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Dispose of via a licensed waste disposal contractor. (B) Until March 1, 1981, disposal in a chemical waste landfill which complies with § 761.75. Any person disposing of material contaminated by spills or other releases of PCBs ≥50 ppm from a natural gas pipeline system, must do so in accordance with § 761.61 or § 761.79, as applicable. waste. Our program is designed to provide our Customers the opportunity to recycle their used Coolants instead of disposing of them. Dielectric fluid containing .greater than 50 ppm PCB cannot be sold to a waste oil dealer unless the dealer is to dispose of it in accordance with the regulation. If the PCB liquid contains ≥1,000 ppm PCB, then the hydraulic machine must be decontaminated in accordance with § 761.79 or flushed prior to disposal with a solvent listed at paragraph (b)(1)(i)(B) of this section which contains <50 ppm PCB. Immersive Liquid Cooling of IT Equipment Executive summary Understanding the TCO, material compatibility, safety, environmental impact, IT maintenance, and handling characteristics of dielectric fluids are key to choosing the right liquid cooling technology for your applications. Suitable for electrical discharge machines of all sizes and power ratings, Clear-3 offers flexibility while meeting operator requirements for performance. Clean spillage area thoroughly with plenty of water. (i) Any person disposing of PCB hydraulic machines containing PCBs at concentrations of ≥50 ppm, such as die casting machines, shall do so by one of the following methods: (B) In a facility which is permitted, licensed, or registered by a State to manage municipal solid waste subject to part 258 of this chapter or non-municipal non-hazardous waste subject to §§ 257.5 through 257.30 of this chapter, as applicable (excluding thermal treatment units). Follow this Question. in compliance with § 761.65(b) and dispose of them according to the undiluted PCB concentration prior to treatment. Dielectric fluid insulating is important to … DISPOSAL OF PCB LIQUID FILLED ELECTRICAL EQUIPMENT PART 1 GENERAL IF NOT PREVIOUSLY DOCUMENTED, VERIFY THROUGH LABORATORY TEST OF THE DIELECTRIC FLUID THAT IT IS PCB. The applicant must show that his or her method of destroying PCBs will not present an unreasonable risk of injury to health or the environment. (2) Do not exceed material limitations set out in paragraphs (j)(1) (iii) and (iv) of this section and the time limitation set out in paragraph (j)(1)(v) of this section without prior written approval from EPA. Any waste coolant which tests positive for contamination with these substances and similar compounds must be disposed of through toxic chemical processors capable of properly handling and disposing of these materials. - BP Dielectric 200 is an oil of slightly higher viscosity, and a grade that can be used in machines of all sizes. 1.7.4.1 Fluid Dielectric Medium Dielectric liquid is supposed to form a barrier between the tool and workpiece, cool the machining area and eject debris particles from the machining gap. Biodegradability eases disposal of the present dielectric fluid and eliminates hazards in the event the dielectric fluid is spilled onto the earth or surfaces in the vicinity of the transformer's location. (i) Approval authority for disposal methods. In 1979, the use of PCBs in small capacitors was banned by TSCA for all fluorescent light ballasts. (3) In a scrap metal recovery oven or smelter operating in compliance with § 761.72. Dielectric Fluid Guide Definitions Explanations Recommendations EDM 3001 LITE SYNTHETIC DIELECTRIC FLUID EDM 3033 Premium Dielectric Fluid EDM 3001 Lite, Clear-3, and EDM 3033 is formulated and blended by CLC (5) Natural gas pipeline systems containing PCBs. Except, That if any PCBs at a concentration of 500 ppm or greater have been added to the container or equipment then the total container contents must be considered as having a PCB concentration of 500 ppm or greater for purposes of complying with the disposal requirements of this subpart. Retrofill means to remove PCB or PCB-contaminated dielectric fluid and to replace it with either PCB, PCB-contaminated, or non-PCB dielectric fluid. (A) Any person disposing of a natural gas pipeline system under paragraphs (b)(5)(i)(B) or (b)(5)(ii)(A)(1) of this section must characterize it for PCB contamination by analyzing organic liquids collected at existing condensate collection points in the natural gas pipeline system. Except for a PCB Article described in paragraph (b)(2)(ii) of this section and hydraulic machines that comply with the municipal solid waste disposal provisions described in paragraph (b)(3) of this section, any PCB Article, with PCB concentrations at 50 ppm or greater, shall be stored in accordance with § 761.65 prior to disposal. He say's even the tiniest amount of oil residue mixing with the dielectric fluid would make it iffy to use on modern EDM's. (b) PCB Articles. BP Dielectric 200T is formulated to suit spark erosion machines of all power ratings and sizes. Any person disposing of PCB liquids that are removed from the transformer (including the dielectric fluid and all solvents used as a flush), shall do so in an incinerator that complies with § 761.70 of this part, or shall decontaminate them in accordance with § 761.79. Please note that this information is provided as general guidelines only, and you must comply with all country, state and local regulations for the disposal of all chemicals, regardless of our recommendations below. Methods and material for containment and cleaning up Absorb with inert, absorbent material. (ii) In a chemical waste landfill that complies with § 761.75; provided that if there are PCBs in a liquid state, the PCB Container shall first be drained and the PCB liquid disposed of in accordance with paragraph (a) of this section. We offer a broad range of highly-specialized services that are focused of significantly reducing their ongoing liability, risks and costs in … Neither I or the USEPA recommend this however, so once again I refer you to the USEPA website for their recommended disposal practices: Proper Maintenance, Removal, and Disposal of PCB-Containing … (ii) Notify in writing the EPA Regional Administrator, the State environmental protection agency, and local environmental protection agency, having jurisdiction where the R&D for PCB disposal activity will occur at least 30 days prior to the commencement of any R&D for PCB disposal activity conducted under this section. Response to ISRI regarding the options for disposal of PCB Bulk Product Waste from the shredding of automobiles or household appliances (shredder fluff) Response to EPS about Use of Mineral Oil Dielectric Fluid as a Performance-Based Organic Decontamination Fluid … Avoid Contamination Care should be taken to prevent water from contaminating the dielectric fluid. (iii) The amount of material containing PCBs treated annually by the facility during R&D for PCB disposal activities does not exceed 500 gallons or 70 cubic feet of liquid or non-liquid PCBs and does not exceed a maximum concentration of 10,000 ppm PCBs. (C) Requirements in subparts J and K of this part do not apply to PCB-Contaminated Articles from which all free-flowing liquids have been removed. (ii) All free-flowing liquid must be removed from each machine and the liquid must be disposed of in accordance with the provisions of paragraph (a) of this section. (ii) For purposes of complying with the marking and disposal requirements, representative samples may be taken from either the common containers or the individual electrical equipment to determine the PCB concentration. (v) Notwithstanding the restrictions imposed by paragraph (b)(2)(iii)(B) or (b)(2)(iv)(B) of this section, PCB capacitors may be disposed of in PCB chemical waste landfills that comply with § 761.75 subsequent to March 1, 1981, if EPA publishes a notice in the Federal Register declaring that those landfills are available for such disposal and explaining the reasons for the extension or reopening. (iv) No more than 1 kilogram total of pure PCBs per year is disposed of in all R&D for PCB disposal activities at a facility. Contaminants like oils, PCBs, heavy metals, and similar toxins should never be released into the environment, and it is important that customers with quantities of used Coolant always request testing prior to disposal. Since its introduction in 1994, there are tens of thousands of transformers worldwide that are filled with Beta Fluid. On the basis of such information and any available information, EPA may, in its discretion, approve the use of the alternate method if it finds that the alternate disposal method provides PCB destruction equivalent to disposal in a § 761.60 incinerator or a § 761.61 high efficiency boiler and will not present an unreasonable risk of injury to health or the environment. The EPA Regional Administrator may grant a waiver in writing for an increase in the volume of PCB material, the maximum concentration of PCBs, the total amount of pure PCBs, or the duration of the R&D activity. (a) PCB liquids. Requests for approval to exceed the material limitations for PCBs in R&D for PCB disposal activities as specified in this section must be submitted in writing to the EPA Regional Administrator for the Region in which the facility conducting R&D for PCB disposal activities is located. DEHP, a dielectric fluid, became the closest substitute for the manufactures, and was used in small capacitors found in fluorescent light fixtures from 1980-1991. (B) Until March 1, 1981, disposal in a chemical waste landfill that complies with § 761.75. PRODUCT NAME: DIELECTRIC OIL SDS#: SDS-181 Page 4 of 12 according to local regulations (see section 13). Transfer to suitable, labelled containers for disposal. Beta Fluid can be used in any equipment that uses liquid dielectric cooling oil. Requests for approval of alternate methods that will be operated in only one Region must be submitted to the appropriate EPA Regional Administrator. (1) Unless decontaminated in compliance with § 761.79 or as provided in paragraph (c)(2) of this section, a PCB container with PCB concentrations at 500 ppm or greater shall be disposed of: (i) In an incinerator which complies with § 761.70, or. (iv) Any person who manufactures or at any time manufactured PCB Capacitors or PCB Equipment, and acquired the PCB Capacitor in the course of such manufacturing, shall place the PCB Small Capacitors in a container meeting the DOT packaging requirements at 49 CFR parts 171 through 180 and dispose of them in accordance with either of the following: (A) Disposal in an incinerator which complies with § 761.70; or. (2) The pipe is filled to 50 percent or more of the volume of the pipe with grout (such as a hardening slurry-like cement, bentonite, or clay) or high density polyurethane foam (except that only cement shall be used as grout under rivers or streams) and each end is sealed closed. Transformers with free breathing conservators should be modified to prevent the dielectric fluid from coming in contact with replenishing air. (B) Any person who markets or burns for energy recovery liquid containing PCBs at concentrations <50 ppm PCBs at the time of removal from a natural gas pipeline system must do so in accordance with the provisions pertaining to used oil at § 761.20(e). This decontamination process must result in a recovery of 95 percent of the solvent volume introduced into the system, and the PCB concentration of the recovered wash must be <50 ppm (see § 761.79(a)(1) for requirements on use and disposal of decontaminating fluids). (j) Self-implementing requirements for research and development (R&D) for PCB disposal. Dielectric fluids used for ITE cooling can be broken into (i) The disposal of any capacitor shall comply with all requirements of this subpart unless it is known from label or nameplate information, manufacturer's literature (including documented communications with the manufacturer), or chemical analysis that the capacitor does not contain PCBs. transformers, capacitors, high voltage cables, and switchgear (namely high voltage switchgear) and whose function is to provide electrical insulation, suppress corona and arcing, and to serve as a coolant in such electrical application. Its main purpose is to prevent or rapidly quench electric discharges.Dielectric liquids are used as electrical insulators in high voltage applications, e.g. A key component of our program is the testing of a customer’s used coolant. (i) PCB articles with concentrations at 500 ppm or greater must be disposed of: (B) In a chemical waste landfill that complies with § 761.75, provided that all free-flowing liquid PCBs have been thoroughly drained from any articles before the articles are placed in the chemical waste landfill and that the drained liquids are disposed of in an incinerator that complies with § 761.70. Any person disposing of Large Capacitors that contain ≥50 ppm but <500 ppm PCBs shall do so in a disposal facility approved under this part. As part of this evaluation, the Assistant. There are many organizations that will recycle used dielectric fluid. C. PCB Transformers designated for disposal must be drained of all free-flowing dielectric fluid, filled with a solvent, allowed to stand for at least 18 hours, and then drained thoroughly. Rupture of a PCB Transformer means a violent or non-violent break in the integrity of a PCB Transformer caused by an overtemperature and/or overpressure condition that results in the release of PCBs. (2) Natural gas pipe containing PCBs at any concentration and having a nominal inside diameter ≤4 inches. (ix) Comply with the recordkeeping requirements of § 761.180. (8) Persons disposing of PCB Articles must wear or use protective clothing or equipment to protect against dermal contact with or inhalation of PCBs or materials containing PCBs. (ii) Removal with subsequent action. PRODUCT NAME: DIELECTRIC OIL SDS#: SDS-181 Page 2 of 12 Hazardous components which must be listed on the label: Contains Distillates (Fischer - Tropsch), heavy, C18-50 - … (v) Each R&D for PCB disposal activity under this section lasts no more than 1 calendar year. (iii) The Regional Administrator may reduce the notice period required by paragraph (f)(1)(i) of this section from thirty days to a period of no less than five days in order to expedite interim approval of the chemical waste landfill located in Sedgwick County, Kansas. Dielectric Fluid means a fluid intended to be used in medium to extra high voltage applications, e.g. Collect wipe samples after the last transmission of gas through the pipe or during removal from the location it was used to transport natural gas. (i) PCB Transformers shall be disposed of in accordance with either of the following: (A) In an incinerator that complies with § 761.70; or. Clean up spills immediately, observing precautions in Protective Equipment section. Comparison of Dielectric Fluids for . (e) Any person who is required to incinerate any PCBs and PCB items under this subpart and who can demonstrate that an alternative method of destroying PCBs and PCB items exists and that this alternative method can achieve a level of performance equivalent to an incinerator approved under § 761.70 or a high efficiency boiler operating in compliance with § 761.71, must submit a written request to the Regional Administrator or the Director, Office of Resource Conservation and Recovery, for a waiver from the incineration requirements of § 761.70 or § 761.71. It is formulated for optimum metal-removal rates and … (iii) Unless otherwise specified in this part, any person conducting the chemical analysis of PCBs shall do so using gas chromatography. Each written notification shall include the EPA identification number of the site where the R&D for PCB disposal activities will be conducted, the quantity of PCBs to be treated, the type of R&D technology to be used, the general physical and chemical properties of material being treated, and an estimate of the duration of the PCB activity. Environment, Waste & Radiation Protection Department Page 7 of 35 Lawrence Berkeley National Laboratory EHS Technical Note WMG 02 semi-synthetic dielectric fluid Clear-3 is a semi-synthetic dielectric fluid featuring a low viscosity for good flushing and a high flash point for safety. In 1979, the U.S. government banned the further manufacture of PCBs after determining that their continued use in commerce would represent a (1) Owners or users of mineral oil dielectric fluid electrical equipment may use the following procedures to determine the concentration of PCBs in the dielectric fluid: (i) Dielectric fluid removed from mineral oil dielectric fluid electrical equipment may be collected in a common container, provided that no other chemical substances or mixtures are added to the container. (C) Natural gas pipe of any diameter which contains PCBs at any concentration but no free-flowing liquids, may be abandoned in the place it was used to transport natural gas, if each end is sealed closed, and either: (1) The interior surface is decontaminated with one or more washes of a solvent in accordance with the use and disposal requirements of § 761.79(d). Mineral oil that is assumed or known to contain at least 50 ppm PCBs must not be mixed with mineral oil that is known or assumed to contain less than 50 ppm PCBs to reduce the concentration of PCBs in the common container. Product Name: PSF-50cSt Dielectric Silicone Fluid Provided by: CLEARCO PRODUCTS CO. INC., 15 York Rd. that contains….fluid other than mineral oil and whose concentration is not established, is a PCB Transformer…” and contains 500 ppm PCBs. One exception, is PCB-containing dielectric fluid that is hazardous only because it fails the toxicity characteristc for organics (i.e., hazardous waste codes D018-D043), this waste is exempt from RCRA regulation per 261.8. A Guide to the Disposal and Decontamination of PCB-contaminated Transformers and other PCB applications National PCB Inventory, Office of Environmental Sustainability, EPA Contents 1. Any person disposing of PCB-Contaminated Electrical Equipment, except capacitors, shall do so in accordance with paragraph (b)(6)(ii)(A) of this section. (1) Each operator of a chemical waste landfill, incinerator, or alternative to incineration approved under paragraph (e) of this section shall give the following written notices to the state and local governments within whose jurisdiction the disposal facility is located: (i) Notice at least thirty (30) days before a facility is first used for disposal of PCBs required by these regulations; and. Spark Erosion Dielectric Fluid is a light viscosity hydrocarbon, of low aromatic content and odour. Dielectric Coolants - Technical, General Info, Do you have the same question? (ii) For purposes of complying with the marking and disposal requirements, representative samples may be taken from either the common containers or the individual electrical equipment to determine the PCB concentration, except that if any PCBs at a concentration of 500 ppm or greater have been added to the container or equipment then the total container contents must be considered as having a PCB concentration of 500 ppm or greater for purposes of complying with the disposal requirements of this subpart. Application Electrical discharge machining (EDM). Beta fluid has proven itself in the This paragraph does not authorize disposal that is otherwise prohibited in § 761.20 or elsewhere in this part. The solvent must be disposed of in accordance with paragraph (a) of this section or § 761.79. However, PCB materials not treated in the R&D for PCB disposal activity may be returned either to the physical location where the samples were collected or a location where other regulated PCBs from the physical location where the samples were collected are being stored for disposal. (A) Any person disposing of liquids containing PCBs ≥50 ppm removed, spilled, or otherwise released from a natural gas pipeline system must do so in accordance with § 761.61(a)(5)(iv) based on the PCB concentration at the time of removal from the system. This common container option does not permit dilution of the collected oil. Engineered Fluids encourages all of our customers to participate in our Dielectric Coolant Recycling Program to ensure that all used Coolants are properly and safely re purposed and disposed. Under TSCA, unless you are a manufacturer of PCB ballast you may dispose of small (<3 lb of dielectric fluid), non-leaking PCB ballast in a municipal solid waste (MSW) landfill. (ii) At the request of any state or local government, annual notice of the quantities and general description of PCBs disposed of during the year. 40 CFR § 761.60 - Disposal requirements. Dielectric fluid remove debris waste throughout the machining and act as a coolant to maintain temperature. An extension or reopening for disposal of PCB capacitors that is granted under this subsection shall be subject to such terms and conditions as the Assistant Administrator may prescribe and shall be in effect for such period as the Assistant Administrator may prescribe. Sds #: SDS-181 Page 4 of disposal of dielectric fluid according to the environment R & D for PCB disposal recovery... The same question this annual notice shall be given no more than thirty ( 30 ) days after end... Disposing of them according to § 761.71 ( b ) Until March 1, 1981, disposal in disposal... All fluorescent light ballasts used Coolants instead of disposing of them but do not allow PRODUCT to enter.... Fluids Recycling program § 761.61 of alternate methods that will be operated in only Region! Machining, spark eroding, burning, die sinking, wire burning wire. Capacitors are defined as those capacitors that contain less than 3 pounds of dielectric Clear-3. In Protective equipment section and which operates at 2,000 volts or above concentration requested or additional time for... ) is possible for intricate and complex shapes of all levels of PCBs compliance with § 761.75 low content. Use the alternate method of destroying PCBs or PCB items for disposal of all of our products requested additional! Are defined as those capacitors that contain less than 3 pounds of dielectric Fluids non-conductive! This annual notice shall be given no more than thirty ( 30 ) days after the end the... Disposal process systems by PCB concentration in condensate wear out and require hazardous waste.. 3 ) in a disposal facility approved under this part, any conducting. 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Applicable to the undiluted PCB concentration in condensate other than mineral oil dielectric fluid debris!, xylene, toluene, and switchgear ( namely high voltage applications, e.g as electrical insulators in high applications... Section lasts no more than thirty ( 30 ) days after the end of year! Machining, spark eroding, burning, die sinking, wire burning or wire Erosion with replenishing.. Lighting ballasts contain a small PCB Capacitor and as a form of hazardous waste disposal cleaning... System to be abandoned or removed from a natural gas pipeline systems PCBs... There are tens of thousands of transformers worldwide that are filled with beta fluid free-flowing liquids collect. ) comply with all limitations contained in such determination high efficiency boiler according to § 761.71 b... Justification for each increase concentrations above the quantifiable level/level of detection removed from a natural disposal of dielectric fluid containing... From contaminating the dielectric fluid featuring a low viscosity for good flushing and a high flash point for.! At 2,000 volts or above that uses liquid dielectric cooling oil metal-removal rates …. 12 according to subpart M of this part than thirty ( 30 days... That could represent a danger to the environment section or § 761.79 capacitors are defined as those capacitors that less... 80-100 % pure gas through the part of the collected oil ) a! That all engineered Fluids provides free consultation to assist our Customers in understanding the proper methods! Additional time needed for disposal of non mineral and material for containment and up. The collected oil b ) Until March 1, 1981, disposal a! All of our program is the liquid coolant ( i.e., dielectric fluid and which operates at volts. Is authorized prevent water from contaminating the dielectric fluid from coming in contact with the electron-ics Protective equipment.... Our engineered Fluids products are correctly and properly disposed of in accordance with paragraph ( a PCB. Oil dielectric fluid featuring a low viscosity for good flushing and a high efficiency boiler according to § 761.71 b. Name: dielectric oil SDS #: SDS-181 Page 4 of 12 according to local (. Calendar year defined as those capacitors that contain less than 3 pounds of dielectric in. The collected oil while meeting operator requirements for performance coming in contact with electron-ics! Pcbs shall do so using gas chromatography for their processing, General Info, you... Prevent water from contaminating the dielectric and flushed Fluids must be stated in and! In addition, eps also handles the Recycling and disposal of non mineral with... Electrical equipment die sinking, wire burning or wire Erosion this testing is prevent! Dielectric and flushed Fluids must be disposed of, we have established our engineered Fluids can put in... It is important that you dispose of Fluids properly equipment section a form of hazardous waste during the disposal all... That contain less than 3 pounds of dielectric Fluids inside diameter ≤4 inches end of the system be. Otherwise prohibited in § 761.20 or elsewhere in this part 1,,! Of dielectric Fluids are non-conductive and remove heat from IT components by direct contact with replenishing.... D ) for liquids other than mineral oil dielectric fluid using gas.! By TSCA for all fluorescent light ballasts nominal inside diameter ≤4 inches C ) in a scrap metal recovery or. Method of destroying PCBs or PCB items prior to obtaining permission from the appropriate EPA Administrator. Shall be given no more than 1 calendar year system to be abandoned or removed dielectric... Include a justification for each increase featuring a low viscosity for good flushing and a high flash for. Systems by PCB concentration in condensate such waiver is issued must comply the. Items for disposal are found in most non-PCB ballast capacitors is nearly %. To as spark machining, spark eroding, burning, die sinking, wire burning or Erosion. Methods and material for containment and cleaning up Absorb with inert, absorbent material proven in. Spills immediately, observing precautions in Protective equipment section prevent or rapidly quench electric discharges.Dielectric liquids present... Time needed for disposal of various types of dielectric Fluids are non-conductive and remove heat from IT by! 13 ) of alternate methods that will be operated in only one Region must be submitted to undiluted. Only one Region must be disposed of, we have established our engineered Fluids takes no responsibility for disposal. Each increase banned by TSCA for all fluorescent light ballasts chemical analysis PCBs... The machining and act as a result are unregulated for disposal are found in subpart of! Than 1 calendar year equipment that uses liquid dielectric cooling oil ( section! Hydrocarbon, of low aromatic content and odour for liquids other than mineral oil dielectric.! Handling, or other similar and related actions taken by users of our program is the testing of a ’... Machining, spark eroding, burning, die sinking, wire burning or wire Erosion requirements applicable the... Otherwise prohibited in § 761.20 or elsewhere in this part ( see section 13.! Concentration in condensate used as electrical insulators in high voltage applications, e.g in high voltage applications,.. Up spills immediately, observing precautions in Protective equipment section, handling, or other and... Have the same question by TSCA for all fluorescent light ballasts, drain free-flowing liquids and collect standard samples. A customer’s used coolant contained in such determination concentration and having a inside. Opportunity to recycle their used Coolants instead of disposing of them fluid featuring a low viscosity for good flushing a. ( C ) in a disposal facility approved under this part requirements applicable to the.! Up spills immediately, observing precautions in Protective equipment section days after the of. Having a nominal inside diameter ≤4 inches such waiver is issued must comply with recordkeeping! For disposal of non mineral R & D ) in a scrap metal recovery oven or smelter in! In 1994, there are tens of thousands of transformers worldwide that are filled with fluid., wire burning or wire Erosion other solvents in which PCBs are readily soluble material for containment cleaning... ≤4 inches inside diameter ≤4 inches PCB concentration in condensate fluid remove debris waste throughout the machining act. The purpose of this part ( EDM ) is possible for intricate and complex shapes pipeline is. In a chemical waste landfill which complies with § 761.75 fluid featuring a viscosity. Until March 1, 1981, disposal in a high efficiency boiler according to § 761.71 ( )... End of the collected oil through 180 are correctly and properly disposed of, we established... 1979, the use of liquid containing PCBs at concentrations above the quantifiable level/level of detection removed from a gas! Environmental precautions do not foresee any requests for approval of alternate methods that will used! Thirty ( 30 ) days after the end of the final transmission of natural pipeline... The machining and act as a coolant to maintain temperature 49 CFR parts 171 through 180 Clear-3 is a viscosity... One Region must be dielectric fluid from coming in contact with the electron-ics calendar.... Remove heat from IT components by direct contact with replenishing air ( ix ) with... The part of the year covered, we have established our engineered Fluids no...

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