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Office-ofToxicscostanees April 1979 WashingtonDC:20460 

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# 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 ImpactAnalysisVUL... ! '- '-VVV rlL..U VV I ,-U III I VI V L... J • il I 111\ I1V, '"I1";V'"t I V";";V I I V";I"'''1



### 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. Anumber of adverse effects on living organisms havevUL IL LUUU I'ILLI UO'LU nil U. tJ L. I. n Ino I1V. '1 IV0'11vvvv

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### Protection

### Agency Region9 ' 

### SEP2**~'** 

### 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 ControlvUL 1C.C.UVU 1'Il.1/ Uv' c.u nil U.,; l.. I. n



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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. NoAction. 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** 

### other statutes adrni ni

### st

### 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.r nl\ nv. 't! ;Jv'tI ;;J;J;J;;J

-iii
### The 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. Anumber 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. r, UU/-J'iI, U'/ -J'i



### -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.r MI\ nv. 't! ;)v'tr,J;);),J r , VO/-J't



### -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 autho ri

### 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.JUL-lc:.-c:.UUU \'ICU UV,C:.C:. Mil Uo;:; Cor , M



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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 about 

## At""I:tb\.tq'lq 

### the Support Document/ Vol untary 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 MStreet, 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.rnl\ nv. '"II;)v'"lr,J;);).J I. IVI ..,)'1



## r. II.
III.

IV.

V. 

### VI. VII. VIII. IX.

X. XI. XII. XIII.

XIV.

XV. XVI. XVII. XVIII. 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 RaLlr'oads.•••.•••••••••••••• /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;>

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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.

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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 3V Vl.o '"'- ,-VVV flL...V VV' L..v IIII VI Loo. I I II I Illl nv. "t I v'V"t Iv'v'v'v' I. I v'1 v'"t



### 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 FR43048), 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 FR50905). More than 70 petitions for

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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 

# I 

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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

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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.

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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,

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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 IV VI.. Iz, c:..VVV YiL.LI Vv'c: I nil V. 0,) L.. I • n r nl\ I1V. '"tIJv'"t IJJJJ I. IvlJ'"t



### 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. 

### Oncoqeni

### citv

. 

# . 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). Ahigh frequency of nodular hyperplasia in 

### the liwer, considered by some authorities to be precancerous,

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### was observed in the rats fed 100 ppm of the three mixtures

.. Asignificant increase in freguenqy in comparison to controls was observed down to the 10 ppmdosage 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

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### dosages as low as 5 ppmof 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 dy

### sfunction.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

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### 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

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### 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

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### 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.

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### 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

" ,

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8. 

### Other Effects Workers exposed to PCBs have been shown to have 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

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### 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 ppmof 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.**c..~/J4** rHI\ l'iV. 41**O~4** (JOOJ 

### 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 Anumber 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

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### 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

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### 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.

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### 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. Anumber 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'

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SOURCE



### SINK tlAtE'R

SINK

Figure 1 Schematic Representation of Transport Processes in the Environment

23aSummary 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 ( oJTable 4.1-1*
Estimated Number ofPCB Transformers in Service Category ofUser Utilities Industrial and Commercial Railroad NumberofUnits 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 BanRegulations define askarel transformers as being any transformers that are filled with a liquid containing PCBs in concentrations exceeding 500ppm. This chapterdiscusses the impact of the regulation on transformers that were originally filled with a PCB based dielectric fluid. Chapter 6discusses the impact of the regulation on those transformers that were originally filled withmineral oil but which have since becomecontaminated with PCBs in concentrations above 500 ppm. 4.2 Requirements of the Regulation Rebuilding and majormaintenance: 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 transformerwill result in rhevuni.t being scrapped. However, retrofilling a PCB transformer several times with a non-PCB liquid may reduce the residual concentrationof PCBs to below 500 ppn, The ban on rebuilding does not apply to such decontaminated transformers. Minormaintenance: There are no restrictions on the**pe~formance** ofmalntenance thatdo not require removal of the coils. After July 1, 1979, transformer service companies cannot sell used orreclaimed askarel unless they have petiboned for an exemption from the provisions of the regulation which ban the processing ofPCBs prior to their distribution in commerce.

24Reclaiming PCB askarel: AfterJune 30, 1979, PCBsmay be reclaimed for reuse only by those**~vho** have petitioned the EPA and been granted an exemption from the "processing" bans. Storage ofPCB askarel: Storage prior to use or resale must be in a speciallymarked area which meets the requirements established by the dispasa.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 of30 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 newwire on the original core. 'Ihis 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 newunit.* 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 newtransformer (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 commentsofMr.**Lynv~** Holley**(~merican** Electric Apparatus Repair

Corr=oration) at the hearings on the PCB BanRegulations, August 28, 1978. **Oral commentsofRobert Sandman**(Sand~n** Electric Company) at the hearings on the PCB BanRegulations, August 28, 1978. 25the present one to tv-D roonths to six rronths ormore, depending on the availabilty ofa satisfactory new transformer*. Theout-of-service**tL~e** might even be longer than woul.d be expected based on past practices because the ban on the manufacture ofnewaskarel transformers will require that each installationofexisting askarel transformers be redesigned whenthe transformer fails and must be replaced. Adequate replacement transformers are usually available in a numberofdesigns including oil-filled**transfo~ers wi~h**  protective vaults and sprinklers, high fire point liquid-filled transformers, and various types ofdry transformers. However, none of these designs are direct replacements for existing askarel transformers, so a certain arrount of engineering timemust be added to the normal delivery time for a newunit.
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 wasexpected to impose on the use of these units. The PCB ban regulations do not affect the resale and reuse ofaskarel transformers by users, and units rerroved fran service becauseofchanges in service demandsmight be made available as replacement units for someof the failed askarel transformers. However, the riskof a spill occuring during transport of anaskarel transformer and the high potential liability incurred by any spill ofPCBs will probably limit anymarket in used askarel transformers. NOt enough information is available to estimate the proportion of askarel transformers that wouldhave 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 ofthe existing askarel transformers wouldhave been rebUilt if itwere 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$373million to $747million over the next 40 years. *Letter from Robert L. Sandman (Electrical Apparatus Service Association,

Inc.) to EPA (PCB BanRegulation Hearing Record), Undated.
26) These foregone savings will not be distributed evenly over the next 40years 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 waspreviouslyestimated that approximately 80,000 gallons ofPCBs were used in the repair of askarel transformers in 1974 (Versar, 1976a). This is enough PCB to fill 335 transfoaners with an average capacityof 240gallons ofliquid (Versar 1978, p. 21). Many transformer service companies have also used reclairned askarel in rebuilt transformers, so the actual numberof transformers rebuilt may be three to four times the number calculated fran data on the**us~** of**ne~** askarel (approximately 1200peryear). The amountofbusiness lost to the transformer rebuilding industry due to the ban on the rebuilding of askarel transformers might be asmuch as (1200 transfonners per year x $12,000 per unit

### = ) $14.4 million per year. The transformer manufacturers would supplynewunits 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 peryear. 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 300companies 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 somecases 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 wasdependenton a single transformer for its power. Rental units might be available, but at ahigher cost to the plant. Theprevious estimate of increased rental

27costs for temporary replacement transformers was$2,380,000 peryear 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 Theregulations do not impose any restrictions on the processing ofPCB based askarel by the owner of a transformeror by a service ccxnpany that returns the askarel to transformers having the same owner. Therefore, there will be no restrictions on the presentmaintenance 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 ownerhas petitioned the EPA for and been granted an**e~emption** from the ban on the distribution in camnerceofPCBs. If the EPAdoes not grant exemptions, there will be a lackof available PCBs to top off askarel transformers that maydevelop small Leaks and to replace 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®, withoutdamaging its electrical properties, there may be little economic impact caused by the ban on sale ofnew and reclaimed PCBs. It should be noted that PCBs fromPCB tranforrners that have been disposed ofor are designated for dispOsal must be incinerated and therefore are not available for recycle or reuse. Disposal of failed transformers and askarel liquids ThePCB BanRegulations 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.icimpacts. Retrofill with**non~PCB** fluid ThePCB BanRegulations clarify the conditions under which a retrofilled transformer maybe considered to be in the sameclass as oil28filled transformers for purposes of servicing and di.sposal. However, the regulations do not establish any limitations on retrofilling. Therefore, the effectof 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 ofPCBs 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 EPAdoes 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 itselectrical properties*, there maybe little economic**L~pact** caused by the ban on the sale ofnewand 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 substanceormixture, after its manufacture, for distribution in camnerce..." (Section 3(10)).**Ther~fore,** activities**~ith** PCBs thatdo not involve its sale are not considered to be "processing" as defined by the Act , and such activities performed for the purposes ofmaintaining transfonners in other than a "totally enclosed manner" are specifically authorized by the regulation until July 1, 1984. Thismeans that there are no restrictions on the filtering orother handling ofaskarel unless there is a change in the ownershipof PCBs. Transformer askarel can continue to be testei and maintained by either the , owner of the transformeror by a service company, but no PCBs,can be added

to the transformer except those that were owned by the ownerof 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").
29transformer no later than 30days after the effective date of the regulation. In addition, "processing" and "distribution in COI1Unerce" for purposes ofdisposal are specifically authorized by the regulation. Theonly significant impact of this provision will be to ban the salvaging of used PCBs by transformer service ccmpanies for use in maintenance ofother transformers. However, the major use of such reclaimed askarels has been in rebuilt transformers, and the rebuilding of askarel transformers is being specificallybanned. '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 BanRegulations 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 BanRegulations clarify the conditions under which a retrofilled transformermay be considered to be in the sameclass as oil-filled transformers for purposes of servicing and disposal. The regulations do not establish any limitations on retrofilling. Theeffect ofretrofilling 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 noeconomic 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 ofPCBs 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 entryofPCBs into the environmentby (1 to 10 lbs perunit x 1/3 to 2/3 of 139,000 units

### = ) 47,000 to 925,000 Ibs.

30The ban on the sale ofPCBs 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 ofreplacement transformers}. $9.6 million (1979); $373 million to $747 mil{ion total '
$2.38 million per year 4.6 Cost Per PoundofPCBs 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 ofone dollar per year indefinitely discounted at 10% equals

$10.

315 • 0 RAThROAD UX:OMGrIVE TRAt'-TSFDR!'IERS 5.1 PresentOwnership and Use Plans Manyof themajor railroads in the northeastern United States are electrified. High voltage alternating current is supplied at 2Shz, 11,000 volts, byoverhead 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 speciallydesigned 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.lityof a severe fire should a derailment occur in one of the tW1nels leading into New YorkCity. The federally funded NortheastCorridor Improvanent Project is upgrading much of the power distribution system between Washington, D.C. and NewYorkCity. 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 nowSeptember, 1983*. The conversion of the catenary power to 60 hz, 25,000 volts, will have a rnajor effect on the continued use ofmanyof 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 fromHarold Snyder, Ul'S/EPAto record.)

32trill1sformers 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 themoperatinq.. 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 ofthe PCB BanRegulations UseofPCB railroad transformers: Authorized until July 1, 1984 subject to the following limits on the concentration ofPCBs in the dielectric liquid:**L~ter** January 1, 1982: AfterJanuary 1, 1984: 6% PCBs maximum 0.1% PCBs maximum Servicing and retrofilling ofPCB railroad transformers and treatment ofPCBs in other than a totally enclosed manner: Authorized until July 1, 1984, provided that there is no change in the ownership ofany PCBs. Processing ofPCB contaminated liquid prior to sale for serva.cmq transformers: Banned afterJuly 1, 1979, unless EPA grants an exemption from the "processing" ban regulation. Sale ofPCBs for servicing railroad transformers: Banned after July 1, 1979, unless EPAgrants an exemption fran the "distribution in commerce" ban regulation. Testing of liquid in PCB railroad transformers to determine concentration ofPCBs: Required immediately after any servicing that is performed to reduce the concentration of PCBs and again 12 to 24months 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 afterJanuary 1, 1982, must be refilled with liquid containing less than 50PPmPCBs.

33Table 5.1-1
S1..IDTrlaIY ofPCB Ccoled Railroad Transformers in service (One Transformerper Car) Effect ofLate 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 letterto EPA franMr. Clifford Gannett, Federal Railroad Administration, 9/15/78.**MaxL~um** concentrationofPCBs in liquid used to service or top offrailroad 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 deadlineon continued use ofPCB railroad transformers: It has not been demonstrated that it is technically possible to reduce the concentration ofPCBs 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 technologyofretrofilling and processing of transformer liquids before the July 1, 1984, ban on the use ofrailroad transfonners containing loore than 500ppm PCBs to assure that this requirement does not cause substantial economic impacts. Compliancewith 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 reviewof these regulations. Required reduction ofPCB levels to below 6% byJanuary 1, 1982: It has been demonstrated that a single retrofilling procedure consisting ofdraining, flushing, and refilling with non-KB coolant liquid can result in PCB concentrations substantiallybelow6% (Walsh, 1977;* Foss, 1977**). The analysis ofthe impacts of the proposed PCB regulation assuned a total materials and labor cost of$20per gallon for retroEilling

*Walsh, E.J., D.E. Voytik and H.A. Pearce, (Westinghouse Electric Corp.) 1977. EvaluationofSilicone Fluid for Replacement ofPCB Coolants in Railway Industry, Flnal Report. Report; 

### Lb. ror-TSc-1294. Cambridge, Ma.: Transportation SystemsCenter, U.S. OOT. JJecenber 1977 (attachment to reply canrnents fran CliffordGannett (Federal Railroad Administration)). **Foss, StephenD., John B. Higgins, Cbnald L. Johnston, and James M. i1cQuade (General Electric Co.). 1977. Retrofilling ofRailroad Transfonners. Cambridge, Ma.: Transportation Systens Center, 

## u.s. DOT, July 1978 (attachment to reply canments fromClifford Gannett (Federal Railroad Administration)).35a transfonuer a single time with silicone liquid (Versar, 1978). Arevised estimate for the cost of retrofilling a transformer based on the procedure develoPed by DowCorning 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. Manyof 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 someof 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. Thecost of this retrofill requirement can be calculated by assuming that all of the transformer replacements aremade byJanuary 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 (DowCorning Corporation). 1977. "Developnent ofMethods 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 EPAdated August 1, 1978). 36Table 5.3-1 Retrofill ofPCB Railroad Transformer with Silicone - 300Gallon CapacityAssumed
Cost Step 1

2

3

4 Procedure Hotdrain askarel from transformer (85% reroval

- Foss, 1977) Fill with 255 gallons trichlorobenzene, circulate and drain Fill with silicone Dispose ofliquid (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 2hours·

4hours

2hours

8hours @$15.00**

Total cost per transformer: COstper 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 fromJames Thompson (T&R Electric SupplyCo.) to EPA, dated August 28, 1978.

37Table 5.3-2 CostofRetrofilling RailroadTransformers toMeet January 1, 1982 

### Limitof 6% PCBs: $21.99/gal.

AssurreAll Transfonrers Retrofilled Assurre'l'ransfomer Replacenent ProgramFinished 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) NUlIberofTr.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 reductionofPCB levels to below 0.1% byJanuary 1, 1984. Reduction of the concentration ofPCBs 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 ofPCBs 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 efficiencyof -25% (i.e., 10 pounds ofnew silicone would be lost in processing and recovering 8 pounds ofcontaminated silicone). This analysis indicates that it would be cheaper to use newsilicone at $12 per gallon, even though activated carbon has been shown to remove PCBs from silicone.** The cost of each retrofill would be $15.14 pergallon 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 ppmwould then be (170,000 gallons x 2 retrofills x $15.14 per gallon

### = ) about $5.15 million. This cost could be reduced ifa less expensive disposal method became available or if someway 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 BanRegulations. Undated. **D:JwCorning Corpor'ation. RemovalofPCB from D:JwComing 56l® Transformer Liquid by Charcoal Filtration, Midland,**t~chigan:** Undated (As cited inVersar, 1978, p. 29).

39Table 5.3-3
Retrofill ofContaminated SiliconeFilledTransformer

- 300GallonCapacityAss11IT'ed

Cost
Step Procedure Materials Labor-man hours

I Hot drain silicone 2hours (85% removal ofliquid)

2 Flush

...vith 45 gallons $540. 2hours silicone, (additional 3% removal ofPCBs) 3 Refill with 255gal. $3060. 2hours newsilicone ($12/gallon)

4 Disposal of6 drums contaminated silicone (@$142)

Sub-total: $ 852.

$4452. 6hours Plus LaborCost

@$15;hour: $90.

Total cost Per transfonrer: $4542. Average cost pergallon: $15.14

40It should be noted that the highest calculated total costof the retrofill program of$21.82/gallon (Table 5.3-1) + 2 x $15.14/gallon (Table 5.3-3) 

### =$52.10/gal is somewhatless than the estimated cost of $78per gallon**ass~~ed** by Charles Engelhardt ofAmtrak and by Dean Aboudera of the American Public TransitAssociation in theiroral commentsat the August 31, 1978, hearings on the proposed PCB BanRegulation. However, it is felt that the**est~nate** of$52.10 per gallon is in fact an upper bound estimate ofthe cost impact of the PCB BanRegulation because of the opportunities available for cost reduction by use ofothermaterials being evaluated by the Federal Railroad Administration such as RTEmp® and Iralec T-l®.* Testing to determine concentration ofPCBs in liquid. Testing of the liquid in each railroad transformer that remains in service will apparently be required four times: upon completion ofeach 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 EPAon the recommended methodologyor estimated costofanalyzing samples of silicone oil for the presence of PCBs. 'The methodolcqy for this analysis should be about the sameas for PCBs in mineral oj although the silicones WJuldrequire additional maintenance of**thc~** col.umn in the gas chromatograph. Cost ofeach analysis therefore might be 5 to $150, including order processing costs. Tbtal costof the**requir(~]** analyses lNOuld be expected to be $440,000 as calculated in**l~blc** 5,]-4.

*Oral canments by Clifford Gannett (Federal Railroad Administration) at August 31, 1978 hearing.

41Table 5.3-4
Cost ofAnalyzing Silicone Oil for the Presence ofPCBs 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 ofthe present regulations is to reduce the amountofPCBs 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 waspresented 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 madeof the effect of the required retrofill programon**G~e** entry of PCBs into the**enviro~ment.** 5.5 Summary - Economic Impacts
Cost ofreducing PCBs to 6% $6.6 million (silicone in 964 transformers) . Costofreducing PCBs to 1000 ppm $5.15 million (silicone in 665 transformers). Analytical Costs: $444,000

425.6 Cost Per Pound of PCBsKept from the Environment At best, each retrofill prevents the entry into the environnent of the amount of PCBsremoved from the transformers. Reduce PCBs to 6%: $6.6 million+ $140,000 .94 x 4million 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* FerpoundPCB

*Assumes all PCBswould be lost to the environment ifnot removed by

retrofilling.

436.0 OIL-FILLED rowER AND DISTRIBUTION TRANSFORMERS 6.1 Present Contamination ofOil Filled Transformers The PCB ban regulations lower the level at which PCB contaninated mineral oil is regulated from 500 ppn to 50ppn. Amineral oil transformer may fall into one of three categories. Amineral oil transformer that has been tested and found to contain over 500ppn PCBs is classified as a "PCB Transformer." A transformer that has not been tested or that has been tested and found to contain between 50ppm and 500ppn PCBs is a "PCB-Contaminated Transformer." Transformers that have been tested and found to contain less than 50ppn 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 motoroil (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 sameplants thatmanufactured askarel transformers (Versar, 1976a, p. 84). The total numberofoil-filled transformers presently in servicewas previously estimated to be about 30,000,000 overhead and distribution transforrners (each containing an average of 16 gallons ofoil) and 5,000,000 otherdistribution and power transformers (each containing an average of250 gallons ofoil) (Versar, 1978, pp.36-39). It was also estimated that nearly all of the polemounted transformers and perhaps 80% of the otheroil-filled transformers are owned by electric utilities (Versar, 1978, pp. 39-40). During the hearings on the proposed regulation, a numberof utilities and transformer repair canpanies presented information on the results of sampling programs that they conducted to evaluate the extent of PCB contamination ofoil-filled transformers. This information is summarized in Tables 6.1-1 and 6.1-2. Thereply canment from the Edison

44Table 6.1-1 Utility Reports of PCBContaminationofOil FilledTransformers withConcentrationsAOOve 50 pPl1

Ccmpany Pole MoW1ted Reference Distribution tbte Transfonrers Other Transfanners Other Samples Sampling Procedure

,j:>. 1.J1 AlleghenyPCMer Service Corp.

BostonEdison Cc:mmnwealth Edison

Consumers PCMer 1

2
3

4 

## oof 2



### oof 9 9 of 33* 

## oof 2

4 of 12

4 of 29 oil storage tanks: 

## oof 2

1 oil storage tank:

PCBs <5 ppn



### 55gallon drums

ofoil: 0 of 4 

### * 33**randorr~y** selected substation transforrrers. Other 6 samples were notpartof the random sample.

100 selected to be representative of age ofoperating transfonrersi no dataon hew these 21 sampleswere chosen to

### be analyzed first, (210 ppn max) • Manysamples 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 PCMerCo. Reference N:>te**~r** 5

6

7 Pole !>bunted Distribution Transformers Other Transforrrers 5 of 17 (in service) 

## oof 9 (new)

2 of 4

## *

51 of 161

### * Other Samples

ReclainEd oil storage tanks:



## oof 3 Sampling Procedure Scm9 of the 17 used transfonners were selected because it was knovm that PCBs were used in the plants where they weremanufactured.



### * 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 500PPTI, 41 presentbelow 100 ppnbut not quantified. "

.....itwas assuued that all samples with detectable arrDunts of PCBs were contaminated above the 50 ppnlevel. IITable 6.1-1 (Continued)

.t:> --..J Company GPU Service Corporation GPU Service Corporation

Northern States PowerCo. ottertail Power Canpany
'IVA Reference tbte Number
8

9

10
11

12 PoleMounted Distribution Transfonrers 15 of 58 distribution transfonrers



### o of other Transfonrers

25% of

### oil in 144 substation transformers 6


## oof 1

2of 38 other Samples oil storage tanks: 2of 18

oil storage tank: 

## oof 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 datedAugust 4, 1978 and September 7, 1978. 

## Y Letter fromCharles 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 (DetroitEdison) to EPAdated August 3, 1978. 

## JJ Written Ccmnents

- "Response Concerning EPA's Proposed PCB

... Bans

..." - sul:xnittedby 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 EPAdated August 4, 1978. 

## V Letter fran EdmundNewton, Jr. (GPU Service Corporation) to EPA dated October 6, 1978.

. 10/ Oral Carrnents ofLyle Salmela (Northern States Pc:wer Company/MidContinentArea Power Pool) at PCB Hearings, August 22, 1978, (pp. 78-79 of transcript). 11/ "Carrments ofottertail Power Co. on the Proposed Arrendments to 40 CPR761." Undated. 12/ Letter franWilliamGerstner and Paul Greiner (Eclison Electric Institute) to EPAdated August 7, 1978; Exhibit III.Table 6.1-2 TransformerManufacturer and Service CompanyRerorts ofPCB Contaminationof Oil FilledTransformersAbove50ppm.

Transformer Consultants 5 ( 185 of 434 On custorrerrequest

- primarily industrial clients; 72ofthe transformers hadrrore than SOOppmPCBs, although several of these mayhave been retrofilled askarel transformers.Table 6.1-2 Notes

1. Letter from WilliamGerstner 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 EPAdated OCtober 6, 1978. 3. "MainCorrrrents

..." sul::mitted in writing to EPAby John Olmsted (RI'E corporat.ion) undated. 4. Letter fromJarres Thanpson (T&RElectric Supply Company, Inc.) to EPA datedAugust 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 letterdated September 13, 1978.

50Electric 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 definition ofdistribution transformers (including rrore than just the poLe mounted units) and include the results of sampling ofoil 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 dataon oil-filled transformers that was not otherwise presented to the EPA. 'Ihe only dataon contamination ofoil-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 Powerwere from a population that excluded the large transformers which Duke Powerbelieved were not contaminated. The other utilities sampled on the basis ofconvenience, 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 theirmanufacturing plant, they refOrted that the level ofPCBs seen in transformers washigher in the older units than in newer ones (none of the transformers was found to be contaminated in concentrations above 50 ppn) . T&Rreport.ed a random sample of used transformers and stated that they felt that the average concentration of PCBs in oil was above 50ppn because their holding tanks for reclaimed oil contained rrore than 50 ppn PCBs. GE and TransformerConsultants report.ed the results ofanalyses done on their own samples and for other companies; these datamayhave also been re1?Jrted by the owners of the transformers and maytherefore be duplicate infonnation. It is not possible to calculate statistics that describe all transformers from the data thathas been r epor't.ed because ofproblems in sampling protocols, possible double reporting ofdata, and uncertainties

51Table 6.1-3 EdisonElectric Institute Summary ofContaminatedTransformerData Submittedby Electric Utilities* DistributioJ! PCMler Total

# Y

No. >50ppn No. >50ppm No. >50ppm >500ppm Ccmn. Ed. 26


## - 17 5 43 5
TVA 34 2 38 2 Consumers 33 4 Duke 1613/ 51 161 51 3

# Y 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 BostonEd 1 Ottertail 1



### -- - 'TOI'AL 37 0 277 67 456 95 5 0% 24% 21% 1%

* Source: Letter fromWilliamGerstnerandJohnKearney (EdisonElectric Institute) to EPAdated OCtober 10, 1978. Appendix B. Appendednotes also from Edison Electric Institute.Ul W Notes to Table 6.1-3

1/ SeeANSI/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 otherPCB articles. 3/ As indicated by Duke PowerCo. in its hearing testimony (August 21, 1978, atTr. 113) its sampling programwas not representative of its system. Rather, itwas designed to sample those transfomers "rrost likely to be PCB-contaminated." Id, 4/ As indicated in the Duke Power' Co. HearingTestirrony (Aug. 21, 1978, Tr. at 134) the 3

- sanples indicating concentration greater than 500 ppmwere from transfomers manufactured by the sane corrpany at least one ofwhichwas incorrectly filled with askarel by the manufacturer. Id. at 129. We strongly believe that any contamination greater than 500 ppmis 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 ofwhich 15 (26%)

- containedmineral oil dielectric contaminatedwith PCBsat levels greater than 50 ppm.Table 6.1-4 EdisonElectric Institute 

### Surrmary ofContaminated Transformer Data Su1:mittedby Transformer Ccmpanies

## * (1)

, ibut.i 2/ Df.st.r.i utaon> Power Total
No. >50 

### ppm No. >50ptm No. >50PfIl1 >500 ppm General Electric2/ 2614/ 20 13 6 294 37
RI'E 19 

### - 19
T &RElectric2! 14E! 6 14 6
U1

. 7/ 4348/ 434

## 21 .t:> 185 205 65 Transfonner Consultants-



### -- 

## - 'IOTAL 294 26 447 191 761 248 65 9% 43% 33% 15%



### * Source: Letter fromWilliamGerstner and John Kearney (&lison Electric Institute) to EPA dated October 10, 1978. Appendix C. Appended notes also frcmEdison Electric Institute.Notes to Table 6.1-4 1/ Westinghouse has.not provided any independent evidence in its carrrents of the contamination

- ofmineral-oil transfanners with PCBs. Its evaluations are solely based on assumptions itmakes using the ccmnents and testinDny of others for the purpose ofderronstrating the econanic impactofthe 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 ithas "no idea how to tackle the problemofwhat percentage ofthe 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 ppnPCBsis without foundation. Includes 75 pole-type transformers ofwhich 4 (5%) were above 50 ppn.

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

- "representative" of its inventory, the electric utility industryI or the class of 35 millionmineral-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 ithas nCfiN analyzed roughly 2,000 oil samples ofwhich approximately 33% contained greater than 50 ppn PCBsand 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 ofTransfonner Consultants (September 13, 1978). Note: These numbers

- differ from those submitted byMr. Westin on September 26, 1978.about the analytical methodol.oqy that was used in each case. However, from inspection of the data, itmight be reasonable to conclude that from 5% to 40% of pole mounted transformers and from 20% to 30% ofotheroil-filled transformers are contaminated with PCBs in concentrations exceeding 50ppm.**Conta~ination** to levels above 500 ppm appears to he rare. Table 6.1-5 summarizes calculations of the amount ofPCBs 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 Boperating companies and approximately 1000 Rural Electric Cooperatives.* About eightmillion of the pole mounted transformers are owned by the 1000 rural systems, of which 950 are distribution cooperatives thatdo not generate any power* and that therefore do not have high efficiency boilers. 6.2 Requirements of the PCB BanRegulation 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 50ppm to 500 ppm, (2) oil-filled tranformers thathave 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 500ppm whentested after at least three months of service following the last decontamination procedure. *Ives, Joseph S. (National Rural ElectricCOoperative Association).

Written statementdated August 7, 1978, and oral testimony atAugust 21, 1978 hearing.

56Table 6.1-5 Estimated AmountsofPCBs in Oil-Filled Transformers

Average oil capacity, gallons per transformer*

x 7.6 

### =Ib oil per transformer Numberof transformers in service* %above 50 PFffi Number of transformers above 50 ppn Pounds ofoil in contaminated transformers Pole Mounted Other

16 gal. 250gal. 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 PCBsconcentration 80 ppm Pounds ofPCBs in contaminated transfonners 29,184 Ib**
Number oftransforrrers below 50 ppm 27,000,000 80 ppm 190,000 Ib**
3,750,000 Pounds ofoil in non-contaminated transformers 3,283 million Ib 7,125 million Ib Assumedaverage PCB concentration Pounds ofPCBs in non-contaminated transfonners1btal pounds ofPCBs 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**

57The 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 ownershipof liquid containing over 50 ppmPCBs. (T:bte: reclaimed transformer oil may be presumed to contain between 50 and 500 ppmPCBs 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 ppmPCB: banned afterJune 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 ofdrained transformers: not restricted. • Dispoaal, of used transformer oil: tested and found to contain no detectable PCBs: not regulated. (Testing may be performed on batches ofoil 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 maynot be used

58as 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 bemarked. 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) Byany othermethod 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 BanRegulation The regulation does not affect the continued use or resale ofPCB contaminated transformers, nor does it affect the Inaintenanceof these transformers except to ban the sale ofreclaimed contaminated fluid. The only unpacts will be on the reclamation and disposal ofcontaminated used transformeroil and other contilloinated transformer liquids. July 1, 1984 deadline on rebuilding oil-filled transformers: AfterJuly 1, 1984, rebuilding ofoil-filled transfonners will onlybe allowed for those units that have been tested and found to contain less than 50ppn PCBs. It is anticipated that EPA will review the status of the rebuilding of transfonners and the occurrence ofPCBs 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 ofthe costs to be

59incurred by the transformer service industry and by the users ofoil-filled transformers byparticipating in the eventual reviewof these regulations. Reclamation ofused fluid from PCB contaminated transformers: According to Duke PowerCompany, 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.* TheCincinnati 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 increaseover the next few years as supplies ofnaphthenic crude oil are depleted and transformer oil must be made by themore expensive process ofdeeply 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 transformeroil by utilities for use in their own transformers. The regulation requires that all transformer oil be preswned to containmore than 50 ppm PCBs unless it has been tested and found to contain less than 50 ppmPCBs. The sale of reclaimed transformeroil is banned afterJune 30, 1979, unless each batch has been shownto have less than 50 ppm PCBs or EPAexempts the seller from this ban reauirement. TheEPA has not yet

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

EPA as a written main commenton the proposed PCB ban regulation

. **Letter from E',E. Galloway (The Cincinnati Gas and Electric Company) to EPAdated August 4, 1978.

60established t.he-bas'i.s on'which it will accept individual or consolidated petitions for exemption, nor has itannounced the basis for granting such exemptions. the filtering ofoil 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 ownershipof 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 routinernaintenance. [vl.aintenance ofITDst of the transformers not owned by the major utilities is performed by transformermanufacturers and by independent repair shops. About 8 million of the 30million pole mounted distribution transformers are owned by small distribution utilities most ofwhich 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 ppmPCBs. If it is assumed that 4% of all oil becomes available for recycling each year (equivalent to assuming an average of 25 years betweenmajor 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. 5million. 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 ofoil reclaimed by transformer shops will depend on the economics involved in testing the oil to demonstrate that each batch contains less than 50ppm PCBs. The total 'amountofoil that could be reclaimed for purposes of resale by transformer maintenance shopsmight be 11.4 million gallons peryear as calculated in Table 6.3-2. If this oil were accumulated in 1000 gallon batches prior to

,.., 0:1.'rable 6.3-1

UsedTransformer Oil Available for Reclamation

Average capacity-gallons Total nwnber in service Owned by industry Owned by small utilities Owned by major utilities Amount ofoil 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 480million gal l,250 million gal 1,730 miLlion gal Amount ofoil used bymajor utilities 352million gal 1,000 million gal 'Ibtal 1,352million gal
Percent of transformer oil used bymajor utilities: 1,352 million gal. 1,730million gal. 

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

### =22%

62Table 6.3-2**EstL~ated** SupplyofTransformerOil Available for Recycling for Sale 'lbtal amount ofoil

x fraction available each year x fraction to transformer repair companies
x fraction assumed recoverable (not too degraded by prolonged use)



## =Total annual supplyofoil available for recycling for sale

63 1.73 billion gallons 4% 22%
75%
11.4 million gallonstesting, 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 ofoil 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 ifas fewas one of every five batches were actually found to have less than 50ppmPCBs. If the total amountofPCBs in transformers is actually the 400,000 pounds estimated in Table 6.1-5, the average concentration ofPCBs in the 1.73 billion gallons of transformer oil tl1at is in use VvDuld be about 30 ppm. This implies that at leastone halfof the batches ofoil that are tested would have less than 50ppm PCBs if care were taken to avoid contamination of the oil with materials used with askarel transformers. Ifonlyone halfof 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 makeavailable (11.4 million gallons x 50% =) 5.7 million gallons ofoil peryear for recycling and resale. If the recycling of this 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 millionperyear. If, however, none of the batches ofoil had Over 50 ppm PCBs, the total cost of the regulation VvDuld be the cost of the analyses (or a total of $912,000 peryear iftesting were ferformed on batches of 1000 gallons) or even less if the average batch size were larger.

64Disposal: ThePCB BanRegulation authorizes the disposal of transformeroil contaminated with 50 to 500ppmPCBs in large, high efficiency boilers meeting certain requirements of size, feed rate of the contaminated oil, presence ofexcess oxygen in the stackgas, 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 30days before the first tline each high efficiency boiler is used to burn transformeroil known or presumed to be contaminated with PCBs. 'The regulations further state that the contaminated oil cannot be fed into the boiler during start-upor**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.* Aspecial holding tank and metering pumpswill be required to feed contaminated transformeroil into a high efficiency boiler. Additional road construction, fencing, orother utilitiesmay add to the cost of equipping a boiler to burn transformer oil in compliance with the regulation. This expenditurewould probablyonly be madeifjustified by savings resulting from (1) decreased disposal costs and (2) the value of heat recovered in burning the transformer oil. *Letter fran NancyGJrmley (Allegheny PowerService Corporation) to EPA

dated August 4, 1978. *Letter fran James Mulloy (CityofIDs Angeles Departmerit ofWater and

Power) to EPAdated August 7, 1978. *Attachment to letter fran L. John Cooper (Nebraska Public PowerDistrict)

to EPAdated August 4, 1978. *"Comments ofOtterTail Power Companyon the Proposed Amendments to 40 CPR

761." Submitted to EPA byJay D. Myster, undated. *Letter fran S. A. Ali (Public Service Indiana) to EPAdated August 4,

1978.

65Disposal of used transformeroil in approved high temperature 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 boilerwould cost $.42 pergallon.* 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 pergallon, this is equivalent to ($2.70/8 

### = ) $.34 per gallon. Shipment oflarge quantities by tank truck \YOuld be considerablycheaper pergallon. Thevalue of the oil to the companythat owns and burns it would be equal to the savings in disposal cost ($.75 pergallon) plus the net fuel value ($.42 -$.34

### =$.08 pergallon). Eventhough most utilities might be able to obtain fuel for their power boilers at a lower cost than is paid byT&R Electric, the savings in disposal cost of $.75 per gallon could quickly pay for the estlinated costof installing additional handling facilities at the boiler. Since the value ofused transformer oil as fuel is roughly equal to the costofhandling and transpxting it, the total costofdisposal to those utilities thathave 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 considerablycheaper than commercial approved PCB incineration for most of the 149 class A and Butilities.

*Letter fromJames Thanpson (T&R Electric SupplyCompany, Inc.) to EPA

dated August 28, 1978.

66Satisfactory high efficiency incinerators will not be generally available to**G~e** many distribution utilities, transfonner repair shops, and industrial owners ofoil-filled transformers. For instance, T&R Electric is a transformer repair shop that burns 200,000 gallons ofused transformer oil each year in a hot watergenerator which has a flame temperatureof 1700° 

### F.* The regulations will require that this oil be disposed ofby incineration in high efficiency boilers or byother approved methods. This will result in increased costs to T&R Electric both to dispose ofthis oil and to replace it. If the requirement that wast.e oil be labeled as PCBs discourages general handling of thismaterial, the value ofthe used oil to the company that generates itmaybe considerably less than its potential fuel**value~** '!he resultmay be disposal costs of up to $.75 pergallon. Sincemuch of the waste oil is now used as**supple~ental** fuel in small boilers that will notmeet the requirements established by the regulation, the opportunity cost of the regulation may be up to ($.75 disposal cost + $.42 fuel value

## = ) $1.17 pergallon of the oil that is incinerated in approved PCB incinerators. The discussion ofreclamationofused transformer oil concluded that the value ofreclaimed oil was such that testing ofbatches ofoil to demonstrate that the PCB content is below 50 ppm will be justified for most ofthe transformer repair shops. Theoil 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 junkyards and other industrial concerns that handle transformers infrequently. It wasestimated above that 5.7 million gallons peryearof available oil would be salvageable and contain less than 50 ppn PCBs.
*r.etter fromJames Thompson (T&R Electric Supply Company, Inc.) to EPA

datedAugust 28, 1978.

67Themaximum econanic cost would be incurred ifthe remaini.nqoil 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 commentsto the EPAby the utilities did not express any interest inmaking this service generally available. The willingness oflarge utilities tomake available thei.r high efficiencyboilers for burning used transformeroil luaybe 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 ofPCBs. Given a perfectmarket, 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 ofoil by the large utilities will not cost them anything, the price that is charged will represent a transferpayment frem the small transformer shops and distribution utilities to the large utilities, anQ will not represent a real economic cost. Real econemic costs wouldresult only fran the higher transportation costs ofmoving the oil to the large utilities and from the greatervalue of the heat contentof 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 500ppn to a concentration of50ppm extends the Impact of the PCB Marking and Disposal Regulations to all used

68TABLE 6.3

....3

Cost of DisfDsal of Transformer Oil from Small Utilities, Transformer Repair Shops, al1dOther 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 yeartransformer oil that is being stored for disposal orreuse and to the oil that is being t.rarisport.ed for disposal.. At a veryminimum, 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 inannual operating costs of $2,125 per year (Versar, 1977, pp. 2-6). Total costs incurred because of the inclusion oftransformeroil may therefore be equal to ($2000 per site x 149 locations

### = ) $300,000 in initial construction costs and ($2125 x 149

### = ) $320,000 peryear thereafter. The regulation also permits bulk storage ofused transformer oil and the provIsIons of the Spill Prevention Control and Countermeasure (SPCC) plans of the oil spill prevention program becomethe storage criteria. Since almost all utilities have SPCC plans, this option probablyresults 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 transformeroil 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. Applicationoflabels to these tanks will cost only a fewdollars per year. 6.4 PCBs Controlled by the Regulation Acertain amountofused transformeroil has been used in the past as fuel in various boilers and pJwergenerating 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 amountofKBs released to the environment by past practices in handling used transformeroil. If it is asswned that past practices resulted in the use of one-halfof the oil as fuel in boilers operating at conditions that

70destroyed 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 

### fbPCBs

### = ) 196,000 pounds of the PCBs in transformer oil. The effect of the regulation is to require the eventual disposal of all transformeroil in high efficiency boilers that will destroy 99.9% of the PCBs present. Therefore, PCB releases to the environmentmay 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 ofPCBs. 6 •5 SLn11ffiary - Economic Impacts: Ban on reclaiming oil for resale: $3.2 million to $5.6 million per year (may be reduced ifEPA exempts processing and resale from the ban requirements). Limitations on disposal of oontarninated transformer oil: Costof storage tanks, etc., at high efficiencyboilers: Cost of incinerating oil generated byother 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. Costmaybe reduced considerably iflarge 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 ofPCBs 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 PC3s7.0 IMPACTS ONTFA"1SFORMERSERVICECO['1PANIES 7.1 PresentStatus**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 50ppn. The regulation bans the sale of any neworreclaimed transformer liquids unless they are known to contain less than 50 ppn PCBs. 7.3 Impact of the Regulation Themajor impact ofthe regulation on the small transformer service companies results from the change in the definition ofPCBs from a concentration level of 500ppm to a level of50ppm. Manyof these companies have discontinued servicing askarel**transformer~** because of the potential liability that could result from spills or worker exposure, and because of the relativelyhigh price ofbuilding the required storage areas for PCB materials. Companies who do not have oil storage facilities meeting SPeCrequiraenents are nowrequired to install special storage areas for the storage ofoil filled transformers and used transformer oil. Transformer service companies wiLl, face increased costs from the ban on reclaiming PCB contaminated transformeroil for resale, and *Letter from Robert L. Sandman (Electric Apparatus Service Association) to EPA. Undated.

72increased 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 ofPCB 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 ofthe 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 ofPCBs entering the environment as the result of improper storage of transformer oil by transformer serJice shops. Therefore, no estimate can be madeof 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 makeestimates of these Irnpacts ,

738.0 MINING**~ffiCHINERY*** 8.1 Current UseofPCB-Gooled Mining Machinery Motors In the late 1960s and early 1970s, PCBs were used as alnotor coolant in three types ofelectric motors manufactured byReliance Electric for Joy Manufacturing Company. Joy used thesemotors in three models of 10,<1 seammining 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 companyalso has portions of several other CU43 miners which theyhave purchased for parts. 'I'<t.o of the machines in use have had the K:B-coolant replaced with a silicone fluid and twoof the threemotors on the third miner have also been filled with silicone. If themotors 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, itwill be assumed that they are contaminated with PCBs at levels in excess of 50 ppm. Fifty-fourof the fifty-seven 9CMcontinuousminers sold in the United States were located by Versar during the course ofa telephone survey. Two of the threemachines**whic~** could not be located were recently sold on the used-machinerymarket. It is assumed that these twomachines are still in use. Thirty-five of the model 9CMminers are currently idle, fifteen are being used tomine coal, three are in use for**rnaintena~ce** or construction, twoare 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 differentmining 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 surveyof 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 fromVersar, 1978, except

where noted.
74Table 8.1-1 Use ofPCB-Coo1ed Electric t-btors in Mining Machinery(1)

_________ J 9C]'! Continuous Miner CUB Continuous Miner

14BUlO Loader

I---- -- - 

# -r---
NLinberof '!btal Nl.mber of 1btal 1btal PCBtbtors PCB Gallons of Gallons of Gallons perMachine tbtors PCBs per tbtor PCBper Machine PCB

------------ - 3 9 4 12 36

3 63 5 15 315

2 517 4 8 2,06e NLiuber Still in Service with PCBtbtors

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 ofMr. A. R. Benvenuto (Joy Manufacturinq Cmpany) at the PCBBan Regulation Hearings, AUCjust25, 1978. (5) Estimated, based on percentage of loaders that have I::een converted.For the past fewyears, Joy has been converting themotors on the loaders to air-cooling. As shownin Table 8.1-1, there are approximately 250 loaders and 17 sparemotors that still contain PCBs. 'The rotors on the continuous miners and the loaders require occasional topping-offwith additional fluid at themines. The amount of fluid Yklich is required is small but is necessary for the continued operationof the machines. 8.2 Requirements of the Regulations ThePCB BanRegulations require or permit the following with respect to the continued use and servicing ofPCB-cooled mining machinery motors:

• PCBs may be used in mining equipnent until January' 1, 1982.

• PCBs may be added to mining equipnentmotors at themines 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 commerceofPCBs for purposes of servicing mining equipnent is permitted afterJuly 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 ofJoy continuousminers as PCBmotors until July 1, 1979. This deadline could be extended to January 1, 1980, ifEPA grants the service shops an exemptionfrc:m the "processing" and "distribution in

76camnerce" bans. There are no non-Pc.Bmotors that can be used inplace 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 ofthesemachines will have to be retired fran use.within about a year after the effective date ofthe 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 machinerymay be technologicallyobsolete beforeJanuary 1, 1982, there are undoubtedly nQmerous small firms which cannot afford the capital investment required for newmachinery and thus relyon olderused machines to fill their needs. In addition, larger firms often use older machinery for spare equipmentor inmine construction. Therefore, the owners willbe confronted with equipnent that they must retire prematurely, losing the remainderof themachine's useful life or the income that could result from the sale of the machinery. Eight canpanies still use 9CMorCU43 continuousminers for coal production. Six ofthese companies are relatively small, with production ranging from 0.7 to 4.2 million tons peryear. Theother twoare large conglomerates withmuch higher annual productions. In addition, six machines are per'forrni.nq operations other than production. Themarket value ofthese machines is roughly $40,000 each (Versar, 1978). Table 8.3-1 summarizes the costs thatwould be incurred byeach of the companies that still use the continuous miners for coal production. Table 8.3-1 omits the 42miners that are idle or in non-production uses because the percentageof those miners that have any value is not known. Ifeach of themhas a value

*TestimohyofMr. EdWarner (Joy Manufacturing 

### cc .) at the EPA PCB

Hearings,**Chic~o,** Illinois, July 19, 1977.

77TABLE 8.3-1 Cost Impact ofForced 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)•

78of$40,000, the additional cost could be asmuch 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 replacementmachinery 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 costof$3,100 per motor, Themotors usually require rebuilding after 18 to 24 months of service*, so most of the rotors will be available for this conversionwitrout incurring additional downtime for the machines. Joy Manufacturing Company h9s stated that its service shop has the capacity to convert all of the PCBmotOrs presently used on loaders to air cooling by the end of 1981. Since the PCBs will be removed from thesemotors for purposes ofdisposal, this activity is not affected by the ban on "processing" ofPCBs. 'Ihe total cost to convert the 517PCB 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 PCBmotors will be allowed to continue in use until January 1, 1982, and most of the conversions will occur when themotors will require normal rebuilding. It is anticipated that maintenance requirements will be greater for the air cooled rrotors than for the PCB cooLedrrotors, but it is not possible to estimate the total economic impact of the resulting increased maintenance costs. Storage Costs: Each mine v.ouldbe required to store PCBs used formaintenance in a storage area thatmeets the requirements ofAnnex III. Joy sells the PCBs in one gallon cans. Anon-leaking 55 gallon drum protected fran the rain woul.d meet the requirenents ofAnnex III and WJuld be of sufficient size to store all the PCBs any mine v.Duld require. Each ofthe 96 companies poasibly involved (88 loaderowners and 8 continuous miner owners) would need such a storage area. The cost for a barrel and a *TestirronyofMr. Ed Warner (Joy Manufacturing Company) at the EPA feB

Hearings, Chicago, Illinois, July 19, 1977.

79label mayamount; 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 amaximumexpected costof $14,400. Exemption Application: It is assumed that Joy**~Bnufacturing wil~**  apply for an exemption underTSCA §6(e)(3)(3) in order to be allowed to rebuild the loader motors and to be allowed to distribute PCBs to the lnines formaintenance. The estirnatec1 $1,600 cost ofpreparing this petition is developed in the chapteron unintentional product contaminants. 8.4 PCBs Controlled by the Regulation The electric ITDtors in use on mining machines contain about 2419 gallons ofPCBs (Table 8.1-1). This is equivalent to about 27,500 pounds ofPCBs with a density of 11.37 pounds per gallon. The regulations will stop the losses ofPCBs from these motors by requiring that they be scrapped or rebuilt as air cooled motors byJanuary 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 ofpounds ofPCBs that will be prevented from entering the envirorunent. 8.5 Summary-Economic Impacts Loaders

- rebuild motors @$3,100 Continuous Miners-premature scrapping of 24operating machines @$40,000 42 otherminers @O

- $40,000 Storage costs - 96 storage areas Exemption application rIDTAL $1,600,000 960,000



## oto 1,700,000 14,400

1,600 $2,576,000 (plus up to $1,700,000

for idleminers)

808.6 Cost Per Pound ofPCBs 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 parpoundPCBs9.0**ELECT~~GNErs*** 9.1 Current Usage Large electranagnets are installed over conveyorbelts to rE5TOve tramp iron fran non-magnetic canrrodities such as coal and grain. Mostof these electromagnets are cooled with 100 to 150gallons ofmineral oil.**~Vhere** increased fire safety wasrequired, the magnets were often filled with PCB based askarel liquid. The threemagnet manufacturers who used PCBs were: Sterns Magnetics, Cudahy, Wis. Eriez [vlagnets, Erie, Pa. Dings Co , , l1ilwaukee, Wis. Dings Co. stoppedusing PCBs inmid-1976; the other two manufacturers have not used PCBs since 1971 or 1972. Atotal of about 250 PCB magnets were manufactured; approximately 200of thesemay still be in use in the United States. tvbstof the PCBmagnets 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 PCBmagnetsmay be used on grain conveyors because ofthe flammability ofgrain dust. The electrcmagnets are ofcompletely welded construction, and very few**le~(age** incidents have occurred with eitheroil-filledor 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 lackofadequate maintenance. Maintenance requirements do not expose vorkers or the environment to contact withPCBs. Since themagnets are suspended over conveyor belts, diking is not feasible, and any leakage wouldbe uncontrolled. However, PCBs dripping onto the coal would be expected to be destroyed in powergenerating boilers, thus making the onlyloss to the envirornnent thatofleachate fran contaminated coal in storage piles. The tot.al amountofPCBs presently in use in electromagnets is probably (200 magnets x 135 gallons permagnet x 11 pounds pergallon x .7 pound PCB per pound askarel

### = ) 207,900 pounds ofPCBs. *All information in this chapter is fromVersar, 1978, Chapter 9, except as

noted. 829.2 Requirements ofthe PCB BanRegulations Continued use: PCB-filled electromagnets are defined as a totally enclosed use ofPCBs and thereforemay 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 ofPCBs: Bannedafter July 1, 1979, unless EPAgrants an oxemption fran the "distribution in canmerce" ban. Reclaiming PCBs: For reuse by the ownerofthe 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 themagnetsmust be incinerated in approved incinerators. 9.3 Cost Impacts ofthe PCB BanRegulations Continued use: Theregulations 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 themanufacture ofnewPCB magnets is·not eXfected to have a significant impact'on either the manufacturers or users of thesemagnets 0 According to the magnet manufacturers, the FeB electromagnets could be replaced with oil-filled units at an average costof$8,000 permagnet. However, the use ofmineral 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 withmineral oil. Such silicone-filled units are 40 to 50% more expensive

83than 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: ThePCB 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. Ifthe average remaining service life of the PCB electromagnets is ten years, themagnets 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 newmagnet, rebuilding is banned by the regulation. The transportation and labor costs would be exPected to be the samewhether amagnet 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 newmagnet 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 peryear. Tbtal costs attributable to the ban on rebuilding PCB electromagnets will be $960,000. Disposal: ThePCB BanRegulations 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 costofpreparing and processing such petitions, but**L~is** cost has been eliminated by the BanRegulations. 9.4 PCBs Controlled by the Regulation The PCB electromagnets presently in use contain about 207,900 pounds ofPCBs. The regulations do not affect the continued use of these

84

### magnets. Theeffect of the ban on rebuilding thesemagnets will be to eliminate the loss ofPCBs to the atmosphere thatmightoccur during the rebuilding process. If these losses were 1 to 10pounds permagnet, as estimated in Chapter 4 for askarel transformers, the regulations would be expect.ed 

### to reduce the amount;

### ofPCBs entering the environment by (200 

### magnets 

### x 1 

### to 10 

### pounds PCBs permagnet

### = ) 200 

### to 2000 pounds 

### ofPCBs. 9.5 

### Surranary

- EconomicImpacts Ban

### on rebuilding: $96,000 

### peryear; $960,000 

### total. Disposal: Elimination ofcostsofpreparing and processing )?etitions for disposal by meansother than incineration. 9.6 

### CostPerPoundofPCBs Kept from the Envirorunent
Costper pound

### = $960,000 200 to 2000 pounds

85 

## = $480 

### to $4800 per pound

### PCBs10.0 HYDRAULIC**SYST~~** 10.1 PresentUse ofPCBs in Hydraulic Systems Prior to 1972, PCB based hydraulic fluids weremarketed by



# - 

# - rbnsanto under the trade**na~e** Pydraul® for use in hydraulic systems where**su~rior** fire resistance was necessary for rrotection oflife 

### and

- property.* Aprevious 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 atGMused PCB based fluids in the following types of systems:** Metal die-casting equipment Trim press hydraulics Plastic injectionmolding machines Metal melting furnace tilt hydraulics Industrial elevators Iron foundry pouring equipment Molten iron holding furnace equipment Induction hardening machine hydraulics Flamehardening 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 ofPCBs by GM were reported to be: Die-casting

- 56%; Foundry

- 35%; other uses - 9%. Areviewof !'1Jnsanto's customer list for 1970-71 indicated that 80% of the purchasers ofhydraulic 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 andSources ofLoas

to the Environment in r>'lichigan." National Conference on Polychlorinated Biphenyls, November19-21, 1975, Chicago, Illinois. Washington, D. C.: Office of 'Ibxic Substances, U. S. Environmental ProtectionAgency (Report No. EPA-560/67-75-004), p. 129. **Letter fran Mr. W. R. Johnson (General Motors Corporation) to EPAdated August 7, 1978.

86\'illenMonsanto discontinued the sale ofPCB based hydraulic fluids in 1972, they recommended to their custaners (1) that there was no

- . need to drain the systems and (2) that compatibleMonsanto hydraulic fluids eO'lifd be used to replace leakage•. Mosthydraulic-;yste.ms requireme addition of newor reclalined fluid at a rate of two to ten tlines the systen capacity each year to replace leakage losses. It is fairly canrronpractice' to recover leaked fluid and to process it for reuse. (Available dataon 

# - 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 fewmachines (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 ofhydraulic fluid. Mr. {)wain Fowkesof RAOCO Corp. reported that the hdraulic fluid which is commercial**~etlines** contains up to 6000 ppn 

# --

-**.~** Therefore, it is possibl,e that the use ofr ecl.aimed hydraulic fluid has resulted in the PCB contamination ofhydraulic 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 wasbased on the. assumptions that 80% of the hydraulic fluid sold during 1970-71 was**u~** inrdie-casting machines, that the annual makeuprequirement ofnewfluid**to~**



# - £eplace leakage is equal to the liquid capacityof the hydraulic system, that the die-casting machine has a ca cit allons of hydraulic fluid (Versar, 1978, pp. 65-66). Mr. Johnson ofGeneral Motors



# - suggested that this estimate may be in error because not all of the hydraulic fluid purchased bycompanies classified as primarilydie-casting concerns wasused in die-casting machines; GH used only 56% of their PCB *Telephone conversation,with L. Fourt (Versar), September 19, 1977, as

reported inVersar, 1978.

87hydraulic fluid in die-casting Inachines and the rest in associated equipment and in their steel foundry operations.* TheOutboard**~Brine** Coq:oration plant inWaukegan, Illinois, contains 135 die-casting machines, 60 associated trimpresses, 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 of460gallons at one plant


# ----- and 1580 gallons at anotherplant. 

# --.:-. ' Mr. William Sharp of the Society of Die Casting Engineers stated that die-casting machines are long-livedpieces ofequipment with
some

# 85- to 40-year-old machines still in operation] 'lhesemachinesare 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 usedmachines.***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 wasused in this type ofmaChine, and that the average annual requirement formakeupfluid was equal to the system capacity of 400 gallons, the numberofdie-casting maChines that onCeused PCB based fluid may have been as high as 700 machines as calculated in Table 10.1-1. No information is available on the numberofcompanies that own PCB contaminated die castingmachines. However, it should be noted that not all the machines that used PCB based hydraulic fluid can be identified from the records becausemanymachines have been resold since 1971. If the total nwnber ofdie-casting machines in use is 10,000**t~** 15,000 (estimate based on an average annual pr@uctlon of 500machines and '"--- an assumed average ownership of 6 to 10machines per company), only 5 to *Letter from {vir. W. R. Johnson (General Motors Coq:oration) to EPAdated

Ausgust 7, 1978. **Oral testirronyofHugh 'lhomas (Outboard Marine corporation) at the hearings on the PCB BanRegulations, August 25, 1978. ***Oral t.est.irrony byWilliam Sharp (SocietyofDie Casting Engineers) at the hearings on the PCB BanRegulations, August 25, 1978.

88Figure 10.1-1
Calculation ofNumber ofDie-Casting Machines that Used PCB Based Hydraulic Fluids
1btal sales ofPCB hydraulic fluid, 1970-1971 Number' ofyears



### =Annual sales ofPCB hydraulic fluid Weightof fluid pergal



### =Gallons PCBs peryear
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 makeupfluid
.;. Assumed: 400 gallons per year per die-casting machine required asmakeup fluid



### =Number ofdie-casting machines using PCB based hydraulic fluid

89 13,500,000 pounds PCBs 

# --cD

6,750,000 pounds peryear

__

## ---'~unds per gal 587,000 gallons per year
x .8 470,000

x .6 282,000 .;. 400

704

# )\\~~ ('v 

### \070 I 7% of the ffiachines presently in seDlice ever used PCB based hydraulic


# - fluid. However, many of the other machinesmay presentlybe contaminated**-----:-----.:,-:--"'----:"----:----::--:--:..-=---_.::...._-~---** with PCBs because 0 actice of reclaiming hydraulic fluid. Otherhydraulic systems: General l'btors reported use of PCB based hydraulic fluids in systems ranging from 50gallons 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 50heat 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 makeupas do die-casting machines. 'fuese systems were probablyowned by all of the companies having die-casting machines plus perhaps an additional 100 steel conpanies, Total PCBs presently in use: Tbtal capacityof all of the hydraulic systems that atone 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% oftheir 

# 'I- die casting systems have PCB concentrations below 500ppn*; Outboard t4arine reported that recent spot checks of theirmachine showPCB levels around "'100ppn, compared to a range of 210 to 1400 ppm in 1976 and 1977**. It is therefore likely that the average concentration ofPCBs in hydraulic fluid 

# --J.. is betw=en 100 ppn and 500ppm if the single groupofdie casting machines known to contain 50% PCB fluid is excluded as a special case. If the average densityof the presently used hydraulic fluid is ten pounds per gallon, the total arrount ofPCBs in use in hydraulic systems may be 

# .I(630,000 gallons x 10 lb pergallon x 100 ppm to 500ppm PCBs

## = ) 630 to 3150pounds ofPCBs.

*Letter fran W. R. Johnson (General Motors Corporation) to EPAdated

August 7, 1978. **Letter fran Hugh Thanas (Outboard tvlarineCOq:oration) to EPAdated August 3, 1978.

9010.2 Requirements of the PCB BanRegulation Continued use ofhydraulic systems contaminated with PCBs in
excess of 50ppm 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 byJuly 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 50ppm PCBs must,have the special PCB label applied.
o Retrofill: Retrofilling or topping off with a hydraulic fluid containing less than 50ppmPCBs is required within 6 months after any test which shows that the concentration ofPCBs exceeds 50ppm. o Disposal ofcontaminated fluid: Hydraulic fluid containing over 50ppm PCBsmust be disposed ofby incineration in special approved PCB incinerators or by incineration in other facilities such as high efficiency boilers approved by the EPA Regional Mministrators. 'Ihismaterial 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 ofhydraulic fluid contaminated with more than 50ppm PCBs. o DisfOsal ofcontaminatedmachine after liquid is drained for incineration: Essentiallynot 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 ppmPCBs, the hydraulic system is. flushed with clean solvent. o Reclaiming ofcontaminated hydraulic fluid: Hydraulic fluid contaminated withmore than 50 ppm PCBs may be reclaimed for reuse in the owner's hydraulic systems only if it is treated to reduce the concentration ofPCBs to below 50ppm. Reclaiming for purposes ofresale is banned unless this activity is exempted by the EPA. 10.3 Cost Impacts of**G~e** PCB BanRegulation Testing: Host of the hydraulic systems that once used PCB based fluids have since been refilled with fluids based on phosphate
91esters. Analysis ofphosphate esters for the presenceofPCBs requires a

..... 

# ------- rather time consillning**treab~nt** of the sample and extraction of the PCBs' before injecting the prepared sample into agas chromatograph. In their written camnent dated August 3, 1978, to the EPAon 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

### deequipnent is set up to specifically analyze for PCBs. Laboratories which wouldonlyoccasionally analyze such samples would probably incur costs exceeding $300 per sample." Only seven of the 50 systems checked byArmco 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. Asmany as 2500die-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 ofcontamination from the use ofreclaimed fluid. The costof the required sampling and analysis program will include sampling and administrative costs ofperhaps $20 Fer system in addition to the laboratory costs ofperhaps $250. Costs for the analysis program required byJuly 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 continuallydecrease in the hydraulic systems because ofretrofilling, leakage, and replacementof tOe 

### tIUld, it is expected that the**ooncent~ation** ofPCBs in almost 

### all**s~** will have decreased to less than 50**p~** by the end of the five 

# -- years authoriZed for continued use ofcontaminated system, and that the**~ting** requirements would not apply to the systems after that time.---

92Retrofill: Based on the experience report.ed by GN and Armco, it is expected thatITDSt 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 capacityof about 400 gallons. Armco stated that the Versar estimate of$14 per gallon for retrofilling wasreasonable;* GM estimated thematerial cost alone to be $17 to 819 pergallon;** Outboard**Ma~ine e~timated**  a cost of$8,000 for a 350 gallon system, or an average of $23 pergallon.*** 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 byboth Armco and**~1,** such a retrofilling programmight be expected to reduce the concentratIon ofPCBs 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 fewcases 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 50ppmmayresult in lowering PCBs levels below 50ppm without incurring the costs ofdraining and refilling the entire**syste~.** Disp?sal ofcontaminated 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 ppmPCBs. Themost recent available price for this incineration is $55 per 55 gallon drum (Rollins, 1978) plus drumcosts of perhaps $15 per drum, transportation of $.02 per pound, and drumdisposal 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 franW. R. Johnson (General Motors Corporation) to EPAdated August?;, 1978.

. . ***Letter fran Hugh Thomas (Outboard Marine Corporaticn) to EPAdated August 3, 1978.

93fluid. If all of the fluid in the calculated system capacityof 630,000 gallons required special disposal because of this change in the regulation, increased disfOsal costs of (630,000 gallons X10 Ib pergallon x $.22 per pound

### = ) $1.4million would be incurred. If the use ofcontaminat.ed reclaimed fluid has resulted in an increased numberof systems contaminated with PCBs in excess of50 ppm, this disfOSal cost might increase by a factor of 2or 3 ormore. Therequired retrofilling will generate a quantity of liquid equal to the calculated systsn capacity, resulting in an additional disfOsal costof$1.4 million. Theregulations 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 boilersmight lower the disposal costs substantially, but no estimate can be made of the resulting decreases in disfOsal costs. Marking: Therequirement, that the special PCB label be applied to systems found to contain from 50 to 500ppn PCBs should nat costrrore than $2 permachine. Evenif (as an upper bound estimate) 2500 such contaminated systems**\~re** found, total labeling costs wouldnot 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 shipped for dispoaal, At a costof $2per 55-gallondrum, labeling costs for disposal couLdtotal (630,000 gallons x 2/55 gallons per drum x $2per label

## = ) $46,000. Special storage areas: Liquids contaminated with 50 to 500 ppm PCBs will be allowed to be stored in drums in temporary storage areas prior to disposal ifa Spill Prevention, Control andCountermeasure Planhas been prepared for the temporary storage area in accordance with 40CFR 112.

94There is no information available in the record that i;,Duld supcort; an estimate of the numberof additional SPCC plans that would have to be prepared under this requirement. 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 someof the 200 firms will therefore have to prepare SPCC plans covering temporary storage areas for PCB contaminated liquid. Disposal ofcontaminatedmachines: It is not anticipated that anyof 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 BanRegulations. Recycling ofcontaminated hydraulic fluid: Newphosphate ester based hydraulic fluid costs about $7.60 per gallon (Versar 1978, p. 68). According to the commentsof**Q~,** the following treatment techniques have

.been found to be incapable ofreducing the concentration ofPCBs to below

50PPn: PAC carbon filter, Florsil filter column, and clay. Openair distillation ofcontaminated phosphate ester fluid resulted in excess oxidation ofthe fluid. Outboard Marine has described a vacuumdistillation procedure which reduces the PCB contentof the hydraulic fluid by 50% at a cost of $3.75 to $4.00 per gallon*. rA.r. Faber Damiani ofRAIX::O Industries in his oral commentsat the August 25, 1978 hearings, described in general terms a fractional distillation process that is "effective in removing PCB. In fact, a numberofruns were madein which PCB concentration was reduced to below 50 PPn." tvlr. Damiani stated thatRAOCO has not developed a process that will reliably reduce the level ofPCBs to below SO ppmand that their present process achieves a reduction to 100 PPn. He stated that the result of a 50ppm 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 amountofcontaminated fluid is available for recycling once peryear 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 BanRegulation. 95gallons 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 ppmPCBs,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 withrrore than 50 ppn KBs maycontain from 630 to 3150 pounds ofPCBs. 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 requiremake-up fluid equal to their vo.lume each year, the losses of KBsprior to the retrofilling mayequal 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 ofPCB. 10.5 Summary - Economic Impacts Testing: 1979 1980-1984 $460,000 to 1,350,000 $1,000,000 total

96Retrofill: Disposal of fluid: t4arking: Special storage areas ofSK:Cplans: Ban on recycling contaminated hydraulic fluid: $10,800,000 to $17,600,000* $1,400,000*, ** $46,000
Insufficientdata 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 PoundofPCBs 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 perpound PCBs *Maybe significantlyhigher ifthe use of reclaimed hydraulic fluids has

contaminated hydraulic systBns that never used PCB based fluids. **May be somewhat; reduced ifEPA approves alternative incinerators for hydraulic fluids.

9711.0 HEAT**TRfu~SFER SYSTD~**  11.1 Present UseofPCBs in Heat Transfer Systems In his letter to the EPA dated August 4, 1978, Mr. W.R. Corey of Lvbnsantoestimated that there were

# § heat transfer

### svst~~ using PCB based fluid in 1972 when Monsanto discontinued sales ofPCBs for those systems. Areview of a Monsanto customer list, however, indicated that sales ofPCB heat transfer fluids were madeto

### ~ferentcom~anie;) during the years 1970 and 1971 (Versar, 1978, p. )6). Mr. Corey estimated that one halfof the heat transfer systems had capacities between 50 and 500 gallons and that the other halfhad 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 ofheat transfer liquid 

# ---- during 1970 and 1971 was 8.2 million pounds, or enough liquid to fill about 550 average systems. TOtal use of PCBheat transfer liquid in the United States since 1929 has been estunated at 21 million pounds, including both newinstallations and makeupfluid (Versar, 1978, p. 75). Mr. Corey ofMonsanto estimated that over 90% of the heat transfer systems using PCBs were converted to alternative non-PCB fluids in 1970-72 and that current systemPCB levels in the industry range from around 100 ppm to three percent. Mr. Jack Pulley ofDow 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-PCBheat transfer fluid. Data is also available for one other heat transfer systen that contained 14,000 gallons ofPCB based fluid. Draining and flushing prior to**replace~nt** of the liquid reportedly reduced the concentrationofPCBs to twopercent (Versar 1978, p. 76). Monsanto and Dow Corning agreed t it is technically infeasible to reduce-r:De concentrationofPCBs in contaminated systems to below 50ppm. 11.2 Requirements of the PCB BanRegUlation All heat transfer systems that ever used PCB based fluids will be considered PCB articles because their surfaces are presently in contact

98with a liquid containing over 50ppmPCBs. These systems will be allowed to remain in service until July 1, 1984, subject to the following conditions: • Use: After October 1, 1979, noheat transfer system containing a liquid with a PCB concentration above 50ppm maybe used in the manufacture or processing ofany food, drug, or cosmetic.

• Testing: Required byJuly 1, 1979, for all heat transfer systems that ever contained a PCB basedheat transfer fluid.**Syst~~s** must be retested within three months after each time the fluid is replaced to reduce the concentration ofPCBs to below 50ppn, Records ofall tests must be kept for five years after the concentration ofPCBs is reduced to 50ppn.

• Retrofill: Within six months following any test that indicates the presence ofmore than 50ppmPCBs in heat transfer fluid, the fluid must be drained and replaced with fluid that contains less than 50ppmPCBs. Tbpping off that results in reduction ofPCB 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 of50 ppm.

• Disposal ofliquid containing over 50ppnPCBs:. For liquids withgreater than 500ppmPCBs, 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 ofPCB contaminated heat transfer fluid.

• Disposal ofcontaminatedmachine after liquid is drained: High temperature incineration required in an approved PCB incineratorordisposal ofmachine in an approved chemical waste landfill. 11.3 Cost Impacts of the PCB BanRegulation Testing: 'Ihe liquids used to replace the PCB based heat transfer liquids may be analyzed for PCBs by a method similar to that used

99to analyze for PCBs in transformeroil. Thecostof such an analysis should be about the Sillne as the price of $60 per**sa~ple** previouslyquoted byVersar for the transformer oil analysis (Versar 1978, p. 41). Sampling and order handling costsmight increase this cost to $100per sample, or a total of $45,000 to $60,000 for the analysis required byJuly 1, 1979, on the 450 to 600 contaminated systems presently in use. Additional testing required within threemonths of each system retrofill is included below as part of the retrofill costs. Retrofill: Theregulations require that the concentration of PCBs in heat transfer systems be reduced to less than 50ppn byJuly 1, 1984. M::>stof 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 newreplacement heat transfer liquid will cost about $8 pergallon.* Disposal ofcontaminated fluid containing over 500ppm PCBs in an approved PCB incineratorwould cost from $1.20 pergallon (in tank truck lots) to $2.10 per gallon (in 55 gallon drums) (Rollins, 1978). TransfOrtationwould add about $.02 perpound or $.16 per gallon to this cost (Versar, 1978). Since one-halfof the systems have capacities ofover 2000 gallons, 80% of the liquidmay be in these large systems which would generate truckload lots offluid when drained. The average disposal cost would therefore be $1.54 pergallon, including transfOrtation. Incineration costs for liquids contaminated with less than 500ppm PCBs were quoted at about one-half the rate for the more contaminated liquids (Rollins, 1978). This would be equal to a cost of$.81 per gallon, including $.02 perpound transportation. Ifeach systemwere drained every six months of90% ofthe 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 gasketmaterial woul.d have a chance to diffuse into the liquid between retrofills. Eachdraining would therefore rerove 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 fromW. R. Corey (Monsanto) to EPAdated August 4, 1978.

100ppm 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 600gallons

### = ) 585,000 to 780,000 gallons. The cost to reduce the concentration ofPCBs from the present 2% to below 50 ppm will be 

### SIS million to $20 million as calculated in Table 11.3-1. Since each systemmust 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: Tnemarking ofheat 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 ofPCB mixture from 500 ppm to 50 ppm in the Ban Regulation is not expected to change the number ofheat 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 ofthe BanRegulation wiLl. be to add this requirement to the disposal ofthe liquid fram the third retrofill. If four labels are required permachine @$2, total additional labeling costs will be (450 to 600machines 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 BanRegUlations. DisFOsal ofHeat Transfer Systems: There is no information in the record that will support; any estimate of the number ofheat transfer systems that will be scrapped before they are decontaminated to PCB levels below 50 ppn,

101Table 11.3-1
CostofRetrofilling Heat Transfer**Syst~~s**

to Meet 50 ppmLimiton PCB Concentration
Number of contaminated systems

xAverage SystemCapacity

=TOtal quantityof fluid


### xWeight per gallon

x Concentration ofPCBs



### =Pounds ofPCBs in fluid

.First Retrofill

Total quantityof liquid

x Drainage efficiency



### =Gallons to be di.spoaed ofand replaced PCB Content @2% Costofreplacement fluid @$8.00/gal
+Costofdisposal @$1.54/gal
+Labor @16 hours/system @$15/hour



### =Total costof first retrofill Second Retrofill PCB content @ 2000 ppn 'lbtal costof 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 $6,840,000Table 11.3-1 (Continued) 'Ihird Retrofil1 PCB content @200 ppn Cost ofrep1ace:nent and labor
+Costofdisposal @$.81/gal



### =Total costof third retrofill
'Ibta1 cost to reach 50 ppn 'Ibta1 1bs PCBs reroved

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 PCBsHowever, sincedisposal ofmachines containing fluid with more than 500ppm PCBs wasrequired by the Disposal and Marking Regulations, the BanRegulations 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 500ppm be disposed of in approved chemical waste landfills wouldhave 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 volumeofmaterial 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 costof $3 percubic foot (Versar 1977, pp. 2-13)• Because of the uncertainty in this estimate, actual disposal cost might be considerablyhigher than this figure. All of these costs would have been incurred, under the requirements ofthe 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 ofpump seal leaks and accidents. The remaining amounts ofPCBs 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 amountofPCBs entering the environment to 2% of the 93,600 to 124,800 pounds presently in the machines, or by 1872 to 2496pounds.

10411.5 Summary -'" Economic Impacts Testing: Initial Following retrofilling Retrofill: Dispoae.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 Prior 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 numberof 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 fewof the machines.* 12.1 Requirements of the PCB BanRegulation Gompressorscontaining a liquid contaminated withmore than 50 ppn PCBs may be used until May 1, 1980, provided a KB label is applied to each contaminated machine. 'Ihese compressors maynot be used afterJanuary 1, 1980, unless they have been decontaminated to a level below 50 ppn PCBs. 12.2 Impacts of the PCB BanRegulation Versar previously estimated that there were r;erhaps ten compressors that would be affected by the proposed PCB BanRegulations and stated that ColumbiaGas and Texas Eastern had been contacted for additional information on the number of contaminated compressors and the cost and feasibility ofdecontamination (Versar 1978, p. 78). In his letter to the EPA ofAugust 4, 1978, Mr. Willard Young of Texas.Eastern Transmission Corporation stated thatTexas Eastern would be able to reduce the level ofPCBs in their canpressors to below 50ppn by the end of 1978 "by another cycle ofdraining, flushing, and installing new lubricants. II He did not include any information on the cost of this procedure or the nuwber ofcompressors requiring decontamination. In his letter to the EPAofAugust 4, 1978, Mr. RobertWelch, Jr., ofColumbia Gas SystemService Corporation stated that forced shutdown ofcompressors on January 1, 1979, could have a significant effect on the *Letter fromWillard 

### T. Young (Texas Eastern Transmission Corporation) to

EPAdated August 4, 1978.

106delivery ofnatural gas, "depending on the numberof 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.** Welchdid 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 ofcontaminated compressors. Since Texas Eastern apparently will be able to meet**L~ese** requirements, total direct costof 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 amountof FeBspresently in use in compressors. 'ilierefore, no estimate can be madeof the amount that will be controlled by the regulation. 12.4 Summary

- Economic Impacts Decontamination costs -- $200,000

10713.0 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. Atotal of 2,376 million gallons of newoil 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 ofnew (virgin) refined oil and availability of used oil for recycling are presented for**L~e** year 1975 in Table 13.1-1. Datagenerated by ReconSystems** 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 ofVersar, 1978. The EPA

promulgated the rules affecting the use ofreclaimed oil with essentiallyno 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).

108Table 13.1-1 NewOil Usage and Waste Oil Availability for Recycling in 1975*

U. S. Sales Fraction Used Oil 1975 -6 Available** Available Type of Oil OutletorUse (gal x 10 ) for Recycle for·Recycling Autonotive Lube Oil Service Stations 239 .63 150 CommercialEngine Fleets 225 .50 112 NewCarDealers 103 .90 93 Auto Fleetand other LubeOil Uses 151 .50 75 Retail Sales for: COI:lllrercialEngines 95 .63 60 Garages, Auto Supply Stores 90 .63 57 Discount Stores 250 .22 55 Factory Fills (Auto & FarmEquiprrent) 54 .90 49 Subtotals 1,207 651 Industrial &Aviation Lube Oils Hydraulic &Circulating SystemOils 314 .42 132 Metalhbrking Oils 145 .70 101 Aviation & Other 147 .50 73 Gas Engine Oils 60 .90 54 RailroadEngine 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 byU. S. ·GoVe.rnm2nt 32 .50 16 GRAND TOI'ALS 2,376 1,154***~'1einstein,** 1974 (as cited inVersar 1978, o , 81). **Fraction available for recycling afte::- losses in use and to environrrent.

109control 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 ReconSystems' estimates for 1970-71, may be as much as 60percent of that 9roduced. Aflow chart showing the distribution and utilization ofwaste oil in the United States, based on the 1970-71 data ofReconSystems, is presented on Figure 13.1-1. Summary data for disposition and usage fran Figure 13.1-1 are as follows:* Fate ofOil After Primary Use Used as fuel Dissipated to environment and waste disposal Applied to roads Re-refined lube oil products Percentage ofNew Oil Production 41.5
42.3 12.9

3.3 100.0 Thegeneral distribution shownin Figure 13.1-1 is believed to be valid at present, although the magnitudes of the specific flows have fluctuated as prices ofvirgin lube oil and fuel oil have varied. The value of fuel oil has increased since 1970-71, and virgin lube oil was scarceduring the period of the Arab boycott and during a portion of the period ofprice controls. One result of these factors has been increased use of waste oil as fuel, eitherby 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.

110APPLIEDTO USEOASFUEL ROADS 

# ,... 1358.10'GAUYR I 17&.10'GAUYRJ

REMOI/EDFROM USfDAS

EOUIPMENT COLLfCnDFOR WASTEOIL FUEL RECYCLE

- PROCESSORS·

. AAERUSE 

# - 600FIRMS 200FIRMS 1610x10'OAUYRI SALES Ul1illl(fGAUVAJ ($Ol.lo-GAUYR) 063x10"GAUYRJ IUl4.100GAUYRJ



### . PRODUCTIONWASTES. REREFINERli

. SPILLS DlSSIPAi-fOT_OTHE JOflRMS ENVIRONMENT. PROCESSWASTES 1246.10'GAUYR I WASTE ANDsnus DISSIPATEDTO tlJ8• 10'GAUYR I 

# ...... TODISPOSAL HIEENVIRONMENT lUSh 10'GAUYRJ In. 10'GAUYRI li7B •10"GAUYR I

REREflNfDtUBE OILPRODUCI'S APPLIED TO

ROADS lal II.10-'GAUYR) 120.10"GAUYR I**r-~** PHOOUCIIONOf

I/IRGINOII. f24iO..1U'GAl/VRj

f-' f-' f-'

SOlJRCE;ADAPTEDFROMTABlE2fl.P.1280FWEINSTEIN.1S74

### * 'FIGURE 13.1·1.DISTfUBUTIONANDUTILIZATIONOFWASTEOil IN THEUNITEDSTATE.SDURING1970·71

*Cited in Versar 1978, p. 82.aviation facilities are also significant sourCeS. Asignificantly larqer fraction ofavailable 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 productpipelines are a locally significant source of waste oil for collection. Theuse pattern ofprocessed or re-refined waste oil is extremelydiffuse. 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). Asmall portionof 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 ofused hydraulic oil,performedprimarily by four companies, results in a product which is marketed as hydraulic oil. 13.2**Requir~~ents** ofthe Proposed Regulations Thedisposal ofoil contaminated with PCBs in excess of 500ppm wasregulated by the 

### res Marking and Disr;osal Regulations (BPi\. 1978a). The PCB BanRegulations! change the definition ofPCB 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 of50ppnmust 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 50ppmmay

### be processed for any use including fuel orreclaimed lubricating or hydraulic oil, but itmaynot be used as road oil or as a constituent ofany sealant, coating, ordust control agent.

11213.3 Sources and AmountsofContaminatedWaste 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 deepmining**equip~ent** where the use ofPCBs resulted in greater fire safety. Although hydraulic systems are nominally air-tight, leaks may occur atdynamic seals, and major spills mayoccur due to hose rupture. tbrrnal leakage is collected in drippans, 'The rupture of a hose can spray hydraulic fluid over a large area due to high operating pressures. It has been estimated that 80% ofphosphate 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 rather than shut the systemdown, 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. wnenMonsanto discontinued manufacturing PCB-basedhydraulic fluids in 1971, they did not**reoan~end** draining or flushing ofhydraulic 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 nowcontain replacement fluids contaminated with 0.006 to 50% PCBs as discussed in Chapter 10. 'The total amount ofcontamination is a function of the system leakage and dilution during the past 

### Eive years.

*U.S. Department ofAgriculture Ad Hoc Group on PCBs. Agriculture's

Responsibility Concerning Polychlorinated Biphenyls (PCBs) Washington, D.C. OfficeofScience and Education, 

## u.s. DeparenentofAgricultrue, 1972 (as cited in Versar 1978, p. 84). 

## **Lapp, T.W. (Midwest Resarch Institute), The Manufacture and Useof Selected Aryl and Alkyl Aryl Phosphate Esters, EPA 560/6-76-008, Feb. 1976, p. 77 (as cited in Versar 1978, p. 84).

113ApDLtion 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 ofhydraulic 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 amountof used oil collected for Leuse in 1970-71 was about 900 million gallons per year, with an additional 600 million gallons used internally fOL fuel or dust control on roads (Weinstein, 1974). Thus, about 60 percent of the amount ofnew 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 wasstudied on a limited basis by the EPANational Enforcement Investigation Center (NEIC) in Denver.

### * Samples ofoil were taken from selected t.ank truck lots of used oil that had been collected in Virginia, t1aryland, and NorthCarolina. This oil had been delivered to Continental Forest Industries in Hopewell, Virginia, for use as supplemental fuel in a stearn boilerof apapermill. 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 *TestimonyofRobert Magruder, (Continental Forest Industries) presented at

the U.S. EPA informal hearings on the PCB ban regUlations atWashington, D.C., July 15, 1977.



### 114oil 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. ThePCB contaminationof 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 mayalso have been added to automobile transmission fluids to control the swelling ofoil 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 permillion in reclaimed oil used to lubricate whetstones.** 13.4 Compliance Costs Collection ofany 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 ofPCBs will be considerably higher than the costs quoted for transformer oil because naturallyoccurring sulfur and chlorine canpounds in petroleumoils 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 inVersar 1978). **Weems, George, (United States Departmentof Interior, Denver, Colorado), "Polychlorinated Biphenyls," File HIS 3-3-10h, June 13, 1977 (as cited in Versar 1978). ***Hofstader, R. A. (ExxonResearch and Engineering Co.); Lisk, D. J., Bache, C. A. (Cornell University), "Interference in the Electron-Capture Technique for Determination ofPolychlorinated Biphenyls by SUlfur-Containing Compounds inPetroleumProducts", Bulletin of Environmental Contamination and Toxicology, Vol. 11, No.2, 1974 (as cited 

### inVersar 1978).

115presence ofPCBs. ThePCB components can onlybe resolved through complex clean-up procedures or the use ofgas 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 peryear (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). Theproposed ban regulations would forbid the use ofoil containing detectable @nounts ofPCBs 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 'Hith used IT'Otor oil. Although virgin nntoroil 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 reported analyses of waste oil for FeBswas basedon 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 ofeven "simple" tests at $70 per sample. Prospective road oilers therefore would be safer using waste oil ifthey take precautions to ensure that it does not contain industrial oils (and certainlyno 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 considerablerronetary and energy cost where the customer is willing to pay the increased price. At an average price of $.375 per gallon for #2 fuel

116oil vs $.08 pergallon collection costs for**us~d** crankcase oil, the cost ofroad oiling woul.d increase (.375

- '.08) x 139 million gallons

### =$94 million peryear (Versar 1978, p. 87). (2) Use synthetic road stabilization chemicals which both reduce dust and provide surface stabilization. The increased costof this type ofmaterial is presentlyoffset by lower road maintenance costs on heavily traveled dirt roads atmines and other industrial facilities. Savings in maintenance on lightly traveled roads 'tX)uld be less significant and 'tX)uld only partiallyoffset the increased material costs. Atypical synthetic fiEterial is Coherex®, manufactured byWitc6 Chemical Corporation. Thismaterial 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 ofone 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 bemore or less expensive than the use ofused motor oil depending on the local supply and price of the used oil. The present choice between the use ofused oil and syntheticmaterials apparently depends on local supply and cost conditions. The total cost resulting from an effective ban on the use ofwaste oil \vould certainly be no greater than $31.7 million peryear, 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 nvitco Chemical Corp.) to EPA dated September

23, 1978.

117Table 13.4-1 Cost ofSubstituting 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: UsedOil: 1/2 gal./yd.2 @.08 to .30/gal.* Equals: Increased Cost (Savings) per sq. yd. x 14080 yd2permile ofroad, 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 byVictor Shepard (Witco Chemical Corp.) for supplies ofused oil. Letter to EPAdated September 23, 1978.

118Users 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 maymore 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. Astrict enforcement; policy with occasional all-out efforts to find PCBs in waste oil could prevent its use as road oil. Diversion ofwaste 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 mightgo 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: Ifcollectors 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.uniti.es to the collectors. Processors: Waste oil for fuel use should become more plentiful as use for road oiling is discouraged or made irnpos si.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;'lasteoil 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).

119used as a supplemental fuel with coal. This use recovers the fuel valueof theoil 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 ofwaste oil with coal in boilers is relatively troublefree, this use is probably very elastic. If coal burning plants can absorb the increased supply, M1ichseems 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 extentof6000 ppn (Chapter 10). In most cases, the reclaiming process renoves norrore 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. Thepresent status ofPCB reduction technology is discussed in Chapter 10. Industrial Waste Oil Generators: Those industries whosewaste oil contains more than 50ppnPCBs willhave to incur dispoaal, costs ofup to $.75 pergallon (seeChapter 6). Evenindustrial oil cont.aminated with less than 50 ppmPCBs may be avoided by waste oil collectors. This may not be amajor problem for canpanies that have large high efficiency boilers. Oil burning boilers can use amixture ofwaste and virgin oil. Mr.**~'1agruder** ofContinental Forest Industries indicated that up to 14 percent waste oil mixed with #6residual oil is feasible.** TheresultInay be the development ofa separatemarket for industrial oil with low levels ofPCBS 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 ofoil containing anymeasurable amounts ofPCBs as a coating ordust control

*Telephone conversion, Dwain Fowkes (RAOCO Corp,') with L. Fourt (Versar),

September 19, 1977 (as cited in Versar 1978, p. 90). **Testii'T\Cmyon Robert ivtagruder (Continental Forest Industries). Presented at the U.S.E.P.A. informal hearings on the,PCB BanRegulations at Washington, D. C., July 15, 1977. 120agent will affect only those waste oils that contain less than 50ppmPCBs, since the disposal of the lnorehighly contaminated oils is controlled by other provisions of the regulation. Theonly 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 wasobtained, and diversion of transformer oil and contaminated industrial oils to high efficiency boilers might significantly reduce the concentration ofPCBs in the remaining waste oil. However, if it is assumed that all of the oil affected by this provisionof 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 + 54million 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 newlubricating 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% thathas been used on roads will control (.129 x 66,176 pounds PCBs

### = ) 8537 pounds ofPCBs. If this oil is used as fuel and re-refined as lube oil products in the sameratio as above, (41.5/(41.5+3.3) 

### =) 93% will be used as fuel and 7% will be re-refined. About one halfof 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 peryear of PCBs used on roads to fuel use. Since many of the boilers using this oil maynot 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 ofPCBs 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 ofPCBs 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 costof obtaining adequate supplies of segregated used rrocor

### oil after level of !?CBs in used rotoroil drops belowdetectable**lL~its.** $0 

### to 31.7 million/year

$0to $6.4 million/year 13.7 Cost PerPoundofPCBs Kept fromthe Environment Cost 

### perpound

## = 

## oto $31.7 million

### peryear

# = 8073pounds/year 

## ato $3925 per pound!?CBs

12214.0 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 ofpigments, a newaluminum 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, inmost 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 ppmPCBs, though there is considerable doubt concerning the validityof 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 maybe contaminated below 50 ppm; again, however, the analytical method has not been validated.
*"Main Canments of DryColor Hanufacturers Association " dated August

7, 1978, p. 16. **Testimonyof the Dry ColorManufacturers Association at the PCB Manufacturing, Processing, Distribution in Canmerce, and Use Bans Hearings, Washington, D.C. August 30, 1978. ***Oral cest.inony ofArthur Hopmeier, (Phthalchem Inc.), at the PCB Manufacturing, Processing, Distribution in Commerce, and Use Bans Hearings, Washington, D.C., August 30, 1978.

123Imports ofblue crude, primarily fromJapan, supplied over 56% of the U.S. market in 1976.* In addition, low-PCB crudes are currently available in canmercial quantities from at leastone 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 wasof inferior quality.*** Diarylide pigments: Diarylide yellow, orange, and red pigments are made byreaction ofprecursors which includedichlorobenzidine as an essential component. Aminor side reaction results in the decomposition of**G~e** dichlorobenzidine to produce 3,3'- dichlorobiphenyl.  Sales ofdiarylide pigments in 1976were about 9,760,000 pounds with a value of$41 million.** ** There are currentlyno 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% ofall yellowpigments produced in the United States.  Aluminum smelting: Alcoa has developed a new smelting process which inadvertently produces over 50ppm ofdecachlorobiphenyl.** *** The PCBs are produced in a preliminary step involving the production of aluminumchloride 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. aluminumchloride to produce metallic**alu~inum.** *Oral testimony ofArthur Hopmeier, (Phthal.chem Inc.) at the PCB

Manufacturing, Processing, Distribution in Camnerceand Use Bans Hearings, Washington, D.C., August 30, 1978 **L€tterto EPA fromW. C. Parle, (Hamon Colors) July 11, 1978. ***Oral commentsofHugh 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 DryColorManufacturers Association

... II dated August 7, 1978, Table 3. ** ***Information on this alurrunum,smelting process and the resulting PCBs was taken from the letter fromJames S. Boyt (Alcoa) to EPA dat.ed October la, 1978.

124This process has several advantages over conventional aluminum smelting. These benefits include elimination of fluoride enissions, reduced energy consumption, and improved product purity. Theenergy savings possible with this process are considerable. Conventional smelting requires 8 KW11 per pound of alurninumproduced. This new process requires 4.5**~iJH** per pound, a savings ofnearly 44%. Using these figures, a 300,000 ton peryear smelter could save up to 1.95 million**~~** 

# peryear.*

I In addition, the production of the aluminumchloride 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 50ppn PCBs. 'Ihe Phillips process is still experimental and apparently involves the use ofPCBs 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 rrodified its process and "because of thesernodifications, the only time a concentration ofPCB in excess of50

### 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 50ppn ofPCBs. Theonly
uses ofPe'Es discussed at the hearings were a numberof applications in microscopy. 'Ihis use has been authorized. Similar applications involve the
use ofcertain**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 PetrOleumCo. 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 EPAdated August 7, 1978. *****I.etter from Elliott Stern (Tennessee Eastman Company) to EPAdated DecEmber 21, 1978. (Letter in record ofTSCA Exemption Docket;

## m. 1)
12514.2 Requirements of the PCB BanRegulations It is assumed here that none of the operations described above quali fy as being "in a totally enclosed manner." Therefore, the manufacture, processing, distribution in commerce, and use of any chenical containing over 50ppmPCBs (including phthalocyanin and diarylide pigments ana the products of the Alcoa smelting process) are banned 30 days after the dateofpromulgation of thePCB BanRegulation 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 lowlevels of PCBs will depend on the actions taken by the EPA in response to patitions 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 enforcementof the regulations begins. Alower 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 banwill 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: InterimProcedural Polychlorinated Biphenyls (PCBIS) BanExemption. II November 1, 1978, pp. 50905-50907.

126 Under Section 6ofthe Rules for

Federal Register,The processes in use by DowCorning, Alcoa, and Phillips Petroleum must cease 30 days after the rule is promulgated unless EPAhas 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 thatmanufacture crude phthalocyanine blue using trichlorobenzene as a solvent; they are American Cyanamid, Chemt ron, and Phthalchel1.* Phthalchem uses a mixed solvent systen which has trichlorobenzene as oneof 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 maycontain over 50 ppn PCBs although Phthalchempigment has consistently shown less than 50 ppmPCBs.** In the absenceof a valid analytical method for determining PCB levels in this material, however, this study will assume that all three companies mustrrDdify their processes. to comply with the regulations. Kerosene appears to be the most feasible solvent to replace trichlorobenzene. Mr. Arthur Hopneier' of Phthalchem testified that it would require 12 rronths and cost roughly $250,000 for him tomodify his plant.** Mr. Paul Malchick testified that the two Chemtron plants could be converted to the use ofkerosene solvent for a total cost of $1,SOD,000 but that considering the age and condition ofChemtron' s

*Letter from Arthur Hopneier (Phthalchem Inc.) to EPA - August 4, 1978. **TestimonyofArthur Hopneier (Phthalchem Inc.) at the PCB i'ltanufacturing, Processing, Distribution in Commerce, and Use Bans Hearings, Washington, D.C., August 30, 1978.

127equipnent, it woul.d be econanically sounder for them to spend $5,000,000 to construct a newplant.* 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 peryear**~ould** cost roughly $4.5 million. No datawere 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 .costfor 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 ofMichigan. It would cost Hamon Colors roughly $2 million to construct a newplant capable ofprOducing 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 Chemical, It appears that the diarylide pigments couldbe 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 MalchickofChentron estimated that it would cost $50,000 to modify their manUfacturing and, because the process modifications wil.l, put themout ofcanpliance with their.):IPDES *Testimony ofPaul Malchick (Cherntron) at the PCB Manufacturing, Processing, Distribution in Commerce, and Use Bans Hearings, Washington, D.C., August 30, 1978. **Testimony ofArthur 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 (HarmonColors) datedJuly 11, 1978.

128permit, an additional $250,000 will be required.* Two other canpanies estimate their cost for complying with a 50ppm limit as follows:** Canpany 1 2 Initial Capital Cost $750,000 $200,000 IncreasedAnnual 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 ofdiarylide pigments already contain less than 50ppn FeBs, one to twoyears will be required to reduce the level ofPCBs to below 50ppn in all of these pigments.** Themanufacturing cost estimates for both types ofpigments 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 50ppn 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 ofcontaminate] pigments presently in inventory. TI1ereis not enough data in the official record to support an estlinate of these costs, but the data which are presentdeseDTe attention and seem to indicate that these additional costs could substantially exceed the conversion costs.

*TestimonyofPaul Malchick (Cherntron) at the FeB Manufacturing,

Processing, Distribution inCommerce, and Use Bans Hearings, Washington, D.C., August 30, 1978, p. 126. **Letter to EPA from Donald Morgan, (Dry ColorManufacturers Association) dated August 7, 1978.

129In 1976,production and i.mports of phthal.ocyani.ne blue totaled 13,200,000 pbunds* with a value, after processing into pigments, ofroughly $87.6 million. Import.s ofblue crude (not pigment), primarily frau Japan (85%), supplied over 56% of the U.S. market in 1976.** Themajority of the imports are high-PCB crude. IDw-PCB crude is being produced in ,Japan, but an increase in demandcould 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 .imported  

, .\ Sales for phthalocyanine and diarylide pigments in 1976 totaled $131 million. Tbtal sales of all organic pigments in 1976** ~ere** $261 million, compared with $200million for inorganic pigments. Thus, the two classes ofpigments inquestion account for over 25% of the domestic market. Thepercentage 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 companythat can no longer produceyellow and/or blue**pi~nents** maylose other portions of its sales because "customers demand a full line of colors.n**** Theminimum conversion time given at the hearings was 12months, 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.entia.l for substitution ofdifferent pigments types and the ease with which productionof low- or non-l?CB pigment could be expanded are not known, but it does appear *Letter to EPA frem ArthurHopneier (Phthalchem) August 4, 1978. **TestirronyofArthur Hor:meierat 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. ** ***TestirronyofDonald Morgan (DCMA) at the PCB Manufacturing, Processing, Distribution in Commerce, and Use Bans Hearings, August 30, 1978.

130that unports could not immediately fill any shortages. However, the available information indicates that extensive ink, dye, and paint reformulation will be required, equipnent; mayrequire 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, itmaybe necessary to test each batch ofpigment 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 maybe occasional batches with higher concentrations due to mechanical failure oroperator error.* In addition to the testing, production ofa 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::>lloColors cnemtron HarmonColors Phthalchem 

### Pope Ridgeway Color and O1ernical Sun Chanical

*Ietter fran Paul Malchick (01emtron) to EPA dated August 3, 1978.



### 131It is also assumed that each ccmpanywill 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 oneman-weekper 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:npanywill be assumed. The total expense for the eight companies listed using the above figures is $19,200. If EPAgrants themanufacturers 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 ofdilution ofmaterial containing rrore than 50 ppmPCBs, 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 EPAmayhandle the labeling prob.Iem, Therefore, no est.imat;e can be madeof the resulting economic impacts ofthese provisions ofthe regulations

. Other**ch~micals:** No information exists in the record to support any estimate of the liupactof the ban regulation on canpanies such as Alcoa and Low Corning that are inadvertentlymanufacturing :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 PCBsControlled 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 peryear 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 ofdairylide 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 ofPCBs entering the environment by (9,760,000 pounds pigment 

### x (95 ppm - 50ppm) 

### =) 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 Eto "Hain Canrnents of Dry Color Manufacturers Asoociation.•.. II

dated August 7, 1978. **Letter from Arthur Hopneier (Phthalchetll Inc, ) to EPA dated August 4, 1978.
133IDwerBound: Exemption applications Aluminum smelting Chemical manufacturing $ 25,600

data tb data· data 14.6 Cost Per PoundofPCBs Kept from the Environment
Phthalocyanine**pigrr~nts** $425,000/*7ear

_ 544 pounds

## year- $781 per pound PCBs
Diarylide pigments $133,000* 

### + $34S,000/year 

## = 441 pounds/year $1084 per pound PCBs

*Tendollars as initial expense is equivalent to continuing annual costs of

onedollardiscounted at 10%.



### 13415 . 0 SPIu, MATERIALS: 50 ppnTO 499 ppnPCBs 'The change in the definition of "FeB" from 500pflnto 50ppn will require thatmaterials 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 ofmaterial that will be transported to these landfills as the result of this change in the regulation. Disposal ofPCB contaminated material in approved landfills has been report.ed to cost $3 per cubic foot (Versar 1977, p. 3-7) and transport.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 costofdisposal will be ($5 per cubic foot/(lOO pounds per cubic foot ofdirt x 275 ppmPCBs) 

### =) $182 per poundofPCB. This figure could be lower in some cases ifEPP>. approves alternative disposal methods in response to specific petitions for exemption from this portionof the disposal regulation.

13516.0 CAPACITOR MANUFACTURING 16.1 Present UseofPCBs 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 ofPCBs. No PCB power factor capaciGJrs were manufactured after late 1977, and there are no PCB capacitors of this type known to remain in manufacturers' inventories (Versar 1978, p. 99). Asurvey ofmanufacturers of industrial capacitors indicated that five**comp&~ies** (Lepresenting a 54% share of theffiaLket in 1976) were planning inmid 1977 to continue using PCBs into 1978 but to discontinue manufacturing PCB capacitoLs during 1978 (Versar, 1978, p. 103). 'I\vo of themanufacturers have provided additional data on their use ofPCBs 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 inventoryon October 1 of less than 100,000 PCB capacitors.* Universal t'1anufacturing Co. (13% market share) has estimated that its inventoD] ofcapacitors 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 CliffordTuttle (Aerovox Industries, Inc.) to EPA dated

August 15, 1978. **Oral commentsofN. RayClark (Universal Manufacturing Corporation) at the August 29, 1978 hearing on the proposed PCB BanRegulation.

136Table 16.1-1 Major Tyf€s**a~d** Uses ofPCB 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 powerdistribution systems.
Usedas part oflarge single phase A.C. motors (air conditioners, etc.). Usedas a component; 0f ballasts for fluorescent lights and high intensity discharge (i.e.,**~ercury** arc and sodium arc) fixtures.
As part of the circuitry in some'IV sets, microwave ovens, computers, etc.

*Source: Versar, 1978, pp 97-98.

13716.2 Requirements ofthe PCB Banrtegulation Manufacturing: The regulation bans the manufacture ofPCB capacitors. Distribution inCommerce: 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 ofthe PCB BanRegulation Manufacturing ban: Theeconomic impact analysis of the proposed PCB regulation esti.mated that non-PCB power factor capacitors woul.d cost 10% to 20% more than feB capacitors having the sameperformance characteristics and that the costof 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 ofRayClark who suggested that "perhaps in the overall, simply based on the difference ofdielectric 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 ofPCB 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 growrapidlyover the next few years because of federally mandated irnprovsnents in the electrical efficiencyofappliances, the total demand for capacitors and the total increased costs resulting from the ban on the use ofPCBs may be greater than these estlinates based on historical sales data. *Oral commentsofN. RayClark (Universal Manufacturing Corporation) at the

August 29, 1978hearings.

138Ban on Distribution in Comnerce: Thedemand 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 newequipnent containing PCB capacitors afterJune 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. Themaximwn inventory losses incurred by the manufacturers of PCB capacitors 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 sameexpected inventory losses as that percentage of annual sales anticipated by Universal, total inventory losses would be (.54 market share for all affected capacitormanufacturers/.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 companyto phase out the use of PCBs and because someopportunities mayexistduring 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 $2million, all oC0Jring during 1979. 16.4 PCBs Controlled by the Regulation 'lbtal consumption ofPCBs by the capacitor manufacturing industry was 21 million**r~w1ds** in 1975 of**\~ich** 45% wasused 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 loston rupture

### = ) 14,200 pounds PCB per year.

139of small capacitors woul.d be equal to (21 million rounds PCBs x 55% in small capacitors 

### x 0.4% ruptured in use x 15% leakout

### = ) 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 estirnat.eofhow 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 mayleach 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 costof non-PCB power factor capacitors: $5.5 million to $11 million per year. Increased cost ofnon-PCB industrial capacitors: $6.6 million to $18.9 million peryear. Inventory losses incurred bymanufacturers ofPCB industrial capacitors: $1 million to $2million (1979 only). 16.6 Cost Per PoundofPCBs Kept from the Environment
Power factor capacitors $5.5 million to $11 million per year 14,200 Ib/year = :;;387 to $775 per fOundPCBs Industrial capacitors



### = 6 million to $18.9 million per year 6930 pounds per year $950 to $2750 per pound

14017.0 l3AL'J ONTHE MANUFACI'URE OF NEW PCB TRANSFORMERS* Liquid filled transformers containing a PCB based liquidknown 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 inhazardous 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 thePCB based askarel , 17.1 Requirements of the Regulations The regulations prchibit the manufacture of

## new PCB transformers after December 31, 1978, but classify continued use ofexisting PCB transfonners, except those used in railroad locomotives, as use in a totally enclosedmanner. The regulations authorize certain minormaintenance of existing transformers butprd:1ibit major rebuilding of failed units. The impacts of the regulationon the servicing and rebuilding of askarel transfonners is discussed indetail inChapter 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 withminx manges fran Veraar, 1978. TheEPA

promulgated without change the proposed regulations that affect the manufacture of new PCB transformers.

141are listed inTable 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 inSeptenber, 1977, only onemanufacturer was still producing askarel transformers, and it planned to stop productionof 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 sameplants. Oil-filled transformers ar-e intercham-' 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 twopercent 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 optiumuse of the available non-PCBs transf'orrners, The choice arronq the available alternative transformer types and materials depends on the requirements ofeach specific applicaiton and the characteristics of the available non-PCB units.

142Table 17.2-)
U.S. Transfonner Manufacturers That UsedPCBs After 1970 Comoany Name NestinghouseElectric Corp.
General Electric Cormany
Research-Cottrell NiagaraTransformerCo. Standard 'I'ransforrne r Co.
HelenaCOI::p. Hevi-Duty Electric KuhlmanElectric Co. Electro Engineering**~~dks** Envirotech Buell R.E. Uptegraff !'lfg., Co. H.K. Porter
VanTran 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, Ca li.f, Lynchburg, Va. Vandalia, HI. Waco, TexasAnwnber 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 theirperformance 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 Codeas 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®, ifpresent transformer service tests are successful, and estimates that the pricewill 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 inhazardous locations without vault protection. Askarelwas essentially defined as a PCB based 1iquid, 'The 1978NEChas 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). Thehigh fire point liquid must have a fire point of at least 300°C, and must not propagate flames.

*Informationpresented byGE at ameeting with EPA Office of Toxic

Substances, June 21, 1978.

144Underwriters Laboratory presently 1ists three 1iquids as meeting thehigh fire point property requirements for transformers operati.nq at voltaqes 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?eof Fluid

, i
I:X:JW Corninq DC 561 Silicone f.X:JN Corning DC 200 Silicone GenenU Electric SF-97 Silicone Union carbide L-305 Silicone SWS Silicohes F-lOl Silicone SWS Silicones F-190 Silicone Rl'E Corporation RTEmp Hydrocarbon GulfOil O1emicals Co. RPDielectric Hydrocarbon Fluid Uniroyal PAo-20E Hydrocarbon

145Mineral oil-filled transformers: If fire safety were not a consideration, there would be no reasonwhy 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 samesize as the askarel units and are considerably lighter inweight. Also, mineral oil has somewhatbetterheat transfer characteristics than askarel, and an electric arc inmineral oil results in breakdown products that are non-corrosive. Themajor disadvantage ofmineral oil is fLammabilityr 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. FireUnderwriters does not approve of the use of oils and other flammable liquids for indoor applications. Whereoil-filled transformers are not specifically prohibited as on-site replacements for PCB-filled units, the National Electrical Code Umposes certain restrictions upon theirrrodeof 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 trans146formers are located outside the buiLdirq 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. Qeenair-cooled transformers: Transformers can be built without the use of a liquid cooli rq medium. Onetype 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 inprice to askarel-filled transformers of the samekVA rating. Hewever, open aircooled transformers are limited inbothheat capacity (which limits their ability to operate underoccasional overload conditions) and dielectric strerqt.h (which limits themaximumvoltage available). Theproblemof electrical insulation is even rrore severe if the open air-cooled transformer only operates intermittently. When the transformer is cper'atirq, the heat generatedwithin the windirqs 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, Openair-cooled transformers must be thoroughly dried before being put into service after. each cool period. Oneotherproblemwith air-cooled transformers is the tendency ofdust 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 conductivepaths and cause short circuits.

147Openair-cooled transformers are generally lindted to dry, clean locations where the load**~equirernents a~e**  fairly even and constant and where themaximum voltage does not exceed 30 kv, Such transformers are being successfully used in large office buildings, particularly tall buildings where the transformars 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'ower inChicago, 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 bymoistur-e and dust in open air-cooled tr-ansformer-s, but they ar-e similarly 1irnited in**ove~load** capacity because of reduced thermal inertia corrpar-ed to liquidfilled transformers. Closed gas-filled transformars must be installed inpr-essur-etight container-s because of changes in gas pr-essur-e caused by changes in tenperat.ure, However, themaximum voltage r-atings ofgas-filled transfOLmer-s can be equal to these of liquid-filled units. 

### Anumberof differ-ent gases have been used as heat transfermedia in closed gas-filled transformers, Themost camrongas 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. Heliumhas not been found to be a satisfactory gas for this application because its low dielectr-ic str-ength results in cor-onadischarges 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.

148Becauseof the necessity for a pressure vessel container, gascooled transfonners are 30 to 40percentheavier 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 expectedheavy load peaks ofpower consurrption. 17.4 Relative Prices ofNon-PCB Transformers The relative prices of distribution transformers of the size and type commonly installed inoffice buildings are summarized in Table 17.4-1. If the RTEmp® high fire point liquid-filled transformer proves to be acceptable for installationwithout auxiliary,fireprotection, there should be 

### nocost increases for new transformer installations resulting from the ban on themanufacture of PCB transformers. Thec:pendry type transformers
are also quite cost competitive with the PCB units for most applications.
Table 17.4-1* Relative Transformer Prices 'I)(Peo,fUnit Oil-filled PCB Non-PCB askarel Rl'Emp® Silicone q;>en air cooled Sealed gas cooled Price: 1000kVAUnit $15,300

19,900 19,000 18,400 22,300 20,700 30,600 Price: 2000kVAUnit $23,300

30,300 29,000 28,000 34,500 35,000 46,600

*Source: MGC Engineers, "DistributionTransformerStatus

- WIT Project."

Memorandum to U.S. General Services Administration, June 1, 1977, as cited inVersar 1978, p.116.

14917.5 Compliance Costs Clean-up costs: The only costs incurred by transformermanufacturers resulting-from the ban on the use ofPCBs will be clean-up and disposal costs of fl.ushirq PCBs fran storage and material handlirq equipment before using this equipment to storehigh 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 perplant, or a total one time cost impact of perhaps $100,000 in 1977 and 1978 (Versar 1978, p.117). Costof substitutes: Thehigh 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 theremay be an increase in the demandfor replacement transformers of 1000 to 2000units peryear. This additional demandshould be easily supplied since the transformermanufacturing industryhas 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 thehigh fire point transformer liquidmaterials and technology. Access to this market segment will open to those transformermanufcturers who did not offer askarel as an alternative to oil. This will primarily afford a marketing opportunity to RTE Corporationwhich has never supplied askarel units but which has a strong market position in thehigh 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 netdecrease in the sales by any of the other manufacturers. Increased fire losses: The presently installed R::B askarel transformers were installed at a premiumcost 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 ifan 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 alternativesmay costlnore 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 ofno more than 2% of the total fluid in the transformer. However, good clean-upof spills should limit the total losses to perhaps 5% of the total liquid vented. Useof R::Bs in transformermanufacturing was about 12million pounds peryear in 1975 (Versar 1976a, p.6). 'Ihe ban on use of PCBs in newtransformers will prevent the loss of (2% x 5% x 12million pounds =) 12,000 pounds of PCBs into the environn1ent from each year's production of transformers.

15117.7 Summary - Economic Impacts Transitional Costs: Clean-up costs for manufacturers Long TermCosts: Higher costs ofnon-PCB transformers 5100,000 1978 only.

$0 to $10 million fer year.
17.8 Cost Per PoundofPCBs Kept Fromthe Environment
Cost perpound = SO to $10million per year - 12,000 pounds per year $0 to $833 per pound PCBs

152Y, 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 BanRegulation (as distinct from the previously promulgated PCB Effluent Standard and the PCB Disposal and riJarking Regulations) are summarized in Table 18.1-1. 18.2 Long TermCost Impacts The costs resulting fran the ban on the manufacture of PCBs wil 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 BanRegulation are summarized in Table 18.2-1.
18.3 Cost PerPound 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 datawas available. These costs are stmrrarized inTable 18.3-1.

1531979 Item (C!lapter) Table 18.1-1 Transitional Cost Irrpacts $MillionPerYear Succeeding Years $Million Total Estimated Reliability ofTotal PCBTransfOl.lT'l2rs: IvlanufacturerClean UpCosts (l7) Ban on Rebuilding 

### (4)

Lost ServiceTime $ .1 9.6
2.4 

## o

**

** $ 

### .1 373 to 749

75 -50% + 500% 

### 2:50%



### 2:50%

/-J lJ1 ..s::..LocoTIDtiveTransformers (5) Retrofill Programto 6% Limit Retrofill Programto 0.1% Limit Analytical Costs Conpleteby Jan. 1, 1982 Ccrrp.Iet;ebyJan. I, 1984 Corrpleteby 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 EPAgrants exerrptions from the "distribution in comrrerce" ban. 

### *** 10 0 10 PCB Capacitors and Equipnent Equiprrent Redesign (16) Manufacturers' Inventory Obsolescence (16) Banon Sales ofEquipment afterJuly 1, 1979 (3)

Cost ofPetitioning 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 40years, probably increasing slcwly for 10 years and then decreasing slowly. ***May be**si~1ificantly** reduced ifEPA accepts class actionpetitions.I tern (Chapter) Table 18.1-1 (Continued) $ millionPerYear 1979 SuceedingYrs $ million total Estimated Reliability ofTotal Oil FilledTransformers (6) Banon Reclaiming Oil for Resale

Cost ofEquippingHighEfficiency Boiler CostofApproved PCB Incineration

Transformer Service (7) Special StorageAreas 3.2 to 5.6
No data 

### o - 11.1



### * :3.2 to 5.6


## o o - 11.1



### * ? Nodata on duration·of impact

? Nodata on -90% to 0%

duration of impact

?No data on duration of impact

f-' Ln LnMiningMachines (8) Rebuild waders ScrapContinuous Miners Storage Costs Exerrption ofApplication Electromagnets (9) Ban on Rebuilding Hydraulic Systems (10) Testing
Retrofill Disposal ofFluid 50-500 ppm PCBs Marking Ban on Recycling Fluid Corrplete by Dec 31, 1.6 ±20% 1981 CompletebyDec 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 

### oto 1.7 .7 to 3.4 -80% + 20%
*InfonnationNotAvailable in Record to Hake estimate.Item (Chapter) HeatTransferSystems (11) Testing Retrofill

Cost Savings

- Disposal ofSystems Compressors (12) Table 18.1-1 (Continued) Estimated $ millionPerYear $ million Reliability 1979 Succeeding Yrs total ofTotal



## -
+ .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 CostofSynthetic Road

Oil Material IncreasedCostofRoadOil

Unintentional Contaminants (14) Process Changes

- Phthalocyanine Pigments
Process Changes

- Diarylide YellowPigments Process Changes

- Other Processes Exemption Applications 

### oto 31.7

4.25
1.3

** .02 

## oto 31.7 (thru 1984) Oto 6.4 (years 6-15)


### o 0***


### o 

### o 

## oto 100



## oto 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 ofPCBs. **Infonrationnot available in the record tomakeestunate. ***Also long term cost impacts: SeeTable 18.2-1.Table 18.2-1
Long TermCost Impacts

Transformers : (Chapter 17)
Increased Cost ofNon-PCB Transformers
Increased Fire Losses Capacitors:

.(Chapter 16)
Increased Cost ofNon-PCB PowerFactor Capacitors
Increased Cost of Non-PCB Industrial Capacitors Diarylide Yellow Pigment (Chapter 14)
IncreasedManufacturing Cost Spill Materials (50 to 500ppm PCBs) (Chapter 15)

157\ $0 to 10million/year $0

$5.5 to 11 mil Lion/year

$6.6 to 18.9 million/year

$345,OOO/year

No dataTable 18.3-1 Economic Costs of the PCB Ban Regulation Chapter Nurrber Itern Total Cost $ Million Pounds PCBs Diverted from the Envirorunent Cost per Pound ofPCBs

1,000

. 5,360 $187,000 These costs will be significantly reduced or eliminated ifEPA grants exenptions fran the "distribution in cOI11TBrce" ban. 3
3

4 SCrap SPare PCB capacitors Renove 

### PCB Capacitors fromEquiprent 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 6.7 Retrofill Railroad 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.aLStorageAreas * * atTransfonrer 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, ofPCBsin 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 TotalCost $ Million Pounds PCBs Diverted fran theEnvironrrent CostperPound of PCBS Decontaminate Hydraulic 21.4 to 25 Systems DecontaminateHeat 12.8 to 17.2 Transfer Systems DecontaminateCorrpressors .2 BanUseofWaste Oilon 0 to 31.7/year Roads 10
11
12 13
14 14 15
f-' U1 16 \D 16 17 PhthalocyanineBlue pigrrents DiarylideYellowPigments SpillMaterials (50-500ppm)- to.ChemicalWaste Landfill BanNewLargePCB capacitors BanNew SmallPCB Capacitors BanNewPCBTransforners .425/year

.478/year



### * 5.5 to 11/year 6.6 to 18.9/year 

## oto 10/year 470 to 2,390 1,872to 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 notavailable in the record tomakeestimate.References Dow Corning CorpoLation. Removal ofPCB fLom Dow COLning 561® TransfocmeL Liquid by ChaLcoal Filtration, Midland, Michigan: undated. EPA. 1976. "WateL PLogLam

- PLotDsedToxic Pollutant Effluent StandaLds for Polychlodnated Biphenyls, 11FedeLal**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 SubstanceControl," Federal**~ister,** December 30, 1977, p, 65264. EPA. 1977c. PCB Marking and Dipp:?sal Regulations

- Support Document, (OTS-068005) Washington, D.C.: Office of Toxic Substances, U.S. Environmental ProtectionAgency, undated. EPA. 1977d. "ProposedToxic Pollutant Effluent Standards for PolyChlorinated Biphenyls (FeBs): Final Decision," Federal Register, February 2, 1977, pp. 6531-6555. EPA. 1978a. "PolychlorinatedBiphenyls (FeBs), Disposal and MaLking," Federal Register, February 17, 1978, pp. 7150-7164. EPA. 1978b. "PolychlorinatedBiphenyls (FeBs), Addendum to Preamble and Corrections to Final Rule," Federal Register, August 2, 1978, pp. 33918-33920. EPA. 1978c.**S~rt** Document/Draft Voluntary Environmental Impact Statement for Polychlorinated Biphenyls (PCBs) Manufacturing, Processing, p"istribution in Commerce and Use BanRegulation (Section 6(e) of TSCA), Washington, D.C.: Office ofToxic Substances, U.S. Environmental ProtectionAgency, May, 1978. EPA. 1978d. "Part 750 - Procedures for Rulanaking Under Section 6 of the Toxic Substance Control Act: Interim PLocedural Rules for Polychlorinated Biphenyls (FeBs) BanExemption," Federal Begister, November 1, 1978, pp •.50905-50907 EPA. 1978e. "PolychlorinatedBiphenyls (FeBs), Manufacturing, Processing, Distribution inCommerce, and UseBans," Federal Register, June 7, 1978, pp. 24802-24817.Jack FaucettAssociates, Inc. 1976. EconomicAnalysis ofProE?sed Toxic Pollutant Effluent Standards for Pol chlorinated Bi hen Is: Transformer,**Ca~citor,** and PCB Manufacturers (EPA 230 1-76-008), Washington, D.C.: Office ofWater Planning and Standards, U.S. Environmental Protection Agency, October 1976. FDA. 1973. "Polychlorinated Biphenyls

- Contamination ofAnimal Feeds, Foods, and FoodPackaging Materials," Federal Register, July 6, 1973, pp. 18096-18103. Foss, StephenD.; Higgins, JohnB. ; Johnston, Donald L.; McQuade, James M. (General Electric Co.). 1977. Retrofilling ofRailroad Transformers, Cambridge, MA: TransPJrtation systens Center, 

### u.s. Dar, July, 1978. Hesse, John L. 1975. "Polychlorinated Biphenyl Usage and Sources of Loss to the Environment in Michigan," Conference Proceedings, National Conference on Polychlorinated Biphenyls (November 19-21, 1975, Chicago, Illinois). Washington, D.C.:Office of**Tb~ic** Substances, U.S. Environmental ProtectionAgency (Report No. EPA 560/6-75-004). Hofstader, R.A. (ExxonResearch and Engineering Co.); Like, D.J.; Bache, C.A. (Cornell University). 1974, "Interference in the Electron-Capture Technique for Determination of Polychlorinated Biphenyls by Sulfur-'-Containing Compounds in PetroleumProducts," Bulletinof Environmental Contamination and ToxicolO2Y, Vol. 11, No.2, 1974. Lapp, T.W. (Midwest Research Institut.e), 1976. TheManufacture and Useof Selected AfYland Alkyl Phosphate Esters, EPA 560/6-76-008, February, 1976. Maugh, T.W., 1976. "RerefinedOil: An OptionThat Saves Oil, Minimizes Pollution," Science, p. 1108-1110, September 17, 1976. Monsanto Industrial Chemicals Co. Aroclors for**-~-,** St. Louis, Mo.: undated. NIOSH. 1977. Criteria for a Recommended Standard.••Occupational Exposure to Polychlorinated Biphenyls (PCBs) (I:HEW (NIOSH) PublicationNo. 77-225), Washington, D.C.: U.S. Governnent Printing Office, September, 1977. Olmstead, J. 1977. Comments and Reoammendations onMakeup Fluid for Askarel Transformers. Waukesha, WI.: R1'E Corporation, November 15, 1977.Page, WilliamC.; Michaud, Terry (Dc:wCorningCorporation). 1977. "DeveloprrentofMethods to Retrofill Transforrrers with Silicone TransfonrerLiquid", IEEE Paper 22-477, Presented at the Electrical Insulation Conference, Chicago, Illinois, September, 1977. (Submitted as attachIrent fromTerryMichaud (DowCorningCorp.) to PCB Record, August, 1978).
Rollins Environmental Service, Inc. 1978. Indemnified Disposal Service for Polychlorinated Biphenyls (PCBs

- Askarels), May 1, 1978. Submitted with T&R Electric SupplyCo. written reply comment on the PCB Ban Regulation. Stendell, Ray C. 1975. "SLU11ITIa.ry ofRecent Information Regarding Effects ofPCBs on Birds and Mammals." in Conference Proceedings, National Conference on Polychlorinated Biphenyls, Nov. 19-21, 1975, Chicago, Ill. Washington, D.C.: Office ofToxic Substances, u.S. Environmental ProtectionAgency (Report No. EPA 560/6-75-004). Versar, Inc. 1976a. PCBs in the United States: Industrial Use and Environmental Distribution, Springfield, Virginia: National Technical Information Service (NTIS PB**252-012/~VP),** February, 1976. Versar, Inc. 1977. Microeconomic lmeacts of the ProposedMarking and Diseosal RegUlations for PCBs (EPA 560/6-77-013), Springfield, Va.: NatIonal Technical InformationService (NTIS PB 267 833/2WP), April, 1977. Versar, Inc. 1978. Microeconomic I acts of the Pro sed "PCB Ban Regulations" (EPA 560 6-77-35), Spri.nqfie.Ld, Va.: National Technical Information Service (NTIS PB 281-881/3WP), May, 1978.1972. Agriculture'S Concerning Pol chlorinated Bi hen Is (PCBs), Washington, ucatlon, u.S. Department ofAgriculture, Walsh, E.J. i Voytik, D.E. i pearce, H.A. (Westinghouse Electric Corp.), 1977. Evaluation of Silicone Fluid for Replacement ofPCB Coolants in Railway Industry, Final Report, (Report No. DOT-TSC-1294). Cambridge, MA.: TransportationSystems Center, 

## u.s. ror, December, 1977. Weems, George. 1977. "Polychlorinated Biphenyls." Denver, Colorado: u.S. Department of Interior, FileHIS 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 Conferenceon Pol chlorinatedBi heny1s,November 19-21, 1975. Chicago, I 10n1S. Was 1ngton, D.C.: Off1ceofToX1C Substances, U.S. Envirorunental Protection Agency (Report; No. EPA560/6-75-004), pp. 317-322.THIS FORMMAY BE REPRODUCED ,"aRM NT1S.311 l"ItV. 10'731 ENDORSeD BY AJ.'l/SI AND UNESCO. BIBLIOGRAPHICDJ.TA. 

### 11. ReportNo. 12
• 3. Recipient's AccessionNo. SHEET EPA230-03/79-001 4.,Tide andSubtitle 5. ReportDate PCB Manufacturing, Processing, Distribution in C<:mrerce, March 30, 1979 and Use Ban Regulation: F.conanic ImpactAnalysis 6.**7.A~)** 8. Performing Organization Repc, Ro Westin, Bruce w:x:rlcock No. 535-1 9. Performing OrganizationName and Address 

### 10. Projecc/T'ask/Work Unir No.

Versar Inc. 6621 Electronic Drive 11. Coneeact/GraneNo. Springfield, Virginia 22151 68-01-4771 12. Spoaaoring OrganizationName andAddress 13. Type ofReport & Period Office of Planning and Manage:nent Covered U. S. Errvi.rcnment.al, Protection Agency Final Report washingtc;)n, D. C. 20460 1-(.
15. SupplementaryNotes 

# I EPAProject Officer: Mr. StephenWeil 16. Abseraers 

# I This report surrrnarizes the estimated econanic impacts ofPCB Ban Regulations which irople:nent the requirerrents of sections 6(e)(2) and 6(e) (3) ofthe Toxic Substances Control Act.

17. KeyWords and DocumentAnalysis. ' 170. Descriptors Polychlorinated Biphenyls Toxic Substances Control Act Liquid Waste Disposal &:::onanic Analysis Public Utilities capacitors Transforrrers Coal Mining Waste Oils**17~** Identifiers/Open-EndedTerms I

17c. COSATIField/Group 18. AnilabiliryStatement 19•.SecurityClass (This 21."No. of ?ages Report) 173 Release Unlimited lm,T <;<;lFIFn I;lV. SeeuriryClass (1his 22. Price Page l

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NCLASSTFIED



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<>U,S,**GOVE~NMENT** PAINTING OFFICE: 1979 291-755'6175"1-3.. 99 United States Envirnornentai Protection A.gency Washington DC20460 Official Business Penaityfor PrivateUse $300 Special Fourth-Classnet;:,' Book Postaqeand**F80~;** F'air) EP/\ -. PermitNo. G-3Ll