Oil-Filled Equipment, Electrical Devices and Transformers

These guidelines are provided to assist departments that operate, maintain, remove from service and dispose of transformers and other oil filled electrical devices comply with federal and state laws with regard to PCB contamination. Owners and operators of these devices should familiarize themselves with the attached regulations and guidance documents.

Definitions

PCB Polychlorinated Biphenyl
Oil Filled Device Oil filled transformer, switch, cable, capacitor, power supply, voltage regulators, hydraulic machine, heat transfer device, etc,
PCB contaminated Contains PCB concentration in excess of 50 PPM but less than 500 PPM
PCB Containing Contains PCB concentration in excess of 500 PPM
PCB Transformer Transformer containing greater than 500 PPM PCB’s

Transformers

All departments that own, operate, and maintain oil filled electrical transformers must have records for all oil filled transformers indicating whether each is PCB containing or non-PCB containing.

From 40 CFR 761:

“(vi)(A) No later than December 28, 1998 all owners of PCB Transformers, including those in storage for reuse, must register their transformers with the Environmental Protection Agency, National Program Chemicals Division, Office of Pollution Prevention and Toxics (7404), 1200 Pennsylvania Ave., NW., Washington, DC 20460. This registration requirement is subject to the limitations in paragraph (a)(1) of this section.

(1) A transformer owner who assumes a transformer is a PCB-Contaminated transformer, and discovers after December 28, 1998 that it is a PCB-Transformer, must register the newly-identified PCB Transformer, in writing, with the Environmental Protection Agency no later than 30 days after it is identified as such. This requirement does not apply to transformer owners who have previously registered with the EPA PCB Transformers located at the same address as the transformer that they assumed to be PCB-Contaminated and later determined to be a PCB Transformer.”

NOTE : Transformers removed from service for disposal need not be registered. This disposal must take place within 30 days of the date of removal from service.

If it is not known if the transformer contains PCB’s a determination shall be made by one of the following methods:

A record of the date of manufacture. Devices manufactured after July 2, 1979 are non-PCB.

A record of the results of a test of the transformer oil using an approved method.

A record of a manufacturers label permanently affixed to the device indicating the oil in the device contains no PCB’s.

In the absence of a record which indicates a determination of PCB concentration using one of the above methods it must be assumed to be PCB containing.

PCB Containing Transformers in Use

Must meet the requirements of 40CFR61.  Contact EHS for guidance.
PCB’s and PCB containing equipment must be labeled in accordance with 40CFR61. Refer to the link below or contact EHS.

Removal of an Oil Filled Electrical Device from Service

When any oil filled equipment or electrical device is removed from service, and records of PCB concentration for that device do not exist, then the oil contained in that device must be sampled for PCB’s. The devices may not be transferred or disposed off until those results are known.   The results of the testing should be known before the oil is removed from the device.

PCB containing devices must be labeled with the date removed from service. A department has 30 days to dispose of the devices before being required to meet the federal storage requirements.

The device must not be disposed of until the results of testing for PCB’s are known

The oil from the device must not be recycled or disposed until the results of testing for PCB’s is known.

Storage and Disposal of Oil Filled Electrical Devices

PCB containing devices may not be stored except in permitted facilities.  PCB containing devices must be disposed of within 30 days of removal from service. PCB contaminated electrical devices removed from service or storage must be disposed in accordance with federal and state law. Contact EHS for assistance.

Spills

Oil spilled from transformers or oil filled devices must be assumed to be PCB containing unless a record of the date of manufacture for transformers, a test results, or a manufacturers labels indicating “no- PCB” is permanently affixed to the device until testing results are available.

Disposal of Oil Filled Equipment, Oil Filled Electrical Devices and the Oil Removed

Disposal of oil filled devices and oils will depend on the concentration of PCB’s. Contact EHS for specific guidance.

References

40 CFR 761 Polychlorinated Biphenyls (PCBs) Manufacturing, Processing, Distribution in Commerce, and Use Prohibitions 

EPA Guidance for Polychlorinated Biphenyls

The Office of Health, Safety and Security Guidance