POLYCHLORINATED BIPHENYL (PCB) - RULE CHANGES

On June 29, 1998, the EPA issued another "Final Rule" concerning known and potential PCB containing equipment. The changes that most directly effect property owners, property managers and lenders concern the assumptions that can be made regarding untested transformers, and registration requirements for known PCB transformers.

EPA regulation break transformers into the following three categories:

• Non-PCB: Transformers containing less than 50 parts per million (ppm) PCBs
• PCB-Contaminated: Transformers containing 50 ppm to less than 500 ppm PCBs
• PCB: Transformers containing 500 ppm PCBs or greater

Under the new final rule, in-use transformers whose PCB content is unknown, but were manufactured after July 2, 1979, should be assumed to be non-PCB. In-use transformers manufactured prior to July 2, 1979, should be considered PCB-contaminated if filled with mineral oil and PCB if filled with a fluid other than mineral oil. Historically, all untested transformers were assumed to be PCB-contaminated until tested. The EPA rule also provides that transformers containing less than 1.36 kg (3 lbs) of fluid, circuit breakers, reclosers, oil-filled cable, and rectifiers whose PCB concentration has not been established, may be assumed to contain less than 50 ppm PCBs. The actual PCB content of all transformers, regardless of date of manufacture, must be known prior to disposal.

For transformers known or assumed to be PCB, the EPA has established a national registration requirement. This registration requirement extends to PCB transformers in use or in storage for reuse. The rule requires the transformer owner to maintain proof the registration occurred. This registration is in place of the previous requirement to notify the local fire department. Existing regulations for transformer labeling, marking and inspections still apply.

The deadline for registering with the Federal Government is December 28, 1998. For all properties constructed prior to 1980, it should be determined if the transformers on the property belong to the local utility company or the property. Property-owned transformers should be classified as non-PCB, PCB-contaminated or PCB based on the rules provided above. All PCB transformers should be registered with the federal government after being brought into compliance with the EPA Final Rules.

For more discussion on the rule changes,contact Aaron & Wright or check out June 29, 1998 on the EPA website at www.epa.gov/fedrgstr.

A partial list of dielectric trade name and common names used by manufacturers for PCBs

Adkarel, ALC, Apirolio, Aroclor, Arochlor B, Asbestol, ASK, Askarel, Capacitor 21, Chlorextol, Chlorinol, Chlorphen, Clophen, Diaclor, DK, Dykanolo, EEC-18, Elemex, Eucarel, Fenclor, Hyvol, Inclor, Inerteen, Kennechlor, Magvar, MCS 1489, Nepolin, No-Flamol, Phenoclor, Pydraul, Pyralene, Pyroclor, Pyranol, Saf-T-Kuhl, Santotherm, and Santovac 1 and 2

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