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United Stat99

Enlilronmental Protuctlon

Agency

Toxic Substances

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Office- of Toxic scostanees April 1979

Washington DC :20460

oEPA Support Document/Voluntary

Environmental Impact 1':'l':'.';~~r~,;\g~;:LJ Region ~. •

Statement S[-.P.J.~1980

and

PCB Manufacturing,

Processing, Distribution in

Commerce, and Use Ban

Regulation: Economic

Impact Analysis
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VOLUNTARY ENVIRONMENTAL IMPACT STATEMENT

SUMMARY SHEET

(Check One)

( ) Draft.

(X) rinal Environmental Statement.

Environmental Protection Agency

Office of Toxic Substances

1. Name of Action. (Check One)

(X) Administrative ~ction.

( ) Legislative Action.

2. De~cription of Action.

This rule implements §6(e) of the Toxic Substances

Control Act (TSCA) which prohibits the manufacturing,

processing, distribution in commerce, and use (unless

the use is totally enclosed) of PCBs and requires

regulations controlling marking and disposal of PCBs.

It applies to any chemical substance or combination of

substances that contain 50 ppm, or greater, PCB. The

rule authorizes several limited exceptions to these

general prohibitions in instances where activities do

not present an unreasonable risk of injury to health and

the environment. These exceptions are related to

limited servicing and use activities involving the

following; electrical transformers, railroad

transformers, hydraulic systems, mining machinery, heat

transfer systems, pigments, electromagnets, natural gas

pipeline compressors, small quantities for research and

development, microscopy, and carbonless copy paper. The

use of PCBs has been extensive throughout the United

States and, therefore, the rule has a nationwide impact.

3. Summary of Environmental Impact and Adverse

Environmental Effects.

PCBs are a significant environmental pollutant occurring

throughout the biosphere. They pose a significant risk

to the health of man and numerous other living things.

A number of adverse effects on living organisms have
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Protection Agency Region 9 '

SEP 2 ~' 1980

ENVIRONMENTAL PROTECTION AGENCY

SUPPORT DOCUHENT/

VOLUNTARY ENVIRONMENTAL IMPACT STATEMENT

, for

Polychlorinated Biphenyls (PCBs)

Manufacturing, Processing, Distribution in Commerce, and

Use Ban Regulation (Section 6(e) of TSCA)

Prepared by

Office of Toxic SUbstances

Approved by

Deputy

the 0

John P. DeKany

lstant Administrator for

ce of Chemical Control
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been demonstrated, including, but not limited to

bioaccumulation, biomagnification, carcinogenicity,

mutagenicity, teratogenicity, and fetotoxicity. PCBs

are extremely persistent in the environment, circulating

among the air, water, and land; and any additional

release of PCBs in the environment will eventually

result in widespread distribution of PCBs and,

thereforet increase exposure and risks.

4. Alternatives Considered.

In developing these proposed rules, EPA considered

whether there were other regulatory or nonregulatory options available as alternative approaches to implementing the §6(e) prohibitions against PCB activities and

otherwise satisfy the purposes of §6(e) of TSCA. Below

is a discussion of the three major options that the

Agency considered.

a. No Action.

This alternative was rejected because Congress

mandated in TSCA that the manufacturing, processing, distribution in commerce, and use of PCBs be prohibit~d according to a certain schedule. EPA's discretion with

respect to these 9rohibitions is to establish an~ clarify certain definitions and to provide exceptions to the

prohibitions if there is no unreasonable risk to health

and the environment.

b. Action Through Other Statutes or Regulatory Bodies.

This alternative was rejected. It was determined that ~·using othe r s ta tutes adrni ni s t er ed by EPA (i. e., Clean

Alr Act, Clean Water Act, Safe Drinking Water Act, or

Resource Conservation and Recovery Act) was

inappropriate because they could not provide the

comprehensive coverage necessary to implement S6(e).

This is also true of statutes administered by other

regulatory agencies or state governments. Furthermore,

there is a strong case that EPA is required by TSCA to

use §6(e) of TSCA to implement and grant exceptions, if

appropriate, to the explicit prohibitions mandated by

§6(e). Section6(e)(4) specifically exempts EPA from the

requirements of §6(c) (1), including that of considering

the use of other EPA-administered authorities as

alternatives to rulemaking under §6 of TSCA. This

indicates that Congress intended that EPA use TSCA to

implement these prohibitions on PCBs.
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-iiiThe use of other authorities to resolve the PCB problem

addressed by §6(e) (2) and (3) would be impractical,

complex, time consuming, and in some cases impossible.

No other Federal statute grants the kind of authority

necessary to directly control the range of PCB

activities covered by §6(e). Sections of·several

statutes might have to be invoked in separate actions

for each aspect of each PCB activity. A number of

indirect controls would be necessary to effectively

prohibit PCB activities as required by TSCA except in

those cases where risks were found to be reasonable.

The other relevant statutes, moreover, are often not

designed to provide this comprehensive coverage, even

when used in concert. For example, many sources of PCB

air emissions are not included within the definition of

sources subject to regulation under the Clean Air Act

(CAA). The concepts of area-wide standards and controls

in the Clean Water Act (CWA) and the CAA do not seem

appropriate for implementing these prohibitions of PCBs

and specific PCB Articles or activities of con~ern.

There are final regulations under §307(a) of the CWA

which complement this regulation and which set effluent

standards prohibiting any discharge of PCBs, but only

from PCB manufacturers, electrical capacitor . manufacturers, and electrical transformer.

manufacturers. If the CWA, the Safe Drinking Water Act,

or the Resource Conservation and Recovery Act were used

in lieu of TSCA, many spills could be controlled, but

other aspects of the PCB problem could not.

Some other Federal statutes not administered by EPA

could also be utilized to control some types of exposure

to PCBs. The National Institute for Occupational Safety

and Health has set a workplace exposure criterion of 5

ppm for empioyee exposure and recommended that the

Occupational Safety and Health Administration prepare

regulations accordingly~ But again, this only addresses

a part of the problem. A few States have regulations on

PCBS, but they are not sufficient to cover all

activities addressed by TSCA nor, obviously, do they

provide control of PCBs on a national scale.

c. Action Under Section 6(e) of TSCA.

Numerous alternatives were considered within the authority of §h(e) of TSCA. These alternatives were fully

discussed in the Support Document/Voluntary Draft

Environmental Impact Statement, the Preamble to proposed

regulation, and the Preamble to this regUlation.

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-iv5. Major Definitions.

hPCB" is defined to mean any chemical substance

that is limited to the blphenyl molecule that has been

chlorinated to varying degrees or any combination of

substances which contains such substances.

"Significant Exposure" is defined as any exposure of

human beings or the environment to PCBs, as measured or

detected by any scientifically acceptable analytical

methOd.

6. Totally Enclosed Activities.

Congress mandated in §6(e) (2) of TSCA that all

non-totally enclosed activities are banned as of

January 1, 1978. Non-totally enclosed was defined by

Congress to mean any manner that resulted in significant

exposure as specified by EPA. Below are identified

those activities that the Agency considers to be totally

enclosed.

PCB Transformers (non-railroad) - Use, except

servicing, of intact, non-leaking PCB

transformers is considered totally enclosed.

PCB-Contaminated Transformers - Use,

except servicing, of intact,

non-leaking PCB-contaminated

transformers is considered totally

enclosed.

Electromagnets - Use, except servlclng,

of intact, non-leaking electromagnets

is considered totally e~closed.

PCB Capacitors - Distribution and use

of intact, non-leaking, PCB

Capacitors are considered totally

enclosed.

PCB Equipment - Processing, distribution in

commerce, and use of PCB Equipment are considered

totally enclosed.
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-v7. Authorizations.

The Agency has found that the following activities dO

not present an unreasonble risk to health and the

environment. In making these decisions the Agency

considered (1) the health and environmental effects of

PCBs, (2) the exposure to PCBs from these activities,

(3) the availability of substitutes in these uses, and

(4) the economic impact from restricting these uses.

Unless otherwise noted, all authorizations expire on

July 1, 1984: however, exemptions must be obtained if

processing and distribution in commerce are to continue

after July 1, 1979.

PCB Transformers (non-railroad) - Processing, distribution in

commerce, and use are authorized.

Servicing (except rebuilding) is

author.ized.

PCB-Contaminated Transformers - Processing,

distribution in commerce, and use are

authorized. Servicing (including

rebuilding) is aut ho r i zed ;

Railroad Transformers - Processing,

distribution in commerce, and use

are authorized. Servicing

(including rebuilding) is

authorized.

Mining Equipment - Processing, distribution

in commerce, and use (including servicing)

are authorized until 1/1/82. After 1/1/80,

rebuilding of continuous miner type motors

is prohibited.

Heat Transfer Systems - Use is authorized.

Hydraulic Systems - Processing, distribution

in commerce, and use are authorized.

Pigments - processing and distribution

in commerce are authorized. Use is

authorized until 1/1/82.

Electromagnets - processing, distribution

in commerce, and use are authorized.

Servicing (except rebuilding) is

authorized.
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Natural Gas Pipeline Compressors - Use

is authorized until 5/1/80.

Small Quantities for Research and

Development - Processing,

distribution in commerce, and use

are authorized.

Microscopy - Processing, distribution

in commerce, and use are authorized.

Carbonless Copy Paper - Use is

authorized indefinitely.

B. Federal Agencies That Participated on EPA's PCB Work

Group:

Department of Commerce

Department of Defense

Department of Transportation

Department of Interior

Federal Railroad Administration

General Services Administration

National Institute for Occupational Safety and Health

Tennessee Valley Authority

9. On or abou t At"" I :tb\.tq'lq the Support Document/ Vol un tary

Environmentalmpact Statement was officially filed with

the Director, Office of Federal Activities, EPA. It is

available to the public. Copies can be obtained by

writing the Industry Assistance Office, Office of Toxic

Substances (TS-793), Environmental Protection Agency,

401 M Street, S.W., Washington, D.C. 20460, or by

'calling (800) 424-9064, in Washington, D.C., call

554-1404. The official record of rulemaking, including

both the draft and final Support Document/Voluntary

Environmental Impact Statement, is located in room 709,

East Tower, Environmental Protection Agency, 401 M

Street, s.v.: Washington, D.C. 20460, (202) 755-6956.

It will be available for viewing and copying from 9 a.m.

to 4 p.m., M~naay through Friday excluding holidays.
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r.

II.

III.

IV.

V.

VI.

VII.

VIII.

IX.

X.

XI.

XII.

XIII.

XIV.

XV.

XVI.

XVI I.

XVI I I.

XIX.

•

Appendix I .

TABLE OF CONTENTS

Introduction .......•.....................p. 2

Significance of Release of PCBs into

the Environment ......• ......•...........p. S

PCB Substitutes.......••......••.........p. 39

Significant Exposure/Totally Enclosed

Manner p.48

PCB Definition: 50 ppm.•........••...... p. ~J

Dllution ............•......••.•.....•.....p. 6L.

Transformers " p. 65

Ra Ll r'o ad s .•••.•••••••••••••• /f ••••••••••••p. ~u

Mining ..•....•••......•......••.........•p. 8::1

Hydraulic Systems •......••...............p. H4

Heat Transter Systems ...........•......•.p. 87

PCB Articles and PCB Equipment••••......• p. 89

Pigments p. 92

Process Contamination •.....•........•....p. 95

Electromagnets .........•.....•........•••p. ~B

Microscopy " p. 9~

Waste Oil p , 1u2

Natural Gas Compressors •......••......•..p. 103

Revised Versar Report p. 105

List of Major Comments .......••......••..p. 10;>

1
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I. INTRODUCTION

PCBs have been used in the United States since 1929 in

such applications as transformer cooling liquids, capacito~

dielectric fluids, heat transfer and hydraulic liquid~, dye

carriers in carbonless copy paper, plasticizers in paints,

adhesives, and caulking compounds, fillers in investment

casting wax, and dust control agents in road construction.

Monsanto was the major U.S. manufacturer of PCBs. Since

1972, Monsanto limited sales of PCBs to manufacturers of

transformers and capacitors. Monsanto ceased manufacturing

PCBs in mid-1977, and shipped the last remaining inventory

"by' October 31, 1977.

Small quantities of PCBs may be produced currently, as

unintentional byproaucts of other chemical processes.

Similarly, chlorination of water which contains appreciable

concentrations of biphenyl can ~esult in the unintentional

formation of PCBs. No natural sources of PCBs have been

identified.

2
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Prior to the enactment of the Toxic Substances Control

Act (TSCA), the authority of the EPA with respect to PCBs

was limited to the regulation of contaminated water from

point sources. EPA promulgated a rule under Section 307(a)

of the Clean Water Act on February 2, 1977 (42 FR

6532-6556), which banned the discharge of PCBs into

navigable waters by electrical transformer and capacitor

manufacturers.

The enactment of TSCA in October 1976, placed additional

restrictions on the use of PCBs and required that certain

actions be taken by EPA. Section 6(e)(1) of TSCA required

that EPA promulgate a disposal and marking rule for PCBs.

This rule, promulgated by EPA on February 17, 1978 (43 FR

7150-7164), regulates the disposal of PCBs and requires that

special warning labels be applied to large capacitors,

transformers, and other PCB Items. The Disposal and Marking

Rule covered liquid PCBs and all other material and

equipment components containing or having contained PCBs in

concentrations of greater than 500 ppm (0.050 percent).

Clarifying amendments to this rule were published on August

2, 1978 (43 FR 33918).

On June 7, 1978 EPA published the proposed rules (43 FR

24802) implementing §§6(e) (2) and 6(e)(3) of TSCA. These

rules proposed to prqhibit or authorize certain PCB

3
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activities that are not conducted in a totally enclosed

manner. This rule also specified those activities that the

Agency considered to be performed in a totally enclosed

manner.

Concurrently with the proposed rule, the Agency also

published a support Document/Voluntary Draft Environmental

Impact Statement (Draft Support Document). In that

document, the Agency discussed the different alternatives it

considered in regulating the various PCB activities.

The Agency held 10 days of public hearings in

Washington, D.C. from August 21 to September 1 to solidit

comments on the proposed rule. Over 50 oral presentations

were made. On September 22, 1978 (43 FR 43048), EPA

published a notice of the opportunity for cross-examination

and extended the reply comment period to October 10, 1978.

Two hearing pa~ticipants conducted cross-examination on

September 26, 1978. EPA received over 200 comments on the

proposed rule.

Section 6(e)(3) (B) of TSCA also provides that persons

may petition the Administrator for exemptions from the

prohibition of the manufacture, processing, and distribution

in commerce of PCBs or PCB Items. Interim rules

establishing procedures for submitting petitions for

exemptions from the prohibitions were published on

November 1, 1978 (43 FR 50905). More than 70 petitions for

4
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exemptions have been received. On Janua1."'y 2, 1979 EPA

announced (44 FR 108) that it would not enforce the PCB

manufacturing and importation ban of §6(e) (3) (A) against

persons who submitted petitions, until EPA had acted on

their request for exemptions.

Concurrently with publication of the final

manufacturing, processing, distribution in commerce, and use

bans, the Agency has PUblished its proposed disposition on

the requests for exemptions from this Rule. public hearing

and pUblication of the final disposition will be

forthcoming.

This Support Document/voluntary Environmental Impact

Statement (Final Support Document) has been prepared to

address the major comments made during the rulemaking

proceedings. Each of the major comments has been listed and

assigned a number in parentheses in Appendix I to this

document. For the convenience of readers, representative

comments are referenced by number when they are addressed by

the Agency in this document. EPA wishes to emphasize,

however, that the comments listed may not represent all of

the comments considered by EPA and Which address the

particular issue discussed. In some cases, discussion of

issues raised by cornmentors will also be found in the

Preamble to the final rule.

As noted, this document responds to comments received on

the proposed rule. It contrasts with the Draf.t Support

Document which discussed the options the Agency considered

5

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to control the various applications of PCBs. Two sections

(Section I, Background and Section II, Alternatives to this

- Rule) in the Draft Support Document that are relevant to

this phase of ru1emaking have been revised and included in

this Support Document in the Introduction and the Summary

Sheet. Section III (Significance of Release of PCBs Into the

Environment), and Section V (Substitutes) of the Draft

Support Document are included as Sections II and III of this

Final Support Document. Minor revisions have been made in

these sections prior- to their inclusion. The three

remaining sections, Section IV (Definition of PCB Mixture) ,

Section vr (Reasonable use Determinations), and Section VII

(Waste Oil), although containing much of the same rationale

used in the final rulemaking, have not been included in this

document. However, those three sections describe (1) the

regulatory options considered by EPA prior to proposal of

this rule and (2) reflect the information that was then

available to the Agency.

This Support Document/Voluntary Environmental Impact

Statement contains the same information as would be prepared

to meet the requirements of Section 6(c)(l) of TSCA. While

not legally required to prepare an Environmental Impact

Statement (EIS) by Section 102(2) (c) of the National

Environmental Policy Act (NEPA) of 1969, EPA has voluntarily

prepared this Support Document/Voluntary Environmental

6
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Impact statement in conformance with the spirit of its 1974

statement on voluntary EIS's (39 FR 37419, October 21,

1974). The voluntary preparation of this document in no way

legally subjects the Agency to NEPA requirements.

Persons who are interested in the approximate costs to

the various industries to comply with the requirements of

the rUle, are referred to the economic study entitled PCB

Manufacturing, Processing, Distribution in Commerce, and Use

Ban Regulation: Economic Impact Analysis (the Versar

Report) found at the end of this document.

EPA wishes to emphasize that equality of PCB regulatory

costs for the different affected industries described in the

,

economic study is not the goal of this regula~ion. EPA is

seeking to regulate as many PCBs as possible. The Agency

recognizes, however, its inability to regulate some

activities, such as disposal of many types of PCB Equipment,

due to the broad ownership ot such equipment at a vast

number of sites. Although equality of: regulatory costs for

different affected industries has not been a goal, EPA has,

where appropriate, taken costs into account by lengthening

the compliance schedule or allowing disposal alternatives.

7

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II. SIGNIFICANCE OF THE RELEASE OF PCBs INTO

THE ENVIRONMENT

Introduction

Section 6(e) (2)(A) of TSCA prohibits the manufacture,

processing, distribution in commerce, and use of PCBs after

January 1, 1978, in other than a totally enclosed manner.

"Totally Enclosed Manner" is defined by TSCA to mean a

manner which will ensure no significant exposure of human

beings or the environment to PCBs, as determined by EPA by

rule [Section 6(e) (2) (C)l. The final rule, in turn,

provides that human or environmental exposure to any

detectable quantities of PCBs shall be deemed significant.

This provision is based on the finding that any release of

PCBs into the environment will eventually result in

widespread exposure of wildlife, including some of man's

major food sources, and humans and that any such exposure

may have adverse effects.

The following sections summarize the variety of adverse

effects which PCBs have been found to have in humans,

laboratory animals, and other organisms, and the extent -t.o

which PCBs released into the environment become distributed

throughout the biosphere. The adverse effects have been

described in greater detail in various documents, including

EPA Report No. 440/9-77-021, Criteria Document for PCBs,

8
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July 1976; Criteria for a Recommended Standard:

Occupational Exposure to Polychlorinated Biphenyls (PCBs),

National Institute for Occupational Safety and Health,

September 1977; and "Environmental Health Criteria;

Polychlorinated Biphenyls and Polychlorinated Terphenyls,"

World Health Organization, 1976. PCB-induced effects were

also reviewed in detail in expert testimony at a public

hearing before EPA and were acknowledged and described in a

decision by the Administrator to promulgate toxic pollutant

water effluent standards for PCBs (42 FR 6532-6556, February

2, 1977). These standards were affir-med in Environmental

Defense Fund vs. Environmental Protection Agency, 12 E.R.C.

1353 (D.C. Cir. 1978).

Significance of Exposure to PCBs

A. Absorption and Storage

PCBs are absorbed through the lungs, the

gastrointestinal tract, and the skin. l After absorption,

PCBs are circulated throughout the body in the blood and are

stored in adipose tissue and in a variety of organs and

tissues, including the liver, kidneys, lungs, adrenal

glands, brain,heart, and skin. 2

B. Specific Adverse Health Effects of PCBs as Observed in

Toxicology Tests and Epidemiological Studies

The view that human health risks resulting from exposure,

to chemicals may be determined experimentally by testing

laboratory animals is one that is widely accepted in the

9

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scientific community and has been adopted by EPA. Because

experimentation on human beings raises ethical questions and

because epidemiological studies often provide incomplete

intormation, toxicology studies on laboratory animals are

otten necessary. However, because the extrapolation from

animals to man is subject to some uncertainty, corroboration

of laboratory test data wlth sound epidemiological

information is desirable. The available toxicological and

epidemiological data relating to the effects of PCBs are

discussed below.

1. Oncoqen . i c i tv.

PCBs appear to have Qaused malignant and benign tumors

in rats and mice in several experiments. 3 In one

carefully conducted experiment, rats fed 100 ppm of Aroclor

1260 in the diet for 21 months developed a high incidence of

carcinomas (26/184) and neoplastic nodules (144/184) in the

liver. Only one ot l7J control animals developed a

carcinoma 1 and none developed neoplastic nodules. In

another exper.iment, rats were fed Aroclors 1242, 1254, and

~2QO for 24 months. Rats exposed to any of the three

mixtures at 100 ppm in the diet developed liver tumors

(hepatomas and cholangiohepatomas), whereas none was

observed in the controls (3/20 for Aroclor 1242, 6/27 for

Aroclor 1254, 7/27 for Aroclor 126U, and U/~O for the

controls). A high frequency of nodular hyperplasia in the

liwer, considered by some authorities to be precancerous,

10
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was observed in the rats fed 100 ppm of the three mixtures..

A significant increase in freguenqy in comparison to

controls was observed down to the 10 ppm dosage level. 4

The results of the epidemiological data, although

somewhat ambiguous, provide additional evidence that PCBs

pose a carcinogenic risk to man. In 1968, at least 1,291

persons were afflicted with a disease known as Yusho as a

consequence of eating rice oil contaminated with PCBs and

relatively smaller amounts of polychlorinated dibenofurans

(PCDFs). Although precise data are not yet available, a

preliminary tabulation of the deaths among Yusho victims

through 1975 showed an excess in the rate of cancer,

particulary of the stomach and liver. S In another

preliminary study, 92 workers considered likely to have been

exposed to Aroclor 1254 at a New Jersey petrochemical

/

facility between 1949 and 19S7 indicated a significant

excess of malignant melanoma and pancreatic cancer. Sa In

the third study, an examination of the death certificates of

50 employees formerly engaged in the manufacture of PCBs

revealed seven cases of lung cancer, compared with an

expected 2.5 cases. However, these results were not

corrected for age or smoking habits and are only

preliminary.6

2. Teratogenic, Fetotoxic, and Reproductive Effects

Beagle dogs fed Aroclor 1254 at the rate of 1.0

mg/kg/day had offspring with a significantly higher

incidence of patent fontanelles than did controls but

11

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exhibited no decrease in the number of offspring. In the

same experiment, dogs fed 5.0 mg/kg/day had a fetal

resorption rate of 45.5 percent (a fourfold increase over

controls). Patent fontanelles we~e present in 50 percent of

7

the offspring.

Sows fed Aroclor 1254 at a aose of 1.0 mg/kg/day for 21

days before breeding and throughout gestation experienced a

statistically significant rate of fetal resorption. Higher

dosages further reduced fertility and caused a variety of

defects in the offspring, including cleft palate,

8

syndactyly, and patent fontanelles.

Female rhesus monkey fed PCBs at 5 ppm and 2.5 ppm in

the diet for 6 months before mating with untreated males

demonstrated severe reproductive dysfunctions. Only one of

the eight animals fed the higher dose gave birth, with five

animals experiencing abortions and two not conceiving at

all. Of the eight monkeys fed the lower dosage, five gave

9

birth to extremely small infants, and three aborted.

In another experiment, three of six infant rhesus

~onkeys born to mothers fed 2.5 ppm of PCB died within 6

months of birth. ~1e surviving three infants exhibited

10

behavioral and learning defects.

Studies with mink have also demonstrated the adverse

effects of PCBs on reproduction. Ranch mink fed coho salmon

contaminated with 12 to 20 ppm of PCBs suffered

reproductive failure and kit mortality. Female mink fed

12
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dosages as low as 5 ppm of Aroclor 1254 and 2 ppm of Aroclor

1016 experienced substantial reductions in the number of

11

live kits born.

3 . Enzyme Induction by PCBs :l

It has been demonstrated in several experiments that ,~l

PCBS induce various microsomal enzymes of the liver,

including mixed-function oxidases. Such induction has

occurred after administration of Aroclors 1016, 1242, 1248,

1254, and 1260 to rats at dosages as low as 1 mg/kg/day for

21-28 days in the diet. Some of the enzymes induced by PCB

mixtures and chlorobiphenyl isomers in rats and other

animals are nitroreductases, dimethy1ases, diethylases,

glucose-6-phosphatases, aryl hydrocarbon hydroxy1ases,

cytochromes P-450 and P-448, NADPH cytochrome reductases,

and delta-aminolevulinic acid synthetases. 12In one study

it was shown that humans exposed to PCBs showed elevated

levels in the blood of the enzyme, gamma g1utamy1

transpeptidase, a sensitive indicator of liver

dys functio n .13

The consequences of this enzyme induction may be guite

significant. Some of the enzymes induced by PCBs, such as

cytochrome P-4S0 and cytochrome P-450 de~endent

N-demethylase, are involved in the metabolism of therapeutic

drugs. Induction of these enzymes would therefore be

expected to alter. the function of such drugs and interfere

with the treatment of diseases in humans. This possibility

has been clearly demonstrated in one experiment in which

13
r Hl\ !'iU. q 1~tjq {j~~j r. t.j/jq

workers occupationally exposed to Aroc1or 1016 for the 2

years immedi.ately before the experiment and to Aroclors

- 1242, 1254, and 1260 in earlier years were administered

antipyrine, a prototype drug substrate. The half-life of

the antipyrine in the plasma of the exposed workers was

approximately two-thirds of that observed in control

14

subjects.

Another expected consequence of the induction of certain

liver enzymes is an alteration of the incidence of human

cancer. Although the mixed-function oxidases detoxify

foreign chemicals in the body, they may also metabolize some

15

of these substances into more toxic or carcinogenic forms.

However, it is difficult to predict whether,induction of

these enzymes would have a net effect of increasing or

decreasing the incidence of cancer.

Induction of liver enzymes by PCBs could also result in

a modification of the overall metabolism of the body by

altering the metabolism of the steroid hormones. 16rn

addition, stimulation of the production of the enzyme

delta-amino-vulinic acid synthetase by PCBs has been

demonstrated to cause porphyria and accumulation of

porphyrins in the liver in rats, mice, and rabbits. 17

4. Effects on the Immunological System

Several experiments have demonstrated that PCB mixtures

produce immunosuppressive effects in laboratory animals. In

14
V VI.. I L LVVV riLV VV' LV rn t Vo"; 1... Ion

I' nl\ nvo 't I ;,)v't , .J;,);,).J I. L't/.J't

one study, guinea pigs were fed Aroclor 1260 at 10 ppm in

the diet for 8 weeks and received injections of tetanus

toxoid to stimulate antitoxin production by the lymphoid

system. In comparison to controls, PCB-treated animals

exhibited reduced numbers of gamma-globulin-containing cells

in the lymph nodes as well as reduced serum gamma-globulin

18

levels. Infant rhesus monkeys dosed with 35 mg/kg of

Aroclor 1248 for 4 weeks exhibited atrophy of the thymus.

The same effect was observed in rhesus monkeys fed daily

19

doses as low as 3 ppm of Aroclor 1242. In addition,

decreased weight and atrophy of the thymus and lymphoid

system were' observed in guinea pigs and rats

20

administered oral doses of PCBs.

5. Mutagenicity

Whydam and co-workers demonstrated that 4-chlorobiphenyl

is a potent mutagen in the Ames test for bacterial

21

mutagenesis. These workers also found that the mutagenic

activity of PCBs decreased with increasing chlorination and

that the most highly chlorinated mixtures had almost no

activity.

In several studies, various doses of Aroclor 1242 and

Aroclor 1254 were administered to rats and the chromosomes

of the bone marrow and testicular cells of these animals

were then examined for abnormalities. No significant

increases in chromosomal aberrations were observed in

15
VUL 1L LUUU ~LlJ UV'C..V nil U. t.J L, I, n r nIl I1V. '11 Jv'1 , JJJJ I. LJI J'1

comparison with controls. In another study, administration

of these chemicals to rats did not appear to induce dominant

22

lethal mutations.

6. Effects on the Liver and Stomach

The induction of hepatic microsomal enzymes and the

causin~ of malignant tumors of the liver by PCBs have

already been discussed. Other adverse effects on the liver

have also been observed and are described here.

In one study, weaning rats fed Aroclor 1254 at 1 ppm in

23

the diet exhibited significantly increased liver weights.

In another experiment, rats fed Aroclors 1248, 1254, and

1260 at 1000 ppm in the diet for 6 weeks were found to have

hypertrophied livers weighing four times as much as those

controls. Abnormal ultra-structural changes within the

liver cells of the PCB-treated animals included

proliferation of smooth endoplasmic reticulum, development of large concentric arrays of membranes, atypical

24

··mitrochondria, and increases in lipid droplets. One

stUdy performed by the National Cancer Institute observed

25

proliferative changes in the liver cells of rats. In guinea

pigs, liver damage has been observed at dosages of Clophen

A60 (a PCB mixture) as low as 250 ppm in the diet.

Increased liver weight has been observed at doses down to 50

26

ppm.

16
vUL-U:'-C.UUU v-ICU Uv·c.v nil U• .; C. I. n

J nl\ nv. '"! 1 '.Iv'"! I '.1'.1'.1'.1 I I ,-VI oJ"1

Low oral doses of PCBs have resulted in stomach lesions

in several species. Dogs fed dietary levels of 1 ppm of

Aroclors 1254 and 1260 and 10 ppm of Aroclor 1242 for 2

years suffered from stomach ulcers and nodules. Rhesus

monkeys fed 2.5 ppm of Aroclor 1248 and 3 ppm of Aroclor

1242 in the diet developed stomach lesions which were severe

in some cases. Sows also suffered from stomach lesions

27

after being fed Aroclor 1242.

7. Effects on Skin and Other Epidermal Tissues

Exposure to PCBs has resulted in various adverse effects

on the skin and other epidermal tissues in humans.

Chloracne, a specific type of acne caused by certain

chlorinated hydrocarbon compounds, has developed among

workers occupationally exposed to air containing PCBs at

28

levels as low as 0.1 mg/m. Skin lesions similar to

chloracne have been one of the major clinical signs observed

in victims of Yusho disease. In addition, Yusho victims

have experienced eye discharges caused by hypersecretion of

the meibomian glands, swelling of the upper eyelids and

hyperpigmentation of the skin, nails, and mucous membranes.

It has been estimated that Yusho disease has resulted from

ingestion of PCBs in contaminated rice oil at a rate as low

as 67 ug of PCB/kg of body weight per day for 3 months,

although it should be noted that the Yusho incident involved

exposure to high concentrations of chlorinated dibenzofurans

and other chemicals which make it difficult to develop

precise conclusions. 27

17

,

"

i

"

,

,I
IJUL i z, r:..UUU \"ICV UiJ' co nil U. oJ C, I. n I, Ll/v'1

8. Other Effects

Workers exposed to PCBs have been shown to hav e eleva ted

levels of fat (triglyceridesl in the bloOd. 30 The best

current thinking in medicine is that such elevations

constitute a serious risk for the development of heart

diseases and strokes. Workers exposed t~ PCBs have

experienced numerous other symptoms and adverse effects,

including digestive disturbances, jaundice, impotence, dry

or sore throat, and headache. 3l In addition/ Yusho

victims have suffered from abdominal pain, menstrual

irregularity, fatigue, cough, and disorders of the

peripheral nervous system. 32

C. Effects on Wildlife

It is reasonble to expect that many of the adverse

effects observed in laboratory animals could also occur in

wild mammals exposed to PCBs. Since, as discussed below/

PCBs have a tendency to collect in waterways and

.~~oaccumulate in fish, fish-eating mammals such as otters,

mink, and bears are particularly at risk. It has already

been noted that mink fed PCB-contaminated fish suffered

reproductive failure. Other effects observed in exposed

mink include reduced weight gain, increased mortality, and

enlargement of the liver, kidneys, and heart. 33

18
VVL.. IL LVVV ril..LI VV'Lv nil V • .; 1.., I, n r nf\ nv, 'i I ;;v'i I -.>;;;;-.> I. CU/-.>'i

Many wild birds are probably also highly susceptile to

PCBs. Several fish-eating birds, including two bald eagles,

have been found dead with lethal quantities of PCBs in the

34

tissues. Ring doves and American kistrels fed 10 ppm of

PCBs suffered from severe reproductive failure. In

addition, birds exposed to PCBs have also exhibited induction of hepatic microsomal enzymes, porphyria, changes in

thyroid activity, abnormal behavior, and increased suscep35

tibility to viral disease.

The various PCB mixtures are highly toxic to several

aquatic invertebrates and fish at extremely low concentrations. Aroclors 1248 and 1254 impair reproductivity of

water fleas at concentrations as low as 0.48-1.0 ppb.

Aroclor 1254 is toxic to several types of shrimp at levels

of approximately 1 ppb. Substantially increased mortality

of the fry of sheepshead minnows resulted from exposure to

water containing 0.16 ppb of Aroclor 1254. It is thought

that PCB levels of only a few parts per trillion in lake

Michigan may be responsible for the reproductive failure of

several species of fish in that body of water. There is

cilso strong evidence that PCBs at concentrations below 1 ppb

36

may adversely affect aquatic insects and crustaceans.

Concentrations of Aroclors1242, 1016, and 1254 as low

as 0.1 ppb have been demonstrated to depress photosynthesis

in phytoplankton and to reduce the rate of cell growth and

19

I

I'

I.

",
r HI\ l'iV. 41 O~4 ( JOOJ r. c..~/J4

division of these organisms. These effects are very

significant since the productivity of the entire marine

ecosystem may depend on the productivity of the

37

phytoplankton within it.

D. Toxicity of PCDFs

Polychlorinated dibenzofurans (PCDFs) are found in small

but variable quantities as impurities in most PCB mixtures.

In addition, PCDFs can be formed by photodegradation of PCBs

in the "environment. At present, it appears impossible to

differentiate the toxic effects of PCBs from those of PCDFs.

Consequently, it is necessary to regulate the commercial PCB

mixtures with recognition that part of their toxicity

38

may be attributable to unavoidable contaminants.

E. Toxicity of PCB Metabolic Products

A number of studies have shown that PCBs are biodegraded

into even more toxic metabolites. For example, it has been

demonstrated that tetrachlorobiphenyl, which is a

substantial component of several major commercial PCB

mixtures, is transformed into toxic intermediate byproducts,

including arene oxides and dihydrodiols. These substances

·'have been found to cause cancer, mutations, and other toxic

39

effects.

F. Relative Toxicity of the PCB Mixture

PCBs are usually sold commercially as mixtures of

biphenyl molecules with varying degrees of chlorination.

Aroclors 1016 and 1242 have relatively low chlorine content,

whereas the chlorine content of Aroclor 1254 is relatively

20
JUL-lC:-C:UUO WCI) UV' JU MIl U• .) C. r . M

r , JUt J'"t

high. It has been argued (174) that the less highly

chlorinated mixtures and components may be less toxic and

hazardous than the more highly chlorinated mixtures, and

therefore the regulation of the former should be less

stringent. This argument was considered in great detail at

public hearings before EPA on Toxic Pollutant Effluent

Standards for PCBs and was rejected by the

Administrator. 40 There were several bases for not

establishing separate standards for the different PCB

mixtures. It was de~ermined that all PCB mixtures then in

use, including the less chlorinated ones (e.g., Aroclor

1016), are capable of inducing sever~ toxic effects at low

levels in mammals and aquatic organisms. In addition, the

compositions of the different PCB mixtures change and may

become more similar after release into the environment, so

that it would make no sense to regulate the mixtures, under

different standards. Furthermore, important components of

all the mixtures, including the less chlorinated ones, are

highly persistent. Finally, while the less chlorinated

components of the PCB mixtures are not stored in tissues as

efficiently as the more highly chlorinated molecules, even

the less chlorinated commercial mixtures have substantial

amounts of components that are subject to significant uptake

and storage. 41

21
V UL. I CLUUU WCI) ua o,JU nil u, oJ Co r . n r nl\ nv, "! I ;,)a"! r ,J;,);,),J I 0 ,J 1I ,J't

G. Inability to Establish a "Safe" Level of Exposure for

PCBs

The available data indicate the PCB may cause several

adverse effects in humans, mammals, birds, and aquatic

organisms at extremely low concentations. Therefore, for

all practical purposes, exposure of humans ana other animals

to any level of PCBs should be deemed significant. This is

especially true in light of the demonstrated carcinogenicity

of PCBs. EPA has adopted the view that "safe" or

"threshold·' levels for carcinogens cannot be established

42

given the present state of scientific knowledge. This

policy has been upheld by the Federal courts in several

43

decisions.

Environmental Exposure to PCBs

A. General

The purpose of this section is to discuss how PCBs

released anywhere into the environment may eventually become

-,w~dely distributed, with the result that many organisms,

including man, may become exposed. This section also

summarizes some of the data indicating that PCBs are already

widely distributed throughout the physical environment and

the biosphere and that this environmental burden is not ,

likely to become reduced in the near future because of the

persistence of these chemicals.

22
\J UL 1'- '-UUU I'II.:.LI UCi',) I nn U. tJ 1.:.. I • n r nf\ I1V. 'i I ;')Ci'i , ,);,);,),) I. .J'-I.J'i

'I

B. Overview of PCB Transport in the Environment

Before presenting a detailed analysis of the manner in

which humans and the general biota might be exposed to

"free" PCBs (i.e., PCBs which have been released into the

environment), it is first necessary to determine the

processes by which free PCBs are distributed throughout the

three compartments of the environment--air, land, and water.

A number of processes affect the nature of this

distribution. Once a PCB substance has entered a physical

compartment, it may be dispersed throughout that

compartment .. In addition, each compartment may have sinks

wherein free PCBs may be rendered physically unavailable to

the biota or may be degraded by chemical or metabolic

processes. Finally, a more or less continuous interchange

of PCBs between the three compartments might be expected.

The general nature of these processes is illustrated

44

schematically in Figure 1, and a summary of the possible

sources, sinks, and exchange processes is given in Table 1.

It should be pointed out that the processes described in

Figure 1 and enumerated in Table 1 are theoretical

possibilities that apply to any environmental pollutant.

Which of these processes play an important role in the

'i

environmental transport of PCBs is determined by the

specific chemical and physical properties of the PCBs as

well as the characteristics 'of each of the compartments.

23

In

I'

,
VVI.. i z, e..VVV I'iLLI VV',JI nil U. tJ L. J. n r nl\ nv. "t I ;,J(J"t I ;;;,J;,J,J I. ,J,J/,J"t

SOURCE

SINK

tlAtE'R

SINK

Figure 1

Schematic Representation of Transport Processes in the Environment

23a
Summary of Processes Involved in the Digtrlb~_ In of a Toxicant in the Environment

tv

Lv

c7'

Table 1.

COMPARTMENT

Atmosphere

Terrestrial

Aqueous

SOURCES

Natural sources

Gaseous residues from incineration

of contaminated materials

Evaporation during manufacturing

processes

Evaporation from consumer product

uses

Evaporation from accidental spills

Degradation of other contaminants

Degradation of discarded consumer

products

Industrial waste disposal by

. landfill

Accidental spills

Natural 80urces

Degradation of other contaminants

Contaminated discharges

Accidental spills

Natural sources

Degradation of other

contaminants

EXCHANGE PROCESSES

Evaporation from. terrestrial

sources of free materials

Coevaporatlon from contaminated

water bodies

Precipitation from contaminated

air

Precipitation from contaminated

air

Runoff from contaminated Boile

Leachant processes from contaminated soils

SINKS

. Photochemical reactions

Oxidative reactions'

Reactions with other

contaminants

Biodegradation

- flora

- fauna

- mlcroflora

Biodegradation

flora

- fauna

- microflora

Chemical degradation

- hydrolysis

photochemical

- active chemical

species reactions

Sorption and entrapment

onto fixed aedimenta

c

c

r

r

r

c

c

C

::l

r

<:

c

c

(

c

I:

r

oJ

(

(

oJ

(

(

(

<.

(

oJ

(

oJ
Table 4.1-1*

Estimated Number of PCB Transformers in Service

Category of User

Utilities

Industrial and Commercial

Railroad

Number of Units

42,000

97,000

1,000

PCB Content-Pounds

105,000,000

191,000,000

4,000,000

*Source: Versar, 1978, p. 19.

The PCB Ban Regulations define askarel transformers as being any

transformers that are filled with a liquid containing PCBs in

concentrations exceeding 500 ppm. This chapter discusses the impact of the

regulation on transformers that were originally filled with a PCB based

dielectric fluid. Chapter 6 discusses the impact of the regulation on

those transformers that were originally filled with mineral oil but which

have since become contaminated with PCBs in concentrations above 500 ppm.

4.2 Requirements of the Regulation

Rebuilding and major maintenance: The regulations forbid the

rerroval of the core and coils from the transformer. As a

result, any significant electrical probleminvolvinq.j.he

windings of an askarel transformer will result in rhe vun i.t being

scrapped. However, retrofilling a PCB transformer several times

with a non-PCB liquid may reduce the residual concentration of

PCBs to below 500 ppn, The ban on rebuilding does not apply to

such decontaminated transformers.

Minor maintenance: There are no restrictions on the pe~formance

of malntenance that do not require removal of the coils.

After July 1, 1979, transformer service companies cannot sell

used or reclaimed askarel unless they have peti boned for an

exemption from the provisions of the regulation which ban the

processing of PCBs prior to their distribution in commerce.

24
Reclaiming PCB askarel: After June 30, 1979, PCBs may be

reclaimed for reuse only by those ~vho have petitioned the EPA

and been granted an exemption from the "processing" bans.

Storage of PCB askarel: Storage prior to use or resale must be

in a specially marked area which meets the requirements

established by the di spasa.l regulations.

Disp:::>sal of failed transformers and PCB based askarel: tb

change from the previously promulgated Disr=osal and ~Brking

Regulations.

Retrofill with non-PCB fluid: Authorized without restriction.

The retrofilled transformer must continue to be considered a PCB

transformer, until the liquid has been tested at least three

months after the transformer was returned to service and

found to contain less than 500 ppn PCBs. The transformer is

then classified as a PCB contaminated transformer.

4.3 Economic Impact of the Regulation

Foregone savings from rebuilding

Askarel transformers have a normal service life of 30 to 40

years or more (Versar 1978, p. 7). Premature failure can occur as the

result of electrical breakdown of the insulation or distortion of the coils

caused by severe overload conditions. tbrmal industrial practice has been

to rebuild failed askarel transformers by removing the core and coils,

burning off the coils, and rewinding the coils using new wire on the

original core. 'Ih i s repair normally costs about 60% of the price of a new

transformer, and the repairs ta~e about 25% as long as normal delivery of a

new unit.* lbis rebuilding service is offered by both the original

manufacturers of the transformers and by approxL~tely 300 small

transfonner service ccmpanies.**

Based on an average price of $20,000 per new transformer (Versar

1978, p. 20), the ban on rebuilding askarel transformers will result in

foregone savings of ($20,000 x (1-60%) = ) $8,000 per transformer. In

addition, the ban will increase the time required to restore service from

*Oral comments of Mr. Lynv~ Holley (~merican Electric Apparatus Repair

Corr=oration) at the hearings on the PCB Ban Regulations, August 28, 1978.

**Oral comments of Robert Sandman (Sand~n Electric Company) at the

hearings on the PCB Ban Regulations, August 28, 1978.

25
the present one to tv-D roonths to six rronths or more, depending on the

availabilty of a satisfactory new transformer*. The out-of-service tL~e

might even be longer than woul.d be expected based on past practices because

the ban on the manufacture of new askarel transformers will require that

each installation of existing askarel transformers be redesigned when the

transformer fails and must be replaced. Adequate replacement transformers

are usually available in a number of designs including oil-filled

transfo~ers wi~h protective vaults and sprinklers, high fire point

liquid-filled transformers, and various types of dry transformers.

However, none of these designs are direct replacements for existing askarel

transformers, so a certain arrount of engineering time must be added to the

normal delivery time for a new unit.

An active market in used askarel transformers existed in the past,

but that market has declined over the past year due to uncertainties about

the restrictions that EPA was expected to impose on the use of these units.

The PCB ban regulations do not affect the resale and reuse of askarel

transformers by users, and units rerroved fran service because of changes in

service demands might be made available as replacement units for some of

the failed askarel transformers. However, the risk of a spill occuring

during transport of anaskarel transformer and the high potential liability

incurred by any spill of PCBs will probably limit any market in used

askarel transformers.

NOt enough information is available to estimate the proportion of

askarel transformers that would have been scrapped due to obsolescence

rather than due to electrical failure; most existing askarel transformers

have not been in service long enough for either aging or changing service

demands to be significant. Assuming as an example that fran one third to

two thirds of the existing askarel transformers would have been rebUilt if

it were not for the ban on rebuilding, the total foregone savings would be

$8,000 per unit x 1/3 to 2/3 of the 140,000 units in service (Versar, 1978,

pg. 21), or a total of $373 million to $747 million over the next 40 years.

*Letter from Robert L. Sandman (Electrical Apparatus Service Association,

Inc.) to EPA (PCB Ban Regulation Hearing Record), Undated.

26
)

These foregone savings will not be distributed evenly over the

next 40 years because present failure rates of askarel transformers are

relatively low. The failure rate is likely to increase as the average age

of the transformers increases. It was previously estimated that

approximately 80,000 gallons of PCBs were used in the repair of askarel

transformers in 1974 (Versar, 1976a). This is enough PCB to fill 335

transfoaners with an average capacity of 240 gallons of liquid (Versar

1978, p. 21). Many transformer service companies have also used reclairned

askarel in rebuilt transformers, so the actual number of transformers

rebuilt may be three to four times the number calculated fran data on the

us~ of ne~ askarel (approximately 1200 per year). The amount of business

lost to the transformer rebuilding industry due to the ban on the

rebuilding of askarel transformers might be as much as (1200 transfonners

per year x $12,000 per unit = ) $14.4 million per year. The transformer

manufacturers would supply new units to replace those not ~ebuilt at an

average cost of $20,000, so increased costs due to the regulation may be

about (1200 units x $8,000 =) $9.6 million per year. Incre9sed labor

requirements by ~~e manufacturers are expected to.offset any job losses by

the repair shops, and in fact little unempl.oyment; is expected in the

transformer service industry because nearly all of the 300 companies that

service askarel transformers also service oil-filled transformers. Since

about 97% of large, pad mounted, liquid-filled transformers contain mineral

oil, the b~n on the rebuilding of askarel transfonners should have a

relatively small impact; on the level of transformer repair business.

Lost service time

The delay in replacing failed askarel transformers might

increase in some cases fran the present four weeks required to rebuild a

unit to as much as six months (Versar 1978, p. 21). This delay could have

serious economic impacts on any industrial plant that was dependent on a

single transformer for its power. Rental units might be available, but at

a higher cost to the plant. The previous estimate of increased rental

27
costs for temporary replacement transformers was $2,380,000 per year

starting in 1979 (Versar, 1978). No additional data were suanitted to the

EPA in written or oral can~ents on the proposed regulation that would

support any revision of this estimate.

Limitations on sale of reclaimed askarel

The regulations do not impose any restrictions on the processing

of PCB based askarel by the owner of a transformer or by a service ccxnpany

that returns the askarel to transformers having the same owner. Therefore,

there will be no restrictions on the present maintenance practice of

periodically filtering the askarel in operating transformers to reduce the

IToisture content and improve its electrical properties. However, after

June 30, 1979, sale of PCBs will be allowed only if the owner has

petitioned the EPA for and been granted an e~emption from the ban on the

distribution in camnerce of PCBs. If the EPA does not grant exemptions,

there will be a lack of available PCBs to top off askarel transformers that

may develop small Leaks and to r eplace the PCBs absorbed by the filtering

material when askarel is routinely filtered. However, since it is

technically feasible to dilute askarel with various solvents, including

trichlorobenzene, RTFmp®, and IraleC®, without damaging its electrical

properties, there may be little economic impact caused by the ban on sale

of new and reclaimed PCBs. It should be noted that PCBs from PCB

tranforrners that have been disposed of or are designated for dispOsal must

be incinerated and therefore are not available for recycle or reuse.

Disposal of failed transformers and askarel liquids

The PCB Ban Regulations do not change the requirements

previously imposed by the PCB Disposal and Marking Regulations in this area

(EPA, 1978a), and therefore there are no additional econom.ic impacts.

Retrofill with non~PCB fluid

The PCB Ban Regulations clarify the conditions under which a

retrofilled transformer may be considered to be in the same class as oil28
filled transformers for purposes of servicing and di.sposal . However, the

regulations do not establish any limitations on retrofilling. Therefore,

the effect of the regulations may be to reduce servicing problemsM1en

make-up askarel is no longer available and to reduce eventual disposal

costs in some cases.

Ban on sale of PCBs

Effective July 1, 1979, neither unused PCBs nor reclaimed PCB

based askarel will be allowed to be sold unless the seller has petitioned

for and been granted an exemption by the EPA frem the "distribution in

cormerce" ban. lfthe EPA does not grant exemptions, there will be a lack

of available PCBs to replace askare.ls lost through small leaks or to

replace the PCBs absorbed by the filtering material M1en askarel is

routinely filtered. Ibwever, since it is teChnically feasible to dilute

askarel with various solvents, including trichlorobenzene, RTEmp®, and

Iralec®, witrout damaging i tselectrical properties*, there may be little

economic L~pact caused by the ban on the sale of new and reclaimed PCBs.

Ban on processing PCBs for sale

'The 'Ibxic Substances Control Act defines the processing of a

chenical as "the preparation of a chemical substance or mixture, after its

manufacture, for distribution in camnerce ... " (Section 3(10)). Ther~fore,

activities ~ith PCBs that do not involve its sale are not considered to be

"processing" as defined by the Act , and such acti vities performed for the

purposes of maintaining transfonners in other than a "totally enclosed

manner" are specifically authorized by the regulation until July 1, 1984.

This means that there are no restrictions on the filtering or other

handling of askarel unless there is a change in the ownership of PCBs.

Transformer askarel can continue to be testei and maintained by either the

, owner of the transformer or by a service company, but no PCBs, can be added

to the transformer except those that were owned by the owner of the

*Olmsted, J. (1977) "Comments and Recc:mmendations on Makeup Fluid for

Askarel Transformers", Waukesha, WI.: RTE Corr:oration, l'bvember 15, 1977.

(Submitted to the PCB Regulation Hearing Record as an attachment to RTE

Cor'porati.on "r1ain Ccmments").

29
transformer no later than 30 days after the effective date of the

regulation. In addition, "processing" and "distribution in COI1Unerce" for

purposes of disposal are specifically authorized by the regulation.

The only significant impact of this provision will be to ban the

salvaging of used PCBs by transformer service ccmpanies for use in

maintenance of other transformers. However, the major use of such

reclaimed askarels has been in rebuilt transformers, and the rebuilding of

askarel transformers is being specifically banned. 'Ine economic impacts of

the ban on "processing" PCB based askarels have been included in the

estimated cost of the ban on rebuiJ,ding askarel transformers.

Disoosal of failed transformers and.askarel liquids

1he PCB Ban Regulations do not change the requirements

previously imposed by the PCB nisposal and Marking Regulations in this area

(EPA, 1978a), and therefore there are no additional economic impacts.

Retrofill with non-PCB fluid

'!he PCB Ban Regulations clarify the conditions under which a

retrofilled transformer may be considered to be in the same class as

oil-filled transformers for purposes of servicing and disposal. The

regulations do not establish any limitations on retrofilling. The effect

of retrofilling may be to reduce servicing problems when make-up askarel is

no longer available and to reduce eventual disposal costs in some cases.

'Ihe ban regulations impose no economic costs relative to retrofilling of

askarel transformers.

4.4 PCBs Controlled by ~he Regul~tion

The ban on rebuilding askarel transformers·will eliminate the

loss of PCBs to the atmosphere that occurs when a transformer is baked-out

Prior to removal of the coils. There is no information available on the

PCB losses that occur during this process. However, if total losses of

PCBs during rebuilding of an askarel transformer were controlled to one to

ten pounds per unit, the regulation would reduce the entry of PCBs into the

environment by (1 to 10 lbs per unit x 1/3 to 2/3 of 139,000 units = )

47,000 to 925,000 Ibs.

30
The ban on the sale of PCBs should accelerate the retirement of

askarel transformers, but there is not sufficient information available to

estimate the effect this will have on the amount of PCBs entering the

envirorunent.

4.5 Summary - Economic Impacts

Foregone savings from rebuilding:

IDst service time (increased

rental of replacement t ransformers}.

$9.6 million (1979); $373

million to $747 mil{ion

total '

$2.38 million per year

4.6 Cost Per Pound of PCBs Kept from the Environment

Ban on rebuilding

$373 million to $747 million + 23.8 million* = $429 to $16,400

47,000 to 925,000 lb per FOund PCB.

*Present value of one dollar per year indefinitely discounted at 10% equals

$10.

31
5 • 0 RAThROAD UX:OMGrIVE TRAt'-TSFDR!'IERS

5.1 Present Ownership and Use Plans

Many of the major railroads in the northeastern United States are

electrified. High voltage alternating current is supplied at 2S hz, 11,000

volts, by overhead catenaries to electric locomotives and multiple unit

electric can.muter cars (MUEC). Transformers on board the locorrotives and

~ruEC cars reduce the voltage to the level required by the traction motors.

These transformers are specially designed to fit into the limited space

available on the car or locomotive and are built to withstand severe shock

and vibration. The transformers incorporate a pump to force the coolant

liquid through cooling fins and thereby improve the thermal efficiency of

the units. It has been standard practice to use PCB based askarel coolant

1iquids in these transformers because of the possib.i.lity of a severe fire

should a derailment occur in one of the tW1nels leading into New York City.

The federally funded Northeast Corridor Improvanent Project is

upgrading much of the power distribution system between Washington, D.C.

and New York City. According to Mr. Clifford Gannett of the Federal

Railroad Administration, the scheduled completion date for conversion of

the power on this {Xlrtion of the railroad system is now September, 1983*.

The conversion of the catenary power to 60 hz, 25,000 volts, will have a

rnajor effect on the continued use of many of the present askarel

transformers on locomotives and MUEC cars operating in this a~ea. Although

sane of the newer equipnent; can be converted to operate at the higher

voltages by changing internal taps in the transformers, many of the

*Original information indicated 3rd quarter of 1982. Letter from Clifford

Gannett (Federal Railroad Mministration) to EPA dated September 18,

1978. Subsequent press reports indicated completion in September of

1983. 'Ibis was confirmed by a telephone call to iVlr. Gannett in February

1979 (See telephone memo dated February, 1979 from Harold Snyder,

Ul'S/EPAto record.)

32
trill1sformers will have to be replaced, and the railroads intend to scrap

many of the oldest cars and 10canotives rather tha~ to invest in the new

transformers that wou.Ld be required to keep them operatinq.. Table 5.1-1

lists the ownership of the MUEC cars and locomotives using PCB cooled

transformers that are presently in service and summarizes the effect of the

voltage conversion on the continued use of these transformers.

5.2 Requirements of the PCB Ban Regulations

Use of PCB railroad transformers: Authorized until July 1, 1984

subject to the following limits on the concentration of PCBs in

the dielectric liquid:

L~ter January 1, 1982:

After January 1, 1984:

6% PCBs maximum

0.1% PCBs maximum

Servicing and retrofilling of PCB railroad transformers and

treatment of PCBs in other than a totally enclosed manner:

Authorized until July 1, 1984, provided that there is no change

in the ownership of any PCBs.

Processing of PCB contaminated liquid prior to sale for

serva.cmq transformers: Banned after July 1, 1979, unl ess EPA

grants an exemption from the "processing" ban regulation.

Sale of PCBs for servicing railroad transformers: Banned

after July 1, 1979, unless EPA grants an exemption fran the

"distribution in commerce" ban regulation.

Testing of liquid in PCB railroad transformers to determine

concentration of PCBs: Required immediately after any servicing

that is performed to reduce the concentration of PCBs and again

12 to 24 months later. Records of these analyses must be

maintained until January 1, 1991.

Rebuilding PCB railroad transformers in other than a totally

enclosed manner: authorized until July 1, 1984. However, any

transformer rebuilt after January 1, 1982, must be refilled with

liquid containing less than 50 PPm PCBs.

33
Table 5.1-1

S1..IDTrlaIY of PCB Ccoled Railroad Transformers in service (One Transformer per Car)

Effect of Late 1982 Voltage Change

Number of Nurrber Nmnber Number PCB

Type of PCB Cars 'I'ranaformers Transfonrers to

CWner Equipment Transformers Scrapped Replaced Remain in Service Gal/Trans.

SEprA MUEC 344 38 74 232

NJOOI' MUEC 122 18 0 104

Conn DOr/MI'A MUEC 244 0 0 244

w MD COT MUEC 7 7 0 0

.f::>

Conrail GG 1 Loco. 51 51 0 0 710

Conrail E33, E44

Loco. 76 0 76 0 500

Amtrak Metroliner 61 0 2 59 255

Amtrak GG 1 Loco. 33 33 0 0 710

Amtrak E60 IDeo. 26 0 0 26 380

- - 964 147 152 665

All data from letter to EPA fran Mr. Clifford Gannett, Federal Railroad Administration, 9/15/78.
MaxL~um concentration of PCBs in liquid used to service or top

off railroad transformers:

No restriction until January 1, 1982. 6% PCBs fran

January 1, 1982, until January 1, 1984. 0.1% PCBs after

January 1, 1984.

5.3 Cost Impacts of the PCB Ban R~ulations

July 1, 1984 deadline on continued use of PCB railroad

transformers:

It has not been demonstrated that it is technically possible to

reduce the concentration of PCBs in PCB railroad transformers to below the

500 ppn level that is used to distinguish "KB transformers" from "PCB

contaminated transformers." It is anticipated that EPA will review the

technology of retrofilling and processing of transformer liquids before the

July 1, 1984, ban on the use of railroad transfonners containing loore than

500 ppm PCBs to assure that this requirement does not cause substantial

economic impacts. Compliance with these regulations will therefore require

that the affected railroads maintain close communication with EPA to

resolve any unanticipated problems. 'lhere is not sufficient information in

the record to support any estimate of the costs that will be incurred by

the railroads in participating in the eventual review of these regulations.

Required reduction of PCB levels to below 6% by January 1, 1982:

It has been demonstrated that a single retrofilling procedure

consisting of draining, flushing, and refilling with non-KB coolant liquid

can result in PCB concentrations substantially below 6% (Walsh, 1977;*

Foss, 1977**). The analysis of the impacts of the proposed PCB regulation

assuned a total materials and labor cost of $20 per gallon for retroEilling

*Walsh, E.J., D.E. Voytik and H.A. Pearce, (Westinghouse Electric Corp.)

1977. Evaluation of Silicone Fluid for Replacement of PCB Coolants in

Railway Industry, Flnal Report. Repo rt; Lb. ror-TSc-1294. Cambridge,

Ma.: Transportation Systems Center, U.S. OOT. JJecenber 1977

(attachment to reply canrnents fran Clifford Gannett (Federal

Railroad Administration)).

**Foss, Stephen D., John B. Higgins, Cbnald L. Johnston, and James M.

i1cQuade (General Electric Co.). 1977. Retrofilling of Railroad

Transfonners. Cambridge, Ma.: Transportation Systens Center, u.s.

DOT, July 1978 (attachment to reply canments from Clifford Gannett

(Federal Railroad Administration)).

35
a transfonuer a single time with silicone liquid (Versar, 1978). A revised

estimate for the cost of retrofilling a transformer based on the procedure

develoPed by Dow Corning Corporation (Page, 1977)* is summarized in Table

5.3-1. Toe use of silicone at $12 per gallon (Versar, 1978, p. 30) in

estimating retrofill costs should give an upperbound but reasonable figure

because, although the alternative liquids may be cheaper, only silicone can

be treated to remove dissolved PCBs by filtration.

The total cost of retrofilling the 964 existing PCB railroad

transformers is calculated in Table 5.3-2 to be $6.6 million. Many of

these transformers will be scrapPed in late 1982 when the scheduled voltage

change on the tbrtheast Corridor is made. It is therefore possible that at

least some of the transformers will be replaced prior to January 1, 1982,

with units which can operate at both the present voltage and the higher

voltage that is planned. If this replacement is made prior to the date

specified for the 6% PCB limit, the present transformers will not have to

be retrofilled. The cost of this retrofill requirement can be calculated

by assuming that all of the transformer replacements are made by January 1,

1982, and that retrofilling is only performed on the 665 transformers that

will remain in service under higher voltage conditions. The cost of this

limited retrofill program is calculated to be $3.7 million. If the

changeover does not occur until Septenber, 1933, all of the cars will have

to be converted to non-PCB transformers in order to take advantage of the

remaining useful life of the exisitng equipment.

*Page, William C. and Terry Michaud (Dow Corning Corporation). 1977.

"Developnent of Methods to Retrofill Transformers with Silicone

Transformer Liquid," IEEE Paper 22-477 presented at the Electrical

Insulation Conference, Chicago, Illinois, September, 1977 (attachment

to letter fran Terry Michaud to EPA dated August 1, 1978).

36
Table 5.3-1

Retrofill of PCB Railroad Transformer with

Silicone - 300 Gallon Capacity Assumed

Cost

Step

1

2

3

4

Procedure

Hot drain askarel from

transformer (85% reroval - Foss, 1977)

Fill with 255 gallons

trichlorobenzene, circulate and drain

Fill with silicone

Dispose of liquid

(PDllins, 1978)***

Sub-total:

+ Labor Cost:

@$15. per hour

Materials

5 drums @$25.00* = $125.00

255 gal TCB @$5.21 = $1329.00

300 gal silicone

@$12.00 = $3600.00

10 drums @ ($115/drum

disposal + $27.28

t.ransport.ation

@$0.04/1b = $1423.00

$64il.00

$120.00

Estimated

Labor-man hours

2 hours·

4 hours

2 hours

8 hours @$15.00**

Total cost per transformer:

COst per gallon:

$6477.00

$21.99

*Versar 1977, pp. 3-8.

**Versar 1978, p. 33.

***Rollins Environmental Service, Inc. 1978. Indemnified Disr::osal Service

for Polychlorinated Biphenyls (PCBs - Askarels), May 1, 1978.

Submitted as an attachment to letter from James Thompson (T&R

Electric Supply Co.) to EPA, dated August 28, 1978.

37
Table 5.3-2

Cost of Retrofilling Railroad Transformers to Meet

January 1, 1982 Limit of 6% PCBs: $21.99/gal.

Assurre All Transfonrers Retrofilled Assurre 'l'ransfomer Replacenent

Program Finished by January 1, 1982

i»

co

CMner

SEPrA

NJror

cnlN ror/MrA

M) tor

~IL

cnMUL

AMrRAK

N1l'RAK

Jl.t-U'RAJ<

Gallons/

&:Jui?JEIlt Transforner*

MUEC 250

M.JEl: 250

MUEC 250

MJEC 250

ail Loco 710

E33, E44 Loco 500

M=troliner 255

GGI Loco 710

E60 Loco 380

Nmber of

Transfonrers

344

122

244

7

51

76

61

33

26

'l'otal:

Cost

$1,891,000

671,000

1,341,000

38,000

796,000

836,000

342,000

515,000

217,000

$6,647,000

(302,000 gallons)

NUlIber of Tr.aJisforrmrs

232

104

244

o

o

o

59

o

26

Cost

$1,275,000

572,000

1,341,000

o

o

o

331,000

o

217,000

$3,736,000

(170,000 gallons)

*Versar, 1978, p. 28.
Required reduction of PCB levels to below 0.1% by January 1,

1984.

Reduction of the concentration of PCBs in each of 665 retrofilled

transformers from an assumed average concentration of 5% to 1,000 ppm will

require two separate retrofilling procedures, assuming that each retrofill

reduces the amount of PCBs in the transformer by at least 86%. It was

suggested that silicone liquid could be processed essentially in place to

reduce the concentration of PCBs and that this processing would cost $4,600

per transfonner + $25 per gallon of liquid in the transformer, or an

average of $40.33 per gallon for a 300 gallon capacity transfonner.* This

estimate was based on an assumed loss of ten pounds of silicone per gallon

of liquid treated by activated carbon, or a recovery efficiency of -25%

(i.e., 10 pounds of new silicone would be lost in processing and recovering

8 pounds of contaminated silicone). This analysis indicates that it would

be cheaper to use new silicone at $12 per gallon, even though activated

carbon has been shown to r emove PCBs from silicone. ** The cost of each

retrofill would be $15.14 per gallon as calculated in Table 5.3-3. TOtal

cost to the railroads for the two retrofill procedures required to reduce

the PCB concentration in each transformer to below 1000 ppm would then be

(170,000 gallons x 2 retrofills x $15.14 per gallon = ) about $5.15

million. This cost could be reduced if a less expensive disposal method

became available or if some way were develoPed to reclaim the silicone.

*Attachrnent 2 to "Ccmments on Proposed Regulations to Ban PCBs."

Sutmitted by General Electric Co. as a written comment; to the EPA

Hearing Record on the PCB Ban Regulations. Undated.

**D:Jw Corning Corpor'ation. Removal of PCB from D:Jw Coming 56l®

Transformer Liquid by Charcoal Filtration, Midland, t~chigan: Undated

(As cited in Versar, 1978, p. 29).

39
Table 5.3-3

Retrofill of Contaminated Silicone Filled Transformer -

300 Gallon Capacity Ass11IT'ed

Cost

Step Procedure Materials Labor-man hours

I Hot drain silicone 2 hours

(85% removal of liquid)

2 Flush ...vith 45 gallons $540. 2 hours

silicone, (additional 3%

removal of PCBs)

3 Refill with 255 gal. $3060. 2 hours

new silicone

($12/gallon)

4 Disposal of 6 drums

contaminated silicone

(@$142)

Sub-total:

$ 852.

$4452. 6 hours

Plus Labor Cost

@ $15;hour: $90.

Total cost Per transfonrer: $4542.

Average cost per gallon: $15.14

40
It should be noted that the highest calculated total cost of the

retrofill program of $21.82/gallon (Table 5.3-1) + 2 x $15.14/gallon (Table

5.3-3) = $52.10/gal is somewhat less than the estimated cost of $78 per

gallon ass~~ed by Charles Engelhardt of Amtrak and by Dean Aboudera of the

American Public Transit Association in their oral comments at the August

31, 1978, hearings on the proposed PCB Ban Regulation. However, it is felt

that the est~nate of $52.10 per gallon is in fact an upper bound estimate

of the cost impact of the PCB Ban Regulation because of the opportuni ties

available for cost reduction by use of other materials being evaluated by

the Federal Railroad Administration such as RTEmp® and Iralec T-l®.*

Testing to determine concentration of PCBs in liquid.

Testing of the liquid in each railroad transformer that remains

in service will apparently be required four times: upon completion of each

of the three retrofill procedures and again 12 to 24 months after the

completion of the final retrofill. Only the initial testing will be

required for those transformers that are replaced in late 1982. There has

been no information submitted to the EPA on the recommended methodology or

estimated cost of analyzing samples of silicone oil for the presence of

PCBs. 'The methodolcqy for this analysis should be about the same as for

PCBs in mineral oj although the silicones WJuld require additional

maintenance of thc~ col.umn in the gas chromatograph. Cost of each analysis

therefore might be 5 to $150, including order processing costs. Tbtal

cost of the requir(~] analyses lNOuld be expected to be $440,000 as

calculated in l~blc 5,]-4.

*Oral canments by Clifford Gannett (Federal Ra i l road Administration) at

August 31, 1978 hearing.

41
Table 5.3-4

Cost of Analyzing Silicone Oil for the Presence of PCBs

in Retrofilled Railroad Transfonners

Initial retrofill: 964 Samples @$150 = 3 x 665 transformers @$150 = 'Ibtal analytical cost =

5.4 PCBs Controlled by the Regulation

$144,600

$299,250

$443,850.

~~ere are presently about 4,000,000 pounds of PCBs in use in

railroad transformers. The fi~ disposal of this matet1al was regulated

by the PCB ['larking and Disp:>sal Regulations. The effect of the present

regulations is to reduce the amount of PCBs lost by leakage of transformers

by requiring that the PCBs be rerroved from the transformers and be replaced

with other liquids. Although it was noted that railroad transformers often

lose liquid by lea~s and venting, no information was presented to the

record that would support a quantitative est~nate of the PCBs required to

top off these transformers to replace lost liquid. Therefore, no estimate

can be made of the effect of the required retrofill program on G~e entry of

PCBs into the enviro~ment.

5.5 Summary - Economic Impacts

Cost of reducing PCBs to 6% $6.6 million

(silicone in 964 transformers) .

Cost of reducing PCBs to 1000 ppm $5.15 million (silicone in

665 transformers).

Analytical Costs: $444,000

42
5.6 Cost Per Pound of PCBs Kept from the Environment

At best, each retrofill prevents the entry into the environnent

of the amount of PCBs removed from the transformers.

Reduce PCBs to 6%:

$6.6 million + $140,000

.94 x 4 million pounds

Reduce PCBs to .1%:

= $1. 75* per pound PCB

$5.15 million + $300,000

170,000 gallons x 8 Jb/gal x 5.9% PCBs = $68* Fer pound PCB

*Assumes all PCBs would be lost to the environment if not removed by

retrofilling.

43
6.0 OIL-FILLED rowER AND DISTRIBUTION TRANSFORMERS

6.1 Present Contamination of Oil Filled Transformers

The PCB ban regulations lower the level at which PCB contaninated

mineral oil is regulated from 500 ppn to 50 ppn. A mineral oil transformer

may fall into one of three categories. A mineral oil transformer that has

been tested and found to contain over 500 ppn PCBs is classified as a "PCB

Transformer." A transformer that has not been tested or that has been

tested and found to contain between 50 ppm and 500 ppn PCBs is a

"PCB-Contaminated Transformer." Transformers that have been tested and

found to contain less than 50 ppn PCBs are not subject to regulation.

~1Jst liquid-filled transformers have been filled with

transformer oil, a non-chlorinated petroleum product similar to SAE 10

motor oil (Versar, 1976a, p. 255). These transformers are similar in

design to PCB askarel transformers, and manv of the oil-filled transformers

were built in the same plants that manufactured askarel transformers

(Versar, 1976a, p. 84). The total number of oil-filled transformers

presently in service was previously estimated to be about 30,000,000

overhead and distribution transforrners (each containing an average of 16

gallons of oil) and 5,000,000 other distribution and power transformers

(each containing an average of 250 gallons of oil) (Versar, 1978,

pp.36-39). It was also estimated that nearly all of the pole mounted

transformers and perhaps 80% of the other oil-filled transformers are owned

by electric utilities (Versar, 1978, pp. 39-40).

During the hearings on the proposed regulation, a number of

utilities and transformer repair canpanies presented information on the

results of sampling programs that they conducted to evaluate the extent of

PCB contamination of oil-filled transformers. This information is

summarized in Tables 6.1-1 and 6.1-2. The reply canment from the Edison

44
Table 6.1-1

Utility Reports of PCB Contamination of Oil Filled Transformers

with Concentrations AOOve 50 pPl1

Ccmpany

Pole MoW1ted

Reference Distribution

tbte Transfonrers

Other

Transfanners Other Samples Sampling Procedure

,j:>.

1.J1

Allegheny PCMer

Service Corp.

Boston Edison

Cc:mmnwealth

Edison

Consumers

PCMer

1

2

3

4

o of 2

o of 9

9 of 33*

o of 2

4 of 12

4 of 29

oil storage tanks:

o of 2

1 oil storage tank:

PCBs <5 ppn

55 gallon drums

of oil: 0 of 4

* 33 randorr~y selected substation

transforrrers.

Other 6 samples

were not part of

the random sample.

100 selected to be

representative of

age of operating

transfonrersi no

data on hew these

21 samples were

chosen to be

analyzed first,

(210 ppn max) •

Many samples were

sul:mitted fran a

repair shop.

Others are samples

taken fran transformers in various

parts of the

state.
Table 6.1-1 (Continued)

,j::o

0'1

Company

Dayton Power

and Light

r:etroit

Edison

Duke PCMer Co.

Reference

N:>te ~r

5

6

7

Pole !>bunted

Distribution

Transformers

Other

Transforrrers

5 of 17 (in

service)

o of 9 (new)

2 of 4 *

51 of 161 *

Other Samples

ReclainEd oil

storage tanks:

o of 3

Sampling Procedure

Scm9 of the 17 used

transfonners were

selected because it

was knovm that PCBs

were used in the

plants where they

were manufactured.

* maximum = 80 ppn,

Only transfonners

rated. at less than

44 kv; higher

voltage units

thought to be less

contaminated•

* of 161 sampled,

3 were above 500

PPTI, 7 between 100

and 500 PPTI, 41

present below 100

ppn but not quantified. " .....it was

assuued that all

samples with detectable arrDunts

of PCBs were contaminated above

the 50 ppn level. II
Table 6.1-1 (Continued)

.t:>

--..J

Company

GPU Service

Corporation

GPU Service

Corporation

Northern States

Power Co.

ottertail Power

Canpany

'IVA

Reference

tbte Number

8

9

10

11

12

Pole Mounted

Distribution

Transfonrers

15 of 58

distribution

transfonrers

o of

other

Transfonrers

25% of oil

in 144 substation

transformers

6

o of 1

2 of 38

other Samples

oil storage tanks:

2 of 18

oil storage tank:

o of 1

(31. 4 ppm)

Sanp1ing Procedure

4 in range 100-499

ppn, 2 above 500

ppn.

Transformers at

repair shop.

P'lanned.vrandom

sample.
Table 6.1-1 Notes

11 Letters fran Nancy H. Gormley (Allegheny Pc:wer Service Corp.) to EPA

dated August 4, 1978 and September 7, 1978.

Y Letter from Charles Dolloff (Boston Edison Co , ) to EPA dated July 5,

1978.

Y Letter from John Hughes (Ccmronwealth Edison) to EPA dated August 4,

1978. , ,

.y Letter from Nathan Haskell (Consumers Pc:wer Co.) to EPA dated August 7,

1978.

"Supplemental Ccm:rents" sul::mitted to EPA by Harold F. Fox (Dayton

Power and Light Company), August 18, 1978.

Y Letter fran Skiles Boyd (Detroit Edison) to EPA dated August 3, 1978.

JJ Written Ccmnents - "Response Concerning EPA's Proposed PCB... Bans... " -

sul:xnitted by Duke Power Co., August 4, 1978 and oral corrments by

Mr. N. J. Melton (Duke Power Co.) at the PCB Hearings, August 21', 1978.

y Letter fran J .R. Thorpe (GPU Service Corp., a subsidiary of General

Public Utilities) to EPA dated August 4, 1978.

V Letter fran Edmund Newton, Jr. (GPU Service Corporation) to EPA dated

October 6, 1978. .

10/ Oral Carrnents of Lyle Salmela (Northern States Pc:wer Company/MidContinent Area Power Pool) at PCB Hearings, August 22, 1978, (pp. 78-79

of transcript).

11/ "Carrments of ottertail Power Co. on the Proposed Arrendments to

40 CPR 761." Undated.

12/ Letter fran William Gerstner and Paul Greiner (Eclison Electric Institute)

to EPA dated August 7, 1978; Exhibit III.
Table 6.1-2

Transformer Manufacturer and Service Company Rerorts of PCB Contamination of

Oil Filled Transformers Above 50ppm.

Transformer

Consultants 5 ( 185 of 434 On custorrer request - primarily industrial

clients; 72 of the

transformers had rrore

than SOOppm PCBs,

although several of

these may have been

retrofilled askarel

transformers.
Table 6.1-2 Notes

1. Letter from William Gerstner and Paul Greiner (Edison Electric Institute)

to EPA dated August 7, 1978. Exhibit III.

2. Versar. 1978, p. 40. Confinued in letter fran James Young (General

Electric) to EPA dated OCtober 6, 1978.

3. "Main Corrrrents ... " sul::mitted in writing to EPA by John Olmsted (RI'E

corporat.ion) undated.

4. Letter from Jarres Thanpson (T&R Electric Supply Company, Inc.) to EPA

dated August 28, 1978.

5. "Response to June 7, 1978 Federal Register Regarding Proposed Change in

PCB Regulations" subnitted to EPA by Stanley Meyers (Transformer

Consultants) as an attachrrent to letter dated September 13, 1978.

50
Electric Institute (EEl) also summarized this information. The EEl summary

is included as Tables 6.1-3 and 6.1-4. Since the EEl tables use a

different defini tion of distribution transformers (including rrore than just

the poLe mounted units) and include the results of sampling of oil storage

tanks in the totals, the resulting tables are not directly comparable to

6.1-1 and 6.1-2. However, the EEl apparently had access to some data on

oil-filled transformers that was not otherwise presented to the EPA.

'Ihe only data on contamination of oil-filled transformers that

were based on a reasonably randcm sample of transformers presently in

service v;ere the data reported by Allegheny Power, Comrromvealth Edison, and

TVA. 'The samples taken by Duke Power were from a population that excluded

the large transformers which Duke Power believed were not contaminated.

The other utilities sampled on the basis of convenience, usually sampling

transformers that were in the shop for repairs or that were being serviced

in the field. RTE Corporation reported data based on a planned random

sample of transformers which they had built. Although RTE rep:xtedly has

never used PCBs in their manufacturing plant, they refOrted that the level

of PCBs seen in transformers was higher in the older units than in newer

ones (none of the transformers was found to be contaminated in

concentrations above 50 ppn) . T&R report.ed a random sample of used

transformers and stated that they felt that the average concentration of

PCBs in oil was above 50 ppn because their holding tanks for reclaimed oil

contained rrore than 50 ppn PCBs. GE and Transformer Consultants r eport.ed

the results of analyses done on their own samples and for other companies;

these data may have also been re1?Jrted by the owners of the transformers

and may therefore be duplicate infonnation.

It is not possible to calculate statistics that describe all

transformers from the data that has been r epor't.ed because of problems in

sampling protocols, possible double reporting of data, and uncertainties

51
Table 6.1-3

Edison Electric Institute Summary of Contaminated Transformer Data Submitted by Electric Utilities*

DistributioJ! PCMler TotalY

No. > 50 ppn No. > 50 ppm No. > 50 ppm > 500 ppm

Ccmn. Ed. 26 - 17 5 43 5

TVA 34 2 38 2

Consumers 33 4

Duke 1613/ 51 161 51 3Y

Allegheny 2 - 20 2 39 9

GPU - - 765/ 17 2

lJl'

tv

Georgia 24 - 24

Detroit 4 2 14 2

Dayton 9 - 17 5 26 5

Boston Ed 1

Ottertail 1 -- -

'TOI'AL 37 0 277 67 456 95 5

0% 24% 21% 1%

* Source: Letter from William Gerstner and John Kearney (Edison Electric Institute)

to EPA dated OCtober 10 , 1978. Appendix B. Appended notes also from Edison

Electric Institute.
Ul

W

Notes to Table 6.1-3

1/ See ANSI/IEEE C-57.80 (1978). This definition includes but is not limited to pol.e--type

- and residential pad-type transfomers.

Includes oil storage facilities and other PCB articles.

3/ As indicated by Duke Power Co. in its hearing testimony (August 21, 1978, at Tr. 113) its

sampling program was not representative of its system. Rather, it was designed to sample

those transfomers "rrost likely to be PCB-contaminated." Id,

4/ As indicated in the Duke Power' Co. Hearing Testirrony (Aug. 21, 1978, Tr. at 134) the 3

- sanples indicating concentration greater than 500 ppm were from transfomers manufactured

by the sane corrpany at least one of which was incorrectly filled with askarel by the

manufacturer. Id. at 129. We strongly believe that any contamination greater than 500

ppm is IIDst unusual and unique and is not at all representative of the 35 million mineral

oil transfonrers.

5/ Includes 58 transfomers not identified as to power or distribution of which 15 (26%)

- contained mineral oil dielectric contaminated with PCBs at levels greater than 50 ppm.
Table 6.1-4

Edison Electric Institute Surrmary of Contaminated Transformer Data

Su1:mitted by Transformer Ccmpanies * (1)

Df.st.r.i , ibut.i utaon>2/ Power Total

No. > 50 ppm No. > 50 ptm No. > 50 PfIl1 > 500 ppm

General Electric2/ 2614/ 20 13 6 294 37

RI'E 19 - 19

T & R Electric2! 14E! 6 14 6

U1 . 7/ 4348/ .t:> Transfonner Consultants- 185 43421 205 65

-- -

'IOTAL 294 26 447 191 761 248 65

9% 43% 33% 15%

* Source: Letter from William Gerstner and John Kearney (&lison Electric Institute)

to EPA dated October 10, 1978. Appendix C. Appended notes also frcm Edison

Electric Institute.
Notes to Table 6.1-4

1/ Westinghouse has.not provided any independent evidence in its carrrents of the contamination

- of mineral-oil transfanners with PCBs. Its evaluations are solely based on assumptions

it makes using the ccmnents and testinDny of others for the purpose of derronstrating the

econanic impact of the proposed regulations.

2/ See ANSI/IEEE C-57 .12. 80 (1978). This definition includes but is not limited to pol.e-type

- and residential pad-type transforrners.

3/

y

GE admits that it has "no idea how to tackle the problem of what percentage of the oil is

contaminated" and that "no statistical basis for any conclusion exists in General Electric."

R.C. Osthoff, letter to Dr. E.L. SiJrons (July 3, 1978). In part.i.cul.ar, the assertion on

page 5 of its Main Caments that 3-10 million pole-type distribution transfonners may

contain in excess of 50 ppn PCBs is without foundation.

Includes 75 pole-type transformers of which 4 (5%) were above 50 ppn.

Vl

Vl

5/ T&R Electric buys ill1d sells used transfonners. Its sample survey is not statistically

- "representative" of its inventory, the electric utility industryI or the class of 35

million mineral-oil transfonners.

§/ Pole-type transformers. See August 28, 1978 Tr. at 126.

7/ Transformer Consultants is a transformer servicing company. Transfonner Consult.ant.s has

-- orally inforned us that it has nCfiN analyzed roughly 2,000 oil samples of which approximately 33% contained greater than 50 ppn PCBs and 10% contained greater fhan 500 ppn

PCBs. Inasmuch as roughly two-thirds of its custorrers are industrial and the remainder

are small utilities, none of the samples conducted by Transformer Consultants is representative of the electric utility industry.

y Generally transformers of 200 kva or greater.

9/ See, Reply Corrroent.s of Transfonner Consultants (September 13, 1978). Note: These numbers

- differ from those submitted by Mr. Westin on September 26, 1978.
about the analytical me thodol.oqy that was used in each case. However, from

inspection of the data, it might be reasonable to conclude that from 5% to

40% of pole mounted transformers and from 20% to 30% of other oil-filled

transformers are contaminated with PCBs in concentrations exceeding 50 ppm.

Conta~ination to levels above 500 ppm appears to he rare. Table 6.1-5

summarizes calculations of the amount of PCBs in all transformers and the

amount present in transformers contaminated above 50 ?pn. Becaus;:: of the

uncertainties in the data, the range of confidence in these estimates must

be at least a factor of four, i.e., each estimate sboul.d be bounded by a

range of -80% to +400%.

Approximately 80% of the oil-filled transformers are owned by

electric utilities, including the 149 class A and B operating companies and

approximately 1000 Rural Electric Cooperatives.* About eight million of

the pole mounted transformers are owned by the 1000 rural systems, of which

950 are distribution cooperatives that do not generate any power* and that

therefore do not have high efficiency boilers.

6.2 Requirements of the PCB Ban Regulation

The regulation defines a class of PCB equipnent called "PCB

Contaminated Transformers" and specifies certain exemptions from the

marking, disposal, and ban requirements that apply to other PCB equipment.

"PCB Contaminated Transformers" include (1) transformers which were not

originally filled with a PCB coolant liquid but that now are known to

contain a liquid contaminated with PCBs in concentrations from 50 ppm to

500 ppm, (2) oil-filled tranformers that have not been tested for PCBs, and

(3) transformers that were originally filled with PCB based askarel but

that have been decontaminated, to the extent that the concentration of PCBs

is found to be below 500 ppm when tested after at least three months of

service following the last decontamination procedure.

*Ives, Joseph S. (National Rural Electric COoperative Association).

Written statement dated August 7, 1978, and oral testimony at August 21,

1978 hearing.

56
Table 6.1-5

Estimated Amounts of PCBs in Oil-Filled Transformers

Average oil capacity,

gallons per transformer*

x 7.6 = Ib oil per transformer

Number of transformers in service*

% above 50 PFffi

Number of transformers above 50 ppn

Pounds of oil in contaminated

transformers

Pole Mounted Other

16 gal. 250 gal.

121.6 10 1900 Ib

30,000,000 5,000,000

10% 25%

3,000,000 1,250,000

364.8 million Ib 2,375 million Ib

Assumed average PCBs concentration 80 ppm

Pounds of PCBs in contaminated transfonners 29,184 Ib**

Number of transforrrers below 50 ppm 27,000,000

80 ppm

190,000 Ib**

3,750,000

Pounds of oil in non-contaminated

t ransformers 3,283 million Ib 7,125 million Ib

Assumed average PCB concentration

Pounds of PCBs in non-contaminated

transfonners

1btal pounds of PCBs

10 ppn

32,830 Ib**

62,000 Ib**

20 ppn

142,500 IQ**

332,500 Ib**

~versar, 1978:, pp. 36-40

**Confidence Ibnits: - 80% + 400%

1btal 400,000 Ib PCBs**

57
The following provisions apply to "PCB Contaminated

Transforrners" :

• Continued use: defined as use in a totally enclosed manner,

and therefore not regulated.

• Marking: exempted fran the requirenent that a PCB

label be applied.

• Servicing and rebuilding in other than a totally enclosed

manner: authorized until July 1, 1984, provided there is no

change of ownership of liquid containing over 50 ppm PCBs.

(T:bte: reclaimed transformer oil may be presumed to contain

between 50 and 500 ppm PCBs unless it has been tested.)

• Reclaiming used transformer oil: authorized without

restriction for use by the owner of the oil in his own

transformers.

• Sale of reclaimed transformer oil: tested and found to

contain less than 50 ppn PCB: not regulated.

T:bt tested for PCBs or tested and found to contain 50 to 500

ppm PCB: banned after June 30, 1979, unless EPA grants an

exemption from the "distribution in cemmerce" bans. EPA has

not yet announced the conditions under which individual and

consolidated petitions for exemption will be accepted.

• Resale of used transformers: excluded by 'ISCA from the

"distribution in COTh'TIerCe" ban.

• Disposal of drained transformers: not restricted.

• Dispoaal, of used transformer oil: tested and found to

contain no detectable PCBs: not regulated. (Testing may be

performed on batches of oil fran different transformers,

i.e., testing of storage tanks is permitted.)

Tested and found to contain detectable PCBs in concentrations

below 50 ppm- not regulated, except the oil may not be used

58
as a sealant, coating, or dust control agent (i.e., not

allowed as road oil or pesticide carrier).

rbt tested or tested and found to contain 50 to 500 ppn PCBs:

storage a~d shipping containers roust have PCB label. Storage

must be in special PCB storage areas and shipping vehicles

must be marked. Disposal must be in one of d1e following:

(1) In an approved PCB incinerator.

(2) In an approved chenical waste landfill.

(3) In a large (50 million BTU per hour or larger)

high efficiency boiler that meets certain

specified operating criteria. The EPA Regional

Administrator must be notified 30 days before the

first time PCB contaminated oil is burned.

(4) By any other method that has been demonstrated to

have as high a destruction efficiency for PCBs as

does a high efficiency boiler and that has been

approved for disposal of PCB-contaminated oil by

the EPA Regional Administrator.

6.3 Cost Impacts of the PCB Ban Regulation

The regulation does not affect the continued use or resale of PCB

contaminated transformers, nor does it affect the Inaintenanceof these

transformers except to ban the sale of reclaimed contaminated fluid. The

only unpacts will be on the reclamation and disposal of contaminated used

transformer oil and other contilloinated transformer liquids.

July 1, 1984 deadline on rebuilding oil-filled transformers:

After July 1, 1984, rebuilding of oil-filled transfonners will

only be allowed for those units that have been tested and found to contain

less than 50 ppn PCBs. It is anticipated that EPA will review the status

of the rebuilding of transfonners and the occurrence of PCBs in the oil of

oil-filled transformers prior to the 1984 deadline. Those companies that

rebuild transformers will therefore have to stay in close contact with EPA

and participate in the regulatory review process in order to ensure that

this deadline does not result in major unforeseen econanic impacts. There

is not sufficient information to support any estimate of the costs to be

59
incurred by the transformer service industry and by the users of oil-filled

transformers by participating in the eventual review of these regulations.

Reclamation of used fluid from PCB contaminated transformers:

According to Duke Power Company, reclaiming and reprocessing

transformer oil saves at least $.40 per gallon on the 170,000 gallons of

oil which they reprocess in-house each year.* The Cincinnati Gas and

Electric Company reported that they salvage 60,000 gallons of used

transformer oil each year from their transformer repair operations and that

this is reprocessed into 58,000 gallons of useable oil at a total cost of

$18,000 or $.31 per gallon.** New transformer oil presently costs about

$1.19 per gallon** and the price is expected to increase over the next few

years as supplies of naphthenic crude oil are depleted and transformer oil

must be made by the more expensive process of deeply dewaxing paraffinic

crude oil fractions.

Not all used transformer oil is recla1~ed because smaller

transformer companies and utilities do not generate enough used oil to

justify the purchase of the necessary equipment. However, reclamation

appears to be the standard practice for most transformer repair shops and

major utilities. The regulations authorize the reclamation of used

transformer oil by utilities for use in their own transformers. The

regulation requires that all transformer oil be preswned to contain more

than 50 ppm PCBs unless it has been tested and found to contain less than

50 ppm PCBs. The sale of reclaimed transformer oil is banned after June

30, 1979, unless each batch has been shown to have less than 50 ppm PCBs or

EPA exempts the seller from this ban reauirement. The EPA has not yet

*"Duke Power Company's Re sponse ..." dated August 4, 1978. SulJmitted to

EPA as a written main comment on the proposed PCB ban regulation . **Letter from E',E. Galloway (The Cincinnati Gas and Electric Company) to

EPA dated August 4, 1978.

60
established t.he-bas'i.s on 'which it will accept individual or consolidated

petitions for exemption, nor has it announced the basis for granting such

exemptions. the filtering of oil by transformer service companies as a

part of routine is allowed because the oil is returned to . -------.-C>

the transformer fran which it is taken and ownership of the oil does not - '

Change, so there is no "distribution in-corrunerce" taking place. .

As calculated in Table 6.3-1, approximately 78% of the

transformer oil is in transformers owned by large utilities, most of which

do their own routine rnaintenance.

[vl.aintenance of ITDst of the transformers not owned by the major

utilities is performed by transformer manufacturers and by independent

repair shops. About 8 million of the 30 million pole mounted distribution

transformers are owned by small distribution utilities most of which do not

repair their own transformers. As calculated in Table 6.3-1, the effect of

the ban on the sale of reclaimed oil is to eliminate the opportunity to

recycle 22% of the available oil unless each batch is tested and sho~m to

contain less than 50 ppm PCBs. If it is assumed that 4% of all oil becomes

available for recycling each year (equivalent to assuming an average of 25

years between major servicing operations on each transformer) and that 75%

of the oil was actually recycled, savings in 1978 would have been (1.73

billion gallons x 4% available x 75% reclaimed x $.40 to $.80 per gallon

savings per gallon reef.aimed =) $20.8 million to $41. 5 million. The cost

of the foregone savings from recycling in 1979 could be as much as 22% of

the 1978 savings, or $4.6 million to $9.2 million.

The actual reduction in the amount of oil reclaimed by

transformer shops will depend on the economics involved in testing the oil

to demonstrate that each batch contains less than 50 ppm PCBs. The total

'amount of oil that could be reclaimed for purposes of resale by transformer

maintenance shops might be 11.4 million gallons per year as calculated in

Table 6.3-2. If this oil were accumulated in 1000 gallon batches prior to

,..,

0:1.
'rable 6.3-1

Used Transformer Oil Available for Reclamation

Average capacity-gallons

Total nwnber in service

Owned by industry

Owned by small utilities

Owned by major utilities

Amount of oil in use

'Ibtal

Fble t-1ounted

Transformers Other

16 250

30,000,000 5,000,000

900,000

8,000,000 100,000

22,000,000 4,000,000

480 million gal l,250 million gal

1,730 miLl ion gal

Amount of oil used by major

utili ties 352 million gal 1,000 million gal

'Ibtal 1,352 million gal

Percent of transformer oil used by major utilities:

1,352 million gal.

1,730 million gal. = 78%

Percent of transformer oil not available for recycling: 1-78% = 22%

62
Table 6.3-2

EstL~ated Supply of Transformer Oil Available for Recycling for Sale

'lbtal amount of oil

x fraction available each year

x fraction to transformer repair companies

x fraction assumed recoverable (not

too degraded by prolonged use)

= Total annual supply of oil available

for recycling for sale

63

1.73 billion gallons

4%

22%

75%

11.4 million gallons
testing, all of the oil could be tested for PCBs by performing 11,400

analyses. Costs of such a routine sampling and analysis program were

previouslyestunated to be from $67 to $80 per sample (Versar 1978, p. 41).

'Ihe cost of performing such an analysis on a 1000-gallon tank full of oil

wou.Ld be only $.08 per gallon. Testing to prove that the oil could be

reclaimed VvDuld be justified as long as the expected cost per gallon

reclaimed is less than the cost savings of $.40 per gallon achievable by

reclaiming the oil. Therefore, the analysis of 1000-gallon batches VvDuld

be justified if as few as one of every five batches were actually found to

have less than 50 ppm PCBs. If the total amount of PCBs in transformers is

actually the 400,000 pounds estimated in Table 6.1-5, the average

concentration of PCBs in the 1.73 billion gallons of transformer oil tl1at

is in use VvDuld be about 30 ppm. This implies that at least one half of

the batches of oil that are tested would have less than 50 ppm PCBs if care

were taken to avoid contamination of the oil with materials used with

askarel transformers. If only one half of the batches were in fact

contaminated to levels of less than 50 ppm, an expenditure of (11,400

analyses at $80 = ) $912,000 for chaoical analyses would make available

(11.4 million gallons x 50% =) 5.7 million gallons of oil per year for

recycling and resale. If the recycling of thi s oil saves $.40 to $.80 per

gallon, the total cost of the ban on selling untested recycled transformer

oil would be reduced by (5.7 million gallons x $.40 to $.80 fer gallon -

$912,000 testing cost = ) $1.368 to $3.468 million fer year. 'Ibtal costs

VvDuld then be ($4.6 to $9.2 million - $1.4 to $3.6 million =i ) $3.2 to $5.6

million per year. If, however, none of the batches of oil had Over 50 ppm

PCBs, the total cost of the regulation VvDuld be the cost of the analyses

(or a total of $912,000 per year if testing were ferformed on batches of

1000 gallons) or even less if the average batch size were larger.

64
Disposal: The PCB Ban Regulation authorizes the disposal of

transformer oil contaminated with 50 to 500 ppm PCBs in large, high

efficiency boilers meeting certain requirements of size, feed rate of the

contaminated oil, presence of excess oxygen in the stack gas, specified

instDJrnentation and ~onitoring procedures, and other specified operating

conditions. The contaminated oil woul.d have to be handled and labeled as

PCBs during sh.i.pnent; and storage.

The regulations require that the EPA Regional Administrator be

notified at least 30 days before the first tline each high efficiency boiler

is used to burn transformer oil known or presumed to be contaminated with

PCBs. 'The regulations further state that the contaminated oil cannot be

fed into the boiler during start-up or shut-do\~ conditions and that the

oil can comprise only ten percent of the fuel while the boiler is

operating. Therefore, special holding tanks and metering pumps will be

required to feed the transformer oil into the fuel stream in a controlled

amount during periods of stable operation of the boiler.

A number of utilities have stated that they have power boilers

that operate at canbustion conditions similar to those specified for PCB

incinerators. * A special holding tank and metering pumps will be required

to feed contaminated transformer oil into a high efficiency boiler.

Additional road construction, fencing, or other util i ties may add to the

cost of equipping a boiler to burn transformer oil in compliance with the

regulation. This expenditure would probably only be made if justified by

savings resulting from (1) decreased disposal costs and (2) the value of

heat recovered in burning the transformer oil.

*Letter fran Nancy GJrmley (Allegheny Power Service Corporation) to EPA

dated August 4, 1978.

*Letter fran James Mulloy (City of IDs Angeles Departmerit of Water and

Power) to EPA dated August 7, 1978.

*Attachment to letter fran L. John Cooper (Nebraska Public Power District)

to EPA dated August 4, 1978.

*"Comments of Otter Tail Power Company on the Proposed Amendments to 40 CPR

761." Submitted to EPA by Jay D. Myster, undated.

*Letter fran S. A. Ali (Public Service Indiana) to EPA dated August 4,

1978.

65
Disposal of used transformer oil in approved high t emperature

PCB incinerators has been quoted to cost $.08 per pound in tank truck lots

(Rollins, 1978) plus perhaps $.02 per p:lund transp:lrtation (Versar, 1977,

pp.2-32). This is roughly $.75 per gallon. T&R Electric estimated that

fuel oil to replace transformer oil us~j in their boiler would cost $.42

per gallon.* Shipping costs to ITove transformer oil in drums to boilers

equipped to burn it will probably not exceed the canmercial trucking costs

of $2.70 per hundred p:lunds for trips under 100 miles (Versar 1977, p.

2-33). For transformer oil weighing 8 pounds per gallon, this is

equivalent to ($2.70/8 = ) $.34 per gallon. Shipment of large quantities

by tank truck \YOuld be considerably cheaper per gallon. The value of the

oil to the company that owns and burns it would be equal to the savings in

disposal cost ($.75 per gallon) plus the net fuel value ($.42 -$.34 = $.08

per gallon). Even though most utilities might be able to obtain fuel for

their power boilers at a lower cost than is paid by T&R Electric, the

savings in disposal cost of $.75 per gallon could quickly pay for the

estlinated cost of installing additional handling facilities at the boiler.

Since the value of used transformer oil as fuel is roughly equal

to the cost of handling and transpxting it, the total cost of disposal to

those utilities that have suitable boilers will be the cost of equipping

the boilers. There is not sufficient information in the record to support

an estimate of the cost of installing this equipment, but this alternative

disp:lsal method should be considerably cheaper than commercial approved PCB

incineration for most of the 149 class A and B utilities.

*Letter from James Thanpson (T&R Electric Supply Company, Inc.) to EPA

dated August 28, 1978.

66
Satisfactory high efficiency incinerators will not be generally

available to G~e many distribution utilities, transfonner repair shops, and

industrial owners of oil-filled transformers. For instance, T&R Electric

is a transformer repair shop that burns 200,000 gallons of used transformer

oil each year in a hot water generator which has a flame temperature of

1700° F.* The regulations will require that this oil be disposed of by

incineration in high efficiency boilers or by other approved methods. This

will result in increased costs to T&R Electric both to dispose of this oil

and to replace it.

If the requirement that wast.e oil be labeled as PCBs discourages

general handling of this material, the value of the used oil to the company

that generates it may be considerably less than its potential fuel value~

'!he result may be disposal costs of up to $.75 per gallon. Since much of

the waste oil is now used as supple~ental fuel in small boilers that will

not meet the requirements established by the regulation, the opportunity

cost of the regulation may be up to ($.75 disposal cost + $.42 fuel value =

) $1.17 per gallon of the oil that is incinerated in approved PCB

incinerators.

The discussion of reclamation of used transformer oil concluded

that the value of reclaimed oil was such that testing of batches of oil to

demonstrate that the PCB content is below 50 ppm will be justified for most

of the transformer repair shops. The oil that will require disposal will

be those batches found to be contaminated above 50 ppn, that oil which has

degraded past the point where reclamation is feasible, and the oil

generated in small batches by junk yards and other industrial concerns that

handle transformers infrequently. It was estimated above that 5.7 million

gallons per year of available oil would be salvageable and contain less

than 50 ppn PCBs.

*r.etter from James Thompson (T&R Electric Supply Company, Inc.) to EPA

dated August 28, 1978.

67
The maximum econanic cost would be incurred if the r emaini.nq oil were

di.sposed of in approved high t.emperat.ure PCB incinerators. The total

annual cost of this incineration is calculated in Table 6.3-3 to be $11.1

million per year. This total would be reduced considerably if the large

utilities were willing to accept contaminated oil for burning in high

efficiency boilers fran other sources, but the comments to the EPA by the

utilities did not express any interest in making this service generally

available.

The willingness of large utilities to make available thei.r high

efficiency boilers for burning used transformer oil luay be increased by the

willingness of the small utilities and transformer repair shops to pay up

to $.75 per gallon for this service. The large utilities would incur no

cost other than the cost of supervising the transfer of truck loads of

liquids to their storage tanks and the monitoring and record keeping costs

that are incurred by the regulations on any disposal of PCBs. Given a

perfect market, the large utilities might be expected to be willing to pay

for the fuel value of the used oil. However, the market is likely to be

very imperfect, and the actual price charged by the utilities for this

service can therefore not be predicted. However, since the burning of oil

by the large utilities will not cost them anything, the price that is

charged will represent a transfer payment frem the small transformer shops

and distribution utilities to the large utilities, anQ will not represent a

real economic cost. Real econemic costs would result only fran the higher

transportation costs of moving the oil to the large utilities and from the

greater value of the heat content of the oil to the smaller canpanies than

to the large utilities. These economic costs are likely to be only a small

fraction of the costs incurred by incineration of this oil in approved PCB

incinerators.

Marking and Storage Costs: The change in the definition of PCB

material fran a concentration of 500 ppn to a concentration of 50 ppm

extends the Impact of the PCB Marking and Disposal Regulations to all used

68
TABLE 6.3....3

Cost of DisfDsal of Transformer Oil from

Small Utilities, Transformer Repair Shops, al1d Other Sou.rces

x

x

=

=

x

=

Total AillOunt of Transformer Oil in Service

Amount Available Each Year

Amount Not Owned by Large Utilities

Amount Available Per Year

Amount Reclaimed and less than 50 ppn PCBs

Total Available for Fuel

COst of Incineration and Lost Fuel Value

Naximt..nn Cost Per Year:

69

1.7 billion gal.

4%

22%

15.2 million gal.

5.7 million gal.

9.5 million gal.

$1.17 per gal.

$11.1 million per year
transformer oil that is being stored for disposal or reuse and to the oil

that is being t.rarisport.ed for disposal.. At a very minimum, special KB

storage areas will be required at each of the 149 large utilities that

maintain their own transformers. TIlese major storage areas were previously

estimated to cost $2000 to construct and to result in annual operating

costs of $2,125 per year (Versar, 1977, pp. 2-6). Total costs incurred

because of the inclusion of transformer oil may therefore be equal to

($2000 per site x 149 locations = ) $300,000 in initial construction costs

and ($2125 x 149 = ) $320,000 per year thereafter. The regulation also

permits bulk storage of used transformer oil and the provIsIons of the

Spill Prevention Control and Countermeasure (SPCC) plans of the oil spill

prevention program become the storage criteria. Since almost all utilities

have SPCC plans, this option probably results in no additional costs being

incurred.

Mditional marking costs will be incurred in applying PCB labels

to drums, tanks, and trucks used to transport used oil to the disposal

sites. Because any tank used to contain transformer oil must be considered

to be a KB container, special deco~tamination will be required before it

could be used for any other service. Therefore, it is likeiy that each

high efficiency boiler facility will have a dedicated truck trailer tank

that is used to haul PCBs. Application of labels to these tanks will cost

only a few dollars per year.

6.4 PCBs Controlled by the Regulation

A certain amount of used transformer oil has been used in the

past as fuel in various boilers and pJwer generating units. When po~sible,

the oil has been reclaimed for use in transformers. Other uses include

roed oiling and re-refining into lubricating oil. Only a very rough

estimate can be made of the amount of KBs released to the environment by

past practices in handling used transformer oil.

If it is asswned that past practices resulted in the use of

one-half of the oil as fuel in boilers operating at conditions that

70
destroyed 98% of the PCBs present and that the ranaining PCBs 1MJuld

eventually enter the environment, the burning would have been expected to

destroy (.98 x .5 x 400,000 fb PCBs = ) 196,000 pounds of the PCBs in

transformer oil. The effect of the regulation is to require the eventual

disposal of all transformer oil in high efficiency boilers that will

destroy 99.9% of the PCBs present. Therefore, PCB releases to the

environment may be reduced from (400,000 196,000 = ) 204,000 pounds to

(400,000 x [1 - .999] = ) 400 pounds, or a net reduction of about 200,000

pounds of PCBs.

6 •5 SLn11ffiary - Economic Impacts:

Ban on reclaiming oil for resale: $3.2 million to $5.6 million

per year (may be reduced if EPA

exempts processing and resale from

the ban requirements).

Limitations on disposal of oontarninated transformer oil:

Cost of storage tanks, etc.,

at high efficiency boilers:

Cost of incinerating oil

generated by other than

large utilities:

Cost of special storage

. area for transformer oil

at utilities:

cannot be estimated fran

information in the record.

Up to $11.1 million per year if

large utilities do not accept oil

for burning in their boilers.

Cost may be reduced considerably

if large utilities make this

service available.

$0 to $300,000 initially plus $0

to $320,000 per year starting 30

days after promulgation of the

regulation.

6.6 Cost Per Pound of PCBs Kept fr~~ the Environment

If it is assumed that the restrictions on disposal and

reclaiming of transformer oil will continue for the 30 year life of the

newest oil filled tranformers:

Ban on reclaiming and special disposal requirenents

$3.2 million to $5.6 million + 0 to $11.1 million + 0 to $.3 million =

200,000 Ibs/30 years

71

$480 to $2550

per' pound PC3s
7.0 IMPACTS ON TFA"1SFORMER SERVICE CO['1PANIES

7.1 Present Status

1~ere are pres8ntly about 300 small com~nies that service the

transformers owned by small utilities and by industry.* The services

offered by these companies include field testing and servicing of

transformers and complete shop maintenance and rebuilding services.

7.2 Requirements of the Regulation

'The regulation requires that all oil-filled transformers be

considered to be PCB contaminated transformers unless the concentration of

PCBs in the oil has been derronstrated by chemical analysis to be less than

50 ppn. The regulation bans the sale of any new or reclaimed transformer

liquids unless they are known to contain less than 50 ppn PCBs.

7.3 Impact of the Regulation

The major impact of the regulation on the small transformer

service companies results from the change in the definition of PCBs from a

concentration level of 500 ppm to a level of 50 ppm. Many of these

companies have discontinued servicing askarel transformer~ because of the

potential liability that could result from spills or worker exposure, and

because of the relatively high price of building the required storage areas

for PCB materials. Companies who do not have oil storage facilities

meeting SPeC requiraenents are now required to install special storage

areas for the storage of oil filled transformers and used transformer oil.

Transformer service companies wiLl, face increased costs from the

ban on reclaiming PCB contaminated transformer oil for resale, and

*Letter from Robert L. Sandman (Electric Apparatus Service Association) to

EPA. Undated.

72
increased disposal costs. These costs were discussed in detail in Chapter

6, and the companies should be able to pass them along to their CJstomers.

The fact that the regulation allows reclamation of PCB contaminated oil for

use in the owner's transformers but not for resale will provide an economic

incentive for utilities and large industrial concerns to perform their own

maintenance rather than contract it out. However, there is not sufficient

information available to support any quantitative estimate of the resulting

market shifts. The economic impact of restrictions on these activities

will be dependent on the extent to which EPA grants exemptions for these

activities.

7.4 PCBs Controlled by the Regulation

There was no information presented on the amount of PCBs entering

the environment as the result of improper storage of transformer oil by

transformer serJice shops. Therefore, no estimate can be made of the

reduction of PCBs entering the environment that will result from the

improvement of storage conditions at these facilities.

7.5 Summary - Economic Impacts

Information is not available from the record to make estimates of

these Irnpacts ,

73
8.0 MINING ~ffiCHINERY*

8.1 Current Use of PCB-Gooled Mining Machinery Motors

In the late 1960s and early 1970s, PCBs were used as a lnotor

coolant in three types of electric motors manufactured by Reliance Electric

for Joy Manufacturing Company. Joy used these motors in three models of

10,<1 seam mining machinery: CU43 continuous miners, 9CM continuous miners,

and 14BUIO loaders. Table 8.1-1 sumnarizes the production statistics and

present usage of these rrachines.

One smalI coal mining canpany in Pennsylvania is operating the

three remaining tvbdel CU43 continuous miners known to be in service. This

company also has portions of several other CU43 miners which they have

purchased for parts. 'I'<t.o of the machines in use have had the K:B-coolant

replaced with a silicone fluid and two of the three motors on the third

miner have also been filled with silicone. If the motors were not

completely cleaned and rewound at the tiJne the silicone fluid was

introduced, it is probable that the motors still contain low levels of

PCBs. For the purposes of this analysis, it will be assumed that they are

contaminated with PCBs at levels in excess of 50 ppm. Fifty-four of the

fifty-seven 9CM continuous miners sold in the United States were located by

Versar during the course of a telephone survey. Two of the three machines

whic~ could not be located were recently sold on the used-machinery market.

It is assumed that these two machines are still in use. Thirty-five of the

model 9CM miners are currently idle, fifteen are being used to mine coal,

three are in use for rnaintena~ce or construction, two are in use on spare

sections, and one is being used in a training program at a vocational

school.

The 14BUIO loaders were originally sold to eighty-eight

different mining operations, the majority of them small; sixty of these

mines have three or fewer of these loaders. Based upon the expected

service life of the machines and a survey of thirty-six mines, it is

estL~ated that essentially all of these loaders are still in service.

*All figures and information in this Chapter are from Versar, 1978, except

where noted.

74
Table 8.1-1 Use of PCB-Coo1ed Electric t-btors in

Mining Machinery (1)

_________ J

9C]'!

Continuous Miner

CUB

Continuous Miner

14BUlO

Loader

I

---- -- -

NLinber of '!btal Nl.mber of 1btal -r--- 1btal

PCB tbtors PCB Gallons of Gallons of Gallons

per Machine tbtors PCBs per tbtor PCB per Machine PCB

---- -------- -

3 9 4 12 36

3 63 5 15 315

2 517 4 8 2,06e

NLiuber

Still in

Service

with PCB tbtors

17 3

57 15 + 6 (3)

533(2) 250 (4)

+ +

34 17 (5)

Spare

tbtors

-----

Nuul::er

Prcxluced

-------4-------

Machine

-J

1J1

(1) Except as noted in (3) and (4) I::elCM, all data is fran Versar, 1978.-

(2) Approximately 280 of these machines nCM have air-cooled notors,

(3) 15 in use for production, 6 for other uses

(4) Oral Ccnment.s of Mr. A. R. Benvenuto (Joy Manufacturinq Cmpany) at the PCB Ban Regulation Hearings,

AUCjust 25, 1978.

(5) Estimated, based on percentage of loaders that have I::een converted.
For the past few years, Joy has been converting the motors on the loaders

to air-cooling. As shown in Table 8.1-1, there are approximately 250

loaders and 17 spare motors that still contain PCBs.

'The rotors on the continuous miners and the loaders require

occasional topping-off with additional fluid at the mines. The amount of

fluid Yklich is required is small but is necessary for the continued

operation of the machines.

8.2 Requirements of the Regulations

The PCB Ban Regulations require or permit the following with

respect to the continued use and servicing of PCB-cooled mining machinery

motors:

• PCBs may be used in mining equipnent until January' 1, 1982.

• PCBs may be added to mining equipnent motors at the mines

until January 1, 1982.

• PCB motors in the loaders must be rebuilt as non-PCB cooled

rrocors whenever the motors are returned to a service shop

for servicing.

• PCB lnotors on continuous miners may be rebuilt as PCB motors

until Janua~! 1, 1980.

• Any PCBs used to service or repair PCB-cooled motors must be

stored in accordance with the storage for di.sposal

requirements of Annex III (§76l.42).

• Processing and distribution in commerce of PCBs for purposes

of servicing mining equipnent is permitted after July 1,

1979, for persons who are granted an exemption under TSCA

§6(e) (3) (B).

8.3 Compliance Costs

Continuous Miners: 'The regulations allow rebuilding of the

motors in the tv.D models of Joy continuous miners as PCB motors until July

1, 1979. This deadline could be extended to January 1, 1980, if EPA grants

the service shops an exemptionfrc:m the "processing" and "distribution in

76
camnerce" bans. There are no non-Pc.B motors that can be used in place of

the PCB ITotors on the continuous miners, and space limitations on the

machines prevent converting these motors to air cooling. Since the PCB

motors on the continuous miners require rebuilding after about 12 months of

serVice*, all of these machines will have to be retired fran use.within

about a year after the effective date of the ban on rebuilding the motors.

Because of the time limits in the authorization, the market for

used 9CM and CU43 continuous miners will virtually disappear, Though this

machinery may be technologically obsolete before January 1, 1982, there are

undoubtedly nQmerous small firms which cannot afford the capital investment

required for new machinery and thus rely on older used machines to fill

their needs. In addition, larger firms often use older machinery for spare

equipment or in mine construction. Therefore, the owners will be

confronted with equipnent that they must retire prematurely, losing the

remainder of the machine's useful life or the income that could result from

the sale of the machinery.

Eight canpanies still use 9CM or CU43 continuous miners for coal

production. Six of these companies are relatively small, with production

ranging from 0.7 to 4.2 million tons per year. The other two are large

conglomerates with much higher annual productions. In addition, six

machines are per'forrni.nq operations other than production. The market value

of these machines is roughly $40,000 each (Versar, 1978). Table 8.3-1

summarizes the costs that would be incurred by each of the companies that

still use the continuous miners for coal production. Table 8.3-1 omits the

42 miners that are idle or in non-production uses because the percentage of

those miners that have any value is not known. If each of them has a value

*Testimohy of Mr. Ed Warner (Joy Manufacturing cc .) at the EPA PCB

Hearings, Chic~o, Illinois, July 19, 1977.

77
TABLE 8.3-1

Cost Impact of Forced Retirerrent of :PCB Continuous Miners

Number of Number of Opportuni,ty

Continuous Continuous Cost Due to

Corrpany Hiners Miners Absence of

No. ~Ddel CU43 l-1ode1 901 Used Equiprrent

in Service Market

1* 3 0 $ 120,000

2* 3 $ 120,000

3* 2 $ 80,000

4* 1 $ 40,000

5 1 $ 40,000

6* 1 $ 40,000

7 2 $ 80,000

8* 5 $ 200,000

(Oth~l:" Uses) 6 s 240,000

TOTAL 3 21 $ 960,000

* Srral1 producer (less than five miLl.i.on tons per year total company

production) •

78
of $40,000, the additional cost could be as much as $1.7 million. In no

case does the economic impact exceed one percent of the value of the coal

~ined annually by any of the affected companies. It is assumed that

replacement machinery could be obtained in time to prevent any interruptions in coal production.

waders: '!he PCB motors used on the loading machines can be

converted to air coo.Li.nq at a cost of $3,100 per motor, The motors usually

require rebuilding after 18 to 24 months of service*, so most of the rotors

will be available for this conversion witrout incurring additional downtime

for the machines. Joy Manufacturing Company h9s stated that its service

shop has the capacity to convert all of the PCB motOrs presently used on

loaders to air cooling by the end of 1981. Since the PCBs will be removed

from these motors for purposes of di sposal , this activity is not affected

by the ban on "processing" of PCBs.

'Ihe total cost to convert the 517 PCB motors used on the loaders

will be (517 x $3,100 = ) $1.6 million. There should be no interruption of

coal production due to the conversion program because PCB motors will be

allowed to continue in use until January 1, 1982, and most of the

conversions will occur when the motors will require normal rebuilding. It

is anticipated that maintenance requirements will be greater for the air

cooled rrotors than for the PCB cooLed rrotors, but it is not possible to

estimate the total economic impact of the resulting increased maintenance

costs.

Storage Costs: Each mine v.ould be required to store PCBs used

for maintenance in a storage area that meets the requirements of Annex III.

Joy sells the PCBs in one gallon cans. A non-leaking 55 gallon drum

protected fran the rain woul.d meet the requirenents of Annex III and WJuld

be of sufficient size to store all the PCBs any mine v.Duld require. Each

of the 96 companies poasibly involved (88 loader owners and 8 continuous

miner owners) would need such a storage area. The cost for a barrel and a

*Testirrony of Mr. Ed Warner (Joy Manufacturing Company) at the EPA feB

Hearings, Chicago, Illinois, July 19, 1977.

79
label may amount; to $50 each for a total cost of $4,800. The zecordkeepi.nq

required for storage areas may increase this cost by a factor of two to

three, for a maximum expected cost of $14,400.

Exemption Application: It is assumed that Joy ~Bnufacturing wil~

apply for an exemption under TSCA §6(e)(3)(3) in order to be allowed to

rebuild the loader motors and to be allowed to distribute PCBs to the lnines

for maintenance. The estirnatec1 $1,600 cost of preparing this petition is

developed in the chapter on unintentional product contaminants.

8.4 PCBs Controlled by the Regulation

The electric ITDtors in use on mining machines contain about 2419

gallons of PCBs (Table 8.1-1). This is equivalent to about 27,500 pounds

of PCBs with a density of 11.37 pounds per gallon. The regulations will

stop the losses of PCBs from these motors by requiring that they be

scrapped or rebuilt as air cooled motors by January 1, 1982. There is no

information in the record on which to base any estimate of the rate at

which PCBs are lost from these rrotors , Therefore, no estimate can be made

of the number of pounds of PCBs that will be prevented from entering the

envirorunent.

8.5 Summary-Economic Impacts

Loaders - rebuild motors @$3,100

Continuous Miners-premature scrapping

of 24 operating machines @$40,000

42 other miners @O - $40,000

Storage costs - 96 storage areas

Exemption application

rIDTAL

$1,600,000

960,000

o to 1,700,000

14,400

1,600

$2,576,000

(plus up to $1,700,000

for idle miners)

80
8.6 Cost Per Pound of PCBs Kept from the Environment

If it is assumed that the regulation will prevent the entry into'

the environment of all the PCBs presently in use, and that all of the PCBs

'NOuld otherNise be lost:

Cost per pound = $2,576,000 to $4,276,000

27,500 fOunds

81 ;

= $94 to $155 par pound PCBs
9.0 ELECT~~GNErs*

9.1 Current Usage

Large electranagnets are installed over conveyor belts to rE5TOve

tramp iron fran non-magnetic canrrodities such as coal and grain. Most of

these electromagnets are cooled with 100 to 150 gallons of mineral oil.

~Vhere increased fire safety was required, the magnets were often filled

with PCB based askarel liquid. The three magnet manufacturers who used

PCBs were:

Sterns Magnetics, Cudahy, Wis.

Eriez [vlagnets, Erie, Pa.

Dings Co , , l1ilwaukee, Wis.

Dings Co. stopped using PCBs in mid-1976; the other two

manufacturers have not used PCBs since 1971 or 1972. A total of about 250

PCB magnets were manufactured; approximately 200 of these may still be in

use in the United States. tvbst of the PCB magnets are being used in coal

mines, coal preparation plants, and in coal-fired generating stations. It

is possible, but not confirmed, that some of the PCB magnets may be used on

grain conveyors because of the flammability of grain dust.

The electrcmagnets are of completely welded construction, and

very few le~(age incidents have occurred with either oil-filled or

PCB-filled magnets. Based on design considerations, electromagnets would

be expected to be less likely to fail than transformers. Those leaks that

have occurred have been caused by physical abuse or lack of adequa te

maintenance. Maintenance requirements do not expose vorkers or the

environment to contact with PCBs. Since the magnets are suspended over

conveyor belts, diking is not feasible, and any leakage would be

uncontrolled. However, PCBs dripping onto the coal would be expected to be

destroyed in power generating boilers, thus making the only loss to the

envirornnent that of leachate fran contaminated coal in storage piles. The

tot.al amount of PCBs presently in use in electromagnets is probably (200

magnets x 135 gallons per magnet x 11 pounds per gallon x .7 pound PCB per

pound askarel = ) 207,900 pounds of PCBs.

*All information in this chapter is from Versar, 1978, Chapter 9, except as

noted.

82
9.2 Requirements of the PCB Ban Regulations

Continued use: PCB-filled electromagnets are defined as a

totally enclosed use of PCBs and therefore may continue to be used

indefinitely.

Servicing: Minor servicing which does not require the reroval of

the coil frQ~ the casing is authorized until July 1, 1984. Removal of the

coils is prohibited.

Sale of PCBs: Banned after July 1, 1979, unless EPA grants an

oxemption fran the "distribution in canmerce" ban.

Reclaiming PCBs: For reuse by the owner of the FeB transformer

or electranagnet: authorized.. For sale: banned unless an exernption is

granted by EPA.

Disposal: By incineration in an approved high tenperature PCB

incinerator. Drained PCB electromagnets may be disposed of in approved

chemical waste landfills; the liquids drained from the magnets must be

incinerated in approved incinerators.

9.3 Cost Impacts of the PCB Ban Regulations

Continued use: The regulations impose no additional requirenents

beyond the labeling previously required by the PCB Disp)sal and Marking

Regulations (EPA, 1978a).

Ban on manufacture: The ban on the manufacture of new PCB

magnets is·not eXfected to have a significant impact 'on either the

manufacturers or users of these magnets 0 According to the magnet

manufacturers, the FeB electromagnets could be replaced with oil-filled

units at an average cost of $8,000 per magnet. However, the use of mineral

oil in ~~ese applications would significantly increase the fire risks. The

, manufacturers regularly furnish silicone-filled magnets for use where more

effective fire resistant characteristics are required than those achievable

with mineral oil. Such silicone-filled units are 40 to 50% more expensive

83
than comparable oil-filled units; the average cost is $12,000 per magnet.

In addition, Eriez offers a proprietary air-cooled electrQnagnet which haS

Underwriters Laboratory approval for use in dirty and dusty environ~ents.

These units cost an average of $10,000 each.

Servicing: The PCB electromagnets are sL~ilar in construction to

askarel transformers, and it is anticipated that the magnets are subject to

the same failure mechanisms, expected service life, and service practices

as the transformers. If the average remaining service life of the PCB

electromagnets is ten years, the magnets would be expected to fail at the

rate of twenty units per year. Although rewinding failed magnet coils

would probably cost 60% of the cost of a new magnet, rebuilding is banned

by the regulation. The transportation and labor costs would be exPected to

be the same whether a magnet is replaced or rebuilt, so the effect·of the

ban on rebuilding is to forego a potential savings of 40% of the purchase

cost of a new magnet each time a PCB magnet fails. Tbtal annual costs

would be expected to be (20 magnets per year x 40% of $12,000 per

magnet = ) $96,000 per year. Tbtal costs attributable to the ban on

rebuilding PCB electromagnets will be $960,000.

Disposal: The PCB Ban Regulations authorize the disposal of

drained PCB electromagnets in chemical waste landfills. The previous PCB·

Disposal and Marking Regulations (EPA, 1978a) authorized only incineration.

Since incineration is not available for magnets, a petition for alternating

disposal means would have had to have been submitted to the EPA each time a

magnet required disposal. There is no info~ation in the record on which

to base an estimate of the cost of preparing and processing such petitions,

but L~is cost has been eliminated by the Ban Regulations.

9.4 PCBs Controlled by the Regulation

The PCB electromagnets presently in use contain about 207,900

pounds of PCBs. The regulations do not affect the continued use of these

84
magnets. The effect of the ban on rebuilding these magnets will be to

eliminate the loss of PCBs to the atmosphere that might occur during the

rebuilding process. If these losses were 1 to 10 pounds per magnet, as

estimated in Chapter 4 for askarel transformers, the regulations would be

expect.ed to reduce the amount; of PCBs entering the environment by (200

magnets x 1 to 10 pounds PCBs per magnet = ) 200 to 2000 pounds of PCBs.

9.5 Surranary - Economic Impacts

Ban on rebuilding: $96,000 per year; $960,000 total.

Disposal: Elimination of costs of preparing and processing

)?etitions for disposal by means other than incineration.

9. 6 Cost Per Pound of PCBs Kept from the Envi rorunent

Cost per pound = $960,000

200 to 2000 pounds

85

= $480 to $4800 per

pound PCBs
10.0 HYDRAULIC SYST~~

10.1 Present Use of PCBs in Hydraulic Systems

Prior to 1972, PCB based hydraulic fluids were marketed by

rbnsanto under - the trade- na~e Pydraul® for use in hydraulic systems where

su~rior fire resistance was necessary for rrotection of life and -

property. * A previous EPA sponsored stUdy repertgg tbat sales of PCB based

J ~~ydraulic fluids during the period 1970-1971 totaled over 13.5 million

pounds to 585 different firms (Versar, , p. b ors

rporation report at GM used PCB based fluids in the following types

of systems:**

Metal die-casting equipment

Trim press hydraulics

Plastic injection molding machines

Metal melting furnace tilt hydraulics

Industrial elevators

Iron foundry pouring equipment

Molten iron holding furnace equipment

Induction hardening machine hydraulics

Flame hardening equipment

Heat-treating furnace hydraulic systems

Forge furnace hydraulic systems

Forge press hydraulic systems

High tension welding machines

Loading dock levelers

Fork lift trucks

Other small miscellaneous systems.

Uses of PCBs by GM were reported to be: Die-casting - 56%;

Foundry - 35%; other uses - 9%. A review of !'1Jnsanto's customer list for

1970-71 indicated that 80% of the purchasers of hydraulic fluid were

primarily die-casting operations and the other 20% were primarily steel

companies (Versar, 1978, p. 65).

*Hesse, John L. 1975. "Polychlorinated Biphenyl Usage and Sources of Loas

to the Environment in r>'lichigan." National Conference on Polychlorinated

Biphenyls, November 19-21, 1975, Chicago, Illinois. Washington, D. C.:

Office of 'Ibxic Substances, U. S. Environmental Protection Agency (Report

No. EPA-560/67-75-004), p. 129.

**Letter fran Mr. W. R. Johnson (General Motors Corporation) to EPA dated

August 7, 1978.

86
\'illen Monsanto discontinued the sale of PCB based hydraulic

fluids in 1972, they recommended to their custaners (1) that there was no - . need to drain the systems and (2) that compatible Monsanto hydraulic fluids

eO'lifd be used to replace leakage •. Most hydraulic -;yste.ms requireme

addition of new or reclalined fluid at a rate of two to ten tlines the systen

capacity each year to replace leakage losses. It is fairly canrron practice'

to recover leaked fluid and to process it for reuse. (Available data on

residual PCB levels in hydraulic s stems indicate that the concentration - of

PCBs ran es from 60 oem to as high as 50% in a few machines (Versar 1978,

p. 65). The differences in concentration apparently reflect differences in

@ the rate of leakage fr011 ~s machi:;.;s @ d~ering cem~y mainte~ce

~POlicies regarding periodic total replacement of hydraulic fluid.

Mr. {)wain Fowkes of RAOCO Corp. r eported that the h draulic

fluid which is commercial ~etlines contains up to 6000 ppn

.~

-- - Therefore, it is possibl,e that the use of r ecl.aimed hydraulic fluid

has resulted in the PCB contamination of hydraulic systems which never

contained PCB based Pydraul® fluids.

Die-casting machines: 'fue analysis of the proposed K:B Ban

Regulations suggested that ~a~ hydraulic ma¥ have been us~in

a 'IQis estimate was based on the.

assumptions that 80% of the hydraulic fluid sold during 1970-71 was u~ in rdie-casting machines, that the annual makeup requirement of new fluid to~

£eplace - leakage is equal to the liquid capacity of the hydraulic system,

that the die-casting machine has a ca ci t allons of

hydraulic fluid (Versar, 1978, pp. 65-66). Mr. Johnson of General Motors -

suggested that this estimate may be in error because not all of the

hydraulic fluid purchased by companies classified as primarily die-casting

concerns was used in die-casting machines; GH used only 56% of their PCB

*Telephone conversation,with L. Fourt (Versar), September 19, 1977, as

reported in Versar, 1978.

87
hydraulic fluid in die-casting Inachines and the rest in associated

equipment and in their steel foundry operations.* The Outboard ~Brine

Coq:oration plant in Waukegan, Illinois, contains 135 die-casting machines,

60 associated trim presses, 30 electric melting furnaces, and several other

furnaces plus numerous other systems, all of y~ich contained PCB based

hydraulic fluid prior to 1971.** The average capacity of the die-casting

machines at Outboard Marine is 350 gallons; ~1 reported that its ... die-casting machines had an average capacity of 460 gallons at one plant ----- and 1580 gallons at another plant. --.:-. '

Mr. William Sharp of the Society of Die Casting Engineers

stated that die-casting machines are long-lived pieces of equipment with

some85- to 40-year-old machines still in operation] 'lhesemachines are in.

use by 1500 to 1800 sew-rate companies, and perhaps 35% of the canpanies ----- . ,

used synthetic hydraulic fluids (not necessarily PCB based). There is a

~ry active market for used machines. ***J

Based on the available information and assuning that 80% of

the companies buying fluid had die-casting machines, that 60% of the fluid

purchased by these companies was used in this type of maChine, and that the

average annual requirement for makeup fluid was equal to the system

capacity of 400 gallons, the number of die-casting maChines that onCe used

PCB based fluid may have been as high as 700 machines as calculated in

Table 10.1-1. No information is available on the number of companies that

own PCB contaminated die casting machines. However, it should be noted

that not all the machines that used PCB based hydraulic fluid can be

identified from the records because many machines have been resold since

1971. If the total nwnber of die-casting machines in use is 10,000 t~

15,000 (estimate based on an average annual pr@uctlon of 500 machines and '"--- an assumed average ownership of 6 to 10 machines per company), only 5 to

*Letter from {vir. W. R. Johnson (General Motors Coq:oration) to EPA dated

Ausgust 7, 1978.

**Oral testirrony of Hugh 'lhomas (Outboard Marine corporation) at the

hearings on the PCB Ban Regulations, August 25, 1978.

***Oral t.est.irrony by William Sharp (Society of Die Casting Engineers) at

the hearings on the PCB Ban Regulations, August 25, 1978.

88
Figure 10.1-1

Calculation of Number of Die-Casting Machines that Used

PCB Based Hydraulic Fluids

1btal sales of PCB hydraulic fluid,

1970-1971

Number' of years

= Annual sales of PCB hydraulic fluid

Weight of fluid per gal

= Gallons PCBs per year

x Assumed fraction purchasing companies

owning die-casting machines

= Gallons PCBs purchased by companies

owning die-casting machines

x Aastmed ; 60% used in die-casting

machines as makeup fluid

= Gallons per year used as makeup fluid

.;. Assumed: 400 gallons per year per

die-casting machine required as makeup

fluid

= Number of die-casting machines using PCB

based hydraulic fluid

89

13,500,000 pounds PCBs

--cD

6,750,000 pounds per year

__---'~unds per gal

587,000 gallons per year

x .8

470,000

x .6

282,000

.;. 400

704
)\\~~ ('v \07 0

I

7% of the ffiachines presently in seDlice ever used PCB based hydraulic - fluid. However, many of the other machines may presently be contaminated -----:-----.:,-:--"'----:"----:----::--:--:..-=---_.::...._-~---

with PCBs because 0 actice of reclaiming hydraulic fluid.

Other hydraulic systems: General l'btors reported use of PCB

based hydraulic fluids in systems ranging from 50 gallons to 4000 gallons,

with most; of the s~stems being in the 300 gallon range. * Canments

--:--:---.:::'-:---- submitted by Armco, Inc., (dated August 3, 1978) s~arized the results of

testing 50 heat transfer and hydraulic systems with an average capacity of

422 gallons. 'fuis is reasonably consistent with an average hydraulic

system capacity of 350 gallons. It implies that perhaps 1,000 other

hydraulic systems used PCB based fluids in the years 1970~7l, assuming

these systems require proportionately as much hydraulic fluid for makeup as

do die-casting machines. 'fuese systems were probably owned by all of the

companies having die-casting machines plus perhaps an additional 100 steel

conpanies,

Total PCBs presently in use: Tbtal capacity of all of the

hydraulic systems that at one time used PCB based hydraulic fluids may be

(700 die-casting machines x 400 gallons per machine + 1000 other systems x

350 gallons per system = 630,000 gallons. Q1 reported that 80% of their

'I- die casting systems have PCB concentrations below 500 ppn*; Outboard t4arine

reported that recent spot checks of their machine show PCB levels around

"'100 ppn, compared to a range of 210 to 1400 ppm in 1976 and 1977**. It is

therefore likely that the average concentration of PCBs in hydraulic fluid

--J.. is betw=en 100 ppn and 500 ppm if the single group of die casting machines

known to contain 50% PCB fluid is excluded as a special case. If the

average density of the presently used hydraulic fluid is ten pounds per

gallon, the total arrount of PCBs in use in hydraulic systems may be .I(630,000 gallons x 10 lb per gallon x 100 ppm to 500 ppm PCBs = ) 630 to

3150 pounds of PCBs.

*Letter fran W. R. Johnson (General Motors Corporation) to EPA dated

August 7, 1978.

**Letter fran Hugh Thanas (Outboard tvlarine COq:oration) to EPA dated August

3, 1978.

90
10.2 Requirements of the PCB Ban Regulation

Continued use of hydraulic systems contaminated with PCBs in

excess of 50 ppm is authorized until January 1, 1984, subject to the

following requirements:

o Testing: Required for all machines that ever contained a

PCB based hydraulic fluid by July 1, 1979, and at least

annually thereafter as well as three mnths after each

refilling performed to reduce the concentration of PCBs to

below 50 ppn ,

o Marking: Hydraulic systems containing liquids

contaminated with over 50 ppm PCBs must, have the special

PCB label applied.

o Retrofill: Retrofilling or topping off with a hydraulic

fluid containing less than 50 ppm PCBs is required within 6

months after any test which shows that the concentration

of PCBs exceeds 50 ppm.

o Disposal of contaminated fluid: Hydraulic fluid

containing over 50 ppm PCBs must be disposed of by

incineration in special approved PCB incinerators or by

incineration in other facilities such as high

efficiency boilers approved by the EPA Regional

Mministrators. 'Ihis material can also go to Chemical Waste

Landfills or high efficiency boilers if it is between 50 and

500 ppm.

o Storage: Special storage facilities required for the

storage for reuse or processing of hydraulic fluid

contaminated with more than 50 ppm PCBs.

o DisfOsal of contaminated machine after liquid is drained

for incineration: Essentially not regulated (either salvage

or disposal as non-hazardous waste allowed) provided the

fluid is first drained from the machine and, if the fluid

contained over 1000 ppm PCBs, the hydraulic system is.

flushed with clean solvent.

o Reclaiming of contaminated hydraulic fluid: Hydraulic

fluid contaminated with more than 50 ppm PCBs may be

reclaimed for reuse in the owner's hydraulic systems only if

it is treated to reduce the concentration of PCBs to below

50 ppm. Reclaiming for purposes of resale is banned unless

this activity is exempted by the EPA.

10.3 Cost Impacts of G~e PCB Ban Regulation

Testing: Host of the hydraulic systems that once used PCB

based fluids have since been refilled with fluids based on phosphate

91
esters. Analysis of phosphate esters for the presence of PCBs requires a ..... ------- rather time consillning treab~nt of the sample and extraction of the PCBs'

before injecting the prepared sample into a gas chromatograph. In their

written camnent dated August 3, 1978, to the EPA on the proposed PCB Ban

Regulations, A~co Inc., stated that their average cost to analyze

hydraulic fluid for PCBs " ..•is probably closer to $200 than the Versar

estimate of $300, once the de equipnent is set up to specifically analyze

for PCBs. Laboratories which would only occasionally analyze such samples

would probably incur costs exceeding $300 per sample." Only seven of the

50 systems checked by Armco contained PCBs in excess of 1000 ppn,

Identification of all systems that contained PCB hydraulic

fluids will require the analysis of the fluid in many systems which might

have contained PCBs. As many as 2500 die-casting machines (Versar, 1978,

p. 75) and perhaps as many other hydraulic systems might have to be tested

to identify the approximately 1700 systems which used PCB fluid and to

evaluate the extent of contamination from the use of reclaimed fluid. The

cost of the required sampling and analysis program will include sampling

and administrative costs of perhaps $20 Fer system in addition to the

laboratory costs of perhaps $250. Costs for the analysis program required

by July 1, 1979, might total (1700 to 5000 systems x $270 per sample = )

$460,000 to $1,350,000. Since the average PCB concentration is probably in

the range of 100 to 500 ppm, most of the systems will have to be

retrofilled within six months and tested again within the next year. A

second retrofill and another test might be required. TOtal testing costs

coul.d easily exceed $1, 000, 000:.

Since the concentration of PCBs will continually decrease in

the hydraulic systems because of retrofilling, leakage, and replacement of

tOe tIUld, it is expected that the ooncent~ation of PCBs in almost all

s~ will have decreased to less than 50 p~ by the end of the five

years authoriZed for continued use of contaminated system, and that the -- ~ting requirements would not apply to the systems after that time.---

92
Retrofill: Based on the experience report.ed by GN and Armco,

it is expected that ITDSt of the systems that ever used PCB based hydraulic , ,

fluid will be found to be contaminated at levels exceeding 50 .ppn. If this

is the case, retrofilling will be required for perhaps 1700 hydraulic

systems having an average capacity of about 400 gallons. Armco stated that

the Versar estimate of $14 per gallon for retrofilling was reasonable;* GM

estimated the material cost alone to be $17 to 819 per gallon;** Outboard

Ma~ine e~timated a cost of $8,000 for a 350 gallon system, or an average of

$23 per gallon. *** Total costs of the first retrofilling program would be

(175 systems x 400 gallons per system x $14 to $23 per gallon = )

$9,800,000 to $16,100,000. According to data presented by both Armco and

~1, such a retrofilling program might be expected to reduce the

concentratIon of PCBs in the liquid by about 90%. Perhaps 10% of these

systems might have PCBs in excess of 50 ppm after being retrofilled, so a

seCond retrofill, and in a few cases even a third retrofill, would be

required. 'lbtal costs for these subsequent retrofills might be $1,000,000

to $1,500,000.

Tbpping off systems ~ith PCB concentrations only ,slightly above

50 ppm may result in lowering PCBs levels below 50 ppm without incurring

the costs of draining and refilling the entire syste~.

Disp?sal of contaminated fluid: Special high tanperature

incineration at liquids contaminated with PCBs in excess of 500 p~n waS

required by the PCB Disposal ,and Marking Regulations. The effect of the

PCB Ban Regulations is to extend this requirement to fluids containing

between 50 and 500 ppm PCBs. The most recent available price for this

incineration is $55 per 55 gallon drum (Rollins, 1978) plus drum costs of

perhaps $15 per drum, transportation of $.02 per pound, and drum disposal

costs of $30, or a total cost of $ .22 per pound for contaminated hydraulic

*Armco, Inc. "nai.n Carrrnents," received by EPA August 3, 1978.

**Letter fran W. R. Johnson (General Motors Corporation) to EPA dated

August?;, 1978. . .

***Letter fran Hugh Thomas (Outboard Marine Corporaticn) to EPA dated

August 3, 1978.

93
fluid. If all of the fluid in the calculated system capacity of 630,000

gallons required special disposal because of this change in the regulation,

increased disfOsal costs of (630,000 gallons X 10 Ib per gallon x $.22 per

pound = ) $1. 4 million would be incurred. If the use of contaminat.ed

reclaimed fluid has resulted in an increased number of systems contaminated

with PCBs in excess of 50 ppm, this disfOSal cost might increase by a

factor of 2 or 3 or more. The required retrofilling will generate a

quantity of liquid equal to the calculated systsn capacity, resulting in an

additional disfOsal cost of $1.4 million.

The regulations authorize the EPh Regional Administrators to

approve alternative incineration facilities for liquids such as

contaminated hydraulic fluids. It is possible that approval for the use of

high efficiency boilers might lower the disposal costs substantially, but

no estimate can be made of the resulting decreases in disfOsal costs.

Marking: The requirement, that the special PCB label be applied

to systems found to contain from 50 to 500 ppn PCBs should nat cost rrore

than $2 per machine. Even if (as an upper bound estimate) 2500 such

contaminated systems \~re found, total labeling costs would not exceed

$5,000.

lui of the liquid that is removed frorn the hydraulic syst.ems

during the retrofill and decontamination activities will also have to be

placed in labeled containers prior to being sh ipped for dispoaal , At a

cost of $2 per 55-gallon drum, labeling costs for di sposal couLd total

(630,000 gallons x 2/55 gallons per drum x $2 per label = ) $46,000.

Special storage areas: Liquids contaminated with 50 to 500 ppm

PCBs will be allowed to be stored in drums in t emporary storage areas prior

to disposal if a Spill Prevention, Control and Countermeasure Plan has been

prepared for the temporary storage area in accordance with 40 CFR 112.

94
There is no information available in the record that i;,Duld supco rt; an

estimate of the number of additional SPCC plans that would have to be

prepared under this r equirement . However, it is assumed that perhaps one

third of the 585 firms that bought PCB hydraulic fluid during the period

1970-1971 will be found to have contaminated hydraulic systems and that

some of the 200 firms will therefore have to prepare SPCC plans covering

temporary storage areas for PCB contaminated liquid.

Disposal of contaminated machines: It is not anticipated that

any of the machines will be scrapped before they are decontaminated to a

level below 50 ppn PCBs. Therefore, there should be no additional disposal

costs due to the PCB Ban Regulations.

Recycling of contaminated hydraulic fluid: New phosphate ester

based hydraulic fluid costs about $7.60 per gallon (Versar 1978, p. 68).

According to the comments of Q~, the following treatment techniques have

. been found to be incapable of reducing the concentration of PCBs to below

50 PPn: PAC carbon filter, Florsil filter column, and clay. Open air

distillation of contaminated phosphate ester fluid resulted in excess

oxidation of the fluid. Outboard Marine has described a vacuum distillation procedure which reduces the PCB content of the hydraulic fluid by 50%

at a cost of $3.75 to $4.00 per gallon*. rA.r. Faber Damiani of RAIX::O

Industries in his oral comments at the August 25, 1978 hearings, described

in general terms a fractional distillation process that is "effective in

removing PCB. In fact, a number of runs were made in which PCB concentration was reduced to below 50 PPn." tvlr. Damiani stated that RAOCO has not

developed a process that will reliably reduce the level of PCBs to below SO

ppm and that their present process achieves a reduction to 100 PPn. He

stated that the result of a 50 ppm requirEment will be to "decrease process

yield, and subsequent economics 10 to 20 percent below that expected

with a 100 PPn specification."

If it is assumed that the total amount of contaminated fluid is

available for recycling once per year and that there is presently 725,000

*Oral testimony by Hugh Thomas (Outboard Marine Corp.) at the August 25,

1978 hearings on the proposed PCB Ban Regulation.

95
gallons of such fluid in service, the successful developnent of a reclaiming process might reduce costs for new fluid by $2.80 per gallon (based on

reclamation costs 20% higher than mentioned by Outboard Marine Corp.) or by

a total of $350,000 to $1,700,000 per year. It is not known whether the

requirement that recycled fluid contain less than 50 ppm PCBs, will

significantly affect the availabilty of such a reclamation service; the

total impact of the regulation therefore cannot be estimated.

10.4 PCBs Controlled by the Regulation

In section 10.1, it was estimated that hydraulic systems

contaminated with rrore than 50 ppn KBs may contain from 630 to 3150 pounds

of PCBs. If the use of these systems were not regulated, all of this

material would be expected to leak out of the systems and eventually enter

the envirornnent. 'The requirement that the contaminated systems be

retrofilled by the end of 1979 will reduce total losses to leaks prior to

the retrofilling. Since hydraulic systems often require make-up fluid

equal to their vo.lume each year, the losses of KBs prior to the

retrofilling may equal 25% of the PCBs present in the systems. The effect

of the regulation, therefore, is to prevent the loss to the envirornnent of

.75 x (630 to 3150 Ibs = ) 470 to 2390 PJunds of PCB.

10.5 Summary - Economic Impacts

Testing:

1979

1980-1984

$460,000 to 1,350,000

$1,000,000 total

96
Retrofill:

Disposal of fluid:

t4arking:

Special storage

areas of SK:C plans:

Ban on recycling

contaminated hydraulic fluid:

$10,800,000 to $17,600,000*

$1,400,000*, **

$46,000

Insufficient data available to estimate

Insufficient data available to estimate. ~Eximum possible impact = $350,000 to

$1,700,000 per year for one or two years.

10.6 Cost Per Pound of PCBs Kept from the EnviroTh~ent

Cost per pound = ($460,000 to $1,350,000 + $1 million +

$10.8 to $17.6 million + $1.4 million +

$700,000 to $3.4 million)/470 to 2390 pounds = $6,000 to $53,000 per pound PCBs

*May be significantly higher if the use of reclaimed hydraulic fluids has

contaminated hydraulic systBns that never used PCB based fluids.

**May be somewhat; reduced if EPA approves alternative incinerators for

hydraulic fluids.

97
11.0 HEAT TRfu~SFER SYSTD~

11.1 Present Use of PCBs in Heat Transfer Systems

In his letter to the EPA dated August 4, 1978, Mr. W.R. Corey of

Lvbnsanto estimated that there were § heat transfer svst~~ using PCB

based fluid in 1972 when Monsanto discontinued sales of PCBs for those

systems. A review of a Monsanto customer list, however, indicated that

sales of PCB heat transfer fluids were made to ~ferentcom~anie;)

during the years 1970 and 1971 (Versar, 1978, p. )6). Mr. Corey estimated

that one half of the heat transfer systems had capacities between 50 and

500 gallons and that the other half had capacities averaging 2000 gallons.

This implies that the a~rage system capacjty wa~300 gallons, or about

15,000 pounds of PCB. 'Ihe total M:)nsanto sales of heat transfer liquid

during ---- 1970 and 1971 was 8.2 million pounds, or enough liquid to fill about

550 average systems. TOtal use of PCB heat transfer liquid in the United

States since 1929 has been estunated at 21 million pounds, including both

new installations and makeup fluid (Versar, 1978, p. 75).

Mr. Corey of Monsanto estimated that over 90% of the heat

transfer systems using PCBs were converted to alternative non-PCB fluids in

1970-72 and that current system PCB levels in the industry range from

around 100 ppm to three percent. Mr. Jack Pulley of Dow Corning, in his

reply canment dated OCtober 9, 1978, stated that Dow Corning replaced PCB

fluids in their heat transfer systems about five years ago and that these

systens still contain PCBs in concentrations fran 1/2% to al::out 2% in the

- new non-PCB heat transfer fluid. Data is also available for one other heat

transfer systen that contained 14,000 gallons of PCB based fluid.

Draining and flushing prior to replace~nt of the liquid reportedly reduced

the concentration of PCBs to two percent (Versar 1978, p. 76). Monsanto

and Dow Corning agreed t it is technically infeasible to reduce-r:De

concentration of PCBs in contaminated systems to below 50 ppm.

11.2 Requirements of the PCB Ban RegUlation

All heat transfer systems that ever used PCB based fluids will

be considered PCB articles because their surfaces are presently in contact

98
with a liquid containing over 50 ppm PCBs. These systems will be allowed

to remain in service until July 1, 1984, subject to the following

condi tions:

• Use: After October 1, 1979, no heat transfer system

containing a liquid with a PCB concentration above 50 ppm

may be used in the manufacture or processing of any food,

drug, or cosmetic.

• Testing: Required by July 1, 1979, for all heat transfer

systems that ever contained a PCB based heat transfer fluid.

Syst~~s must be retested within three months after each time

the fluid is replaced to reduce the concentration of PCBs to

below 50 ppn, Records of all tests must be kept for five

years after the concentration of PCBs is reduced to 50 ppn.

• Retrofill: Within six months following any test that

indicates the presence of more than 50 ppm PCBs in heat

transfer fluid, the fluid must be drained and replaced with

fluid that contains less than 50 ppm PCBs. Tbpping off that

results in reduction of PCB concentration to less than 50

pr;:m is also allowed.

• Marking: Required for all systems found to have PCB concentrations in the fluid in excess of 50 ppm.

• Disposal of liquid containing over 50 ppnPCBs:.

For liquids with greater than 500 ppm PCBs, incineration is

required in an approved PCB incinerator. Liquids between 50

and 500 ppm PCBs can go to approved high efficiency boilers

or chemical waste landfills.

• Storage: Special storage facilities required for the

storage of PCB contaminated heat transfer fluid.

• Disposal of contaminated machine after liquid is drained:

High temperature incineration required in an approved PCB

incinerator or disposal of machine in an approved chemical

waste landfill.

11.3 Cost Impacts of the PCB Ban Regulation

Testing: 'Ihe liquids used to replace the PCB based heat

transfer liquids may be analyzed for PCBs by a method similar to that used

99
to analyze for PCBs in transformer oil. The cost of such an analysis

should be about the Sillne as the price of $60 per sa~ple previously quoted

by Versar for the transformer oil analysis (Versar 1978, p. 41). Sampling

and order handling costs might increase this cost to $100 per sample, or a

total of $45,000 to $60,000 for the analysis required by July 1, 1979, on

the 450 to 600 contaminated systems presently in use. Additional testing

required within three months of each system retrofill is included below as

part of the retrofill costs.

Retrofill: The regulations require that the concentration of

PCBs in heat transfer systems be reduced to less than 50 ppn by July 1,

1984. M::>st of the systems now contain about two percent PCBs. rlonsanto

stated that draining most heat transfer systems will remove at least 90% of

the fluid, and that new replacement heat transfer liquid will cost about $8

per gallon. * Disposal of contaminated fluid containing over 500 ppm PCBs

in an approved PCB incinerator would cost from $1.20 per gallon (in tank

truck lots) to $2.10 per gallon (in 55 gallon drums) (Rollins, 1978).

TransfOrtation would add about $.02 per pound or $.16 per gallon to this

cost (Versar, 1978). Since one-half of the systems have capacities of over

2000 gallons, 80% of the liquid may be in these large systems which would

generate truckload lots of fluid when drained. The average disposal cost

would therefore be $1.54 per gallon, including transfOrtation.

Incineration costs for liquids contaminated with less than 500 ppm PCBs

were quoted at about one-half the rate for the more contaminated liquids

(Rollins, 1978). This would be equal to a cost of $.81 per gallon,

including $.02 per pound transportation. If each system were drained every

six months of 90% of the fluid and then refilled with new fluid that did

not contain PCBs, any PCBs that were adsorbed on the vessel walls or

absorbed into porous gasket material woul.d have a chance to diffuse into

the liquid between retrofills. Each draining would therefore r erove 90% of

the PCBs from the system, progressively reducing the concentration from the

present 20,000 ppm (2%) to 2,000 ppn, then to 200 ppm, and finally to 20

*Letter from W. R. Corey (Monsanto) to EPA dated August 4, 1978.

100
ppm after the third retrofill. If the average system capacity is 1,300

gallons, the 450 to 600 contaminated systems presently contain (1300 x 450

to 600 gallons = ) 585,000 to 780,000 gallons. The cost to reduce the

concentration of PCBs from the present 2% to below 50 ppm will be SIS

million to $20 million as calculated in Table 11.3-1.

Since each system must be analyzed within threerronths after

each retrofilling, a total of (450 to 600 x 3 = ) 1350 to 1800 additional

analyses will be required at a cost of SIOO each, for a total additional

analytical cost of $135,000 to $180,000.

t"larking: Tne marking of heat transfer systems containing

liquids contaminated at levels above 500 ppn PCBs is required by the

Dis[X)sal and Marking Regulations (EPA, 1978a). $ince no systems are

expected to be contaminated at levels between 50 PPn to 500 ppn, the change

in the definition of PCB mixture from 500 ppm to 50 ppm in the Ban

Regulation is not expected to change the number of heat transfer systems

requiring the application of a .special, label.

The drums and trucks used to t.ransport; the contaminated liquid

to the incinerator for disposa.l will also require special labeling. Since

this is already required for Li.qui.ds containing over 500 ppn PCBs, the

effect of the Ban Regulation wiLl. be to add this requirement to the

disposal of the liquid fram the third retrofill. If four labels are

required per machine @ $2, total additional labeling costs will be (450 to

600 machines x 4 labels x $2 per label installed = ) $3600 to $4800.

Storage for Disposal : Since the required disposal areas will

have to be installed at each location that uses contam.inated heat transfer

systems to meet the requirements of the Disposal and l"larking Regulations,

no additional cost will result from the PCB Ban RegUlations.

DisFOsal of Heat Transfer Systems: There is no information in

the record that will support; any estimate of the number of heat transfer

systems that will be scrapped before they are decontaminated to PCB levels

below 50 ppn,

101
Table 11.3-1

Cost of Retrofilling Heat Transfer Syst~~s

to Meet 50 ppm Limit on PCB Concentration

Number of contaminated systems

x Average System Capacity

= TOtal quantity of fluid

x Weight per gallon

x Concentration of PCBs

= Pounds of PCBs in fluid

. First Retrofill

Total quantity of liquid

x Drainage efficiency

= Gallons to be di.spoaed of and replaced

PCB Content @ 2%

Cost of replacement fluid @$8.00/gal

+ Cost of disposal @$1.54/gal

+ Labor @ 16 hours/system @ $15/hour

= Total cost of first retrofill

Second Retrofill

PCB content @ 2000 ppn

'lbtal cost of second retrofill

102

450-600

1,300 gallons

585,000 to 780,000 gallons

8 1bs per gallon

2% PCBs

93,600 to 124,800 Ibs PCBs

585,000 to 780,000 gallons

.9

526,500 to 702,000 gallons

84,200 to 112,300 Ibs PCBs

$4,212,000 to $5,616,000

$810,800 to $1,081,000

$108,000 to $144,000

$5,130,000 to $6,840,000

8,420 Ibs to 11,230 Ibs PCBs

$5,130,000 to $6,840,000
Table 11.3-1 (Continued)

'Ihird Retrofil1

PCB content @ 200 ppn

Cost of rep1ace:nent and labor

+ Cost of disposal @$.81/gal

= Total cost of third retrofill

'Ibta1 cost to reach 50 ppn

'Ibta1 1bs PCBs r eroved

103

842 1b to 1,123 Ibs PCBs

$4,320,000 to $5,760,000

$426,000 to $569,000

$4,746,000 to $6,329,000

$15,000,000 to $20,000,000

93,500 1b to 124,700 Ibs PCBs
However, since disposal of machines containing fluid with more

than 500 ppm PCBs was required by the Disposal and Marking Regulations, the

Ban Regulations only affect the disposal of those machines contaminat~i at

levels between 50 .ppm and 500 ppm.

The previously established requirement that all heat transfer

systems contaminated at levels above 500 ppm be disposed of in approved

chemical waste landfills would have resulted in significant costs.

As a very rough estimate, the volume of each system using heat

transfer fluid might be ten times the vol~me of the fluid which it

contains. The total volume of material requiring disposal in approved

landfills might then be (450 to 600 systems x 1300 gallons/system x 10

gallons system volume/liquid volume 7.43 gallons/cubic foot = ) 800,000 to

1,000,000 cubic feet at a cost of $3 per cubic foot (Versar 1977, pp.

2-13) • Because of the uncertainty in this estimate, actual disposal cost

might be considerably higher than this figure. All of these costs would

have been incurred, under the requirements of the Disposal and Marking

Regulations which defined PCB mixtures as those containing over 500 ppm

PCBs. The effect of the required decontamination will be to'decrease the

eventual disposal costs by $2.4 million to $3 million.

11.4 PCBs Controlled by the Regulation

Monsanto claimed that leakage fran heat transfer systems was

infrequent and would seldom exceed 5% of the capacity of the system in any

single incioent. If retrofilling contaminated heat transfer systems were

not required, as much as 10% of the PCBs presently in the systems would be

spilled or leaked because of pump seal leaks and accidents. The remaining

amounts of PCBs would be incinerated as required by the Disposal and

Marking Regulations. If spill cleanup were 80% effective, the effect of

the regulation would be to reduce the amount of PCBs entering the

environment to 2% of the 93,600 to 124,800 pounds presently in the

machines, or by 1872 to 2496 pounds.

104
11. 5 Summary -'" Economic Impacts

Testing:

Ini tial

Following retrofilling

Retrofill:

Di spoae.l :

Cost savings because

systems are decontaminated

Total

545,000 to $60,000

$135,000 to 5180,000

$15,000,000 to 820,000,000

$2,400,000 to $3,000,000

$12,780,000 to $17,240,000

11.6 Cost per Pound of PCBs Kept from the Environment

Cost per pound = $12,780,000

1872 lbs

to $17,240,000

2496 lbs

105

= $6827 to $6907 per

pound PCBs

(average = $6870/Th)
12.0 COi1PRESSORS

Pri or to 1972, l'bnsanto marketed a PCB based lubricant under the

trade name Turbinol® 153 for use in turbine tyr;e canpressors. This liquid

was apparently used in a number of natural gas pipeline canpressors (Versar

1978, p. 78). Although the liquid was flushed out and replaced with

non-PCB fluid in the early 1970s, residual levels of PCBs have been found

in at least a few of the machines.*

12.1 Requirements of the PCB Ban Regulation

Gompressorscontaining a liquid contaminated with more than 50

ppn PCBs may be used until May 1, 1980, provided a KB label is applied to

each contaminated machine. 'Ihese compressors may not be used after January

1, 1980, unless they have been decontaminated to a level below 50 ppn PCBs.

12.2 Impacts of the PCB Ban Regulation

Versar previously estimated that there were r;erhaps ten

compressors that would be affected by the proposed PCB Ban Regulations and

stated that Columbia Gas and Texas Eastern had been contacted for

additional information on the number of contaminated compressors and the

cost and feasibility of decontamination (Versar 1978, p. 78).

In his letter to the EPA of August 4, 1978, Mr. Willard Young of

Texas .Eastern Transmission Corporation stated that Texas Eastern would be

able to reduce the level of PCBs in their canpressors to below 50 ppn by

the end of 1978 "by another cycle of draining, flushing, and installing new

lubricants. II He did not include any information on the cost of this

procedure or the nuwber of compressors requiring decontamination.

In his letter to the EPA of August 4, 1978, Mr. Robert Welch,

Jr., of Columbia Gas System Service Corporation stated that forced shutdown

of compressors on January 1, 1979, could have a significant effect on the

*Letter from Willard T. Young (Texas Eastern Transmission Corporation) to

EPA dated August 4, 1978.

106
delivery of natural gas, "depending on the number of units affected." t/lr.

Welch also stated that the economic i~pact analysis of the proposed

regulations (Versar, 1978) was deficient because the cost of service

disruption was not estimated. However, ~k. Welch did not furnish any data

on the number of contaminated compressors operated by the industry or by

Columbia Gas, nor did he include any information on the difficulty, cost,

and time required to decontaminate such compressors. Therefore, it is

still not possible to estilnate the total economic costs of the regulatory

requirements which ban the continued use of contaminated compressors.

Since Texas Eastern apparently will be able to meet L~ese requirements,

total direct cost of the decontamination program should not exceed the

$200,000 previously estimated (Versar 1978, p. 79). The requirement that

the decont.ami.nation program be completed by the end of 1979 gives the

industry time to complete the program during the slack summer season, so

there should not be any costs caused by service disruptions.

12.3 PCBs Controlled bv the Regulation

There is no information in the record that will support any

estimate of the amount of FeBs presently in use in compressors. 'ilierefore,

no estimate can be made of the amount that will be controlled by the

regulation.

12.4 Summary - Economic Impacts

Decontamination costs -- $200,000

107
13.0 RECLAIMED OIL*

13.1 Present Status of PCBs in Reclaimed Oil

Approxilnately 1.3 billion gallons per year of used oil is

collected for use as road oil, fuel oil, re-refined hydraulic oil, and

re-refined lubricating oil. Much of the waste oil previously used in

applications other than autanotive lubrication has been contaminated with

low levels of PCBs, and dissipative uses of this contaminated oil can

introduce PCBs directly into the envirorunent.

A total of 2,376 million gallons of new oil were sold during

1975, the major canmercial uses being automotive lubrication (50.8

percent); industrial and aviation lubrication (30.5 percent); and other

industrial uses primarily in rnaterials processing (17.4 percent). The

amount available for collection and recycle was estimated to be 1,154

million gallons, or 48.6 percent of total sales. Data on U.S. use of new

(virgin) refined oil and availability of used oil for recycling are

presented for L~e year 1975 in Table 13.1-1.

Data generated by Recon Systems** for a 12-month period during

1970-71 indicate that, out of a total U.S. production of 2,480 million

gallons per year, approxL~ately 901 million gallons, or about 36.3 percent,

were actually collected for recycling or use as fuel. An additional 601

million gallons were esti~ated to be used on roads (application for dust

*This chapter is adapted from Chapter 13 of Versar, 1978. The EPA

promulgated the rules affecting the use of reclaimed oil with

essentially no changes from the proposed regulations.

**Weinstein, ~brman J., (Recon Systems, Inc.), Waste Oil Recycling and

Disposal, EPA-670/2-74-052, Princeton, N.J.: August, 1974 (as Clted in

Versar, 1978).

108
Table 13.1-1

New Oil Usage and Waste Oil Availability for Recycling in 1975*

U. S. Sales Fraction Used Oil

1975 -6 Available** Available

Type of Oil Outlet or Use (gal x 10 ) for Recycle for· Recycling

Autonotive Lube Oil Service Stations 239 .63 150

Commercial Engine

Fleets 225 .50 112

New Car Dealers 103 .90 93

Auto Fleet and other

Lube Oil Uses 151 .50 75

Retail Sales for :

COI:lllrercial Engines 95 .63 60

Garages, Auto Supply

Stores 90 .63 57

Discount Stores 250 .22 55

Factory Fills (Auto &

Farm Equiprrent) 54 .90 49

Subtotals 1,207 651

Industrial & Aviation

Lube Oils Hydraulic & Circulating System Oils 314 .42 132

Metal hbrking Oils 145 .70 101

Aviation & Other 147 .50 73

Gas Engine Oils 60 .90 54

Railroad Engine Oils 58 .53 31

Subtotals 724 391

Other Industrial Oils Electrical Oils 62 .90 56

Process Oils 340 .10 34

Refrigeration Oils 11 .50 6

Subtotals 413 %

Lube Oils Purchased

by U. S. ·GoVe.rnm2nt 32 .50 16

GRAND TOI'ALS 2,376 1,154

*~'1einstein, 1974 (as cited in Versar 1978, o , 81).

**Fraction available for recycling afte::- losses in use and to environrrent.

109
control and possibly in asphalt) or as fuel oil; this used oil could

conceivably have been collected for recycle so that the maximum a~ount of

oil available for collection, based on the Recon Systems' estimates for

1970-71, may be as much as 60 percent of that 9roduced.

A flow chart showing the distribution and utilization of waste

oil in the United States, based on the 1970-71 data of Recon Systems, is

presented on Figure 13.1-1. Summary data for disposi t ion and usage fran

Figure 13.1-1 are as follows:*

Fate of Oil After

Primary Use

Used as fuel

Dissipated to environment

and waste disposal

Applied to roads

Re-refined lube oil products

Percentage of New

Oil Production

41.5

42.3

12.9

3.3

100.0

The general distribution shown in Figure 13.1-1 is believed to

be valid at present, although the magnitudes of the specific flows have

fluctuated as prices of virgin lube oil and fuel oil have varied. The

value of fuel oil has increased since 1970-71, and virgin lube oil was

scarce during the period of the Arab boycott and during a port ion of the

period of price controls. One result of these factors has been increased

use of waste oil as fuel, either by the industrial concern generating the

waste oil or by processors.

The prL~ary sources of waste oil awailable to collectors are

service stations and other automotive-related facilities. Industrial and

*Versar 1978, p. 83.

110
APPLIED TO USEO AS FUEL ROADS ,... 1358. 10' GAUYR I 17&. 10' GAUYRJ

REMOI/ED FROM USfDAS

EOUIPMENT COLLfCnDFOR WASTE OIL FUEL RECYCLE - PROCESSORS· . AAERUSE

- 600 FIRMS 200 FIRMS 1610x 10'OAUYRI SALES Ul1illl(fGAUVAJ ($Ol.lo- GAUYR) 063 x 10" GAUYR J

IUl4. 100GAUYR J

. PRODUCTION WASTES. REREFINERli . SPILLS DlSSIPAi-fO T_O THE JOflRMS ENVIRONMENT. PROCESS WASTES 1246. 10' GAUYR I WASTE AND snus DISSIPATED TO tlJ8 • 10' GAUYR I ...... TO DISPOSAL HIE ENVIRONMENT

lUSh 10' GAUYRJ In. 10' GAUYRI li7B • 10" GAUYR I

REREflNfD tUBE

OIL PRODUCI'S

APPLIED TO

ROADS lal II. 10-'GAUYR)

120. 10" GAUYR I

r-~

PHOOUCIION Of

I/IRGINOII.

f24iO .. 1U'GAl/VRj

f-'

f-'

f-'

SOlJRCE;ADAPTED FROM TABlE2fl. P.1280FWEINSTEIN.1S74 * 'FIGURE 13.1·1.DISTfUBUTION AND UTILIZATION OF WASTE Oil

IN THE UNITED STATE.SDURING 1970·71

*Cited in Versar 1978, p. 82.
aviation facilities are also significant sourCeS. A significantly larqer

fraction of available oil is collected in urban areas than in suburban or

rural areas. Ac'oording to stuGies in the Pittsburgh area, spills and other

wastes from product pipelines are a locally significant source of waste oil

for collection.

The use pattern of processed or re-refined waste oil is

extremely diffuse. Users include states and municipalities (road

application), industrial and commercial facilities (fuel, re-refined lube

oils, road oil), utilities (fuel), and the consuming public (re-refined

rotor oil).

A small portion of the collection and processing of used

hydraulic oils does not follow the general pattern of scattered sources,

many reclaL~ers, and numerous users indicated for the waste lube oils.

Reclamation of used hydraulic oil ,performedprimarily by four companies,

results in a product which is marketed as hydraulic oil.

13.2 Requir~~ents of the Proposed Regulations

The disposal of oil contaminated with PCBs in excess of 500 ppm

was regulated by the res Marking and Disr;osal Regulations (BPi\. 1978a). The

PCB Ban Regulations! change the definition of PCB used in the Marking and

Disposal Regulations to include all mixtures containing more than 50 ppm

PCBs. Under the provisions of the ban regulations, oil contaminated with

PCBs in excess of 50 ppn must be identified, segregated for purposes of

disposal, and disposed of in accordance with 'one of the approved methods.

Oil' containing measurable amounts of feBs less than 50 ppm may be processed

for any use including fuel or reclaimed lubricating or hydraulic oil, but

it may not be used as road oil or as a constituent of any sealant, coating,

or dust control agent.

112
13.3 Sources and Amounts of Contaminated Waste Oil

Hydraulic Fluids: Oil is used as a low viscosity fluid in

hydraulic systems, and PCB based hydraulic fluids were widely used prior to

1972. The most expensive (and polluting) use was in die-casting machinery.

PCB based hydraulic fluids were also used in construction maChinery, farm

machinery (a source of feed contamination),* and in deep mining equip~ent

where the use of PCBs resulted in greater fire safety.

Although hydraulic systems are nominally air-tight, leaks may

occur at dynamic seals, and major spills may occur due to hose rupture.

tbrrnal leakage is collected in drip pans, 'The rupture of a hose can spray

hydraulic fluid over a large area due to high operating pressures. It has

been estimated that 80% of phosphate ester hydraulic fluid losses occur

fran leaks in the hydraulic system.** In certain industries, operators

state that it is ITOre efficient to continually add hydraulic fluids to the

system r ather than shut the system down, repair any leaks, and refill the

system. Leakage from these systems is often collected and reclaimed.

Monsanto manufactured almost all the PCB-based hydraulic

fluids. wnen Monsanto discontinued manufacturing PCB-based hydraulic

fluids in 1971, they did not reoan~end draining or flushing of hydraulic

systems. 'They did reccnmend that replacement fluids be added to the

remaining PCB fluids in the system. As a result, hydraulic systems which

used PCBs in 1972 and prior years now contain replacement fluids

contaminated with 0.006 to 50% PCBs as discussed in Chapter 10. 'The total

amount of contamination is a function of the system leakage and dilution

during the past Eive years.

*U.S. Department of Agriculture Ad Hoc Group on PCBs. Agriculture's

Responsibility Concerning Polychlorinated Biphenyls (PCBs) Washington,

D.C. Office of Science and Education, u.s. Deparenent of Agricultrue,

1972 (as cited in Versar 1978, p. 84).

**Lapp, T.W. (Midwest Resarch Institute), The Manufacture and Use of

Selected Aryl and Alkyl Aryl Phosphate Esters, EPA 560/6-76-008, Feb.

1976, p. 77 (as cited in Versar 1978, p. 84).

113
A pDLtion of the available used industrial hydraulic oil is

Lefined and" sold for reuse as hydraulic oil. Tnis specialized reclaiming

service is furnished by the following four companies \~ich Leclaim a total

of about 150,000 gallons of hydraulic fluid per year (Versar 1978, p, 85).

E. F. Houghton and Co., philadelphia, Pennsylvania

Radco Corporation, LaFox, Illinois

Findett, Inc., St. Charles, Missouri

Wallover Corp., East Liverpool, Ohio

Automobile and Industrial Lubricating Oil: The amount of used

oil collected for Leuse in 1970-71 was about 900 million gallons per year,

with an addi tional 600 million gallons used internally fOL fuel or dust

control on roads (Weinstein, 1974). Thus, about 60 percent of the amount

of new oil sold was reused. MajoL uses of this oil were as fuel (1028

million gallons), road oil (319 million gallons), and feedstock for

re-refined lubricating oil (138 million gallons) (Versar 1978, p. 85).

The extent of PCB contamination of this oil was studied on a

limited basis by the EPA National Enforcement Investigation Center (NEIC)

in Denver.* Samples of oil were taken from selected t.ank truck lots of

used oil that had been collected in Virginia, t1aryland, and North Carolina.

This oil had been delivered to Continental Forest Industries in Hopewell,

Virginia, for use as supplemental fuel in a stearn boiler of a paper mill.

The oil had been collected primarily from autorrobile service stations,

although it is possible that same industrial oil, including hydraulic oil,

had been included in some of the lots. PCBs were found in the samples of

*Testimony of Robert Magruder, (Continental Forest Industries) presented at

the U.S. EPA informal hearings on the PCB ban regUlations at Washington,

D.C., July 15, 1977.

114
oil at concentrations ranging from 3.2 ppn to 19.4 ppm. Although these oil

samples were collected frQ~ a restricted area, the extent of PCB

contamination is probably representative of waste oil collected throughout

the United States.

The PCB contamination of the waste oil could cane fran

conta~inated industrial hydraulic oil or transformer oil or from PCB

additives used in lubricating oils prior to 1973. In applications such as

railroad car journal box oils, PCBs may have been used as lubricant

additives. * PCBs may also have been added to automobile transmission

fluids to control the swelling of oil seals.

It would not be expected that PCBs would be destroyed during

re-refining of wast.e oils. PCBs were reported to be present in

concentrations of several parts per million in reclaimed oil used to

lubricate whetstones.**

13.4 Compliance Costs

Collection of any waste oil likely to be contaminated with PCBs

for a controlled use would not be attractive financially unless the oil

were known to contain PCBs at levels below the control amount. Analytical

costs for determining low levels of PCBs will be considerably higher than

the costs quoted for transformer oil because naturally occurring sulfur and

chlorine canpounds in petroleum oils cause interferences in the use of

electron capture gas chrowBtography at concentrations of 5 ppm PCBs or

below.*** These interferences result in false p:)sitive indications of the

*Monsanto Chemical Company, Aroclors for ---, St. Louis, Mo.: undated (as

cited in Versar 1978).

**Weems, George, (United States Department of Interior, Denver, Colorado),

"Polychlorinated Biphenyls," File HIS 3-3-10h, June 13, 1977 (as cited

in Versar 1978).

***Hofstader, R. A. (Exxon Research and Engineering Co.); Lisk, D. J.,

Bache, C. A. (Cornell University), "Interference in the Electron-Capture

Technique for Determination of Polychlorinated Biphenyls by

SUlfur-Containing Compounds in Petroleum Products", Bulletin of

Environmental Contamination and Toxicology, Vol. 11, No.2, 1974 (as

cited in Versar 1978).

115
presence of PCBs. The PCB components can only be resolved through complex

clean-up procedures or the use of gas chromatography/mass spectrometry,

techniques that would cost up to several hlmdred dollars per sanple.

PDad Oiling: The most recent data indicates that road oiling

consumes 319 million gallons of waste oil per year (Figure 13.1-1). At an

application rate of 1/2 gallon per square yard, this is sufficient to oil

45,000 miles of roadway 24 feet wide (Versar, 1978, p. 87). The proposed

ban regulations would forbid the use of oil containing detectable @nounts

of PCBs for dust control. Fluids from transformers are likely to have

detectable illuOuntS and other industrial sources are at least somewhat

suspect. Currently these industrial oils are collected along 'Hi th used

IT'Otor oil. Although virgin nntor oil has no FeBs, used motor oil may, have

PCBs fran previous recycling which included industrial oil sources amonq

the feedstocks or from old transmission oils which contained PCBs as an

additive. i'Jevertheless, used rotor oil unmixed with industrial sources is

unlikely to contain as much as 10 ppn PCBs and may have PCB concentrations

that are undetectable without unusually elaborate and expensive analysis.

tbne of the r eport ed analyses of waste oil for FeBs was based on used motor

oil without any possibility of industrial contamination. Presumably waste

oil solely from automotive sources would contain fewer PCBs. It is

doubtful that road oiling could stand the costs of even "simple" tests at

$70 per sample. Prospective road oilers therefore would be safer using

waste oil if they take precautions to ensure that it does not contain

industrial oils (and certainly no electrical oils).

Compliance with the requirements of the proposed regulations

could be achieved by either of the following strategies:

(1) Avoid all waste oil, and substitute virgin oil at

considerable rronet ary and energy cost where the customer is willing to pay

the increased price. At an average price of $.375 per gallon for #2 fuel

116
oil vs $.08 per gallon collection costs for us~d crankcase oil, the cost

of road oiling woul.d increase (.375 - '.08) x 139 million gallons = $94

million per year (Versar 1978, p. 87).

(2) Use synthetic road stabilization chemicals which both

reduce dust and provide surface stabilization. The increased cost of this

type of material is presently offset by lower road maintenance costs on

heavily traveled dirt roads at mines and other industrial facilities.

Savings in maintenance on lightly traveled roads 'tX)uld be less significant

and 'tX)uld only partially offset the increased material costs. A typical

synthetic fiEterial is Coherex®, manufactured by Witc6 Chemical Corporation.

This material is an organic resin in a water emulsion which is sold in

large quantities for $.40/gallon plus transp:>rtation, and is applied after

a 5 to 1 water dilution at a rate of one gallon par square yard.*

Increased costs incurred by the use of this material are summarized in

Table 13.4-1.

The use of synthetic road oiling materials such as Coherex® may

be more or less expensive than the use of used motor oil depending on the

local supply and price of the used oil. The present choice between the use

of used oil and synthetic materials apparently depends on local supply and

cost conditions. The total cost resulting from an effective ban on the use

of waste oil \vould certainly be no greater than $31.7 million per year, as

calculated in Table 13.4-1, and might even result in an overall cost

savings as claimed by Witco Chemical.

*Letter fran Victor Shepard nvi tco Chemical Corp.) to EPA dated September

23, 1978.

117
Table 13.4-1

Cost of Substituting COHEREX® for Used

Motor Oil in PDad Oiling for Dust Control

Coherex®: Bulk Purchase Price

Transportation @.02/lb.

(Versar 1977)

'TOTAL

Material Cost for Coherex®: 1/6 gal./yd2

Minus: Used Oil: 1/2 gal./yd. 2 @.08 to .30/gal.*

Equals: Increased Cost (Savings) per sq. yd.

x 14080 yd2 per mile of road, 24 ft. wide =

x 45,000 miles =

S.40/ga1.

.l7/gal.

s. 57!gal.

.09

.04 to .15

$.05 (.06)

$704 (845)

$31,680,000/year

($38, 025, OOO/year)

*Price range reported by Victor Shepard (Witco Chemical Corp.) for supplies

of used oil. Letter to EPA dated September 23, 1978.

118
Users Other tha'1 Road Oilers: About 27 million gallons per

year of transformer oil will not be available to collectors. However, oil

diverted from road oiling may more than offset this loss of supply. Other

industrial oils mayor may not be contaminated with PCBs; to be absolutely

safe, the recycling industry \\'Ould avoid thEm. Individual industrial firms

can probably continue to use their own 'Haste oil as fuel oil if they make

initial and occasional later spot check laboratory analyses to make sure

their oils continue to contain less than 50 ppm PCBs.

The impact on re-refiners (who make re-refined lube oil) and

external processors (who process waste oil for use as fuel oil) will depend

on what happens to road oiling. A strict enforcement; pol i cy with

occasional all-out efforts to find PCBs in waste oil could prevent its use

as road oil. Diversion of waste oil from this use would create a large

increase in supply for processors and re-refiners. Probably most of this

would originally go to fuel oil use since the capacity of re-refiners is

limited and the consumer acceptance of used motor oil is limited. Later, a

majority of the increase might go to re-refiners if the Frost and Sullivan

market projections of 23 percent growth per year until 1985 proves to be

even roughly accurate.* This would provide an extra use as lube oil while

retaining most of the heat value for later use.

Collectors: If collectors avoid transformer and industrial

oils, their total business will decrease. However, hauling conta~inated

oils to chemical waste incinerators or high efficiency boilers will be

required and could offer new market opport.un i t i.es to the collectors.

Processors: Waste oil for fuel use should become more

plentiful as use for road oiling is discouraged or made irnpos s i.ble by the

regulation. 'lhe effect of a larger supply of waste oil on the price to

processors theoretically would be to Lower the price. 1;'laste oil can be

*Maugh, T. W., liRe-refined Oil: An Option That Saves Oil, ivtinimizes

Pollution," Science, p. 1108-1110, September 17, 1976 (as cited in Versar

1978, p. 89).

119
used as a supplemental fuel with coal. This use recovers the fuel value of

the oil and would destroy any PCBs that might be present; in the oil. Since

PCB contaninated oils may be incinerated in large boilers, and since the

use of waste oil with coal in boilers is relatively troublefree, this use

is probably very elastic. If coal burning plants can absorb the increased

supply, M1ich seems likely, the price decrease should be negligible.

Hydraulic Oil. Re-refiners: Information collected through

telephone interviews indicates that at least three of the companies M1ich

re-refine hydraulic'fluid receive hydraulic fluids which are contaminated

with PCBs. These fluids are sometimes contaminated to the extent of 6000

ppn (Chapter 10). In most cases, the reclaiming process r enoves no rrore

than 10% of these 1:(;Bs. * It is also r'eport.ed that the concentration of

1:(;Bs in some of the hydraulic fluid applications encountered by these

comP4Pies remains at approximately 2000 ppm despite repeated flushings and

drainings. The present status of PCB reduction technology is discussed in

Chapter 10.

Industrial Waste Oil Generators: Those industries whose waste

oil contains more than 50 ppnPCBs will have to incur dispoaal, costs of up

to $.75 per gallon (see Chapter 6). Even industrial oil cont.aminated with

less than 50 ppm PCBs may be avoided by waste oil collectors. This may not

be a major problem for canpanies that have large high efficiency boilers.

Oil burning boilers can use a mixture of waste and virgin oil. Mr.

~'1agruder of Continental Forest Industries indicated that up to 14 percent

waste oil mixed with #6 residual oil is feasible.** The result Inay be the

development of a separate market for industrial oil with low levels of PCBS

for use as fuel. Lonq term economic impacts should not be significant.

13.5 PCBs Controlled by the Regulation

The provision of the regUlation that prohibits the use of oil

containing any measurable amounts of PCBs as a coating or dust control

*Telephone conversion, Dwa in Fowkes (RAOCO Corp,') with L. Fourt (Versar),

September 19, 1977 (as cited in Versar 1978, p. 90).

**Testii'T\Cmy on Robert ivtagruder (Continental Forest Industries). Presented

at the U.S.E.P.A. informal hearings on the, PCB Ban Regulations at

Washington, D. C., July 15, 1977.

120
agent will affect only those waste oils that contain less than 50 ppm PCBs,

since the disposal of the lnore highly contaminated oils is controlled by

other provisions of the regulation. The only available data indicate that

waste oils are presently contaminated with FCBsto levels of 3.2 to 19.4

P8l1 (section 13.3). !.'b information is available as to the sources of the

oils for which this data was obtained, and diversion of transformer oil and

contaminated industrial oils to high efficiency boilers might significantly

reduce the concentration of PCBs in the remaining waste oil. However, if

it is assumed that all of the oil affected by this provision of the

regulation is contaminated at levels of 11 ppm (average of 3 ppm and 19

pr::m), then the PCB content of the used oil that is available for recycling

will be (11 ppn x 8 pounds per gallon x (651 million gallons a,utornqtive oil

+ 54 million gallons gas engine oils + 31 million ga,llons railroad engine

oils + 16 million gallons U. S. governrrent lube oils*) = ) 66,176 pounds.

Approximately 12.9% of new lubricating and industrial oil

production has been applied to roads, 41.5% used as fuel, and 3.3%

re-refined as lube oil. Diversion of the 12.9% that has been used on roads

will control (.129 x 66,176 pounds PCBs = ) 8537 pounds of PCBs. If this

oil is used as fuel and re-refined as lube oil products in the same ratio

as above, (41.5/(41.5+3.3) = ) 93% will be used as fuel and 7% will be

re-refined. About one half of the re-refined oil will be lost to the

environment and the other half will be used as fuel, so the effect of the

regulation will be to divert about 96.5% of the 8537 pounds per year of

PCBs used on roads to fuel use. Since many of the boilers using this oil

may not meet the criteria established for high efficiency boilers, perhaps

2% of the PCBs in the waste oil will not be destroyed. Therefore, the

total amount of PCBs that will be destroyed in the boilers rather than

applied to roads will be (8537 pounds PCB per year x .965 diverted to fuel

use x .98 destruction efficiency = ) 8073 pounds PCBs per year. The actual

amount diverted to the environment may be lower if the controls on the

disposal of transformer oils and contaminated industrial oils decreases the

amount of PCBs in the remaining waste oil.

*Table 13.1-1.

121
13. 6 SLllTIl!lary - Economic Impacts

Compliance Costs

Poad Oi1 - increased costs of

virgin or synthetic material

(first several years)

Poad Oil - increased cost of

obtaining adequate supplies of

segregated used rrocor oil after

level of !?CBs in used rotor oil

drops below detectable lL~its.

$0 to 31.7 million/year

$0 to $6.4 million/year

13.7 Cost Per Pound of PCBs Kept from the Environment

Cos t per pound =

o to $31.7 million per year =

8073 pounds/year

a to $3925 per pound !?CBs

122
14. 0 PCES AS (.JNINTENTIONAL PRODUCT COGi'TAfllIINA.l\ITS

14.1 Current Production

There are a nu~ber of commercial chemical processes which

produce PCBs as an unintentional b~oduct in concentrations over 50 ppm.

These include the proJuction of two classes of pigments, a new aluminum

smelting process, and several other proprietary chemical processes.

Phthalocvanine pigments: Phtha.Iocyanine blue and green

pigments are produced in tv.o steps. * The first step is the production of

crude pigment using, in most cases, trichlorobenzene as a solvent.* In

this instance, a side reaction involving the trichlorobenzene is the source

of the PCBs. The crude is then further processed to produce a number of

different blue and green pi~nents. In 1976, production and imports of

phthalocyanine blue and green pigments were 13,200,000 Ibs* with a value of

roughly $87.6 million. Testing indicates that the majority of this type of

pigment is conta~inated with over 50 ppm PCBs, though there is considerable

doubt concerning the validity of the test lnethod which was used.**

Currently, the only major domestic crude manufacturer which

does not use trichlorobenzene as a solvent is DuPont.*** They reportedly

use kerosene and have developed pigments based on the properties of the

crude they produce. In addition, Phthalchem uses a mixed solvent system

wnich has trichlorobenzene as one of the components. Testing indicates

that this crude may be contaminated below 50 ppm; again, however, the

analytical method has not been validated.

*"Main Canments of Dry Color Hanufacturers Association " dated August

7, 1978, p. 16.

**Testimony of the Dry Color Manufacturers Association at the PCB

Manufacturing, Processing, Distribution in Canmerce, and Use Bans

Hearings, Washington, D.C. August 30, 1978.

***Oral cest.inony of Arthur Hopmeier, (Phthalchem Inc.), at the PCB

Manufacturing, Processing, Distribution in Commerce, and Use Bans

Hearings, Washington, D.C., August 30, 1978.

123
Imports of blue crude, primarily from Japan, supplied over 56%

of the U.S. market in 1976.* In addition, low-PCB crudes are currently

available in canmercial quantities from at least one Japanese supplier.

This is a recent development, and any increase in demand for this product

could not be met for roughly a year.** Also, (Ilr. MacD:mald Smith of Sun

Chemical testified that this low PCB crude was of inferior quality.***

Diarylide pigments: Diarylide yellow, orange, and red pigments

are made by reaction of precursors which include dichlorobenzidine as an

essential component. A minor side reaction results in the decomposition of

G~e dichlorobenzidine to produce 3,3'- dichlorobiphenyl. 

Sales of diarylide pigments in 1976 were about 9,760,000 pounds

with a value of $41 million.** ** There are currently no substitutes for

the diarylide pigments, which are used in printing ink, textile ink,

plastics, and paints. In 1969, diarylide yellow (the diarylide with by far

the highest production) accounted for 84% of all yellow pigments produced

in the United States. 

Aluminum smelting: Alcoa has developed a new smelting process

which inadvertently produces over 50 ppm of decachlorobiphenyl.** *** The

PCBs are produced in a preliminary step involving the production of

aluminum chloride through the reaction of alumina with chlorine in the

presence of coke. 'TIle PCBs and other contaminants are removed in the

second step, which is the electrolysis of the. aluminum chloride to produce

metallic alu~inum.

*Oral testimony of Arthur Hopmeier, (Ph thal.chem Inc.) at the PCB

Manufacturing, Processing, Distribution in Camnerce and Use Bans

Hearings, Washington, D.C., August 30, 1978

**L€tter to EPA from W. C. Parle, (Hamon Colors) July 11, 1978.

***Oral comments of Hugh MacDonald Smith (Sun Chernical Corporation) at

the FeB Manufacturing, Processing, Distribution in Camnerce and Use

Bans Hearings, Washington, D.C., August 30, 1978, p.107.

 "Hain Canments of Dry Color Manufacturers Association ... II dated

August 7, 1978, Table 3.

** ***Information on this alurrunum ,smelting process and the resulting PCBs

was taken from the letter from James S. Boyt (Alcoa) to EPA dat.ed

October la, 1978.

124
This process has several advantages over conventional aluminum

smelting. These benefits include elimination of fluoride enissions,

reduced energy consumption, and improved product purity. The energy

savings possible with this process are considerable. Conventional smelting

requires 8 KW11 per pound of alurninum produced. This new process requires

4.5 ~iJH per pound, a savings of nearly 44%. Using these figures, a 300,000

ton per year smelter could save up to 1.95 million ~~ per year.*

I

In addition, the production of the aluminum chloride in the above

process has a nlli~er of energy and process advantages compared to

conventional alwninum chloride production methods.

Other chemical processes: Phillips Petroleum and Dow Corning,

both have chemical processes that produce over 50 ppn PCBs. 'Ihe Phillips

process is still experimental and apparently involves the use of PCBs as a

chemical interrnediate.** Dow Corning states that during the production of

a chemical intermediate, PCBs, apparently largely monochlorinated biphenyl,

are produced at levels between 50 and 500 ppn.*** Tennessee Eastman also

had a chemical process that produced over 50 ppn PCBs.   However,

Tennessee Eastman subsequently advised EPA that it had rrodi f i ed its process

and "because of these rnodifications, the only time a concentration of PCB

in excess of 50 ppm occurs is after processing to concentrate and di~pose

of the PCBs, as specifically contemplated at 43FR24805 ..... n** ***

Polychlorinated terphenyls (PCTs) fonnerly produced by r/bnsanto

are known to have been contaminated with over 50 ppn of PCBs. The only

uses of Pe'Es discussed at the hearings were a number of applications in

microscopy. 'Ihis use has been authorized. Similar applications involve the

use of certain Aroclor~. These uses have also been authorized.

*I.etter to EPA from .James S.Boyt (ALCOA) dated October 10, 1978.

**Letter to EPA fran Phillips PetrOleum Co. dated }l,.ugust4, 1978.

***I.etter to EPA from Jack Pulley (Dow Corning Corporati.on) dated October

10, 1978.

 I.etter from J. C. Edwards (Tennessee East~n Company) to EPA dated

August 7, 1978.

** ***I.etter from Elliott Stern (Tennessee Eastman Company) to EPA dated

DecEmber 21, 1978. (Letter in record of TSCA Exemption Docket; m.

1)

125
14.2 Requirements of the PCB Ban Regulations

It is assumed here that none of the operations described above

quali fy as be ing "in a totally enclosed manner." Therefore, the

manufacture, processing, distribution in commerce, and use of any chenical

containing over 50 ppm PCBs (including phthalocyanin and diarylide pigments

ana the products of the Alcoa smelting process) are banned 30 days after

the date of promulgation of the PCB Ban Regulation except in those cases

specifically exempted by EPA.

14.3 Economic Impact

Pigment Manufacturers: 'rhe impact the ban regulatiops will have

on these manufacturers who produce products contaminated with low levels of

PCBs will depend on the actions taken by the EPA in response to pati tions

for exemption from the regulation. For the purposes of thi$ analysis, an

upper bound economic impact will be estimated assuming that no exemptions

are granted before enforcement of the regulations begins. A lower bound

economic impact will be estimated assuming that all exemptions are granted

by the EPA. Tnis second assumption also presumes that , where necessary,

exemptions for processing and distribution in caronerce will be granted.

The Interim Procedural Rules for Polychlorinated Biphenyls (PCB's) Ban

Exemption (EPA, 1978d)*, state that only petitions from those affected by

the manufacturing ban will be considered. Therefore, separate petitions

will be required for processing, distribution in oamnerce, and use

exemptions.

*EPA. 1978d. "Part 750 - Procedures for Rulemaking

Toxic Substances Control Act: Interim Procedural

Polychlorinated Biphenyls (PCB IS) Ban Exemption. II

November 1, 1978, pp. 50905-50907.

126

Under Section 6 of the

Rules for

Federal Register,
The processes in use by Dow Corning, Alcoa, and Phillips

Petroleum must cease 30 days after the rule is promulgated unless EPA has

granted or is considering a petition for exemptions (EPA 1978d). The small

amount of economic data available are insufficient to support an estimate

of the Lnpact this will have.

Upper Bound Estimate: There are three companies that manufacture crude phthalocyanine blue using trichlorobenzene as a solvent; they

are American Cyanamid, Chemtron , and Phthalchel1. * Phthalchem uses a mixed

solvent systen which has trichlorobenzene as one of the components; the

others use pure trichlorobenzene. Dupont uses kerosene; Hercules Powder

and Thomasett use a dry process. The crude produced by each of these

comPanies may contain over 50 ppn PCBs although Phthalchem pigment has

consistently shown less than 50 ppm PCBs.** In the absence of a valid

analytical method for determining PCB levels in this material, however,

this study will assume that all three companies must rrDdify their processes.

to comply with the regulations. Kerosene appears to be the most feasible

solvent to replace trichlorobenzene. Mr. Arthur Hopnei er' of Phthalchem

testified that it would require 12 rronths and cost roughly $250,000 for him

to modify his plant.** Mr. Paul Malchick testified that the two Chemtron

plants could be converted to the use of kerosene solvent for a total cost

of $1, SOD,000 but that considering the age and condi tion of Chemtron ' s

*Letter from Arthur Hopneier (Phthalchem Inc.) to EPA - August 4, 1978.

**Testimony of Arthur Hopneier (Phthalchem Inc.) at the PCB i'ltanufacturing,

Processing, Distribution in Commerce, and Use Bans Hearings,

Washington, D.C., August 30, 1978.

127
equipnent, it woul.d be econanically sounder for them to spend $5,000,000 to

construct a new plant. * They would also attempt to purchase Low-K'B crude

fran Japan in order to meet their needs during the 24-30 rronths necessary

to construct this plant.* Purd1ase of the required 3 million pounds of

crude per year ~ould cost roughly $4.5 million. No data were given by

American Cyanamid. Based on (1) a Cherntron estimate of $750,000 to convert

each of their aged plants and (2) Mr. Hopneier's estimate that Phthalchem's

plant would require less to convert than other plants,** the cost for

American Cyanamid is estimated at $500,000. The total .cost for plant

conversion is:

$250,000 + 51,500,000 + 8500,000 = $2,250,000

In addition, Hamon Colors produces either a special crude or

further processes purchased crude in trichlorobenzene to produce a

phythalocyanine pigment which contains 575 ppm of PCBs. This pigment is

used by the autanotive industry and its manufacture has been authorized by

the State of Michigan. It would cost Hamon Colors roughly $2 million to

construct a new plant capable of prOducing this pigment in an alternative

solvent. ***

Four ~npanies presented information which indicates :th~t they

may be producing diarylide pigment with PCB levels in excess of 50 ppm.

They are: (1) Cherntron, (2) Pope, (3) Ridgeway Color and Chemical, and (4)

Sun Chemi cal , It appears that the diarylide pigments could be produced

with less than 50 ppn PCBs if roue process modifications were made. There

are some estimates on the cost of adjusting the w~nufacturing process to

reduce the concentration of PCBs. ttr. Paul Malchick of Chentron estimated

that it would cost $50,000 to modify their manUfacturing and, because the

process modifications wil.l, put them out of canpliance with their.):IPDES

*Testimony of Paul Malchick (Cherntron) at the PCB Manufacturing,

Processing, Distribution in Commerce, and Use Bans Hearings,

Washington, D.C., August 30, 1978.

**Testimony of Arthur Hopmeier (Phthalchem Inc.) at the PCB l<lcmufacturinQ,

Processing, Distribution in Commerce, and Use Bans Hearings,

Washington, D.C., August 30, 1978.

***Letter to EPA from \~. C. Parle (Harmon Colors) dated July 11, 1978.

128
permit, an additional $250,000 will be required.* Two other canpanies

estimate their cost for complying with a 50 ppm limit as follows:**

Canpany

1

2

Initial Capital Cost

$750,000

$200,000

Increased Annual Operating Expense

$250,000

$375,000-500,000

Three of the four companies listed would have an average

conversion cost of $333,000. If this average is used as the cost for the

fourth company, the total conversion cost could be $1.33 million.

Increased operating costs may amount to $345,000 per canpany.** Although

some types of diarylide pigments already contain less than 50 ppn FeBs, one

to two years will be required to reduce the level of PCBs to below 50 ppn

in all of these pigments.**

The manufacturing cost estimates for both types of pigments

include only those costs directly attributable to plant conversion and to

increases in operating costs. If the manufacturers are forced to cease

production of all pigments that contain over 50 ppn FeBs, there will be

additional costs associated with lost production and future loss of

customers who convert to substitutes or foreign suppliers. There may also

be costs associated with the disposal of contaminate] pigments presently in

inventory. TI1ere is not enough data in the official record to support an

estlinate of these costs, but the data which are present deseDTe attention

and seem to indicate that these additional costs could substantially exceed

the conversion costs.

*Testimony of Paul Malchick (Cherntron) at the FeB Manufacturing,

Processing, Distribution in Commerce, and Use Bans Hearings, Washington,

D.C., August 30, 1978, p. 126.

**Letter to EPA from Donald Morgan, (Dry Color Manufacturers Association)

dated August 7, 1978.

129
In 1976 ,production and i.mport s of phthal.ocyani.ne blue totaled

13,200,000 pbunds* with a value, after processing into pigments, of roughly

$87.6 million. Import.s of blue crude (not pigment), primarily frau Japan

(85%), supplied over 56% of the U.S. market in 1976.** The majority of the

import s are high-PCB crude. IDw-PCB crude is being produced in ,Japan, but

an increase in demand could not be met for a year.***

Sales ofdiarylide pigments in 1976 were 9,760,000 pounds with a

value of $41 million. In addition, roughly 275,000 pounds were

.import ed  

, .\

Sales for phthalocyanine and diarylide pigments in 1976 totaled

$131 million. Tbtal sales of all organic pigments in 1976 ~ere $261

million, compared with $200 million for inorganic pigments. ** **Thus, the

two classes of pigments in question account for over 25% of the domestic

market.

The percentage of the industry that would be forced to cease

production in response to a manufacturing ban is not known, but it is

estbnated to be closer to 50% than to 10%.***** This implies that up to

one quarter of the domestic organic pigment producing industry would have

to close down. In addition, a company that can no longer produce yellow

and/or blue pi~nents may lose other portions of its sales because

"customers demand a full line of colors. n**** The minimum conversion time

given at the hearings was 12 months, so in the event an exemption is not

granted, domestic manufacturers would be affected for at least 6 months and

would not be back to full capacity for 18 rronths, Tne pot.enti a.l for substitution of different pigments types and the ease with which production of

low- or non-l?CB pigment could be expanded are not known, but it does appear

*Letter to EPA frem Arthur Hopneier (Phthalchem) August 4, 1978.

**Testirrony of Arthur Hor:meier at the PCS Manufacturing, Processing,

Distribution, and Use Bans Hearings, August 30, 1978.

***Letter to EPA fran W. C. Parle (Harmon Colors) July 11, 1978.

 nHain Comments of Dry Color Manufacturers... " dated August 7, 1978.

** ***Testirronyof Donald Morgan (DCMA) at the PCB Manufacturing,

Processing, Distribution in Commerce, and Use Bans Hearings, August

30, 1978.

130
that unports could not immediately fill any shortages. However, the

available information indicates that extensive ink, dye, and paint

reformulation will be required, equi pnent; may require modification or

replacement, and printing quality will suffer.

There could be additional costs once domestic manufacturers

begin producing low- or non-!:CB pigments. In those cases where process

modification rather than solvent substitution is used, it may be necessary

to test each batch of pigment for !:CBs as it is produced. Chemtron states

that they have made process modifications that reduce the PCB concentration

to low apparent levels but that there may be occasional batches with higher

concentrations due to mechanical failure or operator error.* In addition

to the testing, production of a batch with over 50 ppn vould be illegal

production which could be Subject to a poasib.Ie fine. The lowering of the

permissible limit from 500 tp 50 ppm !:CBs \>.Ould result in the disposal of

additional batches of pigment.

Lower bound estimate: The lower bound estimate assumes that the

following eight "pigment" canpanies will individually apply for (and will'

receive) exemptions:

American Cyanamid

Ap::>llo Colors

cnemtron

Harmon Colors

Phthalchem

Pope

Ridgeway Color and O1ernical

Sun Chanical

*Ietter fran Paul Malchick (01emtron) to EPA dated August 3, 1978.

131
It is also assumed that each ccmpany will apply for t'M::)

exanptions: one for manufacturing and one for processing and distribution

in conmerce .

Preparation of the required petition and attendance at the

hearing may require one man-week per conpany, Considering that, due to the

importance of the issue and the legal aspects involved, much of this work

is usually handled by lawyers and higher level canpany officials, a labor

rate of $200/day will be assumed. In addition, total travel expenses of

$600 for two people per ca:npany will be assumed. The total expense for the

eight companies listed using the above figures is $19,200.

If EPA grants the manufacturers ill1 exanption fran t~e

"manufacturing," "processing," and "distribution in ccmmerce" bans, the

pigment that is manufactured could only be used to formulate. inks, etc., if

the purchasers were in tutTI exempted fran the "processing" and "distribution in carunerce" bans. Further, since the inks will contain PCBs at

levels below 50 ppn because of dilution of material containing rrore than 50

ppm PCBs, all material containing the pigments will have to be labeled as

"PCBs," and t.he users will require exemptions from the "use" ban.

There is no information in the record that suggests whether EPA

will consider class action petitions for exemptions, or that would suggest

how EPA may handle the labeling prob.Iem, Therefore, no est.imat;e can be

made of the resulting economic impacts of these provisions of the

regula tions.

Other ch~micals: No information exists in the record to support

any estimate of the liupact of the ban regulation on canpanies such as Alcoa

and Low Corning that are inadvertently manufacturing :R::Bs in chemi.ca.l's

other than dry pigments. These chemical processes will be subject to the

same ban provisions or, alternatively, the need to obtain exemptions from

the manufacturing, processing, distribution in commerce, and use ban

regulations as described above for dry pigments•

.u~
14.4 PCBs Controlled by the Reoulation

Pigments: Data reporced by Sun Chemica.l Corp. suggests that the

average PCB concentration in diarylide pigments is 95 ppm and in

phthalocyanine pigments is 170 ppm.*

'Ibtal annual sales of the phthalocyanine pigments are 13.2

million pounds of which 56% is Import.ed (most from Japan) . ** The rest is

made in the U. S. by six manufacturers, three of which use trichlorobenzene

and presumably have problems with PCB contamination. If the six

manufacturers have equal lnarket shares, the total PCBs in the production of

the three that use trichlorobenzene would be (13.2 million pounds pigment

per year x .44 u.S. market share x .5 share from companies with PCBs in

product x 170 ppn PCBs = ) 544 pounds PCBs per year.

'Ibtal annual sales of dairylide pigments are 9,760,000 pounds,

all of which is contaminated with 3,3' - dich1orobipheny1 at an average

concentration of 95 ppn, .Reduction of this concentration to 50 ppn by

required process changes would reduce the amount of PCBs entering the

environment by (9,760,000 pounds pigment x (95 ppm - 50 ppm) = ) 441 pounds

per year.

Other chemicals: NJ information is available to support; any

estimate of the total production of PCBs in other chemical processes.

14.5 Summary-Economic Impacts

Upper Bound:

Conversion Cost

Increased Annual

Operating Costs

A.dditional

Costs

Phthalocyanine pigments $4,250,000 l'b dat.a NJ data

Diarylide pigments 1,330,000 345,000 ' t-b data

Aluminum smelting

Chemical manufacturing N::> data l'b data l'b data

*A.ppendix E to "Hain Canrnents of Dry Color Manufacturers Asoociation.•.. II

dated August 7, 1978.

**Letter from Arthur Hopneier (Phthalchetll Inc , ) to EPA dated August 4,

1978.

133
IDwer Bound:

Exemption applications

Aluminum smelting

Chemical manufacturing

$ 25,600

data tb data· data

14.6 Cost Per Pound of PCBs Kept from the Environment

Phthalocyanine pigrr~nts $425,000/*7ear _ 544 poundsyear - $781 per pound PCBs

Diarylide pigments $133,000* + $34S,000/year = 441 pounds/year $1084 per

pound PCBs

*Ten dollars as initial expense is equivalent to continuing annual costs of

one dollar discounted at 10%.

134
15 . 0 SPI u, MATERIALS: 50 ppn TO 499 ppn PCBs

'The change in the definition of "FeB" from 500 pfln to 50 ppn will

require that materials such as dirt that are contaminated with PCBs in this

, concentration range will have to be picked up and buried in an approved PCB

landfill. 'There is no information in the record that can be used to

estimate the total additional volwne of material that will be transported

to these landfills as the result of this change in the regulation.

Disposal of PCB contaminated material in approved landfills has been

r eport.ed to cost $3 per cubic foot (Versar 1977, p. 3-7) and t ransport.ation

to these facilities will cost an additional $2 per cubic foot (Versar 1977,

p. 3-19). If the spill material covered by this regulation is assu.~ed to

be contaminated with 275 ppm PCBs, the cost of disposal will be ($5 per

cubic foot/(lOO pounds per cubic foot of dirt x 275 ppm PCBs) = ) $182 per

pound of PCB. This figure could be lower in some cases if EPP>. approves

alternative disposal methods in response to specific petitions for

exemption from this portion of the disposal regulation.

135
16.0 CAPACITOR MANUFACTURING

16.1 Present Use of PCBs

PCBs were used as the dielectric liquid in almost all

paper/foil and film/foil A.C. electric capacitors Inanufactured prior to

1976. 'The primary types and uses of PCB capacitors are listed in Table

16.1-1.

substitutes for PCBs have been developed by the capacitor

manufacturers in anticipation of the ban on the wanufacture and processing

of PCBs. No PCB power factor capaciGJrs were manufactured after late 1977,

and there are no PCB capaci tors of this type known to remain in

manufacturers' inventories (Versar 1978, p. 99). A survey of manufacturers

of industrial capacitors indicated that five comp&~ies (Lepresenting a 54%

share of the ffiaLket in 1976) were planning in mid 1977 to continue using

PCBs into 1978 but to discontinue manufacturing PCB capacitoLs during 1978

(Versar, 1978, p. 103). 'I\vo of the manufacturers have provided additional

data on their use of PCBs during 1978 and on expected inventories of PCB

capacitors. Aerovox (24% market share) planned to stop using PCBs on

September 9, 1978, and expected an inventory on October 1 of less than

100,000 PCB capacitors.* Universal t'1anufacturing Co. (13% market share)

has estimated that its inventoD] of capacitors at the end of 1978 will be

approximately 800,000 items which cost about one million dollars to

manufacture. In addition, Universal will have an inventory at the end of

1978 of at least 500,000 completed ballasts which cost about $2,500,000 to

make.**

*Letter from Clifford Tuttle (Aerovox Industries, Inc.) to EPA dated

August 15, 1978.

**Oral comments of N. Ray Clark (Universal Manufacturing Corporation) at

the August 29, 1978 hearing on the proposed PCB Ban Regulation.

136
Table 16.1-1

Major Tyf€s a~d Uses of PCB Capacitors

Power Factor Correction

Industrial Capacitors

Motor Control

Ballast

Slectronic

Estimate

1976 Sales*

$54.5 million

$94.5 million

Use*

Used by electrical

utilities in high voltage

power distribution

systems.

Used as part of large

single phase A.C. motors

(air conditioners, etc.).

Used as a component; 0 f

ballasts for fluorescent

lights and high intensity

discharge (i.e., ~ercury

arc and sodi um arc)

fixtures.

As part of the circuitry in

some 'IV sets, microwave

ovens, computers, etc.

*Source: Versar, 1978, pp 97-98.

137
16.2 Requirements of the PCB Ban rtegulation

Manufacturing: The regulation bans the manufacture of PCB

capacitors.

Distribution in Commerce: PCB capacitors and new equi~nent

containing PCB capacitors may not be sold (i.e., distributed in

commerce) after .July 1, 1979.

16.3 Cost Impacts of the PCB Ban Regulation

Manufacturing ban: The economic impact analysis of the

proposed PCB regulation esti.mated that non-PCB power factor capacitors

woul.d cost 10% to 20% more than feB capaci tors having the same performance

characteristics and that the cost of industrial capacitors v.Duld increase

15% to 20% because of the change from PCBs to other dielectric fluids,

(Versar, 1978). The only additional information that has since become

available is the testirrony of Ray Clark who suggested that "perhaps in the

overall, simply based on the difference of dielectric constant (of the

non-PCB dielectric fluid) the non-feB industrial capacitors should cost

rrore on the order of five to seven percent. n* Based on 1976 industry sales

(Table 16.1-1), annual cost increases due to the banning of the manufacture

of PCB capacitors would be expected to be (10% to 20% of $54.5 million =

$5.5 million to $11 million for po\~r factor correction capacitors and (7%

to 20% of $94.5 million = ) $6.6 million to $13.9 million for industrial

capacitors. 'Ihese estimates should be increased by perhaps 15% to

compensate for inflation during 1977 and 1978. Since the use of small

capacitors is expected to grow rapidly over the next few years because of

federally mandated irnprovsnents in the electrical efficiency of appliances,

the total demand for capacitors and the total increased costs resulting

from the ban on the use of PCBs may be greater than these estlinates based

on historical sales data.

*Oral comments of N. Ray Clark (Universal Manufacturing Corporation) at the

August 29, 1978 hearings.

138
Ban on Distribution in Comnerce: The demand for PCB capacitors

remaining in manufactures's inventories at the end of 1978 is likely to be

extrsnely limited because the regulation bans the sale of these capacitors

or new equipnent containing PCB capacitors after June 30, 1979. rne

inventory losses incurred by the companies that use 9nall capacitors in tl1e

manufacture of appliances and equipnent is discussed in detail in

Chapter 3.

The maximwn inventory losses incurred by the manufacturers of

PCB capaci tors woul d occur if all capacitors remaining in inventory at the

end of 1978 were scrapped. If all of therrBnufacturers who used PCBs in

1978 had the same expected inventory losses as that percentage of annual

sales anticipated by Universal, total inventory losses would be (.54 market

share for all affected capacitor manufacturers/.13 Universal market share)

x $1,000,000 Universal inventory loss = ) $4.15 million. However, the

actual loss will probably be lnuch less than this because Universal was the

last company to phase out the use of PCBs and because some opportunities

may exist during the first six months of 1979 to dispose of this inventory.

'Therefore a reasonable estimate of inventory losses Inay be in the range of

$1 to $2 million, all oC0Jring during 1979.

16.4 PCBs Controlled by the Regulation

'lbtal consumption of PCBs by the capacitor manufacturing

industry was 21 million r~w1ds in 1975 of \~ich 45% was used in large high

voltage power factor capacitors and 55% in industrial, lighting, and

appliance capacitors (Versar 1976a, p. 6).

Most large high voltage power factor capacitors do not ruptUl;e

upon failure, and only 20% to 25% of the PCBs escape to the envirorunent

from those that do rupture. If it is assumed that 10% of the capacitors

rupture on failure, the total amount of PCBs entering the envirorunent from

each year's production of large high voltage power factor capacitors WJuld

be equal to (21 million pounds per year PCBs x 45% in power factor

capacitors x 1% rupture on failure x 15% PCBs lost on rupture = ) 14,200

pounds PCB per year.

139
of small capaci tors woul.d be equal to (21 million rounds PCBs x 55% in

small capacitors x 0.4% ruptured in use x 15% leak out = ) 6930 pounds per

year. n1e rest of the PCBs It.Ould be disposed of in municipal landfills.

There is no information in the record to support an est irnat.e of how

Only 0.4% of the small capacitors are assumed to rupture in use

(Chapter 3). If 15% of the PCBs leak out of these ruptured capacitors, the

total amount of :?CBs entering the environment fran each year's producti.on;'1'"

much may leach out of the landfill, but it is expected to be low due to

the absorptive capacity of the surrounding material.

16.5 Summary - Economic Impacts

Increased cost of non-PCB power factor capacitors: $5.5

million to $11 million per year.

Increased cost of non-PCB industrial capacitors: $6.6 million

to $18.9 million per year.

Inventory losses incurred by manufacturers of PCB industrial

capacitors: $1 million to $2 million (1979 only).

16.6 Cost Per Pound of PCBs Kept from the Environment

Power factor capacitors

$5.5 million to $11 million per year

14,200 Ib/year = :;;387 to $775 per

fOund PCBs

Industrial capacitors

= 6 million to $18.9 million per year

6930 pounds per year $950 to $2750 per pound

140
17.0 l3AL'J ON THE MANUFACI'URE OF NEW PCB TRANSFORMERS*

Liquid filled transformers containing a PCB based liquid known

generically as "askarel " have been used for ma.ny years in those installations where the risk of fire justified the use of a fire resistant fluid.

Askarel transformers have been allowed in hazardous locations such as inside buildings without the requirement for a fireproof vault or fire

sprinklers. No substitute transformer liquids have yet been develcped

whicn have fire resistant prcpertiesequal to the PCB based aska rel ,

17.1 Requirements of the Regulations

The regulations prch ibit the manufacture of new PCB transformers

after December 31, 1978, but classify continued use of existing PCB transfonners, except those used in railroad locomotives, as use in a totally

enclosed manner. The regulations authorize certain minor maintenance of

existing transformers but prd:1ibit major rebuilding of failed units. The

impacts of the regulation on the servicing and rebuilding of askarel transfonners is discussed in detail in Chapter 4. Disposal requitements for

failed askarel transformers are specified by the PCB Marking and Disposal

Regulations, and these requirements are not being changed by the PCB Ban

Regulations.

17.2 Industry Structure, Production, and Sales

Monsanto's customer list for PCBs in the early 1970s included

thirteen companies that used PCBs to ma.nufacture askarel transfonners.

'Ihese conpanies and the location of their transformer ma.nufacturing plants

*'Ihis chapcer is repeated with minx manges fran Veraar, 1978. The EPA

promulgated without change the proposed regulations that affect the

manufacture of new PCB transformers.

141
are listed in Table 17.2-1. Production of askarel transfonners averaged

5000 units per year in the early 19705 (Versar 1978, p.109). when these

canpanies were contacted by Versar in Septenber, 1977, only one manufacturer was still producing askarel transformers, and it planned to stop

production of this Dipe of unit before the end of 1977 (Versar 1978,

p.109). All of these manufacturers produced both oil-filled and askarel

transformers in the same plants. Oil-filled transformers ar-e i nt ercham-'

able with askarel tr-ansfor.mers in new applications provided the installation is properly engineered. Other substitutes for askarel transformers

are also available. The 140,000 askarel transformers presently in service

are only two percent of the total number of power and distribution

transformers in use (Versar 1978, p.lll).

17.3 Substitutes for PCB Transformers

The askarel transformers presently in service were specified

because this type of liquid-filled transfor.mer- offered advantages in size,

reliability, and fire safety that were not available with other types of

transformers. Alternatives to PCB transformers have always been available,

although all of the other types of transformers have different design

characteristics and none are direct substitutes for the PCB units. Therefore, eventual replacement of the existing PCB transformers will require

that each of the present installations be re-evaluated and that the

necessary engineering changes be made to allow use of the best available

replacement unit. New transformer installations will be designed to rrake

opt i um use of the available non-PCBs t ransf'orrners, The choice arronq the

available alternative transformer types and materials depends on the requirements of each specific applicaiton and the characteristics of the

available non-PCB units.

142
Tabl e 17. 2-)

U.S. Transfonner Manufacturers That Used PCBs After 1970

Comoany Name

Nestinghouse Electric Corp.

General Electric Cormany

Research-Cottrell

Niagara Transformer Co.

Standard 'I'ransforrne r Co.

Helena COI::p.

Hevi-Duty Electric

Kuhlman Electric Co.

Electro Engineering ~~dks

Envirotech Buell

R.E. Uptegraff !'lfg., Co.

H.K. Porter

Van Tran Electric Co.

Source: Versar, 1976a.

143

Plant Location

South Boston, Va.

Sharon, Pa.

Rome, Ga.

Pittsfield, Mass.

Finderne, .N.J.

Buffalo, N.Y.

Warren, Ohio

Medford, Oregon

Helena, Alabama

Goldsboro, N.C.

Crystal'Springs, V~ss.

San Leandro, Calif.

Lebanon, Pa.

Scottsdale, Pa,

Belrront, Cal i.f,

Lynchburg, Va.

Vandalia, HI.

Waco, Texas
Anwnber of alternatives to the use of PCBs in fire resistant

liquid-filled transformers and to the use of transformers that contain any

dielectric liquid have been developed and are commercially available.

These substitutes for PCB transformers differ in their performance characteristics, applicable fire code installation requirements, and cost. The

following sections discuss the major types of substitute units that are

available.

Non-PCB askarel transformers: Askarels are defined in the

National Electrical Code as non-flammable chlorinated hydrocarbon liquids.

Although all askarel liquids used in the past have been based on PCBs,

there is no requirement that PCBs be present. General Electric is presently testing a non-PCB askarel that is a combination of trichlorobenzene,

tetrachlorobenzene, and a hydrocarbon (either isopropyl biphenyl or terphenyl). GE plans to market this material in 1979 under the trade name

Iralec®, if present transformer service tests are successful, and estimates

that the price will be about one-half that of silicone.*

If Iralec® does prove to be a direct substitute for PCB based

askarel, there may be: no additional costs incurred by the banning of the

use of PCBs in new transformers.

High fire point liquid insulated transformers: The 1975

National Electric Code (NEC) and previous issues allowed only the use of

askarel and dry type .transformers in hazardous locations without vault

protection. Askarel was essentially defined as a PCB based 1iqu i d, 'The

1978 NEC has added a specification (Article 450-23) for "high fire point

liquid insulated transformers" which can be used under these sane conditions (Versar 1978, p.lll). The high fire point liquid must have a fire

point of at least 300°C, and must not propagate flames.

*Information presented by GE at a meeting with EPA Office of Toxic

Substances, June 21, 1978.

144
Underwri ters Laboratory presently 1ists three 1iquids as

meeting the high fire point property requirements for transformers operati.nq at vo l t aqes beIow 600v (Versar 1978, p.1l2):

[X)W Cornirq 561

General Electric SF-97 (50)

SWS Sillcones Corp. F-190

Factory Mutual Research has not yet completed developing formal

approval requirements and procedures for high fire point transformer

liquids. However, based on preliminary tests, Factory Mutual has issued

interim guidelines to its field offices which allCN-l six silicone liquids

and three hydrocarbon liquids at Factory Mutual insured locations without

special fire protection. The list of Factory Mutual accepted liquids

includes the follCN-ling (Versar 1978, p.1l2):

Supplier Designation 'l.)J?e of Fluid , i

I:X:JW Corni nq DC 561 Silicone

f.X:JN Corning DC 200 Sil icone

GenenU Electric SF-97 Silicone

Union carbide L-305 Silicone

SWS Silicohes F-lOl Silicone

SWS Silicones F-190 Silicone

Rl'E Corpo ration RTEmp Hydrocarbon

Gulf Oil O1emicals Co. RP Dielectric Hydrocarbon

Fluid

Uniroyal PAo-20E Hydrocarbon

145
Mineral oil-filled transformers: If fire safety were not a

consideration, there would be no reason why oil-filled transformers could

not be used in all applications. In the past, PCB-filled transformers have

cost about 1.3 times as much as oil-filled units of the same capacity, and

thus most users preferred the oil type where possible (Versar 1978, p.lI2).

The oil-filled transformers are the same size as the askarel units and are

considerably lighter in weight. Also, mineral oil has somewhat better heat

transfer characteristics than askarel, and an electric arc in mineral oil

results in breakdown products that are non-corros ive.

The major disadvantage of mineral oil is f Lammabil i tyr transformer mineral oil has a flash point of 145°C. If an arc occurs in the

transformer, the breakdcwn products will be hydrogen and methane, both of

which are flarnIn'1ble. Detailed records of such failures are maintained by

the electrical industry. Fire Underwriters does not approve of the use of

oils and other flammable liquids for indoor applications. Where oil-filled

transformers are not specifically prohibited as on-site replacements for

PCB-filled units, the National Electrical Code Umposes certain restrictions

upon their rrode of installation.

Oil-filled transformers are used in almost all power transformer

applications and for most substation distribution applications where the

transmission line high voltage is reduced to 12.8 kv for local distribution. Nost rural pole-mounted transformers that reduce the voltage to 220

volts are also oil-filled. The issue of flanunability only becomes Unportant where the distribution transformer must be buried, as in many urban

applications, or located close to, within, or on the roof of the building

it serves. PCB-filled transformers have, in the past, been used in most

such applications. Oil-filled transfonners can be used in these applications only if they are suitably isolated from flammable structures or if

these structures are suitably safeguarded against fires. When trans146
formers are located outside the bui Ldirq they service, the lew-voltage

power must be brought into the building via cables or insulated buses.

Additional energy losses are then caused by heating in the lew-voltage

transmission lines from the transformer to the point of use.

Qeen air-cooled transformers: Transformers can be built without

the use of a liquid cooli rq medium. One type of dry transfonner that is

quite successful, under limited conditions, is the open air-cooled transformer. In this design, coolinj air is driven through the transformer by

either natural convection or forced circulation.. In those sizes where

air-cooled transformers are available, they are about equal in price to

askarel-filled transformers of the same kVA rating. Hewever, open aircooled transformers are limited in both heat capacity (which limits their

ability to operate under occasional overload conditions) and dielectric

st r erqt.h (which limits the maximum voltage available).

The problem of electrical insulation is even rrore severe if the

open air-cooled transformer only operates intermittently. When the transformer is cper'atirq , the heat generated within the wi ndi rqs keeps the insulation dry and maintains a high dielectric strength in the solid insulating

material. However, when the transformer is not operating, the coils cool

to ambient terrperatures and the insulation can absorb moisture from the air

which reduces its dielectric strerqth, Open air-cooled transformers must

be thoroughly dried before being put into service after. each cool period.

One other problem with air-cooled transformers is the tendency

of dust to be attracted from the air to the coils by electrostatic forces.

Dust can build up in the coils and block the flow of air, or it can form

conduct ive paths and cause short circuits.

147
Open air-cooled transformers are generally lind ted to dry,

clean locations where the load ~equirernents a~e fairly even and constant

and where the maximum voltage does not exceed 30 kv , Such transformers are

being successfully used in large office buildings, particularly tall

buildings where the t ransformars are located every fav floor-s. Even in

this application, though, conditions arise that exceed the capabilities of

the transformer. For instance, in the Sears 'I'owe r in Chicago, which is

ove~ 1400 feet tall, the electric pc:wer- is br-ought into the building and up

to the distribution tr-ansformers at 128 kv , which is beyond the voltage

limitations of open air-cooled tr-ansformers (Versar 1978, p.llS).

Closed gas-filled transformer-s*: Tr-ansformer-s can. be built with

dry inert gas (usually at an elevated p~essur-e) as a heat tr-ansfer- medium.

These transformers avoid the maintenance pr-oblems caused by moistur-e and

dust in open air-cooled tr-ansformer-s, but they ar-e similarly 1irni ted in

ove~load capacity because of reduced thermal inertia corrpar-ed to liquidfilled transformers.

Closed gas-filled t ransformars must be installed in pr-essur-etight container-s because of changes in gas pr-essur-e caused by changes in

t enperat.ure, However, the maximum voltage r-atings of gas-f illed t ransfOLmer-s can be equal to these of liquid-filled units.

A number of differ-ent gases have been used as heat transfermedia in closed gas-filled t ransformers, The most camron gas used in the

U.S. is the fluorocar-bon hexafluor-oethane (C2F6)' Nit~ogen and sulfur

hexafluor-ide have also been used successfully in cer-tain applications.

Helium has not been found to be a satisfactory gas for this application

because its low dielectr-ic str-ength results in cor-ona discharges within the

transformer. Hydr-ogen is unsatisfactory because any leak in the transformer- would ~esult in a sever-e fire hazard.

*This section is repeated from Versar 1978, pp.llS-116.

148
Because of the necessity for a pressure vessel container, gascooled transfonners are 30 to 40 percent heavier than PCB-filled transformers and cost two-thirds more (and twice as much as oil-filled transfawners). In addition, the gas-filled transformers must be sized larger

than oil-filled units to allow for the expected heavy load peaks of power

consurrption.

17.4 Relative Prices of Non-PCB Transformers

The relative prices of distribution transformers of the size and

type commonly installed in office buildings are summarized in Table 17.4-1.

If the RTEmp® high fire point liquid-filled transformer proves to be

acceptable for installation without auxiliary, fire protection, there should

be no cost increases for new transformer installations resulting from the

ban on the manufacture of PCB transformers. The c:pen dry type transformers

are also quite cost competitive with the PCB units for most applications.

Table 17 .4-1*

Relative Transformer Prices

'I)(Pe o,f Unit

Oil-filled

PCB

Non-PCB askarel

Rl'Emp®

Silicone

q;>en air cooled

Sealed gas cooled

Price: 1000 kVA Unit

$15,300

19,900

19,000

18,400

22,300

20,700

30,600

Price: 2000 kVA Unit

$23,300

30,300

29,000

28,000

34,500

35,000

46,600

*Source: MGC Engineers, "Distribution Transformer Status - WIT Project."

Memorandum to U.S. General Services Administration, June 1, 1977, as cited

in Versar 1978, p.116.

149
17.5 Compliance Costs

Clean-up costs: The only costs incurred by transformer manufacturers resulting-from the ban on the use of PCBs will be clean-up and

disposal costs of f l.ushirq PCBs fran storage and material handli rq equipment before using this equipment to store high fire point· liquids. This

equipment consists prlinarily of storage tanks, filters, pumps, and piping.

Clean-up costs, including disposal of contaminated solvents, should not

exceed $10,000 per plant, or a total one time cost impact of perhaps

$100,000 in 1977 and 1978 (Versar 1978, p.117).

Cost of substitutes: The high fire point liquid cooled transformers and air-cooled transformers will cost about the same to 10% more

than askarel units depending on the acceptability of non-PCB askarels and

hydrocarbon base high fire point transformer liquids. Based on past sales

of 5000 askarel units per year at an average price of $20,000, a 10% cost

increase would increase sales and costs to the users by (5000 x $20,000 x

10% = ) $10,000,000 per year. There should be no effect on the demand for

transformers for new installations, and there may be an increase in the

demand for replacement transformers of 1000 to 2000 units per year. This

additional demand should be easily supplied since the transformer manufacturing industry has recently been operating at only about 60% of capacity

(Versar 1978, p.117).

Market structure should not be significantly affected because

all of the former manufacturers of askarel transformers will have equal

access to the high fire point transformer liquid materials and technology.

Access to this market segment will open to those transformer manufcturers

who did not offer askarel as an alternative to oil. This will primarily

afford a marketing opportunity to RTE Corporation which has never supplied

askarel units but which has a strong market position in the high fire point

liquid transformer area. The increased sales by RTE will probably be less

than the total increase in transformer sales, so this small shift in

150
!narket structure should not result in a net decrease in the sales by any of

the other manufacturers.

Increased fire losses: The presently installed R::B askarel

transformers were installed at a premium cost oanpared to oil-filled units

in order to achieve improved fire safety. 1'bt all of the substitutes for

PCBs have as good fire resistance. In particular, the high fire point

transformer liquids ca~ burn under certain conditions, including exposure

to an external fire, and can release flammable gases if an electrical arc

occurs within the transformer.

Various non-flammable substitutes for R::B askarel transformers

are available, including the various dry type units and non-PCB askarels.

Although these alternatives may cost lnore than the PCB units they replace,

they can achieve equal fire safety. 'Therefore, the banning of the manufacture of PCB-filled transformers is not expected to result in significant

increased fire losses.

17.6 PCBs Controlled by the Regulation

There is no infonnation in the record to support any estiInate of

the probability that PCBs used in askarel transformers will enter the

environment from accidental spills and venting of transformers. Venting

results in the loss of no more than 2% of the total fluid in the

transformer. However, good clean-up of spills should limit the total

losses to perhaps 5% of the total liquid vented. Use of R::Bs in

transformer manufacturing was about 12 million pounds per year in 1975

(Versar 1976a, p.6). 'Ihe ban on use of PCBs in new transformers will

prevent the loss of (2% x 5% x 12 million pounds =) 12,000 pounds of PCBs

into the environn1ent from each year's production of transformers.

151
17.7 Summary - Economic Impacts

Transitional Costs:

Clean-up costs for manufacturers

Long Term Costs:

Higher costs of non-PCB transformers

5100,000 1978 only.

$0 to $10 million

fer year.

17.8 Cost Per Pound of PCBs Kept From the Environment

Cost per pound = SO to $10 million per year -

12,000 pounds per year

$0 to $833 per pound PCBs

152
Y,

18 • 0 SUi-il'iiARY

18.1 Transitional Cost Impacts

Costs of decontaminating or scrappil~ existing equipment and the

ban on rebuilding of PCB transformers are all transitional costs. These

costs will end when the existing PCBs are finally removed from service.

The transitional cost ir~acts identified in this analysis of the impacts of

the PCB Ban Regulation (as dist inct from the previously promulgated PCB

Effluent Standard and the PCB Disposal and riJarking Regulat ions) are

summarized in Table 18.1-1.

18.2 Long Term Cost Impacts

The costs resulting fran the ban on the manufacture of PCBs wi l l

be continuing costs and will result in along term economic iJ~act. 1hese

costs include the additional cost of non-PCB capacitors and transformers.

Tne long term costs identified as resulting from the PCB Ban Regulation are

summarized in Table 18.2-1.

18.3 Cost Per Pound of PCBs Kept from the Environment

The effectiveness of the regulation in preventing the entry of

PCBs into the environment was calculated for each industrial segment if

sufficient data was available. These costs are stmrrar iz ed in Table 18.3-1.

153
Item (C!lapter) 1979

Table 18.1-1

Transitional Cost Irrpacts

$ Million Per Year

Succeeding

Years

$ Million

Total

Estimated

Reliability

of Total

PCB TransfOl.lT'l2rs:

Ivlanufacturer Clean Up Costs (l 7)

Ban on Rebuilding (4)

Lost Service Time

$ .1

9.6

2.4

o

**

**

$ .1

373 to 749

75

-50% + 500%

2:50%

2:50%

/-J

lJ1

..s::..

LocoTIDtive Transformers (5)

Retrofill Program to 6% Limit

Retrofill Program to 0.1% Limit

Analytical Costs

Conplete by Jan. 1,

1982

Ccrrp.Iet;e by Jan. I,

1984

Corrplete by Jan. 1,

1985

6.6 ~20%

5.15 2=.20%

.444 2:50%

1,000 0 1,000 -100% + 50%

These costs will be significantly reduced or eliminated if

EPA grants exerrptions from the "distribution in comrrerce" ban.

10*** 0 10

PCB Capacitors and Equipnent

Equiprrent Redesign (16)

Manufacturers' Inventory Obsolescence (16)

Ban on Sales of Equipment after July 1, 1979 (3)

Cost of Petitioning for Exerrptions

*

1 to 2 o 1 to 2 2:50%

*Data not available to support; estimate; probably snall cost irrpact.

**Costs will be incurred over 30 to 40 years, probably increasing slcwly for 10 years and then

decreasing slowly.

***May be si~1ificantly reduced if EPA accepts class action petitions.
I tern (Chapter)

Table 18.1-1 (Continued)

$ million Per Year

1979 Suceeding Yrs

$ million

total

Estimated

Reliability

of Total

Oil Filled Transformers (6)

Ban on Reclaiming Oil for Resale

Cost of Equipping High Efficiency Boiler

Cost of Approved PCB Incineration

Transformer Service (7)

Special Storage Areas

3.2 to

5.6

No data

o - 11.1

*

:3.2 to

5.6

o

o - 11.1

*

? No data on

duration· of

impact

? No data on -90% to 0%

duration of

impact

?No data on

duration of

impact

f-'

Ln

Ln

Mining Machines (8)

Rebuild waders

Scrap Continuous Miners

Storage Costs

Exerrption of Application

Electromagnets (9)

Ban on Rebuilding

Hydraulic Systems (10)

Testing

Retrofill

Disposal of Fluid 50-500 ppm PCBs

Marking

Ban on Recycling Fluid

Corrplete by Dec 31, 1.6 ±20% 1981

Complete by Dec 31, 1 to 2.6 +

-50%

1981

.01 0 .01 +-50%

.001 0 .001 ±50%

.1 .1 .96 +-20%

.5 to 1(1980-84 1.5 to 2.4 ±20%

1.4 total)

+

9.8-16.1 1..1.l)(lQ80 onlv) 10.8 to 17.6 -50%

by 1984

1.4 .2 (1980 only) 1.6 -80% + 20%

.05 0 .05 2:.50%

.3 to 1.7 o to 1. 7 .7 to 3.4 -80% + 20%

*Infonnation Not Available in Record to Hake estimate.
Item (Chapter)

Heat Transfer Systems (11)

Testing

Retrofill

Cost Savings - Disposal of Systems

Compressors (12)

Table 18.1-1 (Continued)

Estimated

$ million Per Year $ million Reliability

1979 Succeeding Yrs total of Total -

+

.045 to .06 .135 to .18 .18 to .24 -50%

5.1 to 6.8 9.9 to 13.2 15 to 20 +

-50%

(1980 only) (by 1980)

+

(2.4 to 3.0) -50%

.2 0 .2 -50% + 100%

P~laimed Oil (13)

Increased Cost of Synthetic Road

Oil Material

Increased Cost of Road Oil

Unintentional Contaminants (14)

Process Changes - Phthalocyanine Pigments

Process Changes - Diarylide Yellow Pigments

Process Changes - Other Processes

Exemption Applications

o to

31. 7

4.25

1.3

**

.02

o to 31. 7

(thru 1984)

Oto

6.4

(years 6-15)

o

0***

o

o

o to 100

o to 64*

4.25

1. 3 ***

**

0') .

-80% + 50%

-80%+ 50%

-80'0 + 50%

* Costs to continue indefinitely until waste .indust.r.iel oil no longer contains rreasurable arrount.s of PCBs.

**Infonration not available in the record to make estunate.

***Also long term cost impacts: See Table 18.2-1.
Table 18.2-1

Long Term Cost Impacts

Transformers : (Chapter 17)

Increased Cost of Non-PCB Transformers

Increased Fire Losses

Capacitors: . (Chapter 16)

Increased Cost of Non-PCB Power Factor

Capacitors

Increased Cost of Non-PCB Industrial

Capacitors

Diarylide Yellow Pigment (Chapter 14)

Increased Manufacturing Cost

Spill Materials (50 to 500 ppm PCBs)

(Chapter 15)

157\

$0 to 10 million/year

$0

$5.5 to 11 mi l Lion/year

$6.6 to 18.9 million/year

$345,OOO/year

No data
Table 18.3-1 Economic Costs of the PCB Ban Regulation

Chapter

Nurrber I tern

Total Cost

$ Million

Pounds PCBs Diverted

from the Envirorunent

Cost per Pound

of PCBs

1,000 . 5,360 $187,000

These costs will be significantly reduced or eliminated if EPA

grants exenptions fran the "distribution in cOI11TBrce" ban.

3

3

4

SCrap SPare PCB

capacitors

Renove PCB Capacitors

from Equiprent in

Inventory

Ban Rebuilding

Askarel 'I'r'anaforroer-s

1

397 to 771 (30 yrs)

500

47,000 to 925,000

$ 2,000

$429 to $16,400

**(>$68)

$480 to $2,550

*k (>$1. 75)

**(80,240 lb. total)

**(3.76 ~llion lb)

total

5.15

Retrofill Railroad 6.7

Transfo:r:lrers to 6%

Retrofill Railroad

Transfo:r:lrers from

6% to .1%

Re:}uire Incineration of 96 to 510 (30 yrs) 200,000

Transfo:r:lrer Oil

6

5

5

I-'

U1

co

7

8

9

Spec.i.aL Storage Areas * *

at Transfonrer Service

Stops

RetrofilljBan PCB Miner 2.6 to 4.3 ? (27,500 lb total)

.M:>tors

Ban Rebuilding Electro- .96 200 to 2,000

magnets

*

? (>$94 to $155)

$480 to $4,800

*Information not available in record to make estimate.

**Figure represents total amount, of PCBs in this use. Information not available in record to

make an estiuate of arrount; diverted fran the envirol1l"rerit.
Table 18.3-1 (Continued}

Chapter

Nurrber Itern

Total Cost

$ Million

Pounds PCBs Diverted

fran the Environrrent

Cost per Pound

of PCBS

Decontaminate Hydraulic 21. 4 to 25

Systems

Decontaminate Heat 12.8 to 17.2

Transfer Systems

Decontaminate Corrpressors .2

Ban Use of Waste Oil on 0 to 31.7/year

Roads

10

11

12

13

14

14

15

f-'

U1

\D 16

16

17

Phthalocyanine Blue pigrrents

Diarylide Yellow Pigments

Spill Materials (50-500ppm)-

to.Chemical Waste Landfill

Ban New Large PCB capacitors

Ban New Small PCB Capacitors

Ban New PCB Transforners

. 425/year

. 478/year

*

5.5 to 11/year

6.6 to 18.9/year

o to 10/year

470 to 2,390

1,872 to 2,496

*

8,073/year

544/year

441/year

*

14,200

6,930/year

12,.000/year

$6,000 to $53,000

$6,870

*

$0 to $3,925

$781

$1,084

$182

$387 to $775

$950 to $2,730

$0 to $833

*Inforrnation not available in the record to make estimate.
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Liquid by ChaLcoal Filtration, Midland, Michigan: undated.

EPA. 1976. "WateL PLogLam - PLotDsed Toxic Pollutant Effluent StandaLds

for Polychlodnated Biphenyls, 11 FedeLal R~ister, July 23, 1976, pp.

30468-30477.

EPA. 1977a. "Polychlorinated Biphenyls (fCBs), Toxic Substance ContLol,"

Federai RegisteL! May 24, 1977, pp. 26564-26577.

EPA. 1977b. "Polychlodnated Biphenyls (FeBs) , Toxic Substance Control,"

Federal ~ister, December 30, 1977, p, 65264.

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Railway Industry, Final Report, (Report No. DOT-TSC-1294). Cambridge,

MA.: Transportation Systems Center, u.s. ror, December, 1977.

Weems, George. 1977. "Polychlorinated Biphenyls." Denver, Colorado:

u.S. Department of Interior, File HIS 3-3-10h, June 13, 1977.
weinstein, Norman J. (Recon Systems, Inc.) 1974. Waste Oil Recycling and

Disp::>sal, EPA-670/2-74-052. Princeton, N.J.: August, 1974.

iibod, David (Lvbnsanto). 1975. "Chlorinated Biphenyl Dielectrics, Their

Utility and Potential Substitutes" in Conference Proceedings, National

Conference on Pol chlorinated Bi heny1s,November 19-21, 1975. Chicago,

I 10n1S. Was 1ngton, D.C.: Off1ce of ToX1C Substances, U.S.

Envirorunental Protection Agency (Report; No. EPA 560/6-75-004), pp.

317-322.
,"aRM NT1S.311 l"ItV. 10'731 ENDORSeD BY AJ.'l/SI AND UNESCO. THIS FORM MAY BE REPRODUCED

BIBLIOGRAPHIC DJ.TA. 11. Report No. 1

2

• 3. Recipient's Accession No.

SHEET EPA 230-03/79-001

4., Tide and Subtitle 5. Report Date

PCB Manufacturing, Processing, Distribution in C<:mrerce, March 30, 1979

and Use Ban Regulation: F.conanic Impact Analysis 6.

7.A~) 8. Performing Organization Repc, Ro Westin, Bruce w:x:rlcock No. 535-1

9. Performing Organization Name and Address 10. Proje cc/T'as k/Work Unir No.

Versar Inc.

6621 Electronic Drive 11. Coneeact/Grane No.

Springfield, Virginia 22151 68-01-4771

12. Spoaaoring Organization Name and Addre ss 13. Type of Report & Period

Office of Planning and Manage:nent Covered

U. S. Errvi.rcnment.al, Protection Agency Final Report

washingtc;)n, D. C. 20460 1-(.

15. Supplementary Notes

I EPA Project Officer: Mr. Stephen Weil

16. Abseraers I

This report surrrnarizes the estimated econanic impacts of PCB Ban Regulations which

irople:nent the requirerrents of sections 6 (e) (2) and 6 (e) (3) of the Toxic Substances

Control Act.

17. Key Words and Document Analysis. ' 170. Descriptors

Polychlorinated Biphenyls

Toxic Substances Control Act

Liquid Waste Disposal

&:::onanic Analysis

Public Utilities

capacitors

Transforrrers

Coal Mining

Waste Oils

17~ Identifiers/Open-Ended Terms

I

17c. COSATI Field/Group

18. Anilabiliry Statement 19•.Security Class (This 21. "No. of ?ages

Report) 173 Release Unlimited lm,T <;<;lFIFn

I;lV. Seeuriry Class (1 his 22. Price

Page

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.. 99

United States

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A.gency

Washington DC 20460

Official Business

Penaity for Private Use

$300

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Book

Postaqe and F80~; F'air) EP/\ -.

Permit No. G-3Ll