PCB Testing - Part 2

PCB Testing, Part 2

In Part 1 of this series on PCB testing we presented some background information on PCBs, addressed when PCB testing is appropriate, and described how a typical laboratory may perform PCB testing. In Part 2 of this series we will discuss PCB regulations, and the classification of electrical equipment based on PCB test results.

However, before proceeding, we must first present a short disclaimer: The material in this article is for general information only. It does not constitute any interpretation of the PCB rules, nor is it to be construed as regulatory or legal advice of any kind.

Federal PCB regulations (40 CFR 761.3) define three classifications for transformers and other electrical equipment based on the PCB content:

• PCB – Transformers and electrical equipment that contain PCBs 500 ppm (mg/kg) or greater.

• PCB – Contaminated – Transformers and electrical equipment that contain PCBs 50 ppm or greater, but less than 500 ppm.

• Non-PCB – Transformers and electrical equipment that contain PCBs less than 50 ppm.

Note that these classifications apply to electrical equipment only. Liquids or solids that are not in electrical equipment (for example, dielectric fluid in a drum or gravel in a substation) are classified as non-PCB if less than 50 ppm, but as PCB if 50 ppm or greater.

Federal PCB rules regulate the continued authorized use and disposal of PCBs and of equipment and materials that contain or are contaminated by PCBs. Among these rules is a requirement that all PCB transformers must be registered with the United States Environmental Protection Agency, effective December 28, 1998 (40 CFR 761.30(a)(1)(vi)). If equipment has not been tested for PCB content, owners must follow the requirements of the Assumptions for Use (40 CFR 761.2) in order to determine the classification of their electrical equipment. Assumptions for Use are summarized as follows:

• Mineral oil-filled equipment containing greater than 3 pounds (1.36 kilograms) of fluid must be assumed to be PCB-Contaminated if the equipment was manufactured prior to July 2, 1979 or if the date of manufacture cannot be established.

• Units manufactured after July 2, 1979 or fluid-filled units containing less than 3 pounds (1.36 kilograms) of fluid may be assumed to be non-PCB.

• Units containing 1.36 kilograms or more of a fluid other than mineral oil and that were manufactured prior to July 2, 1979 must be assumed to be PCB.

The assumption rules apply only to use. Decisions for disposal of equipment or for clean-up of accidental releases of PCBs must be based on actual PCB content data. Also, this discussion concerns Federal rules only. State or local agencies may have different or more stringent requirements.

When determining PCB content through analytical methods, USEPA requires the accuracy of the test method to be taken into account. "EPA will not consider it to be good judgment to assume that the sample has less than 50 ppm PCB because the experimental error of the procedure overlaps the cut-off point." (Federal Register, Volume 44, No. 106, 5/31/79. P. 31538.)