to report an oil spill which "may be harmful to the public
health or welfare, or environment". A reportable oil spill is defined as one that either (1) violates
water quality standards, (2) causes a sheen or discoloration on the surface of a body of water, or
(3) causes a sludge or emulsion to be deposited beneath the surface of the water or on adjoining
shorelines. The oil spill must be contained, cleaned up, and reported to the National Response
Center, the federal point of contact for all chemical and oil spills.
Table 1 illustrates the types and amounts of waste oil change-outs, spills, and associated clean-up
costs that a small to medium-sized electrical utility transmission system monitoring and
maintenance facility experienced in 1992. This facility, which is only one of several operated by
June 2002 1
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the electrical utility, generated 155 tons of spilled oil and contaminated soil, most of which was
caused by accidents involving utility poles and transformers.
Table 1. Summary of 1992 PCB Waste Generation - Electric Utility
Waste Generated Annual Quantity Annual
Generated (tons) Costs ($)
Oil Spill and Leak
Residue 155 46,000
Source of Waste: Primarily damage to transformers
Waste Oil from
Electrical Transformers 126 100,000
Source of Waste: Draining of oil prior to reconditioning or decommissioning transformers
Wastes Containing PCB 28 50,000
Source of Waste: Primarily damage to transformers and PCB recovery
Source: U.S. EPA, Risk Reduction Engineering Laboratory, EPA/600/S-92/063 - October 1992
Envirotemp®FR3™Dielectric Insulating Fluid
Cooper Power Systems (Cooper) has developed a vegetable oil-based dielectric fluid comprised
of >98.5% vegetable oil and <1.5% additives. Envirotemp®FR3™ fluid is used in liquid-filled
electrical apparatus such as transformers to act as an electrical insulating medium. This material
is currently used in pole, padmount, network, and small and medium power transformers with a
voltage rating of 35 kV and a maximum rating of 10 MVA. Cooper is preparing to retrofill two
69 kV transformers, one 35 MVA, and one 50 MVA, for a midwestern facility. Other electrical
apparatus include loadbreak switches, cables, electromagnets, klystron modulators, power
supplies, and bushings. To date, approximately 475 transformers currently use
Envirotemp®FR3™ fluid. Customers that use this product include Universal Studios, Miller
Park, US Gypsum, and the Jet Propulsion Laboratories.
Evaluation Approach
The Envirotemp^RS fluid evaluation was designed to provide the data necessary to draw
conclusions on the technology's performance, chemical composition, toxicity, and safety. The
evaluation included a review of supporting documents, information, and laboratory data
submitted by Cooper, and field sampling to provide independent data on the technology's
performance, chemical composition, and toxicity.
The field sampling was conducted at Cooper's manufacturing facility in Waukesha, Wisconsin
and at San Mateo High School in San Mateo, California and Texas Instruments in Santa Cruz,
California. San Mateo High School and Texas Instruments are customers of Artwel Electric, Inc.
June 2002 2
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(Artwel), Cooper's distributor. Artwel and Cooper agreed to provide staff and access to these in-
service transformers as part of the field sampling activities. Prior to the field sampling, the
Department of Toxic Substances Control staff (DISC) prepared a Technology Evaluation
Workplan (Workplan) to identify specific field objectives, data quality objectives, testing
procedures, and roles and responsibilities. Cooper assumed overall responsibility for providing
staff for sampling and obtaining access to all locations where field sampling was conducted.
DISC staff provided independent oversight and was present to observe all field sampling
activities. The agreed-upon Workplan specified that DTSC would maintain a record of all
samples collected, and record all measurements and observations made during sampling.
The oldest transformer in service with Envirotemp^RS fluid as the dielectric insulating fluid is
4.8 years old. Since the technology is still new, no data was available to assess the performance
of Envirotemp®FR3™ fluid over a transformer's service life or the fluid's waste characteristics at
the end of the transformer's service life. Based on accelerated life tests, Cooper expects the
normal service life of an Envirotemp®FR3™ transformer to be about 20 years.
June 2002
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Section 2. Description of Technology
Cooper has developed a vegetable oil-based dielectric fluid comprised of >98.5% vegetable oil
and <1.5% additives. Antioxidants are added to prevent the unsaturated bonds in the oil from
polymerizing with oxygen from the air. Color is added to visually differentiate it from mineral
oil. Envirotemp®FR3™ fluid is manufactured using a food-grade vegetable oil purchased from an
off-site processor. Each vegetable oil shipment is tested and compared to Cooper's quality
control specifications before it is accepted. At Cooper's facility, the oil is degassed and then
blended with antioxidant and color additives. During and after the blending process, the product
is tested and compared to Cooper's product specifications.
Envirotemp®FR3™ fluid is used in electrical apparatus such as liquid-filled transformers as an
electrical insulating medium. In addition to providing electrical insulation, the oil transports heat
generated around the transformer's windings, core and connected circuits to cooling surfaces
where the heat is dissipated by radiation and convection to the outside air. For this
verification/certification, 3-phase transformers were the only electrical apparatus sampled. An
example of a 3-phase transformer is presented in Figure 1. The main parts of a transformer are
the core, the windings, the tank containing the core and windings, and the cooling system. The
core is made of thin steel sheets laminated with varnish or an oxide film to insulate the sheets
from each other. Two distinct sets of coils called windings are wound upon the core at a suitable
distance from each other. These windings consist of wire insulated with a kraft paper covering.
When the transformer is in-service, the oil and core expands and contracts as the heat generated
by the transformer windings varies with the load. As the oil becomes heated, the hot oil rises to
the top of the transformer where heat is dissipated to the outside, and then moves along the case
to the bottom. Fins are sometimes attached to deflect moving air against the case and to increase
the cooling area. Overheating the core can lead to damage, and overheating the windings can
cause the paper insulation to deteriorate, which reduces the life of the transformer. Nearly all
distribution transformers in the United States are sealed to prevent the oil from oxidizing with the
air.
Figure 1. Transformer Cross Section
III
June 2002
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Some of the more expensive transformers or transformers servicing critical electrical loads are
designed to have a nitrogen gas seal to prevent the oil from oxidizing with the air. The
expansion of the oil reduces the volume of the nitrogen gas causing the gas pressure to be greater
during power load periods. Large transformers may also use radiators, fans, circulating pumps or
cooling water to increase heat exchange.
According to Cooper, the Institute of Electrical and Electronic Engineers (IEEE) accelerated life
tests performed on transformers using Envirotemp®FR3™ fluid passed with an operational
equivalence of 100 years. This operational equivalence is five times the normal transformer.
According to Cooper, the insulation in the Envirotemp®FR3™ transformers showed less
degradation than the insulation in identical transformers using mineral oil per this test. Based on
this information, the normal service life is expected to be in the range of 20 years.
Because this fluid exhibits a high fire point (>300°C), Envirotemp®FR3™ fluid is classified by
Underwriter Laboratories (UL) and approved by Factory Mutual Research Center (FMRC) as a
less flammable transformer fluid. Typically, the less-flammable fluids are used in transformers
where additional fire safety is required, such as inside buildings, rooftops, vaults, and adjacent to
buildings.
Figure 1 shows a side view cutaway of the transformer tank and housing. Referring to Figure 1,
the transformer coils and windings (labeled 15), are housed in a tank (labeled 10), which is filled
with Envirotemp®FR3™ fluid. The fluid level is labeled 18. The transformer is also equipped
with an automatic pressure release valve (labeled 40).
Section 450-23 of the National Electrical Code (NEC) contains the installation requirements for
less-flammable liquid insulated transformers housed inside or near buildings. This section
outlines simpler requirements for installing transformers in fire-sensitive areas when the
transformers are filled with a less-flammable insulating fluid compared to mineral oil. This
section requires that transformers using less flammable fluids such as Envirotemp®FR3™ fluid
must meet specific requirements of the UL or FMRC Approval.
The UL requirements specify that a classified less-flammable fluid such as Envirotemp®FR3™
fluid used in 3-phase transformer installations with a rating of 45 to 10,000 kVA meet three "use
restrictions". These "use restrictions" are as follows: (1) only 3-phase transformers with tanks
capable of withstanding an internal pressure of 12 psig without rupture be used, (2) transformer
tanks are equipped with pressure release valves to limit the internal pressure buildup and prevent
tank rupture due to gas generation under low current arcing faults, and (3) transformers are
equipped with either current limiting fuses or other overcurrent protection.
For the FMRC requirements, an approved less-flammable liquid insulated transformer is used in
the 35kV Class or lower transformer installations rated at 5 kVA to 10,000 kVa for naturally
cooled class transformer. The transformers are equipped with electrical protection for clearing
high and low current faults. The transformer tank must also withstand an internal pressure of 20
psi for a cylindrical shaped tank and 15 psi for a rectangular shaped tank without rupture. All
transformer tanks are required to be equipped with a pressure relief device.
June 2002 5
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Section 3. Verification Objectives
The field sampling objectives were to verify the applicant's technology performance claims for
the Envirotemp®FR3™ dielectric insulating fluid listed below.
Verification/Certification Claim #1 - General Performance
• In the following composition ratio (>98.5% vegetable oil, <1.5% additives),
Envirotemp^RS fluid meets the dielectric breakdown specifications listed in ASTM
D3487, Standard Specification for Mineral Insulating Oil, ASTM D5222, Standard
Guide for High Fire Point Fluids of Petroleum Origin, IEEE C 5 7.121, 1998 IEEE Guide
For Acceptance and Maintenance of Less Flammable Hydrocarbon Fluid in
Transformers, IEC 1099, Specifications for Unused Synthetic Organic Esters for
Electrical Purposes, and LEG 1203, Synthetic Organic Esters for Electrical Purposes-
Guide for Maintenance of Transformer Esters in Equipment.
Verification/Certification Claim #2 - Aquatic Biodegradability
• Envirotemp®FR3™ fluid biodegrades 99% based on the average of several biodegradation
tests, as measured by OPPTS 835.3110, Ready Biodegradability
Verification/Certification Claim #3 - Flammability
Envirotemp®FR3™ fluid has a Flash Point of at least 320°C, and Fire Point of 350°C,
based on the average of several performance tests by independent labs performing ASTM
D92 (Cleveland Open Cup).
Verification/Certification Claim #4 - Acute Toxicity
• Results for virgin product tested by U. S. EPA/600/4-90/027F Test for Acute Toxicity of
Effluents and Receiving Waters to Freshwater and Marine Organisms passes the aquatic
toxicity characteristic criterion specified in the Code of California Regulations, Title 22,
Section 66261.24(a)(6).
Other Verification/Certification Tests:
• To verify that Envirotemp®FR3™ fluid consists of >98.5 % vegetable oil and <1.5%
additives, and that the formulation meets selected Cooper product specifications.
• To establish a baseline for measuring potential metals leaching and oil degradation of
Envirotemp®FR3™ fluid under electrical loading over time.
• To evaluate the worker health and safety aspects of Envirotemp®FR3™ fluid.
• Estimate costs of Envirotemp®FR3™ fluid as compared to those of mineral oil.
June 2002 6
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Section 4. Verification Activities and Results
4.1 Verification Activities
4.1.1 Field Sampling
Prior to sampling, DISC developed a technology evaluation workplan, which described the
sample collection procedures and analyses to be performed. A copy of the technology evaluation
plan is included in Appendix B. To ensure independent and representative samples were
collected, DTSC personnel oversaw the sample collection in the field for virgin product and in-
service transformers. Samples were assigned a field sample identification number, which was
determined prior to sampling. Table 2 lists the samples collected and the analysis performed as
part of this verification /certification. Proper chain of custody and storage procedures were
followed. Laboratories sent data directly to DTSC. For more information on the sample
collection procedures, refer to Appendix B.
Virgin Product
Samples of virgin fluid were collected at Cooper's dielectric fluid formulating facility in
Waukesha, Wisconsin. Three different lots were sampled by a Cooper representative with DTSC
oversight. A total of 12 samples (four samples per lot) were collected. One sample from each of
the three lots was analyzed for SVOCs, metals, acute toxicity, aquatic biodegradation, and select
AOAC and ASTM methods. One duplicate was analyzed for SVOCs, metals, and select AOAC
and ASTM methods. Two matrix spikes and an equipment blank were analyzed for SVOCs and
metals. A field blank was analyzed for metals only. Table 2 lists the analyses performed on each
sample collected. Duplicate samples collected from each lot were held for future analyses if
questionable data were produced.
Cooper also collected split samples from each lot sampled by DTSC for future quality control
analyses. These split samples were analyzed for the following properties: dielectric breakdown
voltage by ASTM D877 and Dl816, dissipation factor at 25°C by ASTM D924, water content by
ASTM Method D1533, interfacial tension by ASTM D971, neutralization number by ASTM
D974, pour point by ASTM D97, flash and fire point by ASTM D92, and viscosity at 40°C and
100°C by ASTM D445. These samples were initially analyzed by Cooper to verify the
dissipation values reported by Doble Engineering.
DTSC sampled two lots from 55-gallon drums (Lots 01D1 and 01C6) while the third lot (Lot
01P2) was sampled from a 2,500-gallon finishing tank. Drum samples were collected using a
glass Coliwasa. A new glass Coliwasa was used at each new drum sampled to reduce the
potential of cross contamination between samples. The finishing tank samples were collected at
a sampling spigot located beneath the tank. Approximately one pint of oil was drained from the
tank via the spigot prior to sampling. Sampling activities are presented in Figures 2 and 3.
June 2002
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.in-
2. Envirotemp FR3 Samples and Analyses
Sample
ID
VFR3-01
WR3-02
WR3-03
WR3-04
WR3-05
VFR3-06
WR3-07
WR3-08
WR3-09
WR3-10
VFR3-11
WR3-12
WR3-15
WR3-16
ISFR3-01
ISFR3-02
ISFR3-03
ISFR3-04
ISFR3-05
ISFR3-06
ISFR3-07
Lot No.
01D1
01D1
01D1
01D1
01C6
01C6
01C6
01C6
01P2
01P2
01P2
01P2
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
SVOCs
a
a
a
a
a
a
c
c
a
a
a
c
c
a
c
Metals
b
b
b
b
b
b
b
b
b
b
b
b
Acute
Toxicity
e
e
e
Aquatic
Biodegradation
d
d
d
AOAC
Methods
f
f
f
f
f
f
f
f
ASTM
Methods
g,h,i,k,l,m,n,
P,V
g,h,i,k,l,m,n,
p,q,r
g,h,i,k,l,m,n,
P,Q,r
g,h,i,k,l,m,n,
P,V
g,o,p,q,r,s
g,o,p,q,r,s
g,o,p,q,r,s
g,o,p,q,r,s
Comments
Duplicate not analyzed. Sampled from
same drum as VFR3-01 .
Matrix spike
Duplicate not analyzed. Sampled from
same drum as VFR3-03.
Analyzed duplicate. Sampled from
same drum as VFR3-05.
Analyzed duplicate
Duplicate not analyzed. Sampled from
same drum as VFR3-07.
Matrix spike
Duplicate not analyzed
Duplicate not analyzed
Equipment blank
Field blank
Field blank
Equipment blank
Field blank
The letter assigned to each sample corresponds to the analysis performed:
a - U.S. EPA Method, 8270 (SVOC screening) and prepared per U.S. EPA Method 3580
b - U.S. EPA Method 6010 (metals screening) and prepared per U.S. EPA Method 3051
c - U.S. EPA Method, 8270 (SVOC screening) and prepared per U.S. EPA Method 3510
d - U.S. EPA Method OPPTS 835.31 10, Ready Biodegmdability
e - U.S. EPA Method 600/4-90/027F, Methods for Measuring the Acute Toxicity of Effluents and Receiving Waters to Freshwater and
Marine Organisms and prepared per the requirements in California Regulations, Title 22, Section 6626 1 .24(a)(6), Static Acute
Bioassay Procedures for Hazardous Waste Samples.
f - AOAC Method 981.11, Oils and Fats, AOAC Method 972.28, Total Fatty Acids in Oils and Fats, AOAC Method 963 .22, Methyl Esters
of Fatty Acids in Oils and Fats, AOAC Method 983.15, Phenolic Antioxidants in Oils, Fats, and Butter, and AOAC Method 977.17,
Polymers and Oxidation Products of Vegetable Oil.
g - ASTM Method D92, flash and fire point n - ASTM Method D924, dissipation factor (25°C & 100°C)
h - ASTM Method D97, pour point o - ASTM Method D924, dissipation factor (25°C)
i - ASTM Method D445, kinematic viscosity (0, 40, & 100 C) p - ASTM Method D971, interfacial tension
j - ASTM Method D445, kinematic viscosity (40 C) q - ASTM Method D974, neutralization number
k - ASTM Method D877, dielectric breakdown (minimum) r - ASTM Method Dl 533, water content
1 - ASTM Method D1816, dielectric breakdown (gap) s - ASTM Method D4308, conductivity
m - ASTM Method D3300, dielectric breakdown (impulse)
June 2002
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Figure 2. Tank Sampling
Figure 3. Sampling Spigot
In-Service Transformer
In-service fluid samples were taken from four transformers that have been in use for at least one
year and part of a regular sampling/testing program. In-service fluid samples were collected by
Cooper and Artwel Electric, Inc. representatives under DTSC oversight and in conjunction with
the normal on-going sampling program. Only one sample per transformer was collected to
minimize the amount of fluid removed from each transformer and the impact to the ongoing test
program. New Tygon tubing connectors were used at each transformer fluid sampling port to
reduce the potential of cross contamination.
The transformer pressure valve is checked to confirm the unit is under positive pressure prior to
sampling. A stainless steel sampling cylinder with Tygon tubing is attached to the sampling port.
Oil is purged from the transformer into the sampling cylinder to ensure ambient air is not
introduced into the transformer. After a few pints of oil have been purged through the sampling
cylinder, the sample bottles are filled using Tygon tubing attached to the sampling cylinder.
Four transformers were sampled as part of this verification/certification: two owned by Cooper
located in Waukesha, Wisconsin, one owned by San Mateo High School (SMHS) in San Mateo,
California and one owned by Texas Instruments (TI) in Santa Cruz, California. Weather
conditions during sampling at the Cooper transformers consisted of intermittent snow showers.
Weather conditions during sampling at SMHS and TI were dry and sunny. Equipment
information such as the transformer type, size, and service date is listed in Table 3. Transformer
sampling activities are shown in Figures 4 and 5.
June 2002
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Table 3. Equipment Information on Sampled Transformers
Owner
Cooper
Cooper
San Mateo
High
Texas
Instruments
Transformer Information
Type
3 -phase pad mounted
transformer
3 -phase pad mounted
transformer
3 -phase pad mounted
transformer
3 -phase pad mounted
transformer
Serial
Number
966001430
966001429
0037017339
0026000482
kVA
Rating
(kVA)
225
225
225
2500
Primary
Voltage
(kV)
5
5
21
21
Secondary
Voltage
(kV)
480
480
480
480
Temp.
Rise
(°Q
65
65
65
65
Initial
In-Service
Date
July 1996
July 1996
March 2000
May 2000
Figure 4. Transformer Sampling
performed at SMHS and TI
Figure 5. Transformer Sampling at
Cooper
4.1.2 Historical Data
In addition to field sampling conducted under DTSC oversight, DTSC staff reviewed internal
product development testing data provided by Cooper. These data were collected as part of
ongoing testing for internal use by Cooper. This data collection happened prior to entry into the
verification/certification agreement. These data provided background information on the
technology performance for past virgin lots and to develop trends on the fluid's performance in
tested transformers for select ASTM parameters. Historical data collected by independent testing
facilities under contract with Cooper were also used.
June 2002
10
-------
4.2 Results: Objective 1, General Performance
For this verification/certification, Envirotemp®FR3™ fluid was tested for select physical (e.g.,
pour point, viscosity), chemical (e.g., neutralization number, interfacial tension, water content),
thermal (e.g., flash and fire point) and dielectric (e.g., dielectric breakdown, dissipation factor)
properties to verify general performance claims listed in Cooper's product specifications. The
results for the thermal properties are discussed in Section 4.4. Since no standard specifications
exist for vegetable oil-based dielectric fluids, two ASTM specifications, two International
Electrochemical Commission (IEC) specifications, and one Institute of Electronic and Electrical
Engineers (IEEE) specification were used to evaluate Envirotemp®FR3™ fluid performance.
ASTM D3487 and ASTM D5222 were developed to evaluate the performance of virgin mineral
oil-based dielectric fluids and virgin high molecular weight hydrocarbons (HMWH),
respectively. IEEE C57.121 was developed to evaluate the performance of virgin silicone fluids.
IEC 1099 and IEC 1203 were developed to evaluate the performance of virgin synthetic organic
esters and in-service synthetic organic esters, respectively. These specifications were selected
since Cooper claimed the dielectric breakdown voltages for Envirotemp®FR3™ fluid were similar
to those of mineral oil, HMWH, silicone and synthetic esters. The physical and chemical
properties of virgin Envirotemp®FR3™ fluid were only compared to Cooper specifications since
these properties differ due to the nature of the fluid. Samples were sent to Doble Engineering
(Doble), an independent testing laboratory, to perform testing for select dielectric, physical, and
chemical properties using the ASTM methods listed in Table 2. The ASTM, IEEE, IEC, and
Cooper specifications and virgin sample results are presented in Table 4.
4.2.1 Virgin Product Performance Results
Dielectric Properties (or Dielectric Strength)
Dielectric breakdown is the common property used to evaluate a dielectric fluid's
performance. Table 4 lists the minimum dielectric breakdown values specified by ASTM
D3487, ASTM D5222, IEEE C57.121, IEC 1099 and Cooper that were used to evaluate
Envirotemp®FR3™ electrical performance. The dissipation factor is compared to the
Cooper specification since chemical properties vary between the various types of
dielectric fluids.
Dielectric Breakdown
Both the minimum and gap dielectric breakdowns indicate the minimum voltage required
to cause arcing between two submerged electrodes in a dielectric fluid. A low dielectric
breakdown value may indicate the presence of water, dirt, or other electrically conductive
particles in the oil, which may cause damage to the transformer core or windings due to
arcing. The dielectric breakdown voltages for virgin Envirotemp®FR3™ samples were
higher than the minimum dielectric breakdown voltage for four specifications. For the
0.04-inch (1.0 mm) gap dielectric breakdown, sample values were higher than the
minimum voltage listed for all five specifications. No precision criteria were specified in
ASTM Method D877 (minimum breakdown voltage)
June 2002 11
-------
Table 4. Performance Results for Virgin EnvirotempRFR3 Samples
Performance Parameters
Specification Standards
Cooper
ASTM D3487
ASTM D5222
IEEE C57. 121
IEC 1099
Sampling Results
Lot 01D1
VFR3-01
Lot 01C6
VFR3-05
VFR3-07
Lot 01P2
VFR3-10
Average
Physical Properties
Pour Point (°C)
Viscosity (cSt)
@100°C
@ 40°C
@ 0°C
<-18
<8.5
<35
NA
-40
<3
<12
76
-24
11.5-14.5
100-140
1800-2200
<-21
—
100-130
—
<-45
-
<35
—
-18
8
32.63
188.01
-18
7.88
32.67
187.14
-18
7.9
32.79
187.53
-18
7.95
32.74
187
-18
7.93 ±0.09
32.71 ±0.11
187.42 ±0.72
Dielectric Properties
Dielectric breakdown (kV)
minimum
gap
impulse
Dissipation Factor (%)
@ 25°C
@ 100°C
>30
>20
—
<0.15
—
>30
>28
>145
<0.05
<0.3
>42
>30
—
<0.01
<0.3
> 25-30
> 20-30
—
< 0.05-0.1
< 0.30-1.0
—
23
—
—
2.5
45
36
170
0.127
2.70
45
37
168
0.159
3.17
45
34
164
0.157
3.23
46
39
168
0.127
2.46
45 ±1
37 ±3
168 ±4
0.143 ±0.029
2. 89 ±0.59
Chemical Properties
Interfacial Tension (dyne/cm)
Neutralization Number (mgKOH/g)
Water Content (ppm)
>18
<0.07
<75
>40
<0.03
<35
>45
<0.01
<25
> 38-40
<0.03
<25
—
<0.03
<200
28
0.03
53
27
0.03
59
28
0.02
57
28
0.03
52
28 ±1
0.03 ±0.01
55 ±5
Note: The dielectric breakdown value listed in the five specifications is similar and is the basic property used to evaluate a dielectric fluid's performance. Since the
specification values vary due to the chemical and physical nature of the dielectric fluid type, the following values are compared to the Cooper performance
specification: viscosity, pour point, neutralization number, dissipation factor, interfacial tension, and water content. Data variability was calculated at 95% confidence using
a two-tailed T-test and assuming normal distribution.
Acronyms and Abbreviations:
— = No specification value available
ASTM D3487 = American Society for Testing and Materials (ASTM) standard specification for mineral insulating oil used in electrical apparatus.
ASTM D5222 = ASTM standard specification for high fire-point electrical insulating oil.
cm = centimeter
Cooper = Virgin product specification for Envirotemp® FR3™ developed by Cooper Power Systems
cSt = centistoke
IEC 1099 = International Electrochemical Commission (IEC) Specifications for Unused Synthetic Organic Esters for Electrical Purposes
IEEE C57. 121 = Institute of Electrical and Electronic Engineers (IEEE) 1998 IEEE Guide for Acceptance and Maintenance of Less Flammable Hydrocarbon Fluid in Transformers
KV = kilovolt
mgKOH/g = milligrams of potassium hydroxide per gram
ppm = parts per million
June 2002
12
-------
and ASTM Method D1816 (gap breakdown voltage). Since Envirotemp®FR3™ fluid's
dielectric breakdown values were higher than the values for each specification in Table 4,
the fluid met these performance criteria and would not likely cause damage to the
transformer core or windings due to arcing.
The impulse dielectric breakdown value is designed to determine the minimum voltage to
cause arcing in the fluid under lightning or power surge conditions. A high impulse
voltage may indicate the oil has a low contaminant or water content, which will not
adversely affect transformer performance. The impulse breakdown voltage for all
samples is higher than the minimum voltage specification for mineral oils under ASTM
D3487. Cooper does not have a specification value for the impulse breakdown voltage
but has found this value typically ranges from 130 to 170 kV in virgin product. The 95%
confidence interval for the data collected was ± 4.0 kV, which meets the precision criteria
of ±13 kV at 95% confidence listed in ASTM D3300. Envirotemp®FR3™ fluid meets
ASTM D3487's performance specification for the impulse dielectric breakdown voltage
and has values within the range of typical values exhibited in past virgin product lots.
Dissipation Factor
The dissipation factor is used to measure the dielectric losses to an insulating dielectric
fluid (such as oil) when it is exposed to an alternating electric field. For ASTM Method
D924, the dissipation factor is determined by passing an alternating electric current
through a test cell filled with dielectric fluid and measuring the capacitance with an
electronic bridge circuit. This value is also used to control the product quality, and to
determine changes in the fluid due to contamination or degradation during use. A low
dissipation factor indicates a low dielectric loss and a low contaminant concentration
(e.g., dirt, water, or metals).
For two samples, the dissipation factor at 25°C was measured below the maximum
Cooper specification value while the other two samples were slightly above this value.
The average dissipation factor for the samples (0.143%) was below the Cooper maximum
specification value. All samples were above the maximum value specified at 25°C and at
100°C for the other four specifications listed in Table 4. Cooper tested their split samples
from lots 01C6 and 01D1 to verify the dissipation factor at 25°C reported by Doble.
Cooper reported a dissipation factor of 0.131% for Lot 01C6 and 0.097% for Lot 01D1.
The precision criterion for results from two different laboratories, which is outlined in
ASTM Method D924, was used to evaluate the results from Doble and Cooper. The
difference between the results for Lot 01C6 was 0.039% and Lot 01D1 was 0.030%,
which met the precision criteria of being less than 25% percent of the higher result plus
0.001 (±0.041% for Lot 01C6 and ±0.033% for Lot 0ID 1). Past performance testing by
Doble measured the dissipation factor at 25°C of 0.0610%, which met the Cooper
specification. Cooper does not routinely test for the dissipation factor at 100°C but
reported three past samples had values ranging from 1.4% to 1.9%.
The average dissipation factor at 25°C did not meet the Cooper specification value of <
0.15%. All samples had higher dissipation factors at 100°C than past sample results
June 2002 13
-------
reported by Cooper, which may be due to contaminants introduced during product
storage, sample collection, sample preparation, or sample testing. However,
Envirotemp®FR3™ fluid did not meet the other four specifications for the dissipation
factor since these specifications were developed for other types of fluids.
Chemical Properties
Neutralization Number
The neutralization number is used as a quality control guide for lubricating oil
formulation. This number determines the relative amount of acidic substances contained
in the oil by the amount of base titrated. The acidic substances may be additives or
degradation products formed during service, such as oxidation products. When an in-
service fluid is analyzed for this property, an increasing neutralization number over time
may be an indicator of oil degradation due to oxidation. According to ASTM Method
D974, this test cannot be used to predict the corrosiveness of an oil under service
conditions. There is no general correlation known between the neutralization number and
the corrosive tendency of oils toward metals.
The neutralization number was consistent between lots and met Cooper's, ASTM D3487,
IEEE C57.121, and IEC 1099 specifications. The difference between the test results at
the 95% confidence level was 0.01 mg KOH/g, which met the repeatability criteria of
< 0.03 mg KOH/g listed in ASTM Method D974.
The split sample results tested by Cooper for Lots 01C6 and 01D1 were 0.027 mg KOH/g
and 0.025 mg KOH/g, respectively. The difference between Cooper and Doble data was
0.010 mg KOH/g for Lot 01C6 and 0.003 mg KOH/g for Lot 01D1, which met the
reproducibility criteria in ASTM Method D974 of less than 0.04 mg KOH/g.
Envirotemp®FR3™ fluid met Cooper's specification for the neutralization number and
also met the specifications for ASTM D3487, IEEE C57.121, and IEC 1099.
Water Content
Water content is used by industry to monitor a dielectric fluid's quality and as an
indicator of possible oil deterioration, which could adversely affect the oil's electrical
properties such as dielectric breakdown. This value is based on the relative saturation of
the water in the dielectric fluid. The relative saturation is based on the amount of water
dissolved in the oil divided by the total amount of water the oil could hold at that
temperature. The dielectric strength of oil starts to fall when saturation reaches about
50%. For petroleum based dielectric oils, 50% saturation at room temperature is 30-35
mg/kg. Synthetic esters and vegetable oil contain about 500-600 mg/kg of water at room
temperature and 50% saturation. A water content at or near 50% saturation may indicate
the oil has deteriorated and may cause a lower dielectric breakdown voltage, which can
damage the transformer core and windings.
June 2002 14
-------
Water content was tested by Doble using ASTM Method D1533, water in insulating
liquids. Water content for all four samples varied between 52 and 59 ppm which was less
than the maximum water content of 75 ppm specified by Cooper and 200 ppm specified
by IEC 1099. The water content was consistent between lots with a difference of 5.2
ppm, which was greater than ASTM Method D1533 precision criteria of less than 3 ppm
at the 95% confidence level.
Split sample results analyzed by Cooper reported the water content at 55 ppm for Lot
01C6 and 51 ppm for Lot 01D1. Comparing the results from Doble with the split sample
results, the data met the reproducibility criteria with a difference of less than 10 ppm.
Envirotemp®FR3™ fluid met the Cooper and IEC 1099 specifications for water content.
Envirotemp®FR3™ fluid was not expected to meet the ASTM D3487, D5222, and IEEE
specifications since these specifications are based on mineral and silicone oil properties.
Interfacial Tension
The interfacial tension was developed to gauge the presence of hydrophilic compounds in
mineral oil. Interfacial tension is a measurement of the amount offeree needed to detach
a platinum ring from the water-oil interface. In practice, this value has been found to be a
good indicator of oil degradation due to oxidation. A lower interfacial tension value
indicates a higher hydrophilic or water content in the oil which may adversely affect the
oil's dielectric properties.
The interfacial tension value measured for all samples was consistent and averaged 27.8
dynes/cm, which met Cooper's specification of < 18 dyne/cm. The data also met the
precision criteria in ASTM D971 where the results did not differ from the mean by more
than 2%. Split samples analyzed by Cooper reported the interfacial tension at 28
dynes/cm for Lot 01C6 and 27.7 dynes/cm for Lot 01D1. The differences between the
Cooper and Doble results met the reproducibility criteria in ASTM D971 by not differing
by more than 5% of the mean. Envirotemp®FR3™ fluid met the Cooper specification for
interfacial tension. It was not expected to meet the other four specifications since they
were based on the chemical properties for mineral oils, HMWH, silicone oils, and
synthetic esters.
Physical Properties
Pour Point
The pour point indicates the lowest temperature an oil can be used. The pour point was
consistently measured at -18°C for all samples and met the Cooper specification. The
data also met the precision criteria listed in ASTM D97. The split samples analyzed by
Cooper had pour points at -22°C for Lots 01C6 and 01D1. The difference between
Cooper's and Doble's results did not exceed 6°C per the reproducibility criteria in ASTM
Method D97. Envirotemp®FR3™ fluid met the Cooper specification for pour point but did
not meet the ASTM D3487, ASTM D5222, IEEE, and IEC 1099 specifications.
Envirotemp®FR3™ fluid was not expected to meet these latter specifications since they
June 2002 15
-------
were based on the physical properties for mineral oils, HMWH, silicone oils, and
synthetic esters.
Viscosity
The dielectric fluid's viscosity is used by transformer designers to confirm that the fluid is
appropriate for the unit under certain operating conditions. The viscosity of
Envirotemp®FR3™ fluid was determined at 0°C, 40°C, and 100°C. The results at 40°C
had a confidence coefficient of ± 0.11 cSt and met the precision criteria in ASTM Method
445 where the results did not differ by more than 0.35% of the mean (0.11 cSt) at the
95% confidence level. However, the viscosity results at 100°C differed by 0.09 cSt,
which was greater than the precision criteria of < 0.03 cSt.
Split samples analyzed by Cooper reported the viscosity at 40°C and 100°C at 32.13 cSt
and 7.47 cSt for Lot 01C6, and at 32.68 cSt and 7.49 cSt for Lot 01D1, respectively. The
precision criteria for results from two separate laboratories should not differ more than
0.70% of the mean. The results for Lot 01C6 met the precision criteria for values
measured at 40°C but not at 100°C. Results for Lot 01D1 did not meet the precision
criteria. No precision criteria were listed in the method for viscosity at 0°C.
Envirotemp®FR3™ fluid met Cooper specifications for viscosity at 40°C and 100°C.
Cooper has no specification for viscosity at 0°C. Although Envirotemp®FR3™ fluid did
not meet the other specifications for viscosity, it was not expected since those
specifications were based on the physical properties of mineral oils, HMWH, silicone
oils, and synthetic esters.
4.2.2 In-service Transformer Fluid Results
In-service transformer samples were tested for dissipation factor at 25°C, water content,
interfacial tension, neutralization number, and conductivity. Past available monitoring results for
each transformer over its service life have been plotted on graphs and are presented in Figure 6.
Interfacial tension results are compared only to Cooper specifications to evaluate the fluid
performance. The dissipation factor, water content, and neutralization number for
Envirotemp®FR3™ fluid are compared to the IEC 1203 specification because Envirotemp®FR3™
fluid is reported to have similar fluid characteristics to synthetic esters when in use. Table 5
presents the sample results obtained as part of this verification/certification along with the ASTM
and IEEE specifications to illustrate the difference in the fluid characteristics with mineral oil,
HMWH, and silicone oil, respectively.
The sample results for the dissipation factor at 25°C ranged from 0.120% to 0.196% and met the
Cooper and IEC 1203 specifications for in-service fluid. When the historical data for the oldest
transformers (S/N 966001429 and 966001430) are plotted over time, the dissipation factor
appears to gradually increase. The relatively small changes in the data over the service life for
the oldest transformers indicate the fluid has not degraded with use.
June 2002 16
-------
Figure 6. Trends for In-Service Transformer Parameters
(Dissipation Factor, Neutralization Number, Water Content, Volume Resistivity,
Interfacial Tension)
p
S n R
«
§
•s 0 4
1
W
™02
Q U.Z
• ISFR3-02(S/N 96600 1429)
D ISFR3-03 (S/N 26000482)
X ISFR3-06 ((S/N 370 1 7339)
A ISFR3-01 (S/N 96600 1430)
it-L^ '^uo ^ominuea oervice rnaxirnurn
p*a& »A * X x x
3123
Years in Service
X A
4 J
400
D)
B) 300
Ł
c
"c 200
o
O
s> 100
j
0
• ISFR3-02 (S/N 96600 1 429)
D ISFR3-03 (S/N 26000482)
A ISFR3-01 (S/N 966001430)
A A,, A
*A**4 »* SF • A .
0 1.0 2.0 3.0
Years in Service
'
"
A •
•
4.0 5
0
o
E
Z
N
•! nm '
t
• ISFR3-02 (S/N 96600 1 429)
X ISFR3-06 (S/N 37017339)
A ISFR3-01 (S/N 96600 1430)
X
A
31234
Years in Service
A
,
1.E+16
o 1 E+15
CJ
~ 1 E+14
t) {
« j
$ 1 E+13
E
3 1 F+12
(
• ISFR3-02 (S/N 966001429)
D ISFR3-03 (S/N 26000482)
X ISFR3-06 (S/N 37017339)
A ISFR3-01 (S/N966001430)
AA. A
AA ^
3123
Years in Service
A
in
4 !
?
« 30
>
T i
K
_2
(
«AA> Aft 4 A 4 A
* Do,
A
9 ISFR3-02 (S/N 966001429)
D ISFR3-03(S/N 26000482)
X ISFR3-06 (S/N 37017339)
A ISFR3-01 (S/N 966001430)
P
5123
Years in Service
A A
4 :
5
June 2002
17
-------
TableS. Performance Results for In-Service EnvirotempRFR3 Samples
Performance Parameters
Dissipation Factor (%) @ 25°C
Water Content (ppm)
Interfacial Tension (dyne/cm)
Neutralization Number (mgKOH/g)
Conductivity @ 25 °C (pS/m)
Specification Standards
Cooper
<1.0
<400
>18
<2.5
-
ASTM
D3487
<0.05
<35
>40
<0.03
-
ASTM
D5222
<0.01
<25
>45
<0.01
-
IEEE
C57.121
<1.0
<35
>24
<0.2
-
IEC
1203
<0.8
<400
...
<2.0
1.1
Sampling Results
ISFR3-01
0.139
98
26
0.03
10.6
Note: Envirotemp*FR3™ performance while in use is similar to synthetic oil monitored by IEC 1203
ISFR3-02
0.196
56
26
0.02
17
ISFR3-03
0.120
33
24
0.01
12.75
ISFR3-06
0.146
41
23
0.08
13.6
and therefore the
following parameters are compared to Cooper and IEC 1203 specifications: neutralization number, dissipation factor,
and water content. The ASTM and IEEE specification values pertain to virgin product and are provided as a reference.
1 . ISFR3-01 and ISFR3-02 were collected from transformers owned by Cooper Power.
2. ISFR3-03 was collected from the transformer owned by Texas Instrument.
3. ISFR3-06 was collected from the transformer owned by San
Acronyms and Abbreviations:
— = No specification value available
cm = centimeter
Cooper = In-service fluid specification for :
Envirotemp*FR3™
Mateo High School.
developed by Cooper Power Systems
IEC 1203 = International Electrochemical Commission (IEC) Synthetic Organic Esters for Electrical Purposes - Guide
for Maintenance of Transformer Esters in Equipment
mgKOHYg = milligrams of potassium hydroxide per gram
ppm = parts per million
pS/m = picosiemen per meter
The sample results for the water content met the Cooper and IEC 1203 specifications for in-
service fluid. Referring to Figure 6, the water content after more than one year of service is
similar for all four transformers. Again, the historical data for the oldest transformers appears to
show a gradual increase over time. The small fluctuations in the data for the oldest transformers
indicate the fluid has not degraded with use.
Interfacial tension results for the samples listed in Table 5 all met the Cooper specification. One
of the four samples did not meet the IEEE C57.121 specification. Although the data for the fluid
in the oldest transformers have fluctuated over time, the interfacial tension values have remained
above the minimum value specified by Cooper. The current data trend, including the oldest
transformers, indicates the fluid has not degraded with use.
The neutralization number for all four samples ranged from 0.01 mg KOH/g to 0.08 mg KOH/g
and met the Cooper and IEC 1203 specifications for in-service fluid. Samples ISFR3-01, ISFR3-
02, and ISFR3-03 also met the ASTM D3487 specification. Comparing the values for all four
transformers after one year of service, sample ISFR3-06 collected from the SMHS transformer
had the highest neutralization number. ISFR3-03 collected from the TI transformer had a value
comparable to virgin product. Data collected over the oldest transformers' service lives were
well below the maximum value specified by IEC 1203 of 2.0 mg KOFI/g. The small fluctuations
in the data for the oldest transformers indicate the fluid has not degraded with use.
June 2002
18
-------
The conductivity values were converted to volume resistivity units (1 pS/m = 1.0 x 1014 Qcm)
for comparison to IEC 1203 criteria. The converted conductivity values for samples ISFR3-01,
ISFR3-02, ISFR3-03, and ISFR3-06 were 9.4 x 1012 Qcm, 5.9 x 1012 Qcm, 7.8 x 1012 Qcm, and
7.4 x 1012 Qcm, respectively. All values were above the minimum volume resistivity of 6.00 x
10uQcm.
The historical results for the two oldest transformers indicate the oil has degraded little over the
service period of 4.8 years. As the service life of the transformer increases, the interfacial tension
will drop as the water content, dissipation factor and neutralization factor rise. Changes in these
parameters for Envirotemp®FR3™ fluid would also expected to be observed in mineral oil
transformers.
June 2002 19
-------
4.3 Results: Objective 2, Aquatic Biodegradability
Three virgin Envirotemp®FR3™ samples, one from each lot, were analyzed by U.S. EPA Method
OPPTS 835.3110, Ready Biodegradability, using the carbon dioxide (CO2) evolution method.
Three test solutions were prepared: one consisting of a stock solution (bacteria in a mineral
nutrient medium), one of a stock solution with Envirotemp®FR3™ fluid, and one of a stock
solution with a known biodegradable material (phthalic acid) as a reference. The
biodegradability result for the phthalic acid solution is used as a control check on the selected
stock solution and test apparatus. Each solution was tested in parallel in an apparatus consisting
of a stoppered flask connected to a series of barium hydroxide (Ba(OH)2) absorbers with flexible
tubing. Each flask was aerated with a low flow of carbon-dioxide free air under continual
darkness. After the second or third day of the test, the first Ba(OH)2 absorber in the series for
each solution was removed and titrated with hydrochloric acid to determine the CC>2 content. A
new absorber was connected to the end of the absorber series for each testing set-up. This
process was repeated every two (2) or three (3) days during the first ten (10) days of the test and
then every fifth (5) day until the twenty-eighth (28) day. The amount of CC>2 produced by the
degrading Envirotemp®FR3™ fluid was calculated by subtracting the amount of CC>2 produced by
the stock solution from the amount of CC>2 produced by the stock solution and
Envirotemp®FR3™ fluid. The degree of biodegradation was calculated by dividing the amount of
CC>2 produced by Envirotemp®FR3™ fluid by the theoretical CC>2 content (ThCO2). The ThCC>2
amount for each sample is listed in Table 6 below.
An inhibition test where the stock solution, phthalic acid, and Envirotemp®FR3™ fluid are
combined in the same flask was performed to determine if the Envirotemp®FR3™ fluid would
inhibit the phthalic acid's ability to biodegrade. Global Tox International (Global Tox), an
independent testing laboratory, performed this test for each lot. These tests were conducted in
parallel with other biodegradation tests for this verification/certification.
In the past, Cooper performed aquatic biodegradability tests on three different types of
transformer fluids by U. S. EPA Method OPPTS 83 5.3100, Aerobic Aquatic Biodegradation.
The fluids were Univolt 60, a mineral oil-based transformer fluid; R-Temp, a HMWH
transformer fluid; and Envirotemp®FR3™ fluid. Samples were analyzed by the Thomas Edison
Research Center (TERC) who is owned by Cooper Power Systems. This method also estimated
the amount of CO2 produced by the test solution by calculating the difference in the CO2
produced in the test flask and the control (inoculum) flask. Method OPPTS 835.3110, used for
this verification/certification, has replaced OPPTS 835.3100 as U.S. EPA's current test method
for ready biodegradability.
Table 6 lists the results by Global Tox by OPPTS 835.3110, Ready Biodegradability, and the
TERC by OPPTS 835.3100, Aerobic Aquatic Biodegradation. The results from Global Tox
meets the method's validity criteria of less than 20% difference between the replicate end results
except for Sample VFR3-10 which had a percent difference of 35%. The higher percent
difference for VFR3-10 was thought to be due to a leak in the second replicate testing apparatus,
which had the lower reported CO2 content.
June 2002 20
-------
Table 6. Aquatic Biodegradability Results
Sample ID
VFR3-011
VFR3-051
VFR3-101
Average
Historical Data2
Lot
Number
01D1
01C6
01P2
-
-
Average
ThC02 (mg)
75.23
67.44
74.00
-
-
Inhibition Results
(%)
83
91.6
21.4
-
-
Biodegradability
(%)
132.7
121.4
105.9
120 ± 33
99 ±19
lrThe higher than expected biodegradability percentages may be due to a loss of CO2 from
leaks in the stock solution test system.
2This value is the average of three test results listed in a report prepared for Cooper by TERC
dated April 1999.
The average biodegradability of Envirotemp®FR3™ fluid was 120% ± 33% after 28 days. The
higher than expected biodegradability value indicated the stock solution testing apparatus may
have leaked CC>2 to the atmosphere. A lower CC>2 value for the stock solution would cause the
amount of CC>2 for the test substance to be higher and therefore the biodegradability to be higher
than 100%. The error propagation associated with the barium hydroxide traps has been cited to
cause 125% CO2 production results (Gerike, P., 1984). A review of the stock solution data
showed a CO2 production drop between day 10 and day 21, and again on day 28. If the CC>2
amounts are adjusted by using data from days 8 and 21, then the average biodegradation rate after
28 days for Envirotemp^R3 fluid would be 108% and for phthalic acid would be 67%. Both
of these new rates would be greater than the 60% biodegradation criterion required after 28 days
by this method. Based on this, Envirotemp^RS™ fluid is considered to be readily
biodegradable. However, the rates are considered to be a qualitative measurement.
To check the testing apparatus and stock solution selected, a reference flask containing the stock
solution (bacteria in a mineral nutrient medium) and phthalic acid (a known biodegradable
material) was tested in parallel with flasks containing only the stock solution, and the stock
solution with Envirotemp^RS fluid. The reference stock solution had a biodegradation rate of
>60% after 14 days and after 28 days which verified that the appropriate test system and bacteria
inoculum were used.
Inhibition tests were run for each lot to determine if the Envirotemp®FR3™ fluid would inhibit
the bacteria ability to biodegrade phthalic acid. The inhibition tests indicated the
Envirotemp®FR3™ fluid was not toxic to the bacteria except for Sample VFR3-10. Global Tox
thought the low inhibition result for Sample VFR3-10 was likely a false result due to leaks of
CC>2 to the atmosphere from the test apparatus since the sample did exhibit a biodegradability of
> 60%. A large difference in the amount of CC>2 generated on days 8 and 28 are observed
between the sample and its replicate for sample VFR3-05. Results from this test should be
considered a qualitative measurement of Envirotemp®FR3™ fluid biodegradability.
June 2002
21
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While mineral oil was not tested as part of this study, literature data are available on
biodegradability using U.S. EPA and the Organization of Economic Cooperation and
Development (OECD) methods. These methods are equivalent to OPPTS 835.3110.
Biodegradation rates for conventional mineral oil ranged from 42 to 49% after 28 days using
U.S. EPA Method 560/6/-82-003, Aerobic Aquatic Biodegradability (USAGE, 1997, 1999).
Another study by CONCAWE reported a ready biodegradation rate for a light naphthenic
distillate mineral oil of 28% after 28 days when analyzed by OECD 301B, Sturm Test
(CONCAWE, 1997). These results agree with historical results obtained by TERC as part of
their biodegradability testing for Envirotemp®FR3™ fluid. TERC reported average
biodegradation rates after 28 days of 30.5% for Univolt 60, 21.3% for R-Temp, and 98% for
Envirotemp®FR3™ fluid(TERC, 1999).
Based on these reported biodegradation rates for mineral oil, the Envirotemp®FR3™ fluid appears
to biodegrade more readily. Although Envirotemp®FR3™ fluid readily biodegrades per this test,
the product's ability to degrade in the environment is dependent on site-specific factors such as
climate, geology, moisture, pH, temperature, oxygen concentration, dispersal of oil, the presence
of other chemicals, soil characteristics, nutrient quantities, and populations of various
microorganisms at the location (U.S.EPA 1997).
June 2002 22
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4.4 Results: Objective 3, Flammability
The flash point and fire point for virgin and in-service Envirotemp®FR3™ fluid were determined
using ASTM Method D92, Cleveland Open Cup test. The flash point was measured to assess the
overall flammability of the fluid and determine the presence of volatile or flammable material at
elevated temperatures. The fire point was measured to determine the temperature at which the
fluid would support combustion. These values were compared to the Cooper specifications,
ASTM D3487 specification for flash point and ASTM D5222 specification for fire point, and are
presented in Tables 7 and 8. The individual and average flash and fire point values for both the
virgin and in-service fluid met the Cooper and ASTM specifications. The deviation in the fire
point data is within the precision margin of ± 8°C at 95% confidence specified in ASTM Method
D92. The flash point exceeded this criteria and the reported values should be considered an
approximation. Historic flash and fire point data for the two transformers sampled at Cooper's
facility are plotted and presented in Figures 7 and 8. The fluid in the oldest transformers after
approximately 4.5 years of service have flash and fire points above 320°C and 350°C,
respectively. These values are greater than the minimum values specified by the Cooper and
ASTM specifications for virgin mineral oil and HMWH.
The fire point results also agreed with those obtained by Underwriters Laboratory (UL). UL
evaluated this product using ASTM Method D92 (Cleveland Open Cup) and reported the fire
point at 358°C. The flash point determined by UL was 255°C using ASTM Method D93
(Pensky-Martens Closed-Cup). The lower flash point was due to the different test method used
byUL.
Table 7. Flash Points for Virgin and In-service Envirotemp FR3 Samples
Sample Numbers
Product Lot No./
Transformer SN
Specification Criteria (°C)
Cooper
ASTM D3487
ASTMD5222
Flash Point
(°C)
Virgin Product
VFR3-01
VFR3-05
VFR3-07
VFR3-10
01D1
01C6
01C6
01P2
Average
>320
>320
>320
>320
>320
>300
>300
>300
>300
>300
NA
NA
NA
NA
NA
328
332
334
318
328 ±11
In-service Transformer Fluid
ISFR3-01
ISFR3-02
ISFR3-03
ISFR3-06
966001430
966001429
26000482
37017339
>320
>320
>320
>320
>300
>300
>300
>300
NA
NA
NA
NA
338
328
330
340
Note: Data variability was calculated at 95% confidence using a two-tailed T-test assuming a
normal distribution.
NA = Not applicable SN = Serial Number
June 2002
23
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Table 8. Fire Points for Virgin and In-service Envirotemp FR3 Samples
Sample Numbers
Product Lot No./
Transformer SN
Specification Criteria (°C)
Cooper
ASTMD3487
ASTMD5222
Fire Point
(°C)
Virgin Product
VFR3-01
WR3-05
WR3-07
VFR3-10
01D1
01C6
01C6
01P2
Average
>350
>350
>350
>350
>350
NA
NA
NA
NA
NA
304-310
304-310
304-310
304-310
304-310
362
364
362
362
363 ±2
In-service Transformer Fluid
ISFR3-01
ISFR3-02
ISFR3-03
ISFR3-06
966001430
966001429
26000482
37017339
>350
>350
>350
>350
NA
NA
NA
NA
304-310
304-310
304-310
304-310
362
364
364
364
Note: Data variability was calculated at 95% confidence using a two-tailed T-test assuming a
normal distribution.
NA = Not applicable SN = Serial Number
UL classified Envirotemp®FR3™ fluid as a dielectric medium and transformer fluid with a fire
hazard rating of 4 to 5 which is less hazardous than paraffin oil. The UL fire rating system uses
the flash point determined by Pensky-Martens Closed-Cup to rate the material's flammability.
The material's flammability is rated and classified using the following scale arranged from
flammable to nonflammable: ether rated at 100, gasoline from 90 to 100, ethyl alcohol from 60 to
70, kerosene from 30 to 40, paraffin oil from 10 to 20, and water at 0. Envirotemp®FR3™ fluid is
one of five products listed by UL as a Class 4 to 5 dielectric medium and one of three products
listed as a Class 4 to 5 transformer fluid (UL, 2001). The other UL listed dielectric medium
products are either silicone oil-based, HMWH, or vegetable oil-based fluids. The other UL
classified transformer fluids are either a silicone oil-based or HMWH fluids.
Envirotemp®FR3™ fluid is also classified as a less flammable transformer fluid by Factory
Mutual Research Center (FMRC). FMRC defines a less flammable transformer fluid as having a
fire point greater than 300°C when tested per ASTM D92 (Cleveland Open Cup).
Envirotemp®FR3™ fluid is one often products classified as a less flammable transformer fluid.
The other products classified as less flammable consist of either silicone oil-based, HMWH, or
vegetable oil-based transformer fluids (FMRC, 1999). FMRC also identified Envirotemp®FR3™
fluid as an alternative to high fire point hydrocarbons, silicone fluids, and synthetic esters or
hydrocarbons where fire resistance, improved high temperature operation, and improved cooling
are desired.
June 2002
24
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Figure 7. Flash Point Trend for Transformers Sampled
ocn
? 330
•Ł
Ł '
f
S8 Tin
u.
oqn
(
X
AA?& 1 &
L *A A
« ^ = • ISFR3-02(S/N966001429)
^ D ISFR3-03 (S/N 26000482)
X ISFR3-06 (S/N 3701 7339)
A ISFR3-01 (S/N966001430)
D 1 2 3 4
Years in Service
A
•
_
-
-
i
Figure 8. Fire Point Trend for Transformers Sampled
I
ocn
o
o
.E oon
O oou
Q_
Ł
LL.
•510
oon
i
^AA% A y A A A j
• ISFR3-02 (S/N 966001 429)
D ISFR3-03 (S/N 26000482)
X ISFR3-06 (S/N 3701 7339)
A ISFR3-01 (S/N 966001 430)
D 1 2 3 4
Years in Service
A
i
June 2002
25
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4.5 Results: Objective 4, Acute Toxicity
Three virgin Envirotemp®FR3™ samples, one from each lot, were analyzed using U.S. EPA
method, Methods for Measuring the Acute Toxicity of Effluents and Receiving Waters to
Freshwater and Marine Organisms., EPA/600/4-90/027F, August 1993. Tests were performed
by Associated Laboratories, a California independent laboratory, which performed the work
under contract with DTSC. Based on earlier acute toxicity results provided by Cooper, the
screening test was not conducted and instead three test chambers were prepared containing 750
mg/1, 500 mg/1, and 250 mg/1 of Envirotemp®FR3™ fluid. Duplicate testing was performed in
parallel with the test samples. The test method presented in the test plan was modified by using
juvenile pimephales promelas (fathead minnow) instead of juvenile oncorhynchus mykiss
(rainbow trout). Samples were prepared by the "Static Acute Bioassay Procedures for
Hazardous Waste Samples" developed by the California Department of Fish and Game, Water
Pollution Control Laboratory in the Code of California Regulations, Title 22, Section
66261.24(a)(6). This procedure requires shaking the sample for six hours using a wrist-action or
similar type of shaker to dissolve the oil in 200 ml of water before the sample is added to the
aquatic bioassay fish tank. Dissolved oxygen (DO) content, pH, and temperature were monitored
and maintained at 6.0-7.0 mg/1, 7.0-7.5, and 20°C, respectively as required by the method.
Associated Laboratories also performed a second set of tests using adult pimephales promelas
(fathead minnow) at the same concentrations. The acute toxicity tests for the adult and juvenile
pimephales promelas were conducted in parallel.
Earlier tests performed by Global Tox, an independent laboratory, under contract with Cooper
analyzed the samples per the Organization of Economic Cooperation and Development (OECD)
Procedure 203, Fish Acute Toxicity Test which used rainbow trout. Oil samples were prepared
using an acetone carrier solvent to make the oil miscible in water. Dissolved oxygen (DO)
content, pH, and temperature were monitored and maintained at between 8.0 and 9.0 mg/1, 7.8,
and 15°C ± 1°C, respectively, as outlined in the method.
Table 9. Fish Bioassay Results for Virgin Envirotemp®FR3™ Samples
Sample Numbers
VFR3-01
VFR3-05
VFR3-10
Average2
Historic Data3
California Toxicity Criteria1
(mg/L)
<500
<500
<500
<500
<500
Sample Results (mg/L)
Juvenile
<250
<250
<250
<250
>1,000
Adult
314
386
250
317 ±169
—
lrThe virgin oil is considered to exhibit a toxic characteristic if the LC50 is
less than 500 mg/1 when measured in soft water.
2Data variability was calculated at 95% confidence.
3The result is for a single sample collected by the Cooper in December 1998.
Results are compared to the toxicity characteristic listed in the Code of California Regulations,
Title 22, Section 66261.24(a)(6) in Table 9. A waste is considered to exhibit a toxic
June 2002
26
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characteristic if the LCso is less than 500 milligrams per liter when measured in soft water (total
hardness 40 to 48 milligrams per liter of calcium carbonate).
A DTSC aquatic toxicologist reviewed the reports prepared by both Associated Laboratories and
Global Tox to identify the differences, which could lead to such conflicting results. As part of
the review, the toxicologist also reviewed the test methods, and material safety data sheets for
Envirotemp®FR3™ fluid and its additives. The tank water was not analyzed for breakdown
products associated with degraded vegetable oil by either the Global Tox or Associated
Laboratories. The main difference between the two sets of test was the sample preparation
method used. Associated Laboratories used a shaker table per the method cited in the test plan.
Global Tox prepared their samples per OECD Procedure 203, Fish Acute Toxicity Test., where an
acetone carrier solvent was used to make the oil miscible in water. Oil samples prepared using
the wrist action method stratify the oil at the top of the tank. Fish swimming through this upper
layer of the tank are thought to become coated with the product, which would impair gill
exchange. Oil samples prepared using the wrist shaker method are thought to provide a more
realistic result for conditions, which may occur during an environmental release. Samples
prepared using the OECD method provided results that reflect systemic or chemical impacts on
fish.
In California, insoluble, viscous waste samples are prepared using the wrist-shaker method and
ultrasonic method, and sometimes the solvent carrier method as part of the fish bioassay
screening tests for hazardous waste characterization. The preparation method yielding the most
conservative LCso result is then used to perform the definitive tests. This methodology is
required by DTSC Waste Evaluation Unit and overseen by the Department of Health Services
Environmental Laboratory Accreditation Program's Aquatic Toxicity Bioassay Section who
certifies laboratories performing aquatic toxicity tests for DTSC. Cooper disagrees with DTSC's
methodology (see vendor's comment section for Cooper's opinion). The reader should note that
this methodology is used to characterize the hazardous characteristics for waste. Any statement
concerning the hazardous characteristic of the Envirotemp®FR3™ fluid applies to the spent
(waste) fluid only and is not intended to classify the virgin product.
The lower LCso results and physical effects described above are similar to those presented by the
U.S. EPA in their responses to comments on the rule for Oil Pollution Prevention at Non-
Transportation Related Onshore Facilities (40 CFR Part 112). The physical effects observed in
the toxicity tests performed by Associated Laboratories have been observed in vegetable oils, and
oils in general, and were therefore expected (Polisini, personal communication). Based on these
limited results which were performed on virgin product, the spent Envirotemp®FR3™ fluid may
be classified in California as hazardous waste and need to be managed accordingly. The end-user
should characterize the spent Envirotemp®FR3™ fluid at the time of disposal since changes may
occur to the oil due to use, storage, or age. The end-user should also consult the appropriate
regulatory authority about applicable waste characterization regulations and the appropriate
disposal method for their area.
June 2002 27
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4.6 Results: Other Verification/Certification Objectives
Chemical Composition
The chemical composition of the virgin and in-service fluids was analyzed by selected
Association of Analytical Chemist (AOAC) methods, semivolatile organics (SVOCs) by EPA
Method 8270, and metals analysis by EPA Method 6010. The AOAC methods were selected to
provide a chemical "fingerprint" for Envirotemp®FR3™ fluid. Samples were also analyzed for
SVOCs and metals to identify any contaminants of concern. Silliker, an independent laboratory,
analyzed samples per the AOAC methods while the Hazardous Materials Laboratory (HML)
analyzed the SVOC and metals samples.
Cooper has reported the composition of Envirotemp®FR3™as follows. The product is composed
>98.5% vegetable oil and <1.5% additives (e.g., antioxidants and color). The vegetable oil is
comprised of at least 23.5% monounsaturated, 61% polyunsaturated fatty acids, and 15.5%
saturated fatty acids. According to the Cooper, the antioxidants may consist of combination of
antioxidants, which include butylated hydroxyl anisole (BHA), mono-tertiary butylhydroquinone
(TBHQ), 3,5-di-tert-butyl-4-hydroxytoluene (BHT or DBPC), and Vitamin E.
Tables 10 and 11 present the sample results for virgin and in-service Envirotemp®FR3™ fluid.
Analytes detected at percentages greater than 5% in virgin samples met the repeatability criteria
listed in AOAC Method 963.22 with a relative percent difference between results of < 3% and an
absolute percent difference of < 1%. Results for the in-service samples were not compared to the
precision criteria since no duplicate was collected to minimize impacts on the transformer and
the on-going sampling program.
Table 10. AOAC Results for Virgin Envirotemp FR3 Samples
Analyte
Sample Number
VTR3-01
VTR3-05
VTR3-06
VTR3-10
Total Fatty Acids
Hexadecanoic (Palmitic)
Octadecanoic (Stearic)
Octadecenoic (Oleic)
Octadecadienoic (Linoleic)
Octadecatrienoic (Linolenic)
Eicosanoic (Arachidic)
Eicosenoic (Gadolelc)
Docosanoic (Behenic)
Tetracosanoic (Lignoceric)
Unknown components
16:0
18:0
18:1
18:2
18:3
20:0
20:1
22:0
24:0
Phenolic Antioxidants (AOAC Method 983. 15) (ppm)
Polymers and Oxidation Products (%)
10.60%
4.35%
23.40%
52.40%
7.58%
0.33%
0.24%
0.35%
0.11%
0.40%
2,001
1.3
10.60%
4.18%
23.60%
52.30%
7.55%
0.34%
0.25%
0.36%
0.11%
0.43%
3,047
<1.0
10.60%
4.20%
23.60%
52.30%
7.56%
0.34%
0.25%
0.36%
0.11%
0.43%
3,074
1.3
10.60%
4.29%
23.50%
52.30%
7.56%
0.34%
0.25%
0.35%
0.11%
0.44%
3,025
<1.0
Average
10.60%
4.26% ±0.1 3%
23.53%±0.15%
52.33% ± 0.08%
7.56% ± 0.02%
0.34% ±0.01%
0.25% ±0.01%
0.36% ±0.01%
0.11%
0.43% ± 0.03%
2787 ± 834
1.2 ±0.3
Results are presented for the individual fatty acids along with their number of carbons and the
number of double bonds (i.e., 18:1 represents 18 carbons and one double carbon bond). The
June 2002 28
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percentage of monounsaturated and polyunsaturated fatty acids are determined by adding the
fatty acids with one, two or three double carbon bonds together, respectively. The percentage of
monounsaturated fatty acids consists of fatty acids with one double carbon bond such as
octadecenoic or oleic acid (18:1). The polyunsaturated fatty acids consist of di- and tri-
unsaturated fatty acids (e.g., 18:2 and 18:3). The percentage of saturated fatty acids consist of the
fatty acids with no double carbon bonds such as hexadecanoic (16:0), octadecanoic (18:0),
eicosanoic (20:0), docosanoic (22:0), and tetracosanoic (24:0).
The virgin Envirotemp®FR3™ samples had monounsaturated fatty acid ranging from 23.8% ±
0.2%, polyunsaturated fatty acids ranging from 59.9% ± 0.1%, and saturated fatty acids ranging
from 15.7% ± 0.1%. This agrees closely with the formulation reported by Cooper. The in-
service Envirotemp®FR3™ samples had monounsaturated fatty acid ranging from 22.0% to
23.8%, polyunsaturated fatty acids ranging from 59.8-62.4%, and saturated fatty acids ranging
from 15.2-16.3%. The in-service sample results are also consistent with Cooper's reported
formulation.
Table 11. AOAC Results for In-Service Envirotemp®FR3™ Samples
Analyte
Sample Number
ISFR3-01
ISFR3-02
ISFR3-03
ISFR3-06
Total Fatty Acids
Hexadecanoic (Palmitic)
Octadecanoic (Stearic)
Octadecenoic (Oleic)
Octadecadienoic (Linoleic)
Octadecatrienoic (Linolenic)
Eicosanoic (Arachidic)
Eicosenoic (Gadolelc)
Docosanoic (Behenic)
Tetracosanoic (Lignoceric)
Unknown components
16:0
18:0
18:1
18:2
18:3
20:0
20:1
22:0
24:0
Phenolic Antioxidants (AOAC Method 983. 15) (ppm)
Polymers and Oxidation Products (%)
10.60%
4.03%
21.80%
54.20%
8.14%
0.30%
0.20%
0.31%
<0.1%
0.00%
3,954
<1.0
10.60%
3.99%
21.80%
54.20%
8.15%
0.30%
0.20%
0.31%
<0.1%
0.06%
4,598
2.3
10.20%
5.15%
23.50%
52.50%
7.35%
0.43%
0.24%
0.36%
0.10%
<0.1%
4,108
2.7
10.20%
5.10%
23.50%
52.60%
7.34%
0.42%
0.24%
0.36%
<0.1%
<0.1%
4,181
2.8
AOAC Method 983.15, Phenolic Antioxidants in Oils, Fats, and Butter Oil, was used to
determine the concentration of 7 commonly used antioxidants in food grade oils and fats. The
results for the virgin and in-service transformer samples are presented in Tables 10 and 11.
Antioxidants were detected in all the virgin product between 2,787 ppm ± 834 ppm. The in-
service transformer samples had antioxidant concentrations between 3,950 ppm and 4,600 ppm.
The higher antioxidant content in the in-service samples compared to the virgin samples reflects
a formulation change by Cooper.
The polymers and oxidation products listed in Tables 10 and 11 above are simple indicators used
in the food industry to assess the quality of vegetable oil after exposure to heat. If higher values
are reported for an oil as it is reheated, the difference is assumed to show an increase in non-
elution material (compounds not removed using a solvent) that indicates the polar compounds in
June 2002
29
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the oil are degrading. Compared to the average virgin product value of 1.2% ± 0.3%, three of the
four in-service fluid samples appear to have degraded slightly due to use.
Virgin and in-service samples were screened for 65 standard SVOC compounds using U.S. EPA
Method 8270/3580. All the virgin samples and in-service samples were extracted outside the 7-
day extraction window, which deviated from the holding time requirements listed in the test
evaluation plan. HML noted the recovery of pyrene in the matrix spikes could not be reliably
calculated due to matrix interference. HML also noted difficulty in analyzing both the virgin and
in-service fluid samples. The samples may contain non-volatile components that do not readily
elute from the chromatographic column. Due to this difficulty and extraction times exceeding
those listed in the test plan, the reported SVOC results should be regarded as approximations and
not be used in lieu of actual waste characterization data.
None of the 65 standard SVOC compounds analyzed by the HML lab were detected in the virgin
product samples. For the in-service samples, bis-(2-ethylhexyl)phthalate, butyl benzyl phthalate,
and di-n-butyl phthalate were detected. These compounds were also detected in the equipment
blank and all but butyl benzyl phthalate were detected in the field blank. These compounds were
probably contaminants introduced from the Tygon tubing and/or deionized (DI) water used.
Other tentatively identified compounds were bis-2-ethylhexyl hexanedoic acid (DEHA),
squalene, and sterols such as tocopherol, stigmasterol, campesterol, and gamma sitosterol.
These sterols are normally found in vegetable oils. Due to the deviations discussed above, the
SVOC data should be considered a qualitative measurement but does not change the assessment
that Envirotemp®FR3™ fluid consists primarily of vegetable oil and a small percentage of
antioxidants.
Virgin and in-service samples were analyzed by U.S. EPA Method 6010/5030. Other than the
sample preparation method used, no other deviations to the final test evaluation plan were noted
by the laboratory. Barium and zinc were detected in the virgin product samples at concentrations
ranging from 26 mg/kg to 36 mg/kg and from 11 mg/kg to 24 mg/kg, respectively. No metals
were detected in the equipment blank. For the in-service transformer samples, metals were
detected in two of the four in-service transformer samples. ISFR3-01 and ISFR3-02 had barium
and zinc concentrations ranging from 25 mg/kg to 27 mg/kg and from 12 mg/kg to 13 mg/kg,
respectively. Cadmium and molybdenum were also detected in the sample ISFR3-01 at 0.42
mg/kg and 2.6 mg/kg, respectively. No metals were detected in the equipment blank associated
with the in-service transformer sampling. Quality assurance/quality control (QA/QC) results met
the criteria outlined in the HML User's manual for EPA Method 6010. The barium and zinc
might have been introduced during degassing process or from the finishing tank used to store all
new batches manufactured. These metals do not appear to have been introduced due to sampling
since they were not detected in the equipment blank. It is also not clear why barium or zinc was
not detected in the ISFR3-03 and ISFR3-06.
June 2002 30
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Worker Health and Safety Aspects
This section presents some of the potential hazards associated with Envirotemp®FR3™ fluid and
compares them to those for select mineral oil-based and silicone oil-based transformer fluids.
This is not considered a comprehensive review where all potential hazards associated with
Envirotemp®FR3™ fluid has been identified. End-users should review all applicable worker
health and safety regulations for use of this product.
Envirotemp^RS fluid is used to cool the core and coils within a transformer. The fluid is held
in a tank inside the transformer. The tank is equipped with a pressure relief valve where gases in
the headspace may be released to the ambient air. Transformers that use mineral oil or other
types of insulating fluid are also equipped with pressure relief valves. Transformers that use
Envirotemp®FR3™ are usually located in or adjacent to buildings, or in underground vaults where
higher fire protection is required.
The Envirotemp®FR3™ dielectric insulating fluid is composed >98.5% vegetable oil and <1.5%
additives (e.g., antioxidants and color). The antioxidants used in this product are not listed as a
hazardous material and have been cleared for use as a food grade antioxidant. Although the
components of Envirotemp®FR3™ fluid are food-grade, this product was not intended for human
consumption and should not be used as a food product.
According to the Envirotemp®FR3™ material safety data sheet (MSDS), this product is also not
considered a hazardous substance as defined under Title 8, California Code of Regulations,
Section 5194, Hazard Communications. However, this does not relieve the end-user who uses
this product from providing workers with information and training necessary to handle
Envirotemp®FR3™ fluid safely. Workers should review the MSDS and be familiar with the
information concerning first aid procedures, physical properties, personal protective equipment
(PPE), respiratory protection, and slip hazards. Workers should wash skin that has contacted the
product with soap and water. For eye contact, the eyes should be flushed with water. The
primary physical property workers should be aware of is the product's flash point of greater than
300°C. In the case of an Envirotemp®FR3™ spills, employees should be aware of the increased
slip hazard in the affected area due to the product.
Before working with Envirotemp®FR3™ fluid, employees should ensure the work area has
adequate ventilation, and the appropriate respiratory protection and protective clothing are
selected. When working with hot Envirotemp®FR3™ fluid, workers should don neoprene gloves,
rubber boots and aprons. Respiratory protection should only be worn if oil mists or dusts
contaminated with oil are detected at concentrations equal to or exceeding the permissible
exposure limit (PEL). Occupational Safety and Health Administration (OSHA) has set the
permissible exposure limit (PEL) for vegetable oil mist as a nuisance paniculate at 15 mg/m3 and
5 mg/m3 for respiratory protection for an 8-hour time-weighted average (TWA) exposure. In
California, the nuisance particulate PEL is 10 mg/m3. The end-user should consult the
appropriate regulatory authority about applicable nuisance particulate PELs used in their area.
If the transformer is located in a poorly ventilated area, then workers should use appropriate
engineering controls to ventilate the area. Based on the MSDS information on
June 2002 31
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Envirotemp®FR3™'s antioxidants, Envirotemp®FR3™ fluid may produce carbon monoxide,
carbon dioxide, nitrogen oxides, and other toxic compounds when the antioxidants thermally
decompose. Mineral oil-based and silicone oil-based transformer fluids may also thermally
decompose and produce fumes, smoke, carbon monoxide, aldehydes and other products. For
some mineral oil-based transformer fluids, sulfur oxides are also listed as a possible
decomposition product while silicon dioxide is listed for some silicone oil-based fluids. No data
are available on the composition of emissions from transformers in general.
When comparing the PPE requirements for handling Envirotemp®FR3™ fluid to select mineral
oil-based transformer fluids, the requirements were found to be similar. This comparison is
based on MSDS information for select mineral oil-based transformer fluids obtained from the
Vermont Safety Information Resources, Inc. (SIRI) MSDS archive. Respiratory protection for
the mineral oil-based transformer fluids is required at a lower nuisance particulate OSHA PEL of
5 mg/m3 for an -8-hour TWA exposure compared to Envirotemp®FR3™ fluid. For select silicone
oil-based transformer fluids found in the Vermont SIRI MSDS archive, workers are advised to
don impervious gloves and chemical goggles when handling the fluid.
Occupational exposure to transformer fluid is limited and associated to infrequent activities such
as filling, draining, or sampling of transformers. These activities are not likely to generate a mist
or aerosol at concentrations approaching the PEL. Potential hazards associated with filling or
draining the transformer include slipping on work surfaces where the product was spilled, or
splashing of the material into the eyes or onto the skin. Potential hazards associated with
sampling the transformer include coming in contact with extremely hot oil, potential electrical
arcing from the transformer, or slipping hazards due to spilled Envirotemp®FR3™ fluid on the
floor.
MSDS information for three silicone transformer fluids identified as less-flammable transformer
oils by UL and FMRC were reviewed along with several mineral oil-based transformer fluids
listed in the Vermont SIRI MSDS Archive. Health and safety information on the components
listed on the MSDSs was compared to information listed in Sax's Dangerous Properties of
Industrial Materials. The primary component of the mineral oil-based transformer fluid was a
hydrotreated light naphthenic petroleum distillate (CAS No 64742-53-6) ranging from 30-100%
which was identified as an International Agency for Research on Cancer (IARC) confirmed
carcinogen based on experimental data for animals (Lewis, 2000). The primary ingredient of the
silicone oil-based transformer fluids was dimethyl polysiloxane (CAS No. 63148-62-9) listed at
100% and identified as a combustible liquid, a teratogen, and the cause of reproductive effects
based on experimental data on animals (Lewis, 2000).
Estimated Cost of Using Envirotemp®FR3™ versus Mineral Oil
An average life for a transformer using Envirotemp®FR3™ fluid is estimated to be 20 years. A
new Cooper transformer unit containing Envirotemp®FR3™ fluid costs approximately 1.2 to 1.3
times more than a comparable new Cooper mineral oil transformer. The price of the
Envirotemp®FR3™ fluid is approximately $9 to$10 per gallon depending on the volume
purchased. Prices for mineral oil typically range from $2 to $4 per gallon depending on quantity
(Luksich, 2001). The fluid is available in 5-gallon containers, 55-gallon drums, 200-gallon totes,
June 2002 32
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6,000-gallon tanker trucks, or by the rail car. Monitoring costs will vary depending on the
maintenance program the purchaser has in place. The waste characterization cost for a
transformer using Envirotemp®FR3™ fluid or mineral oil is anticipated to be approximately the
same except for mineral oil suspected to contain PCBs where the costs will be higher. The
disposal cost for mineral oil and Envirotemp®FR3™ fluid are assumed to be comparable since
data are not available on the waste characteristics of Envirotemp®FR3™ fluid after 20 years of
use.
For a retrofilled transformer, no additional costs due to modifications on the transformer unit are
incurred for using Envirotemp®FR3™ fluid. The costs associated with draining and disposing of
the used oil are expected to be the same for both mineral oil and Envirotemp®FR3™ fluid. The
cost of flushing and filling the transformer with Envirotemp®FR3™ fluid versus mineral oil will
be higher and ranges from approximately $5 to $8 per gallon. The accelerated life testing results
performed by Cooper indicate the paper insulation around the windings showed less degradation
for the Envirotemp®FR3™ transformers than the identical mineral oil transformers. Less
degradation of the paper insulation indicates the Envirotemp®FR3™ transformers may have a
longer service life per this test.
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Section 5. Regulatory Considerations
A review of Federal and California regulations was conducted to identify applicable regulations
for virgin and spent Envirotemp®FR3™ fluid. This review is not considered to be a
comprehensive review of existing regulations. Waste management is based on the limited
amount of data available on this product. The reader should consult with their local
environmental regulatory agency concerning other applicable local and State regulations, and the
status of the regulations cited below. These regulations may have been updated or superseded
since this review was conducted.
Virgin (or unused) Envirotemp®FR3™ fluid is a vegetable oil-based dielectric fluid consisting of
>98.5% food-grade vegetable oil and < 1.5% additives such as antioxidants and color. The
product has a flash point of 255 C by ASTM Method D93 and an average of 328 C by ASTM
Method D92. The product has a neutral pH (pH = 7.0) and is not reactive with other chemicals at
room temperature but is incompatible with strong oxidizers. As part of this
verification/certification, three samples of virgin Envirotemp®FR3™ fluid were tested and had an
acute aquatic LCso value of less than 250 mg/L. The historical LCso value provided by Cooper
was greater than 1,000 mg/L. The difference between the results was thought to be due to the
sample preparation method used. The lower LCso value was thought to reflect the physical
impacts of an oil spill to fish while the higher LCso was thought to reflect the systemic (chemical)
impacts to fish.
5.1 Regulation of Virgin Envirotemp®FR3™ Dielectric Fluid
Information on new product and materials introduced for commercial use are submitted to the
U.S. EPA for review under the Toxic Substances Control Act (TSCA) unless the new product is
a mixture of listed materials. The components of Envirotemp®FR3™ are listed under the TSCA
as Chemicals in Commerce. None of the components are listed as an imminently hazardous
chemical substance or mixture which the EPA Administrator has "taken action under" Section 7.
Envirotemp®FR3™and its components are also not listed as hazardous substances under Section
3001 of Resource Conservation and Recovery Act (RCRA), and Section 112 of the Clean Air
Act (CAA). The product is included under Section 311 of the Clean Water Act (CWA), which
addresses oil, and hazardous substance releases to water. The product is shipped as a non-
hazardous material per Department of Transportation regulations.
The components of Envirotemp®FR3™ fluid are not listed in the Consolidated List of Chemicals
Subject to Emergency Planning and Community Right-To-Know Act (EPCRA) and Section
112(r) of the CAA and therefore, is not reportable under Section 313. However, a material safety
data sheet (MSDS) is required as part of the EPCRA under Section 311. California facilities
should consult Health and Safety Code (HSC) Chapter 6.8 and determine if business plans need
to be modified in the areas of emergency preparedness and response, and water quality if
Envirotemp®FR3™ fluid is used at their facilities.
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5.2 Waste Characterization/Disposal Requirements
5.2.1 Waste Characterization and Disposal of Virgin EnvirotempRFR3 Fluid
Under the RCRA definition of a hazardous waste, a waste is considered hazardous if it is a listed
waste under Section 261.2 or exhibits a hazardous characteristic as defined in 40CFR261.20
through 40CFR261.24. A hazardous characteristic is defined as either having a flash point less
than 60°C (ignitability), has a pH < 2.5 or pH > 12.5 (corrosivity), is reactive, or contains a
contaminant equal to or greater than the regulatory value listed in 40CFR 261.24 (toxicity) per
the Toxicity Characteristic Leaching Procedure (TCLP). The virgin Envirotemp®FR3™ fluid is
not a listed RCRA waste nor does it meet the definition of a hazardous waste per 40CFR261.20
through 40CFR261.24. Virgin Envirotemp®FR3™ fluid which is off-specification or has
exceeded its shelf life is not listed as a hazardous waste per 40CFR 261.33 and may be returned
to the manufacturer or disposed of as a non-hazardous material.
In California, a waste is considered hazardous if it is a RCRA listed waste or exhibits a
hazardous characteristic per California Code of Regulations (CCR), Title 22, Division 4.5,
Chapter 11, Article 3, Section 66261.20 (22CCR66261.20). The ignitability, corrosivity, and
reactivity criteria listed under 22CCR66261.20 are the same as those listed for 40CFR261.20
through 40CFR261.23. The toxicity characteristic defined under 22CCR261.24 lists several
criteria which are as follows: (1) the waste meets the criteria per 40CFR261.24, (2) the waste
contains a substance listed in 22CCR66261.24 as determined by the Waste Extraction Test
(WET), (3) the waste has an acute oral lethal dose (LDso) of less than 5,000 mg/kg, (4) the waste
has an acute dermal LD50 of 4,300 mg/kg, (5) the waste has an acute inhalation lethal
concentration (LCso) of less than 10,000 ppm as a gas or vapor, (6) the waste has a acute aquatic
96-hour LCso of less than 500 mg/L, or the waste contains any of the substances listed in
22CCR66261.24(a)(7). Spent Envirotemp®FR3™ fluid, which includes off-specification
material, may exhibit a hazardous characteristic and therefore may be subject to hazardous waste
management regulation. Off-specification material may be considered a retrograde material if it
meets the criteria per HSC 25121.5 and may be returned to the manufacturer without a manifest.
5.2.2 Waste Characterization of Spent Envirotemp®FR3™ Fluid
Spent Envirotemp®FR3™ fluid should be characterized by the generator per 40CFR261.20
through 40CFR261.24 or by the applicable State requirements prior to disposal. To date, the
longest continuous use of Envirotemp®FR3™ in a transformer has been approximately 4.8 years.
The average service life of a transformer is approximately 20 years. Since changes to the oil may
occur due to use, the generator must characterize the spent Envirotemp®FR3™prior to disposal.
As part of the waste characterization for transformers that exclusively used Envirotemp®FR3™
fluid, the generator should determine the metals concentration per EPA Method 1311 and the
TCLP. For retrofilled transformers, the spent Envirotemp®FR3™ must also be tested for PCBs
per EPA Method 8082 if the transformer was known or suspected to have contained PCBs prior
to using Envirotemp®FR3™ fluid. If the spent Envirotemp®FR3™ fluid is characterized as
hazardous, then the fluid must be managed as a hazardous waste per the applicable State and
federal regulations.
June 2002 35
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For spent Envirotemp®FR3™ fluid generated in California, the Waste Extraction Test (WET)
should also be performed as defined in 22CCR Section 66261.24 (a)(l) and 66261.24 (a)(2),
respectively, in addition to EPA Method 1311. The used oil should also be characterized for
acute aquatic toxicity per 22CFR66261.24(a)(6) in addition to the TCLP. If the spent
Envirotemp®FR3™ fluid is characterized as hazardous per the federal definition, then the fluid
must be managed as a hazardous waste. If the spent Envirotemp®FR3™ fluid is characterized as
hazardous per 22CCR66261.20, then the fluid must be managed as used oil per the Used Oil
Management Program (22CCR66279).
Characterization results for Envirotemp®FR3™ fluid for a specific transformer model may be
used for others if the transformer has only used Envirotemp^RS fluid during its service life
and has not been retrofilled with a different dielectric fluid during its service life. Depending on
the results of the waste characterization, the spent Envirotemp®FR3™ fluid may be sent to a
waste oil recycler or fat Tenderer for facilities located outside California. Facilities outside of
California should consult their State environmental agency for certified waste oil recyclers or fat
Tenderers in their area and the recyclers' acceptance criteria for used vegetable oil. In California,
the spent Envirotemp®FR3™ fluid may only be sent to licensed waste oil recycler if the waste
characterization results show the fluid to exhibit a hazardous characteristic per 22CCR66261.20.
5.2.3 Disposal of Spent Envirotemp®FR3™ Fluid
Under the federal Used Oil Management Program, spent Envirotemp®FR3™ fluid is not included.
The U.S. EPA defines used oil as being "refined from crude oil or any synthetic oil, that has been
used and as a result of such use is contaminated by physical or chemical impurities"
(40CFR279.1). The U.S. EPA has stated that animal and vegetable oils are excluded from the
federal used oil definition even when used as a lubricant (U.S. EPA, 1996). Spent
Envirotemp®FR3™ fluid may be subject to hazardous waste management under RCRA if the
spent oil meets the federal hazardous waste characteristics listed in 40CFR261.20 through
40CFR261.24 or contains a listed RCRA hazardous waste. End-users outside California should
contact their local or State environmental agency on applicable used oil management regulations
in their area.
In California, used Envirotemp®FR3™ fluid may be included in the Used Oil Program under the
definition of a synthetic oil per 22CCR 66279. l(d). As part of the synthetic oil definition,
"vegetable or animal oil used as a lubricant, hydraulic fluid, heat transfer fluid or for other
similar industrial purposes shall be managed as used oil if it is identified as a non-RCRA
hazardous waste. Used vegetable or animal oil identified as RCRA hazardous waste is not used
oil" (22CCR66279. l(d)) and must be managed as a hazardous waste. A non-RCRA hazardous
waste is one that does not contain a RCRA listed waste, does not exhibit a hazardous waste
characteristic per 40CFR261.20 through 40CFR261.24 but does exhibit a hazardous waste
characteristic per 22CCR66261.20. Transformer oils are included under the California program
if the oil does not exhibit a federal hazardous waste characteristic, does not contain a RCRA
listed waste, contains no more than 5 ppm of PCBs, or has a total halogen content of less than
1,000 ppm.
Used oil (e.g., mineral oils, synthetic oils) managed under the California program must be
managed as a hazardous waste unless it is shown to meet one of the specifications for recycled
June 2002 36
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oil in Health and Safety Code (HSC) Section 25250. l(b) or qualifies for a recycling exclusion
under HSC 25143.2. Used oil generators are required to meet all used oil generator requirements
except householders who perform their own oil changes. DTSC issues an EPA Identification
Number for each site where used oil is stored except for generators of 100 kilograms or less of
hazardous waste per month (including used oil) who ship used oil under a modified manifest.
Above-ground storage tanks and containers accumulating used oil, and fill pipes used to transfer
used oil to underground storage tanks must be labeled with the words "USED OIL _
HAZARDOUS WASTE" and the initial date of accumulation. Used oil must be sent to an
authorized used oil storage or treatment facility by a registered hazardous waste transporter.
However, spent Envirotemp®FR3™ fluid may be exempt from the used oil regulations if the oil is
removed from a transformer, filtered, and then reused on-site in electrical equipment as a
dielectric fluid (HSC 25250.4(b)). This exemption does not apply to transformer fluid that has
been removed, filtered, and then sent off-site for reuse. Facilities should contact their local
environmental agencies on applicable recycling regulations.
5.2.4 Disposal of Waste the Clean-up of Virgin and Spent Envirotemp®FR3™ Spills
In the event of a spill, responders should consult the MSDS and their spill prevention, control,
and countermeasures (SPCC) plan or facility response plan (FRP), if applicable, for the
appropriate clean-up measures. End-users should consult with their local environmental
regulatory agencies on clean-up levels and disposal options for waste generated from these spills.
Since spent Envirotemp®FR3™ fluid may exhibit a hazardous characteristic per California's
hazardous waste definition, the waste generated from spill clean-ups in California should be
presumed hazardous until the waste has been characterized.
5.3 Spill Management
The spill management regulations listed in this section apply to both virgin and spent
Envirotemp®FR3™ fluid. Facilities should contact their local environmental regulatory agency
on other local regulations pertaining to oil spill management.
Oil Discharge
Under 40CFR 110, Discharge of Oil Regulation, facility owners and operators that handle, store,
or transport oils are required to report an oil discharge which "may be harmful to the public
health or welfare, or the environment". A reportable spill is defined as one that either; (1)
violates water quality standards, (2) causes a sheen or discoloration on the surface of a body of
water, or (3) causes a sludge or emulsion to be deposited beneath the surface of the water or on
adjoining shorelines. The term "oil" applies to petroleum based oil products and non-petroleum
based oil products, which include animal fats, vegetable seed-based oils, and synthetic oils.
Adding dispersants or emulsifiers to the oil prior to discharge are prohibited under 40 CFR
Section 110.4.
Oil discharged into or upon the navigable waters of the United States must be reported to the
National Response Center, contained, and cleaned up. Depending on the discharge volume,
June 2002 37
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extent and proximity to sensitive areas (e.g., wildlife areas), coordination and involvement of
local emergency response agencies and the National Response Center may be required for the
clean up effort. These reporting requirements apply to mineral oils and synthetic oils, as well as
vegetable oils.
Oil Pollution Prevention
Under 40 CFR Part 112.1 through 112.7 of the Oil Pollution Prevention; Non-Transportation
Related Onshore Facilities, facilities "that could be expected to discharge oil into or upon the
navigable waters of the United States or adjoining shorelines, and that have (1) a total
underground buried storage capacity of > 42,000 gallons, (2) a total aboveground oil storage
capacity of > 1,320 gallons, or (3) an aboveground oil storage capacity in a single container of >
660 gallons" are required to prepare and submit a SPCC plan. Some facilities may not be
regulated if, due to their location, they could not reasonably be expected to discharge oil into
navigable waters of the U.S. or adjoining shorelines.
Under the 40 CFR Part 112, facilities are required to prepare and submit a facility response plan
(FRP) if they transfer > 42,000 gallons of oil over water to a vessel or have a storage capacity >
1,000,000 gallons and meet at least one of these four criteria; inadequate secondary containment,
proximity to environmentally sensitive areas, proximity to public drinking water intakes, or
occurrence of a 10,000 gallon or more oil spill in the last 5 years. The FRP includes response for
worst-case discharges, estimates of planned resources, emergency response plans, and training
drills/exercises. Under this regulation, the requirements for animal fats and vegetable oils are
similar to those for petroleum oils, but involve new specific methodology for planning response
actions for vegetable oils and animal fats.
The U.S. EPA's analysis of the impacts of the SPCC program indicated that a majority of electric
utility substations and transformer installations would meet the aboveground storage capacity
thresholds. Facilities such as schools and small business complexes are not anticipated to meet
the SPCC or FRP program requirements. Typically, these facilities have several pad-mounted
transformers with an average oil tank capacity of 40 gallons. For compliance, the facility owner
is required to determine if oil storage capacity at a given site meets the criteria listed in the SPCC
and FRP.
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Section 6. Conclusions
6.1 Objective 1, General Performance
The general performance specifications are useful for end users to determine whether the product
will meet their needs. Envirotemp®FR3™ fluid meets Cooper's performance specifications for
dielectric breakdown (minimum and gap), pour point, viscosity (40°C, 100°C), water content,
interfacial tension, and neutralization number. When compared to the ASTM, IEEE, and IEC
specifications, Envirotemp®FR3™ fluid meets these specifications for the dielectric breakdown
(minimum, gap, impulse). It also meets ASTM D3487, IEEE, and LEG specifications for the
neutralization number. However, it had an average dissipation factor at 25°C that did not meet
the Cooper specification. It also had higher dissipation factors at 100°C compared to those
reported for three past samples tested by Cooper. These higher dissipation factors may be due to
contaminants introduced during product storage, sample collection, sample preparation, or
sample testing. Envirotemp®FR3™ fluid did not meet and was not expected to meet the ASTM,
IEEE, and IEC specifications for dissipation factor, pour point, water content, interfacial tension,
and viscosity since these specifications were based on fluids with different physical and chemical
properties.
The in-service transformer fluid sample results for the dissipation factor, neutralization number,
interfacial tension, conductivity and water content met all the Cooper and IEC 1203
specifications for in-service fluid. Based on the historical data for the oldest in-service
transformers, Envirotemp®FR3™ fluid appears to have degraded little over the units' service life.
6.2 Objective 2, Aquatic Biodegradability
The average biodegradability of Envirotemp®FR3™ fluid was 120% ± 33% after 28 days based
on U.S. EPA Method OPPTS 835.3110 results. These results may be biased high due to possible
CC>2 losses in the control samples and should be considered a qualitative measure of the
product's ready biodegradability. Based on these results, the virgin Envirotemp®FR3™ fluid
appears to biodegrade more readily than mineral oil. Although Envirotemp®FR3™ fluid readily
biodegrades per this test, the product's ability to degrade in the environment is dependent on site-
specific factors such as climate, geology, moisture, pH, temperature, oxygen concentration,
dispersal of oil, the presence of other chemicals, soil characteristics, nutrient quantities, and
populations of various microorganisms at the location (U.S.EPA 1997). Therefore, releases to
the water should be prevented.
6.3 Objective 3, Flammability
The flash and fire point for the virgin and in-service fluids were consistently above the minimum
performance values specified by ASTM D3487, D5222, and Cooper. The fire point results
obtained also agreed with values reported by UL.
June 2002 39
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6.4 Objective 4, Acute Toxicity
The average LCso for virgin Envirotemp®FR3™ fluid was less than 250 mg/L. Based on this
limited set of data for virgin product, the spent Envirotemp®FR3™ fluid may exhibit a hazardous
characteristic per 22CCR 66261.24(a)(6). The end-user should characterize their spent
Envirotemp®FR3™ fluid at the time of disposal since changes to the oil may occur due to use,
storage, or age. End-users should also consult their appropriate local, State, or federal regulatory
authority about applicable waste characteristic regulations and available disposal options in their
area.
6.5 Other Verification/Certification Objectives
Chemical Composition
The AOAC results for the virgin Envirotemp®FR3™ samples showed the fluid consisted of
23.8% ± 0.2% monounsaturated fatty acids, 59.9% ± 0.1% polyunsaturated fatty acids, and
15.7% ± 0.1% saturated fatty acids. The in-service transformer fluid consisted of 22.0% to
23.8% monounsaturated fatty acids, 59.8% to 62.4% polyunsaturated fatty acids, and 15.2% to
16.3% saturated fatty acids. These results were all consistent with Cooper's reported
formulation.
Antioxidant concentrations in the virgin Envirotemp®FR3™ samples ranged from 2,787 ppm ±
834 ppm. Antioxidant concentrations in the in-service transformer samples ranged from 3,550
ppm to 4,595 ppm. The antioxidants detected agreed with ingredients list provided by Cooper.
For the 65 standard SVOC compounds analyzed by the HML lab, none were detected in the
virgin product samples. Bis-(2-ethylhexyl)phthalate, butyl benzyl phthalate, and di-n-butyl
phthalate were detected in the in-service transformer samples. These compounds were suspected
to be contaminants introduced from the sampling equipment and DI water used. Other
tentatively identified compounds were various sterols normally found in vegetable oils.
Barium and zinc were detected in the virgin product samples at 26 mg/kg and 36 mg/kg, and at
11 mg/kg and 24 mg/kg, respectively. Barium and zinc were also detected in two in-service
transformer samples at 25 mg/kg and 27 mg/kg, and at 12 mg/kg to 13 mg/kg, respectively.
Cadmium and molybdenum were detected in one in-service transformer sample at 0.42 mg/kg
and 2.6 mg/kg, respectively. The barium and zinc might have been introduced during the
processing of the basestock oil, degassing of the oil, or storage in the finishing tank.
Worker Health and Safety
When comparing the PPE requirements for handling Envirotemp®FR3™ fluid to select mineral
oil-based transformer fluids, these requirements were found to be similar. This comparison is
based on MSDS information for select mineral-oil-based transformer fluids obtained from the
Vermont SIRI MSDS archive. However, respiratory protection for the mineral oil-based
transformer fluids is required at a lower nuisance particulate OSHA PEL than Envirotemp®FR3™
June 2002 40
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fluid. Envirotemp®FR3™ fluid also has less stringent PPE requirements for workers compared to
select silicone oil-based transformer fluids found in the Vermont SIR! MSDS archive.
The ingredients for Envirotemp®FR3™ fluid appear to have less serious health effects listed than
those for select mineral oil-based and silicone oil-based transformer fluids reviewed as part of
this verification/certification. These select mineral oil-based transformer fluids listed a
hydrotreated light naphthenic petroleum distillate, which is an IARC confirmed carcinogen. The
silicone oil-based transformer fluids listed dimethyl polysiloxane as the primary ingredient,
which is a teratogen in animals. The end-user must comply with all applicable worker health and
safety regulations for this product.
Estimated Cost of Using Envirotemp®FR3™ Fluid versus Mineral Oil
The initial purchase cost of a new transformer unit containing Envirotemp®FR3™fluid is
approximately 1.2 to 1.3 times more than a comparable mineral oil transformer.
Envirotemp®FR3™ fluid costs approximately $5 to $8 more per gallon than mineral oil-based
transformer fluid depending on the volume purchased.
June 2002 41
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Section 7. Vendor's Comment Section
The follow ing information was provided by Cooper Power Systems. The purpose is toprovide
the vendor with the opportunity to share their comments on their environmental technology
verification report. This information does not reflect agreement or approval by U.S. EPA and
Cal/EPA.
Vendor's Comment:
The aquatic toxicity test performed by the California EPA is not in accordance with the
recommended sample preparation method for insoluble materials cited in the California Code of
Regulations. Rather than using the appropriate solvent blending method for insoluble materials,
they instead created an emulsion by extreme blending (several hours) of the vegetable oil based
Envirotemp FR3 fluid with water. The resulting heavy emulsion produced is a physical hazard to
fish. This prevented any evaluation of possible toxicological effects of the product.
Testing of acute aquatic toxicity on Envirotemp FR3 fluid was performed by an independent
laboratory using the appropriate sample preparation method for insoluble materials. The tests
resulted in a zero mortality of the trout fry throughout the test duration (96 hours).
We believe that it is essential that the acute aquatic toxicity test method be used for its stated
purpose, the determination of relative systemic toxicity, and not misused to test physical hazard.
Our environmental claim involving acute aquatic toxicity was limited to relative toxicity. Cooper
Power Systems stands by its Verification Claim #4 submitted to the California EPA that
Envirotemp FR3 dielectric coolant is not toxic to trout fry.
June 2002 42
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