PCBs AND ASSOCIATED AROMATICS 905
PCBs in non-manufacturing buildings have been investigated
by NIOSH. Their data are shown in Table 38 for comparison.
Reported eventful failures of PCB contaminated electri-
cal equipment have been well documented only in the United
States, Canada, Finland and Sweden. Table 39 lists some of
the major PCB fires in Scandinavia. The toxic Substances
Control Act was the first regulatory authority which the EPA
had concerning PCBs. Section 6(e) of TSCA requires proper
disposal of PCBs, and prohibits the manufacture, processing,
distribution in commerce, and use of PCBs. Under section
6(e)(2) of TSCA the EPA allows the use of PCBs in “a totally
enclosed manner” such as transformers, capacitors and elec-
tromagnets based upon considerations of cost and risk reduc-
tion. However, when the August 1982 rule was promulgated
it was based upon the assumption that the principal route
of release of PCB-containing dielectric fluid into the envi-
ronment was from leaks and spills. Since that time, it has
been found that fires involving transformers occur frequently
enough to present a significant risk and this has led the EPA
to reconsider the August 1982 rule and place the follow-
ing additional restrictions and conditions on the use of PCB
transformers (40 CFR Part 761:50 FR 29170) July, 1985:1) High secondary voltage PCB transformers (480 V
and above, including 480/277 V) configured in a
network fashion and used in or near commercial
buildings must be removed from use, placed into
storage or disposal, disposed, or reclassified to PCB
contaminated or non-PCB status by Oct. 1, 1990.
2) PCB transformers can no longer be installed in
commercial buildings after Oct. 1, 1985.
3) PCB transformers used in or near commercial
buildings (other than high secondary voltage
network PCB transformers) must be equipped
with enhanced electrical protection, by Oct. 1,
1990, to avoid failures and fires from sustained
electrical faults.
4) All transformers must be registered with appro-
priate emergency response personnel and with
building owners by Dec. 1, 1985.
5) All PCB transformer locations must be cleared of
stored combustible materials by Dec. 1, 1985.
6) All PCB transformer fire-related incidents must
be immediately reported to the National Response
Center, and measures must be taken as soon as
practically and safely possible to contain poten-
tial release of PCBs and incomplete combustion
products to waterways.EPA defines commercial buildings to include all types of
buildings other than industrial facilities and would include
locations such as office buildings, shopping centers, hospi-
tals, and colleges. A PCB transformer located in or near a
commercial building is located on the roof of, attached to the
exterior wall of, in the parking area of, or within 30 meters of
a commercial building.
The EPA has had to consider both the benefits of PCBs
as well as the availability of substitute materials balancedagainst the costs of regulatory control measures. It was
concluded that the removal or retrofill of PCB transform-
ers is both the most effective and the most costly mea-
sure to reduce the frequency of serious transformer fires.
It was suggested that a less costly, but also less effective,
alternative could be represented by providing better elec-
trical protection of the equipment. The effectiveness of
increased electrical protection is expected to approach that
of phaseout/retrofill but EPA recognizes that electrical pro-
tective devices are also subject to malfunction and that PCB
transformer fires can result from less common mechanisms
of failure. At this point it would be useful to clarify what
is meant by the retrofill and reclassification of PCB trans-
formers. The retrofill of a PCB filled transformer involves
the replacement of the original PCB dielectric fluid with a
substitute oil. The main advantage of retrofilling is that an
owner’s liability is minimized at minimum cost. In addition,
record keeping and reporting requirements are reduced or
eliminated and servicing is allowed.
There are three categories of PCB transformers:- A PCB transformer is defined as one which con-
tains more than 500 ppm PCB. - A PCB contaminated transformer is one which
contains PCBs in the concentration range 50–
500 ppm PCB. - A non-PCB transformer contains less than 50 ppm
PCB.
If the flushed carcass is buried in an approved chemical
waste landfill there is the possibility of long term liability
associated with PCB leaching. Alternatively, carcasses can
be cleaned to less than 10 μ g PCB/100 cm^2 and the clean
metal returned to the secondary metals market.
PCB transformers may not receive servicing which
requires the removal of the core/coil assembly. Inspections
must be made for leaks and records kept. When the unit
is to be replaced, the fluid must be burned in an approved
incinerator and the transformer carcass either incinerated or
flushed. PCB contaminated transformers (50–500 ppm PCB)
do not need to be inspected for leaks and may be repaired
or serviced as necessary. EPA reaffirmed its August 1982
determination that the continued use of PCB contaminated
transformers does not present unreasonable risks to public
health and the environment.
Non-PCB transformers, containing less than 50 ppm
PCB, may be used with almost no restrictions since the
unit is then not under TSCA purview. The may 1979 PCB
ban rule prohibits rebuilding of PCB transformers but does
allow for their reclassification. Under the provisions for
reclassification the equipment must be put back into ser-
vice for three months before the bulk oil is tested for its
PCB concentration. The final rule clarifies the definition of
in-service use for transformers by specifying a minimum
dielectric fluid temperature of 50°C to correspond to a con-
dition of light electrical loading. If a unit is retained as a
PCB transformer an immediate cash outlay is avoided but
this might not be the lowest-cost option in the long term.C016_003_r03.indd 905C016_003_r03.indd 905 11/18/2005 1:12:39 PM11/18/2005 1:12:39 PM