860 PCBs AND ASSOCIATED AROMATICS
with more than 50% chlorination, are present in the general
environment and are a threat to certain species of wildlife....
To be sure that the Inerteen and Inerteen contaminated mate-
rials do not contaminate the environment they must be incin-
erated in approved equipment.”
A disposal section in the handling instructions describes
the disposal of Inerteen liquid, solvent rinses contaminated
with Inerteen, solids contaminated with Inerteen and the
cleaning of contaminated drums.
February 9, 1976: The NYDEC found GE to have violated
two State laws by its discharge of PCBs.
February 17, 1976: Ogden Reid (Comm. NYDEC)
announced that he would issue orders closing the Hudson
River as a commercial fishery for most species of fish
because of PCB contamination.
February 13, 1976: The Hudson River was ordered
closed to commercial fishing with the exception of chad.
February 24–25, 1976: The transformer subcommit-
tee of ANSI met on February 24 and 25, 1976 and issued
minutes which contained the following: “Transformers
with Replacement Fluids: Apparatus that has contained
PCBs which have been replaced with another fluid should
be labeled as indicated below, and the disposal ultimately
should follow the same disposal procedures as those recom-
mended for PCB liquids and PCB-filled apparatus.”
February 25, 1976: Versar Task I final report: “It is
estimated that approximately 1.5 billion pounds of PCBs
have been sold for industrial use in the US since initiation
of production around 1930. Of this amount, at least 95% is
still in existence; most is in service in capacitors and trans-
formers, but about 290 million pounds are believed to reside
in landfills and dumps and about 150 millions pounds are
believed to be ‘free’ in the environment. The magnitude of
these values indicates that there is a strong future threat from
PCBs in land disposal sites,”.... “Although PCB content in
industrial wastes can be reduced through various approaches
(treatment, substitution, etc.), the large amounts of PCBs
already contained in land disposal sites present a severe
hazard for the future.”... “Monsanto and portions of the
electrical equipment industry which use PCBs have greatly
reduced PCB releases to water and land over the past few
years, primarily through improvement of plant housekeep-
ing, improved waste collection and handling, and disposal of
liquid wastes through incineration.”
March 26, 1976: Senator Nelson introduced an amend-
ment to the Toxic Substances Act which would eliminate the
remaining uses of PCBs unless EPA finds that there is not a
serious health hazard. The amendment was incorporated into
TSCA as Section 6(e) and became a legislated requirement
when TSCA was signed into law on October 11, 1976. The
effective data of TSCA was January 1, 1977.
April 1, 1976: EPA issued recommended procedures
for disposal of PCBs by industrial users under the Solid
Waste Disposal Act. Recommended options for the disposal
of PCB-containing wastes were given in priority order as
(1) incineration and (2) controlled land disposal. In the case
of land disposal it was mentioned that wastes containing
PCBs should not be disposed of with other mixed wastes
in a sanitary landfill. At this point in time the characteris-
tics of transport of PCBs through soil were not definitively
established. The regulations pointed out that “The ubiquity
and persistence of PCBs indicate that their disposal should
be carefully controlled until additional data are developed.”
Non-chemical waste landfills were then strongly contrasted
with the following description of a chemical waste landfill.
“In general terms, a chemical waste landfill provides com-
plete long term protection for the quality of surface and sub-
surface waters from hazardous waste deposited therein, and
against hazards to public health and the environment. Such
sites should be located or engineered to avoid direct hydrau-
lic continuity with surface and subsurface waters. Generated
leachates should be contained and subsurface flow into the
disposal area eliminated. Monitoring wells should be estab-
lished and a sampling and analysis program conducted.”
June 1976: Instructions for handling Inerteen ® insulating
fluid and installation and maintenance of inerteen transform-
ers were issued by Westinghouse’s Small Power Transformer
Division in June 1976 [Westinghouse, 1976]. A section was
included on environmental considerations in which PCBs
were described as extremely persistent in the environment.
In closing the section, Westinghouse goes beyond the rec-
ommendation of the ANSI C-107 guideline by indicating
that the Inerteen and Inerteen contaminated materials should
be incinerated in approved equipment. No mention is made
of the second ANSI guideline alternative of draining and
flushing the transformer carcass before disposal in a scrap
yard. The suggested method of disposal is quite the opposite
and leads to the ultimate destruction of PCB contaminated,
porous materials such as absorbing clay, filter paper, car-
tridges, sawdust, rags and insulation while the non-porous
metallic transformer components are solvent cleaned and the
solvent incinerated.
TABLE 4
In Service Age (yr.) Temperature(°C) PCBs(ppm) PCQs*(ppm) PCDFs(ppm)
14 180–270 968,400 31,000 510
3 200–220 999,000 690 277
0 ‡ — 999,800 209 33
(^) * (^) PCB polychlorinated quaterphenyl.
‡ not used.
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