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40 CFR Part 761 Polychlorinated Biphenyls in Electrical Transformers; Final Rule 

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# - ;rHeinOnline -- 50 Fed. Reg. 29170 1985 

### 29170 Federal Register 

## I Vol. 50. No. 137 

## I Wednesday. July 17. 1985 

## I Rules and Regulations

ENVIRONMENTAL PROTECTION AGENCY

40 CFRPart 761

[OPTS 620350; TSH FRL 2835-6J

Polychlorinated Biphenyls In Electrical Transformers

AGENCY: Environmental Protection Agency (EPA).

ACTION: Final rule.

SUMMARY: This final rule amends portions ofan existing EPA rule concerning the use ofpolychlorinated biphenyls (PCBs) by placing additional restrictions and conditions on the use of PCB Transformers (Electrical transformers containing 500 parts per million orgreaterPCBs). This rule: (1) Prohibits the use ofhigher secondary voltage (480 volts and above) network PCB Transformers in or nearcommercial buildings after October 1, 1990, (2) requires. by October 1, 1990, the installation ofenhanced electrical protection on lower secondary voltage network PCB Transformers and higher secondary voltage radial PCB Transformers in use in ornear

, commercial buildings, (3) prohibits

further installation ofPCB Transformers in ornear commercial buildings after October 1. 1985, (4) requires the registration. by December 1. 1985. ofall PCB Transformers with fire response personnel and building owners. (5) requires the marking, by December 1. 1985. ofthe exterior ofall PCB Transformerlocations, and (6) requires the removal, by December 1, 1985. of stored combustibles located nearPCB Transformers.

EPA is also requiring that owners of PCB Transformers involved in firerelated incidents immediately notify the National Response Center, and, take

measures as soon as practically and safely possible to contain any potential releases ofPCB's or incomplete combustion products to water.

DATES: In,accordance with 40 GFR 23.5 (50 FR 7271), this rule shall be promulgated for purposes ofjudicial review at 1 p.m. Eastern DaylightTime

on July 24, 1985. These amendments shall be effective on August 16, 1985.

FOR FURTHER INFORMATION CONTACT: Edward A. Klein, Director, TSCA Assistance Office (TS-799), Office of Toxic Substances, Environmental Protection Agency, Rm. E-543, 401 M St.. SW., Washington, D.C. 20460. Toll free: (800-424-9065). In Washington, D.C.: (554-1404). Outside the USA: (Operator202-554-1404). SUPPLEMENTARY INFORMATION: OMB Control Number: 2070-0073.

I. Background,

Section 6(e) ofthe Toxic Substances Control Act (TSCA) generally prohibits the use ofPCBs afterJanuary 1, 1978. The statute does, however, set forth two exceptions under which EPA may, by rule. allow a particular use ofPCBs to continue. Under section 6(e)(2) ofTSCA. EPA may allow PCBs to be used in a "totally enclosed manner." A "totally enclosed manner" is defined by TSCA
to be "any manner which will ensure that any exposure ofhuman beings or the environment to a polychlorinated biphenyl will be insignificant. as determined by the Administratorby rule." TSCA also allows EPA to authorize the use ofPCBs in a manner otherthan a totally enclosed manner if the Agency finds that the use "will not present an unreasonable risk ofinjury to health orthe environment."

EPA promulgated a rule. which was published in the Federal Register ofMay 31, 1979 (44 FR 31514), to implement section 6(e) (2) and (3) ofTSCA. This rule is listed in the Code ofFederal Regulations under40 CFR Part 761. The rule, among otherprovisions, designated all intact. nonleaking capacitors. electromagnets, and transformers. other than railroad transformers, as "totally enclosed," thus permitting their use without specific authorizations or conditions. The Environmental Defense Fund (EDF) petitioned the U.S. Court of Appeals for the District ofColumbia Circuit to review a number ofprovisions ofthe rule. including the portion ofthe rule that designated all intact and nonleaking capacitors, electromagnets, and transformers as "totally enclosed" (EnvironmentalDefense Fund. Inc. v. EnvironmentalProtectionAgency. 636 F.2d 1267).

On October 30. 1980, the court, among other things. decided that there was insufficient evidence in the record to support the Agency's dassification of transformers, capacitors. amI electromagnets as totally enclosed. The
court invalidated this portion ofthe rule,

as well as other provisions, and remanded the rule to EPA for further action.

As a consequence ofthe October 1980 decision. EPA undertook a number of rulemaking actions. The rule relevant to the subject oftoday's final rule was published in the Federal Register of August 25, 1982 (47 FR 37342) (hereafter, PCB Electrical Use Rule). This rule amended the May 1979 rule by authorizing the continued use ofPCB Transformers (electrical transformers containing greater than 500 ppm PCBs) in facilities involved in handling offood

or feed items until October 1, 1985, and by authorizing the use ofall other categories ofnon-railroad eleotrical transformers containing or contaminated with PCBs for the remainder oftheir useful lives. In its August 1982 decision, EPA made a determination that authorizing the use of these tranformers for the remainder of their useful lives did not present an unreasonable risk to public health or the environment for the following reasons:

1. EPA determined that ifit did not authorize the use ofPCBs in transformers, the costs to the public and United States industry would be bl\lions ofdollars, primarily as a result ofthe disruption ofelectrical service. EPA determined that the resulting reduction in risk would not outweigh these substantial costs.

2. EPA determined that the inspection and maintenance programs required underthe rule reasonably reduced the
exposure risks associated with the use ofPCBs in PCB Transformers, and the servicing conditions prevented further PCB contamination oftransformers.

3. EPA determined that releases of PCBs to the environment and exposure to humans and biological organisms from mineral oil transformers are minimal. EPA estimated that these transformers contain less than 0.15 percent ofall the PCBs used in tranformers and release less than one halfofa percent ofthese PCBs on annual basis.

4. EPA determined that the costs associated with otherrisk reduction

measures such as accelerated phase-out, reducing the PCB concentration in the dielectric fluid, orproviding containment for tranformers were not reasonable when compared to the potential reduction in release ofPCBs achieved.

In evaluating the risks posed by the continued use ofelectrical transformers containing PCBs for the August 1982 PCB Electrical Use Rule, EPA considered exposures resulting from leaks and spills ofPCB-containing dielectric fluid as constituting the principal route ofrelease ofPCBs to the environment from this equipment.

However, EPA has learned that fires involving transformers also can be responsible for the release ofPCBs. and. that PCBs released from transformers in fire situations can be volatilized and converted into materials which are orders ofmagnitude more toxic than PCBs. For example, on February 5, 1981. in the Binghamton State Office Building in Binghamtom. New York, a PCBHeinOnline -- 50 Fed. Reg. 29171 1985 

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Transformer was involved in a fire in the basement ofthe building. PCBs and oxidationproducts were distributed throughout the 18-story office building via two vertical ventilation shafts that

ran the length ofthe building and opened into the transformervault in the basement. Monitoring. completed after the fire, indicated thatPCBs.

. polychlorinated dibenzofurans (PCDFs) (including the toxic congener 2,3,7.8- tetrachlorodibenzofuran (2,3,7,8-TCDFH. and polychlorinated dibenzodioxins (PCDDs) (including the toxic congener 2,3,7.8.-tetrachlorodibenzo-p-dioxin (2.3.7.8-TCDD)) were distributed throughout the interiorofthe building. From laboratory studies. it appears that PCDFs are formed from both the oxidation ofPCBs and the oxidation of chlorinated benzenes in combustion situations. PCDDs. however. appear to be formed only from the oxidation of chlorinated benzenes. (Tri- andTetrachlorinatedbenzenes often make up 30- 35 percent ofPCB askarel dielectic fluid. and can be present at low levels as contaminants in otherfluids.)

At the time ofpromulgation ofthe August 25. 1982 PCB Electical Use Rule. EPA believed that PCB Transformer fires were very rare. isolated events. Thus, although EPA made determinations that the use ofelectrical transformers containing PCBs did not pose unreasonable risks to public health

or the environment. EPA did not directly consider the public health and environmental risks posed by firerelated events. EPA also did not evaluate the cost ofimplementing risk reduction measures to mitigate the risks posed by fires involving this equipment

orfactor into its economic assessment certain now-identified costs associated with the continued use ofthese

.. transformers. principally. the very high
costs ofcleanup following more serious incidents. These costs reduce the benefits associated with the continued

use ofthese transformers.

After the promulgation ofthe PCB Electrical Use Rule. additional information came to EPA's attention that indicated that PCB Transformer fires may occurmore frequently than previously expected, and that transformerfire-related hazards are not restricted solely to transformers located inside buildings. OnMay 15. 1983. in the One MarketPlaza complex in San Francisco. California. a PCB Transformerwas involved in a smoky transformervault fire. Monitoring completed after the fire indicated the
presence ofPCBs, PCDFs. and PCDDs. in soot from this fire. Although the vault housing the transformerwas located exterior to the building itself(in a sidewalk vault), JInsealed conduits from the vault to the basement and outside air intake vents drew contaminated smoke into the building.

The SanFrancisco incident. and four

more recent incidents, in the First. National BankBuilding in Chicago, Illinois. in September 1983; inTulsa, Oklahoma. in December 1983 andMay 1984; and inMiami, Florida, inMay 1984, have promptedEPA to reassess its earlierposition on the expected frequency offire-related incidents involving transformers that contain PCBs.

EPA issued an Advance Notice of ProposedRulemaking (ANPR). which

was published in the Federal Registerof March 23, 1984 (49 FR 11070), to solicit additional information on the risks posed by fires involving transformers containing PCBs, theirfrequency of

occurrence. the costs ofcleanup following these incidents, and the effectiveness and costs associatedwith regulatory control measures. At that time. EPA indicated that itwoulduse the new information to reconsiderthe.

use authorizationissued in the August 1982 PCB Electrical Use Rule for the continued use ofmost electrical transformers containing PCBs.

In the ANPR, EPA solicitedcomments

on a wide range ofpotential regulatory control measures. including the phaseout ofPCB Transformers. increased electrical protection, fire and smoke control technologies, and fire hazard inspection programs. EPA also solicited comments on the relative risks posed by PCB Transformerfires in commercial buildings such as office buildings, versus the risks posedby fires in industrial facilities and outdoor electrical substations. EPA suggested in the ANPR that the risks posed by PCB Transformerfires in commercial buildings may be greaterthan those posed by transformerfires in industrial facilities and outdoor electrical substations.

EPA received over50 comments on .• the ANPR during the public comment period. which closed onMay 22. 1984. EPAreceivedinformation from a numberofdifferent sources, including**~he** 

### insurance industry. fire departments. building owners. industrial transformer
users, and utilities. (The comments on the ANPR are summarized in: "PCB TransformerFires: Comments on the Advance Notice ofProposed Rulemaking" (September 1984).) Several
comments were received following the close ofthe commentperiod. and EPA reserved these comments for consideration following the issuance of the Proposed Rules.

After considering the comments received in response to the ANPR, and aftercompleting further analyses of available data, EPA issued a Proposed Rule. which was publishedin the Federal RegisterofOctober 11, 1984 (49 FR 39966). to address the risks posed by fires involving transformers that contain PCBs. The Proposed Rule presented EPA's determination that additional regulatory control measures were warranted on the use ofPCB Transformers. At the same time. EPA reaffirmed its August 1982 determination that the indefinite use ofPCBContaminated transformers does not presentunreasonable risks to public health or the environment. EPA's determinations were based on analyses ofthe risks posed by fires involving electrical transformers containing PCBs, the benefits ofPCBs and the availability ofsubstitutes, and the costs andbenefits ofcontrol measures designed to mitigate

oreliminate the fire-associated risks posedby the equipment.

EPAreceived over130 comments on the ProposedRule during the public
comment period, which closed on February 11, 1985. OnJanuary 14, 15. and 16. 1985, EPAheld a public hearing in Washington. D.C., where 15 parties provided testimony,on various

.provisions ofthe ProposedRule. EPAhas considered all the comments receivedin response to the Proposed Rule (as well as the comments received after the close ofthe ANPR comment period). andhas modified the rule where appropriate. Further. EPAhas prepared

a support document for this rulemaking which addresses all substantive
comments on the ProposedRule and includes EPA's responses to comments which did notresult in the actual modification ofthe rule. This document, entitled: "Response to Comments on the PCB TransformerFires ProposedRule (July 1985)." is available by contacting the Toxic Substances Control Act Assistancce Office (see FOR FURTHER INFORMATION CONTACT).



### II. Summary ofthe Final Rule

Under section 6(e)(2)(B) ofTSCA, EPA

can authorize a use ofPCBs provided that the use "willnotpresent an unreasonable risk ofinjury to health or the environment:' EPA's August 1982 decision to allow the continued use of electrical transformers containing PCBs

was based on the reported low frequency ofleaks and spills ofPCBs from this equipment compared to the high costs associated with replacing this equipment with substitute transformersHeinOnline -- 50 Fed. Reg. 29172 1985 

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### Rules and Regulations**_,~~~~~~~~~~~~~~~~~~~~~**

orrequiring secondary containment to limit the spread ofspilled materials:

EPA subsequently undertook an evaluation ofthe fire-related risks posed by the continued use ofPCB Transformers. and the costs and benefits ofmeasures designed to reduce those risks. On October 11.1984. EPA issued a Proposed Rule which contained EPA's determination that PCB Transformerfires (fires involving transformers containing greater than 500
ppm PCBs). particularly fires which

occurin or nearbuildings, do present risks to human health and the environment. EPA reached this determination afterconsidering the
extreme toxicity ofmaterials which can be formed and released during fires involving this equipment, as well as the potential for human and environmental
exposures to these compounds from a single incident. and the expected frequency ofincidents over the remaining useful life ofthis equipment.

EPA further determined that the continued use ofPCB Transformers without additional restrictions does present an unreasonable risk ofinjury to health and the environment. EPA reached this determination after considering the risks posed. the costs of. cleanup following these incidents. the availability ofadequate substitute materials. and the costs andbenefits associated with riskreduction measures. EPA did. therefore. propose additional regulatory controls on the use ofthis equipment.

EPAproposed to require: (1) The immediate registration ofall PCB Transformers with appropriate fire departmentjurisdictions. and the immediate registration withbuilding

owners ofall PCB Transformers located in ornearbuildings. (2) the immediate marking ofthe exteriorofthe vault door. machinery room door. means ofegress,

orgrate(s) accessing a PCB Transformers with PCB identification labels. (3) the immediate removal of stored combustibles from PCB Transformers locations. (4) the installation. by July 1.1988. ofadditional electrical protective devices on PCB Transformers in ornearbuildings in high secondary voltage systems (480/277 volt systems). and (5) the isolation. by July 1. 1988. ofall PCB Transformers in

or nearbuildings from building ventilation systems. building ductwork. and openings in construction to reduce the widespread contamination of
structures and the environment by smoke and soot in the event ofa PCB Transformer fire. In addition. to facilitate monitoring compliance with the isolation requirements, EPA proposed that PCB Transformerowners maintain records oftteirefforts in isolating transformers through the completion ofPCB Smoke Spread Reduction Plans (PCB-SSRPs).

Finally. in the event ofa PCB Transformerfire. EPA proposed to require PCB Transformer owners to take immediate measures to contain potential
waterdischarges. and to report all PCB Transformer fire-related incidents to the National Response Center (NRC) prior
to the initiation ofcleanup efforts.

This final rule modifies and clarifies

some ofthe requirements presented in the Proposed Rule as a result of information and comments provided to the Agency during public comment periods and at the pl.blic hearing. In developing the ProposedRule. EPA evaluated the risks posed by PCB Transformerfires in ornearbuildings by using an office building setting to evaluate generically the nature ofan potential for human and environmental
exposures to PCBs and incomplete combustionproducts. EPA determined that additional control measures. principally the isolation ofPCB Transformers from building ventilation equipment and ductwork. were necessary to reduce the risks posed by the continued use ofthis equipment.

During the public commentperiod for the Proposed Rule. EPA received extensive comments in three specific

areas. and has modified the final rule accordingly. First, many comments received in response to the Proposed Rule suggested that EPA consider evaluating separately the fire-related risks posedby the continued use ofPCB Transformers in industrial locations

versus the fire-related risks posedby the

use ofPCB Transformers in ornear buildings such as office buildings.
stores. hospitals and schools (hereafter, all non-industrial. non-substation buildings will be referred to as "commercial buildings"). This final rule adopts this suggestion and addresses the use ofPCB Transformers in ornear industrial buildings separately from the

use ofPCB Transformers in ornear commercial buildings.

Second. many comments on the Proposed Rule discussed the probability ofPCB Transformerfailures and fires. and suggestedthat certain types ofPCB Transformerinstallations. network installations with higher secondary voltages (secondary voltages of480 volts and above. including 480/277 volt secondaries). may be particularly likely
to be involved in fire-related incidents. These comments suggest that ifEPA

were to pursue additional restrictions on the use ofPCB Transformers. these installations should be the subject of

more stringent control measures. In
response to these comments. this final rule considers factors such as the relative probabilities offailures and fires in different types ofPCB Transformer installations and places

more stringent controls on those transformers which EPA believes pose higher risks offailures and fires.

Finally. in response to comments on the Proposed Rule. in this final rule. EPA has increased its emphasis ofthe prevention ofPCB Transformer fires through increased electrical protection. and decreased its emphasis on the use ofisolation measures to minimize the spread ofalready formed and/or released contaminants.

This final rule prohibits: 1. The continued use ofhigher secondary voltage network PCB Transformers (network PCB Transformers with secondary voltages
at or above 480 volts, including 480/277 volt systems) in ornearcommercial buildings beyond October 1. 1990.

2. The further installation ofPCB Transformers (which have beenplaced into storage forreuse) in ornear commercial buildings.

This final rule also requires: 1. The installation. by October 1. 1990. ofenhanced electrical protection on lower secondary voltage network PCB Transformers and on higher secondary voltage radial PCB Transformers (radial PCB Transformers with secondary voltages at or above 480volts, including 480/277 volt systems) used in ornear commercial buildings.

2. The registration, by December 1, 1985 ofall PCB Transformers with fire departments orfire brigades with primary response function. and the registration. by December 1. 1985. ofall PCB Transformers located in ornear buildings with building owners.

3. The marking, by December 1, 1985. ofthe exterior ofall PCB Transformer locations (excludinggrates and manhole covers).

4. The removal, by December 1, 1985. ofcombustible materials stored within a PCB Transformerenclosure, within 5
meters ofa PCB Transformerenclosure.

orwithin 5 meters ofan unenclosed PCB Transformer.

This rule also requires the immediate notification ofthe National Response Center in the event ofa PCB Transformer fire-related incident; and, that PCB Transformerowners take

measures as soon as practically and safely possible to contain any potential
water releases associated with a PCB Transformer fire-related incident. These

measures include, but are not limited to.HeinOnline -- 50 Fed. Reg. 29173 1985 

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the blocking offloor drains. the containment ofwaterrunoff, and the control and treatment ofcleanup water prior to discharge.

Fire events involving the rupture of PCB Transformers can lead to contamination ofsewers. sewage treatment systems. sewage sludges and bodies ofwater. Liquid PCBs and incomplete combustion products such as dioxins cr fl1rans may be conveyed through drains into storm or sanitary

sewer systems. This process is facilitated when water is used in firefighting operations or is present as a result ofthe r:Jpture ofwater pipes. Disruption ofsewage treatment processes can alRO be caused. and eventually car:tarninants may be discharged into receiving waters poorly**t~cated** or not treated at all.

Contamination ofreceiving waters presents a risk oflong lasting adverse effects on aquatic life and bottom sediment, as well as threats to public health through contamination of drinking water supplies and direct public contact with contaminated water.

The cost ofcleaning up contaminated

sewer systems and associated treatment facilities may be very high. Sludge contaminated with PCBs. dioxins and furans may be required to be handled and disposed ofas hazardous waste under the resource Conservation and Recovery Act (RCRA) and pursuant to the PCB regulations under the Toxic Substances Control Act (TSCA). Clean
up ofwaterbodies and bottom sediments. ifpossible. would also be
very**e~pensive.** Data indicating water and sewer treatment system contamination following the Binghamton fire confirm that water treatment facility sludge can become contaminated with PCBs as a result ofreleases during PCB Transformerfires.

Forthese reasons. it is important that

sewer systems and treatment plant operators have as much notice as possible ofa PCB Transformer fire
event. The sooner this information is available. the sooner action can be taken to isolate or contain contaminants (ifpossible). to limit their spread and to

assure properhandling.

Fire departments are required to be notified pursuant to § 761.30(a)(1)(vi) of this regulations as to the location ofPCB Transformers. Fire departments generally maintain good information for
response to emergencies and have plans and a coordinating capacity for dealing with fires involving hazardous materials. EPA therefore strongly urges fire departments. on a voluntary basis.
to contact storm and sanitary sewer system and treatment plant operators in the areas served by the fire department. once the information required to be submitted to the fire departments under § 761.30(a)(1)(vi) is available. EPA also
urges the fire department to work wih

sewer system and treatment plant operators to develop contingency plans for handling contamination entering the

sewers as a result ofPCB Transformer fire events.

EPA also urges owners ofPCB Transformers and owners ofbuildings in which those transformers are located to 'plan ahead for a fire event. Building

owners. working with otherparties. should plan their best course otaction to prevent or limit release ofPCBs and other contaminants in the event ofa fire. These plans should give special consideration to the location of individual PCB Transformers. the location ofdrains near these transformers. and methods for closing the drains in the event ofa PCB Transformer fire.

To support this voluntary cooperative effort. EPA will develop guidance for

use by owners and operators ofsanitary

sewer systems and treatment facilities. pointing out the availability at local fire departments ofinformation on the location oftransformers and the potential impact ofthe release ofPCBs and othercontaminants into the sewer system in the event ofa fire. EPA will also evaluate the possible roles of organizations such as the Water Pollution Control Federation. the Association ofState and Interstate WaterPollution Control Authorities. the American Public Works Association. and the National Fire Protection Association in distributing information. and may request their cooperation in this effort.

Forpurposes ofthis rule. commercial building is defined as a non-industrial (non-substation) building which is typically accessible to both members of the general public and employees. Commercial buildings include: (1) Public assembly properties, (2) educational properties. (3) institutional properties. (4) residential properties. (5) stores, (6) office buildings. and (7) transportation
centers (Le

.. airport terminal buildings. subway stations. bus stations. and train stations). Forpurposes ofthis rule. "in

or near" a commercial building is defined as: (1) Within the interiorofa commercial building. (2) on the roofofa commercial building or attached to the exteriorwall ofa commercial building. (3) in the parking area ofa commercial building. or (4) located within 30 meters ofa commercial building.

An industrial building is defined as a building directly used in manufacturing

or technically productive enterprises. Industrial buildings are not generally or typically accessible to other than workers. Industrial buildings include buildings used directly in the production ofpower. the manufacture ofproducts. the mining ofraw materials. and the storage oftextiles, petroleum'products. wood and paper products. chemicals or plastics. and metals.

EPA has determined that requiring the removal ofparticularly high risk PCB Transformers from use and adding conditions and restrictions on the use of the remaining PCB Transformers (including enhanced electrical protection. registration, and labeling) will significantly reduce the fire-related risks posed by the use ofPCB Transformers. EPA has determined that the continued use ofPCBs in PCB Transformers which comply with the conditions and requiremeIJ.ts described above do not present unreasonable risks
to public health orthe environment. Further. afterconsidering the risks posed by fires involving transformers containingless than 500ppm PCBs. and the costs ofregulatory control measures. EPA is reaffirming its August 1982 determination that the continued use of PCB-Contaminated transformers and non-PCB transformers (transformers containing 50-500 ppm PCBs, and less than 50ppm PCBs respectively) do not present unreasonable risks to public health and the environment.

The enhanced electrical protection requirements for higher secondary voltage radial PCB Transformers consist ofthe installation ofprotection against transformerfailures from sustained low
current faults. EPA has determined that the enhanced protection ofthese PCB Transformers is necessary to reduce the fire-related risks posed by the continued

use ofthese transformers in commercial locations. This protection will reduce the frequency ofPCB Transformer fires in these types oftransformers by allowing forrapid deenergization in the
eventofa sustained low current fault.

While EPA is aware ofat least five basic types ofradial installations (simple radial systems. expanded radial systems. primary selective systems. primary loop systems. and secondary selective systems). existing data do not indicate that the probability oflow
current fault-related failures would be significantly different among these five types ofradial installations. Thus. EPA has required enhanced electrical protection on all commercial higher secondary voltage radial PCB Transformers.

EPA recognizes, however, that additional experience and further research into the causes ofPCB Transformer**failure~and** fires mayHeinOnline -- 50 Fed. Reg. 29174 1985 

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result in the development ofdata by industry which would indicate that there

are significant differences in the probabilities offault-related failures
among the different types ofradial systems. Ifthese data are developed. they should be submitted to EPA for consideration. Based on the timely submission ofnew information, that is, within 2years ofthe date of

. promulgation ofthis final rule, EPA may choose to revisit this particular requirement.

.

The remainder ofthis preamble describes the basis for the determinations reached in this final rule.

III. Use Authorizations Under Section 6(e)

In orderto authorize a use ofPCBs under section6(e)(2)(B} ofTSCA. EPA
must find that such use "will notpresent

an unreasonable risk ofinjury to health

or the environment." To determine whether a risk is unreasonable. EPA
must**balanc~** the probability that harm will occurfrom the use against the benefits to society ofallowing the continued use. In completing this
assessment for the use ofPCB containing electrical transformers, EPA has considered the following factors for each offour categories ofelectrical transformers containing PCBs (PCB Transformers located in ornear commercial buildings. PCB Transformers located in ornearindustrial facilities, PCB Transformers located outdoors (away from commercial buildings), and PCB .Contaminated transformers):

1. The effects ofPCBs and their incomplete combustionproducts on human health and the environment.

2. The magnitude ofhuman and environmental exposure to PCBs and theirincomplete combustion products.

3. The benefits ofusing PCBs and the availability ofsubstitutes.

4. The economic impactresulting from the rule upon the national economy, small business, technological innovation, the environment, and public health.

These are the same types of considerations listed in section 6(c) of TSCA, which describes factors EPA
mustconsiderin deciding whether a chemical presents an unreasonable risk undersection 6(a) ofTSCA.

The remaining units ofthis preamble will discuss these key factors in the unreasonable risk determinations made in this rule, and the basis forEPA's determination to allow the continued

use ofPCB-containing transformers with certain additional conditions and restrictions. IV. TransformerFire-Related Risks

A. Toxicity of PCBs andIncomplete Combustion Products

In earlierrulemakings, EPA has already concluded that, based upon available information persons exposed
to PCBs can develop chloracne; and, that based on animal data, there is a potential forreproductive effects and developmental toxicity as well as oncogenicity in humans exposed to PCBs. While fires involving PCBcontaining transformers have resulted in the releaS'e oflarge quantities ofPCBs, these incidents have also resulted in the formation oftoxic products of incomplete combustion.

Many othercompounds ofpotential toxicological significance, including PCDFs, PCDDs. and polychlorinated biphenylenes, were measured in soot samples following fires involving PCB Transformers. However. the bulk of toxicity testing ofPCDF and PCDD
congeners has been completed on what

are anticipated to be the most toxic species, the 2,3,7,6 substitutedPCDFs and PCDDs. EPA has evaluated the risks posedby PCB Transformerfires through

an evaluation of: (1) The toxicities of PCBs, 2,3,7,6-TCDF, and 2,3,7,6-TCDD; (2) the toxicities and potential toxicities ofotherPCDF and PCDD congeners; and (3) the potential for exposure to these materials as a result ofa fire.

While the majority oftoxicological testing has been completed on PCBs, 2,3,7,6-TCDF and 2,3,7,8-TCDD, this does
not mean thathuman and environmental
exposures to othercongeners ofPCDFs and PCDDs as well as polychlorinated biphenylenes pose little risk oftoxic effects. Forexample, limited testing of 1,2,3,7,8-pentachlorodibenzo-p-dioxin (1,2,3,7.8-PeCDD), 1,2,3,6,7,6- hexachlorodibenzo-p-dioxin (1,2,3.6,7,8- HxCDD), and 1,2,3,7,8,9- hexachlorodibenzo-p-dioxin (1,2,3,7,8,9- HxCDD) suggest that these congeners

are qualitatively similarin their toxic action to 2.3,7.8-TCDD for observed effepts. However, they are less toxic for the observed effects than the 2,3,7,8- TCDD congener. EPA expects that similar structure-activity relationships would exist between 2,3,7,8-TCDF and 1.2,3,7,8-PeCDF, 1,2,3,7,8,9-HxCDF, and 1,2,3,6,7,8-HxCDF. However. EPA also believes that reducing exposures to the extremely toxic congeners, 2,3,7,8-TCDD and 2,3,7,6-TCDF, will alsoreduce
exposures to these othercompounds of potential toxicological significance.

According to EPA's February 1984 Ambient Water Quality Criteria (AWQC) for 2,3,7,8-tetrachlorodibenzop-dioxin (2,3,7,8-TCDD), 2,3,7,8-TCDD is

one ofthe most toxic substances known to man. It exhibits delayed biological
response in many species and is highly lethal, at low doses, to aquatic organisms, birds, and mammals. It has been shown to be acnegenic, fetotoxic, teratogenic, mutagenic (limited evidence), carcinogenic, and adversely affects the immune response in mammals.

The AWQC lists the acute LD50 for 2.3,7,6-TCDD for several species. The oral LD50 values ranges from 0.6 microgramperkilogram (kg) body weight (bw) for guinea pigs to 5,051 micrograms perkilogram body weight for hamsters. The AWQC presents the acceptable daily intake (ADI) value for

a 70 kg man as 2.2X 10- 7micromoles 2,3.7,6-TCDD per day. This ADI is based

on the lowest-observed-adverse-effect levels (LOAEL) inrats. and has been calculated in accordance with the National Academy ofScience's guidelines for calculating an ADI based

ona LOAEL.

Although the ADI value presented above is very low, it still may not be sufficiently protective ofhuman health. This ADI level does not take into
account the demonstrated carcinogenic effects of2.3,7.8-TCDD in laboratory animals. The AWQC concludes that 2,3,7,6-TCDD is an animal carcinogen and that the epidemiological findings

are consistent with the conclusions drawn from animal studies that 2,3,7,8- TCDD is a probable human carcinogen.

The carcinogenic potency of2,3,7,8- TCDD using the linearized multistage. model has been estimated relative to 53 other chemicals which EPA's Cancer Assessment Group (CAG) has evaluated

as suspect carcinogens. This relative potency index is 5X107permillimole (mmol) perkg perday (137 per ug perkg
per day), making 2,3,7,8-TCDD the most potent carcinogen that the CAGhas evaluated. CAGranks 2,3,7,8-TCDD as a 2-A carcinogen, which means that there

are sufficient laboratory animal data indicating its carcinogenicity as well as suggestive human evidence.

The limited data on otherPCDD
congeners indicate that they are qualitatively similar in their toxic action
to 2,3,7,8-TCDD when comparisons are made in a single species. This is illustrated in mice, where 2,3,7,8-TCDD has an LD50 value of0.88 micromoles (umol) per kg and 1,2,3,7,8-peCDD; 1,2,3,6,7,6-HxCDD and 1,2,3,7,8,9-HxCDD have LD50 values of0.94, 3.19, and 3.67 umol/kg, respectively.

Toxicological testing ofPCDFs. specifically, 2,3,7,8-TCDF, has been

more limited than testing of2.3,7.8- TCDD. The acute oral LD50 in the guinea pig is reported to be 5HeinOnline -- 50 Fed. Reg. 29175 1985 

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micrograms perkg bw (as compared with the acute oral LD50 for 2,3,7,8- TCDD in this species which is reported
to be 0.6 microgram perkg bw). Subchronic testing of2,3,7,8-TCDF in rhesus macaques indicated that this compound is extraordinarily toxic. Based uponEPA's review ofthis study, the No ObservedEffect Level (NOEL) for 2,3,7,8-TCDFis expected to be below 5.0 parts perbillion (ppb). The author of this study concluded that continued daily oral intake ofsmall amounts of 2,3,7,8-TCDFgave monkeys a disease which is clinically and morphologically similar to acute orchronic ingestion of 2,3,7,8-TCDD. The clinical course is marked chiefly by weight loss, swelling ofthe eyelids, dryness and granularity ofthe skin, hair loss and reduced physical activity. Formost ofthe observed biological effects. the potency ofthe two compounds are within an orderofmagnitude ofeach other, with 2,3,7.8-TCDF being somewhat less toxic than 2,3,7,8-TCDD. Some scientists have estimated that in laboratory animals. 2,3,7.8-TCDF is 2to 33 percentless toxic than 2,3,7,8-TCDD, depending upon the particularendpoint in question. Further. the toxicity of2,3,7,8-TCDF in rhesus
macaques has been estimated to be about 20 times that of3,4,4'.5'- tetrachlorobiphenyl and 1.000 times

more toxic than PCB Aroclor 1248.

Based on its assessment ofavailable literature on the toxicity of2,3,7,8-TCDF and the structural similarity of2,3,7,8- TCDF to 2.3.7,8-TCDD, EPA has concluded that it is prudent to assume that exposures to 2.3,7,8-TCDF would
pose risks ofsimilar toxic effects as exposures to 2,3,7,8-TCDD. Further, based on structure-activity relationships and limited in-vitro studies. EPA

assumes that otherPCDF congeners, particularly 1,2,3,7,8-PeCDF, 2,3,4,7,8- PeCDF, 1,2,3,4,7,8-HxCDF, 1,2.3,6,7,8- HxCDF, and 1,2,3,7,8,9-HxCDFmay also
pose risks ofsimilar toxic effects as exposures to 2.3,7,8-TCDF (and 2,3,7,8- TCDD).

Following the Binghamton fire. several researchers completed toxicological testing ofsoot samples in guinea pigs. Based on these studies, using Binghamton State Office Building (BSOB) soot, EPA has concluded that
exposures to sootfrom PCB Transformer fires have the potential to produce toxicity in the thymus, the hematopoietic system, the salivary gland duct epithelium and, possibly, the liver.

It is worth noting that thymic atrophy, bone marrow depletion, and diminished body weightgain. all effects ofthe subchronic administration ofthe BSOB soot, have been routinely demonstrated in acute studies in guinea pigs using PCDFs and PCDDs, In addition, the
group ofguinea pigs dosed with 231.1
ppm BSOB soot (in feed) in the subchronic study exhibited symptoms characteristic ofacute exposure to 2,3.7,8-TCDD and 2,3,7,8-TCDF, which include skeletal muscle degeneration, fatty changes in hepatocytes. and degeneration ofgastrointestinal tract epithelium.

One paper stated that the oral LD50 of the BSOB soot in guinea pigs is 410 milligrams perkilogram body weight, which would classify this material as very toxic.

Formore in-depth analyses ofthe toxicities ofPCBs, PCDFs, and PCDDs

see documents 2, 3, 4, 5, 6, 8, and 13 in Unit X.B.

B. The Formation ofOxidationProducts From PCBs

There is direct evidence ofthe formation ofPCDFs and PCDDs from heating and burning commercial mixtures ofPCBs and diluents from: (1) Chemical analyses ofmaterials at the sites where fires were known to involve transformers that contained PCBs and chlorinatedbenzenes, and (2) laboratory experiments published in chemical and otherliterature. PCBs, PCDFs. and PCDDs were found in some soot specimens fromboth the Binghamton and SanFrancisco fires. Data submitted
to EPA following the issuance ofthe Proposed Rule indicate that PCDFs and PCDDs were also measured in samples taken following the Miami and Chicago fires.

Laboratory studies provide the best available information on the conversion ofpure PCBs to PCDFs. In these studies,

a number ofdifferentPCB congeners and mixtures ofcongeners have been heated and the resulting materials analyzedfor PCDFs and PCDDs. A specific PCB compoundreacts to form a limited number ofPCDFs. The formation ofPCDFs involves intramolecular elimination ofthree kinds ofdiatomic molecules, with orwithout some rearrangement ofchlorine atoms on the phenyl rings in the product dibenzofuran. From the products obtained in the PCB reactions, the diatomic molecules, hydrogen, hydrogen chloride, and chlorine. are formed from hydrogen and chlorine atoms in ortho positions on each ofthe two phenyl rings in the original polychlorinated biphenyl molecule. The optimum temperature range for the published laboratory experiments was 600 ·C. Yields ofPCDFs have been reported in the literature to be as high as 10percent (calculated on the amount ofPCB decomposed) for'reaction temperatures from 550 ·C to 600 ·C, but drop offto tenths ofa percent at temperatures below 500 ·C and above 650 ·C.

EPA-sponsored studies ofthe formation ofPCDFs and PCDDs indicate that the optimum conditions for the formation ofPCDFs from (neat) PCBs

are 675 ·C for 0.8 second orlonger, with 8percent excess oxygen. Under these conditions, a 3percent conversion efficiency (PCBs to PCDFs) was observed for askarel fluid. Under the

same conditions, PCDFs were also formed from PCBs present at concentrations of5, 50. and 500ppm in mineral oil and silicone oil. The EPA study ofthe formation ofPCDFs PCDDs from PCB-containing mineral oil and silicone oil indicates a 4percent conversion efficiency ofPCBs to PCDFs when PCBs are present in these materials at concentrations of5, 50, and 500ppm. Statistical analysis showed a linearrelationship between the amount ofPCB present and the amount of PCDFs formed,

PCB dielectric fluid may also contain chlorina.ted benzenes as diluents or contaminants, as a result ofpast servicing activities. Laboratory experiments in the published literature have shown the formation ofPCDDs in addition to PCDFs from the pyrolysis of mixtures ofchlorobenzenes. Amounts of PCDFs ranged as high as several tenths ofa percent for mixtures of trichlorobenzenes. Tetrachlorobenzene and pentachlorobenzene mixtures formed amounts ofPCOFs and PCDDs which were two orders ofmagnitude smaller than the amounts ofthese compounds formed by trichlorobenzene. These reactions are bimolecularand the experimental concentrations of chlorobenzenes were high.

EPA-sponsored studies ofthe incomplete combustion ofchlorinated benezenes indicate thatPCDFs, and to a lesserextentPCDDs, are formed from the incomplete combustion of trichlorobenzene dielectric fluid containing no detectable PCBs. EPA also studied the incomplete combustion of tetrachloroethylene (perchloroethylene) and high temperature hydrocarbons (both ofwhich are potential PCB substitutes) to determine whether PCDFs and PCDDS would be formed from these materials in fire situations. EPA's preliminary study indicates that PCDFs and PCDDs are formed from the incomplete combustion of tetrachloroethylene fluid. The two high temperature hydrocarbon fluids did not produce PCDFs orPCDDs underthe experimental conditions.

The presence oflow concentrations of chlorobenzenes as contaminants inHeinOnline -- 50 Fed. Reg. 29176 1985 

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dielectric fluids that also contain PCBs

are not expected to lead to substantial increases in the amounts ofPCDFs formed from burning orheating the PCBs, but, may result in the formation of

some PCDDs. EPA believes that the PCDD levels found in the Binghamton
soot samples resulted from the pyrolysis

or incomplete combustion of chlorobenzenes. The low level PCDDs found following the San Francisco fire could have been associated with the
presence ofchlorobenzenes in that fluid

as well.

Forfurther discussions ofthe formation ofincomplete combustion products from PCBs and otherpotential substitute fluids, see the EPA-sponsored studies completed by the Midwest Research Institute, documents 10 and 11 in Unit X.R.

The description and characterization ofthe chemical reactions occurring in a fire in which aroclors (or any other commercial mixtures ofmany PCB compounds) are burned are far more complex than the laboratory experiments. However, EPAbelieves that reactions observed in the

. laboratory should also occurin fire.

situations where the reactants and reactions conditions are similarto laboratory reaction conditions. Data from actual PCB Transformer fires confirm the relatively high rates of conversion ofPCBs to PCDFs in actual PCB Transformer fires.

PCDFs and PCDDs have also been detected following high temperature incineration. High temperatures incineration is required by EPA regulations to dispose ofPCBs in oil. However, the levels ofPCDFs and PCDDs measured following high temperature incineration have been substantially less than those measured following the above described laboratory experiments. This is because ofhigh temperature incineration requires a 1200 ·C temperature, a 2- second residence time, and sufficient
oxygen to sustain complete combustion. As explained above, laboratory experiments indicate that the reaction temperature for the formation ofPCDFs is optimized at around 600 ·C. It is probable that yields ofPCDFs from PCBs are reduced at higher temperatures because ofincreased destruction efficiency and ease ofcombustion.

C. 

### Causes of PCB TransformerFireRelatedFailures

PCB Transformer fire-related incidents can occurfrom many causes, including overloading. overheating, electrical faults (overcurrent conditions

or low current faults eitherin the transformer itselforexternal to the transformer in associated electrical equipment), and fires near transformers, involving building components or stored materials. PCB Transformer fires can also occuras a result ofmechanical failures which can lead to electrical faults, and then, to fires. Ofthe welldocumented PCB Transformerfires.
many have reportedly occurred as a result ofelectrical faults, which led to transformerfailures and fires. Electrical faults are oftwo basic categories: faults characterized by high current or excessive current flow (high current· faults), and faults characterized by low
current flow (low current faults).

Electrical faults can occur in transformers themselves orin associated electrical equipment. Faults in associated electrical equipment are of equal concern to faults inside transformers. first, because these faults

can ultimately cause transformerfailure, and second. because most faults occur external to the transformers themselves. in associated electrical equipment. Thus,

as a general rule, the more associated electrical equipment present, the higher the probability ofa fault occurring. Further. electrical faults are more likely
to be self-sustained rather than selfextinguishing when voltages are higher.



### 1. Mechanisms of failure-a. Excessive currentflow. The first failure mechanism is excessive current flow of the transformer. This is termed an overcurrent condition or simply, "overcurrent". Prolonged overcurrent conditions can lead to fires inside a transformer. Ifthe overcurrent condition is due to a fault in the transformer itself, then there is a high energy arc in the transformer's insulating fluid. Failure to extinguish quickly high current arcs in a transformer will result in rapid transformer failure, involving the rupture ofthe transformercasing and loss ofdielectric fluid. Ifthe overcurrent condition is due to a fault in the associated electrical equipment, then there is high energy fault in the associated electrical equipment. Faults

are more likely to occur externally, in associated electrical equipment, than in the transformer itself. However a high
current fault in associated electrical equipment can draw excessive current from the transformer, heat the solid insulation, increase the discharge activity in the transformer and cause transformerfailure (rupture and release ofdielectric fluid).

According to comments on the Proposed Rule, electrical faults which

occur on the load side or secondary side ofa transformer (in the low voltage winding, low voltage leads, or in other associated switchgear and equipment)

are more likely to be self-sustaining rather than self-extinguishing when the secondary or load side voltage is higher. That is, self-sustained high current faults in the secondary (the low voltage side)

are more likely in highervoltage secondaries (i.e., 480 volt secondaries) than in lower voltage secondaries (i.e

.. 208 volt secondaries).

Current-limiting fuses or energylimiting devices and overcurrent protective relays are the types of electrical protective devices which can be used to quickly extinguish high
current arcs inside the transformer casing, as well as high current faults which occur external to the transformer in associated electrical equipment. PCB Transformer fires which occur as a result ofovercurrent conditions occur when overcurrent electrical protective devices (fuses and/or circuit breakers)

are notpresent; when overcurrent protection is not set sensitive enough to deenergize the transformerbefore high temperatures orpressures are reached; and when overcurrentprotection simply fails to operate when called upon.

b. 

### Lowcurrentfaults. The second failure mechanism is the widely recognized (in written comments on the Proposed Rule and in testimony at the public hearing) possibility that low
current faults may occur in a transformeritself, or external to a transformer. in its associated electrical equipment, and not activate conventional overcurrent protective devices (the fuses and circuit breakers discussed earlier). Fora low current fault in a transformer to release sufficient energy to lead to tank rupture, the fault must first produce a pressure rise in the transformer tank. In contrast to the short time involved from the

occurrence ofa sustained high energy (high current) arc to the reputure ofa transformer, low current faults may take

some time to release sufficient energy to

cause tankrupture.

Low current faults can also occur external to a transformer, in associated electrical equipment such as network protectors (circuit breakers which are typically installed on the secondary side ofnetwork transformers) and network collectorbuswork. Sustained or prolonged low current faults external to

a transformercan ultimately involve the transformer itself, causing rupture and release ofPCBs.

As was the case for high current faults, comments on the Proposed Rule indicate that when the secondary voltage ofa transformeris higher, low
current faults which occur in the secondary (in the low voltage winding, low voltage leads, or associated equipment) have a greaterlikelihood ofHeinOnline -- 50 Fed. Reg. 29177 1985 

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being self-sustained rather than selfextinguishing. That is, low current faults in480 volt secondaries have a greater likelihood ofbeing sustained than low
current faults in 208 volt secondaries.

Protecting against sustained low
current arcing faults in a transformer involves the use ofappropriate sensors and disconnect equipment. The sensors

are designed to detect a pressure rise in the transformer tank and/or a temperature rise in the lower voltage transformerwinding. Protection against sustained low current arching faults in external associated electrical equipment (which can ultimately involve the transformer) involves placing heat or ultraviolet sensors in this equipment. When the sensors detect an abnormal condition. (Le., a rise in pressure or temperature) the transformeris rapidly deenergized. either automatically or manually (following the receipt ofan audio or visual signal at a control center).

2. Protection currentlyprovided againstcommonmechanisms offoultrelatedfailures. Comments submitted in
response to the Proposed Rule and testimony supplied at the public hearing indicate that PCB Transformers are currently equipped with electrical protection to reduce the frequency of transformer failure; but, that theo\evel and type ofelectrical protection provided varies depending upon the
nature ofthe transformer installation. Certaintransformers and installations

are betterprotected againstfault-related failures than other types oftransformers and installations. Forpurposes ofthis section, it is sufficient to divide the applications into two types.

The first application includes all arrangements in which the PCB' Transformercan be energized only from the primary winding. These transformers

are termed radial PCB Transformers. (There are, however, five basic types of radial installations. simple radial systems. expanded radial systems. primary selective systems. primary loop systems. and secondary selective systems.)

The second application includes those arrangements in which the PCB Transformer can be energized from either the primary winding orthe secondary winding. The secondary winding is the winding from which
energy flows during normal operation. In these systems, the primary winding can be energized from the secondary winding under abnormal conditions. These transformers are termed network PCB Transformers. There are two basic types ofnetwork installations, grid networks and spot networks. Functionally, there are two types of electrical protection devices. One type interrupts the flow ofcurrent by vaporizing a segment ofthe conductorif the current exceeds a**predet~rmined** 

### level. Fuses and distribution cutouts operate in this manner. The second type ofelectrical protection device operates by opening a switch. A circuitbreaker
opens a switch in response to a temperature rise in the device due to the
current flowing in the circuit. Aground fault interrupter opens switch contacts in response to an unbalanced current flow. A networkprotector opens switch
contacts in response to a reversal ofthe
current flow.

"Non electrical" protection devices

are also available. Devices such as pressure sensors open (or close) relay
contacts to switches whe'n the pressure (orrate ofrise ofpressure) exceeds a predetermined level. Temperature

sensors and fluid level sensors operate in a similarmanner.

a. 

### RadialPCB Transformers. According to comments submitted in
response to the Proposed Rule, radial PCB Transformers are typically equipped with overcurrent protection (on the high voltage side) in the form of either a current-limiting fuse orcircuit breaker, and, often, with fuses and/or circuitbreakers on the low voltage side

or the load side. The overcurrent protection on the primary is set at a predetermined level to clearhigh current faults on the primary and is typically set sensitive enough to clear downstream high current faults in the secondary as well. These fuses/circuitbreakers are set to operate quickly enough to avoid transformerfailure in the event ofhigh
current faults in the primary or secondary.

Radial transformers are not. however, typically protected against low current arcing faults; these faults do not activate conventional overcurrent protective devices. Low current arcing faults can

occurin areas such as the secondary winding and low voltage leads ofradial transformers and canprogress unseen by existing overcurrent protection. leading to transformer failure. Radial transformers with higher secondary voltages are more likely to experience a low current arcing fault on the secondary whichis self-sustained than radial transformers with lower secondary voltages.

According to comments on the ProposedRule, many radial PCB Transformers used in industrial applications are equipped with temperature and pressure relays and circuitbreakers on-site which can be manually operated to actuate transformer deenergization in the event ofa sustained fault. However, ifon-site control ofa radial transformer is not possible (through the use ofa manually operable circuitbreaker), which is more likely the case in commercial installations, deenergization would involve contacting the utility substation
to deenergize the substation primary feeder. Comments on the Proposed Rule indicate that this is a difficult thing for a utility to do, because deenergizing the primary feeder results in the deenergization ofall transformers served from thatprimary feeder. This results in the loss ofelectric power to many buildings served by this same primary feeder.

b. 

### NetworkPCB Transformers. According to comments on the Proposed Rule, network transformers are typically equipped with the least sensitive
overcurrent protection ofall utility distribution transformers. While radial transformers are typically equipped with
overcurrent protection onthe primary

. (which is set sensitive enough to clear high current faults on the primary as well as downstream high current faults in the secondary), network transformers

are not typically equipped with currentlimiting orenergy-limiting devices on the primary circuit. Electrical protection for high current faults on the primary (in the primary feeder, the high voltage leads, and switchgear) is typically provided by relays to a primary feeder circuit breaker at the utility substation. The relays to the primary feeder breaker
cannot detect downstream sustained high current faults in the secondary.

Further, while the relays to the substation primary feeder breaker on network transformers will operate for sustained high currentfaults in the primary (allowing for deenergization), deenergization may not occur quickly enough to avoid switchgear and/or

. transformerrupture. Thus, switchgear rupture and transformerfailure can

occur in network transformers from high
current faults on the primary.

Unlike radial transformers. network. transformers are equipped with network protectors. which are circuitbreakers located on the secondary side of network transformers. The network protectoris set to operate when it

senses a reverse powerflow. Thus, it operates to preventpowerbeIng fed backinto the transformer in the event that the primary feeder breakerhas been activated. The networkprotector operates in a coordinated fashion with the substation breakerrelays to isolate

a faulted network transformer. By isolating the faulted network transformer, service continues to beHeinOnline -- 50 Fed. Reg. 29178 1985 

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supplied to the load by other transformers in the network. '

According to comments on the Proposed Rule. current-limiting fuses are used in the secondary ofhigher secondary voltage network transformers (in the service's and in the network protector). These fuses operate when high current faults occurdownstream from these areas. However, the presence ofthese fuses does not mean that the entire secondary is protected against high current faults. There is a zone in the secondary in network transformers which is currently "unprotected." where high current faults can occur and not be

seen by the relays to the primary feeder breakerorby these fuses in the services and the network protector. High current faults in this area can result in ' transformer failures and fires. Network transformers with higherf?econdary voltages are more likely to experience high current faults in the seconda,ry which are self-sustaining, than network transformers with lower secondary voltages.

Like radial transformers, network transformers are not typically**pr~tected** against low current arcing faults. Further, in network transformers, there is typically more associated electrical equipment where these faults can occur. Low current arcing faults in network transformers can occur in the network protectorand (for spot network transformers) in the network collector bus as well as in the secondary winding and low v9ltage leads. Again, these faults are more likely to be selfsustaining rather than self-clearing when the secondary voltage is higher.

Unlike industrial transformers, commercial transformers, particularly network transformers are not typicaHy equipped with primary circuit breakers

on site. The deenergization ofa commercial network transformer after failure from a sustained (undetected) low current or high current fault would typically require the manual opening of the utility substation primary feeder breaker, after the utility has been contacted about a malfunction in the equipment. As indicated earlier, utilities

are generally hesitant to open primary feeder breakers because oftheir desire for continuity ofservice to their
customers.

3. Conclusions. Comments on the Proposed Rule suggest that there are ways in which both radial and network PCB Transformer installations could be better protected to minimize the likelihood offault-related failures and fires. Several comments on the Proposed Rule discussed the role ofhigh current faults in PCB Transformer failures and fires, the level ofprotection currently provided against these faults in different types oftransformer installations, and
ways in which PCB Transformers could be betterprotected to minimize the chance offailure from these types of faults. Network PCB Transformers are currently the least well-protected against high current faults ofall distribution class PCB Transformers in

use. According to comments submitted in response to the Proposed Rule, the Tulsa PCB Transformerfire was associated with this type offault in the high voltage switchgear ofa 208/120 volt network PCB Transformer.

Many comments on the Proposed Rule, however, focused on sustained low
current arcing faults in PCB Transformers as the culprit in the number ofdocumented PCB Transformerfires. These comments discussed the level ofprotection currently provided against these faults' in PCB Transformerinstallations and,
ways in which PCB Transformers could be better protected to avoid low current fault-associated failures and fires. The San Francisco fire, the Chicago fire, and the Miami fire have been associated with these types offaults in 480/277 volt network PCB Transformers.

Simply stated, sustained low current arcing faults can occurin PCB Transformers and associated electrical equipment, and with existing levels of conventional protection, progress undetected and unseen, resulting in transformer failure and fire. According
to comments submitted in response to the Proposed Rule, low current arcing faults can occur in the secondaries ofall types oftransformer installations, radial transformers, lower secondary voltage network transformers, and higher secondary voltage network transformers. They are, however, more likely to occurin installations with

more, as opposed to less, associated electrical equipment and are more likely
to be sustained in transformer secondaries when the secondary voltage is higher. This is because faults are more likely to "restrike" orbe sustained at higher voltages than be selfextinguishing or self-clearing.

All types ofPCB Transformers typically lack the sensors (pressure and/

ortemperature sensors) necessary for the early detection oflow current arcing faults. Further, many commercial PCB Transformers are typiclllly unequipped with on-site primary circuit breakers to actuate transformer deenergization. This

means that low current arcing faults can progress unseen in these transformers, and that these transformers cannot be easily deenergized, even after transformer rupture has occurred. Deenergization ofcommercial PCB, Transformers (when disconnect ' equipment is not present on site) typically requires the opening ofthe primary feeder breaker at tlte electric utility substation, which is often miles
away from a transformer installation. According to testimony at the public hearing, the opening ofa primary feeder breaker at an electrical substation is a'
very difficult thing for a utility to do, because opening the primary feeder breaker for a malfunction in a single PCB Transformer will also result in other (well-functioning) transformers in the distribution system being deenergized.

D. PotentialforExposure

Toxicity and exposure are the two basic components ofrisk. In Unit IV.A, EPA addressed the toxicity ofPCBs, PCDFs, and PCDDs. The following summarizes EPA's evaluation ofthe potential for human and environmental
exposures to PCBs, PCDFs, and PCDDs from transformerfires.

As discussed in Unit IV.C, high

, current faults and low current faults in electrical transformers and/or associated equipment, as well as the ignition ofcombustible or flammable materials in a transformer location, can all lead to the rupturing ofa transformer, the volatilization ofPCBs, and the formation ofincomplete combustion products. Sustained high temperatures in the area ofa ruptured transformer increase the potential for the formation oftoxic products ofincomplete combustion, including PCDFs, 2,3,7,8- TCDF;PCDDs, and 2,3,7,8-TCDD. These high temperatures can eitheroccur as 

## a result ofthe initial malfunction or as a result ofpr010nged arcing associated with an inability to deenergize the transformercompletely. Smoke and soot from a high temperature fire involving a PCB Transformer can contain high concentrations ofvolatilized PCBs and oxidation products.

The most extensive monitoring data

on PCB, 2,3,7:8-TCDF and 2,3,7,8-TCDD levels in buildings following PCBTransformer fires were obtained from the Binghamton State Office Building site. Acomposite soot sample from this fire indicated the presence of7,200 ppm PCBs, 231 ppm 2,3,7,8-TCDF, and 2;9
ppm 2,3,7,8-TCDD. For a full description ofPCB, PCDF, and PCDD levels measured following transformer fires,

see the quantitative exposure assessment completed for this final rule, support document 1 in Unit X.B.

EPA believes that the levels ofPCBs and oxidation products measured in
soot samples following the BinghamtonHeinOnline -- 50 Fed. Reg. 29179 1985 

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### 29179

fire are values which are representative ofsituations in which combustion conditions are conducive to the formation and/or release ofPCBs and oxidation products. Therefore, in this rule, EPA has used these values to estimate human and environmental
exposures to PCBs, PCDFs, and PCDDs from PCB Transformer fires and fires involving PCB Contaminated transformers.

In the Proposed Rule, EPA evaluated the likelihood and nature ofhuman and environmental exposures from transformer fires in ornearbuildings by analyzing likely exposures from a PCB Transformer fire in ornear an office building. A number ofcomments received in response to the Proposed Rule suggested that EPA evaluate separately the expected exposures from transformer fires in ornearindustrial facilities and the costs ofcontrol

measures for these transformers. Comments suggested that the use ofPCB Transformers in industrial facilities pose lower fire-related risks than the use of PCB Transformers in commercial buildings and that the costs ofthe proposed transformerisolation requirement would be substantially greater for industrial facilities than for commercial buildings.

.

EPA agrees that industrial facilities should be evaluated separately from commercial buildings. Accordingly, EPA has evaluated the potential for human and environmental exposures for the following categories ofPCB Transformer fires: (1) A PCB Transformerfire in or

near a commercial building (both before the implementation ofrisk reduction

measures and after the implementation ofrisk reduction measures); (2) a PCB Transformer fire in an industrial facility; (3) a PCB Transformer fire in an outdoor electrical substation; and (4) a PCB Contaminated transformer fire in ornear

a commercial building. '

The first step in evaluating the potential for human exposures to PCBs and oxidation products is to determine the populations that are likely to experience these exposures. EPA has identified six populations that may be at risk ofexposure to PCBs and oxidation products in the event ofa fire involving

a transformer containing PCBs. These

are: (1) Persons present in a building or possibly in an adjacent building at the time ofa fire in or near a building: (2) firemen and otheremergency response personnel responding to a fire: (3) onlookers present during the extinguishing ofa fire and members of the general public in the vicinity ofthe fire: (4) persons involved in sampling and cleanup operations following, the fire; (5) persons returning to the building following cleanup; and. (6) persons exposed to equipment, automobiles. etc. that may have been contaminated during or after the fire. Human
exposures to PCBs and oxidation products from transformer fires would be expected to occurprincipally through the inhalation and dermal routes.



### 1. PCB Transformerfires in ornear commercialbuildings-a. Nature of installations andoperation. PCB Transformers serving commercial buildings are typically located in basements, in machinery rooms on the first few floors ofbuildings, orin**sidewal~** orunderground vaults adjacent to buildings. Commercial PCB Transformers may also be located on roof-tops ornearbuildings in outside locations such as parking areas or loading docks. Electrical transformers used in or nearcommercial buildings are most typically located in areas which

are not easily accessible orvisible to building occupants. Based on the results ofthe Equitable Life Assurance survey ofcommercial transformerlocations, EPA estimates that 69 percent of commercial transformers located on lowerfloors ofbuildings are vaulted, and that transformers located on interior
upperfloors are gEmerallY located in separate mechanical rooms. The majority oftransfoMJ:Iers located exterior
to commercial buildings are also vaulted. According to utility representatives, in many cases. more than one PCB Transformer is located in

a vault. Typically, two to four PCB Transformers are located within a single vault.

While commercial buildings may have janitorial crews on duty for building maintenance, electrical equipment operations are not typically closely supervised ormonitored by trained electrical engineers or technicians. Maintenance and testing ofthese transformers would, in general, be expected to be less than that provided for utility substation equipment or industrial transformers. Further, disconnect equipment (Le., circuit breakers) is generally not present in commercial installations, and there is typically no one present on site who is trained in disconnecting the equipment,

even ifsuch equipment were provided.

Commentll on the Proposed Rule and EPA's analysis ofavailable information indicates that there are approximately 77,568 PCB Transformers used in ornear' commercial buildings. Ofthese 77,568 PCB Transformers, EPA estimates that approximately 29 percent are network PCB Transformers and

## n percent are radial PCB Transformers. Further, ofthe estimated 7,600480 volt network PCB Transformers in use (those transformers with a particularly high probability of fault-failure), EPA believes that over97 percent ofthese transformers are used in ornearcommercial buildings.

b. 

### Frequency of PCB Transformer fires. In the Proposed Rule. EPA

. estimated that 0.003 to 0.004 percent of nonsubstation PCBTransformers are involved in "serious" PCB Transformer fires (PCB Transformer fires involving smoke spread into buildings) each year. Within the category of"serious" fires

are fires with moderate smoke distribution and fires with extensive smoke distribution. EPA used data from the National Fire Incident Reporting System (NFIRS) for 1982 on the frequency ofstructure-related electrical transformerfires, data from the NFIRS

on the frequency ofstructure-related transformerfires with smoke spread beyond the room oforigin ofthe fire. limited data from the NFIRS on the make, model. and year oftransformers involved in these fires, and data supplied by various sources in response to the ANPR to develop this estimate. While EPA received several comments

on this estimate (some indicating that EPA had severely underestimated the frequency ofoccurrence and other indicating thatEPA had significantly overestimated the frequency of occurrence). little additional quantitative data were submitted to support modifying EPA's estimate ofthe frequency ofoccurrence ofserious PCB Transformerfires. Thus, EPA believes that its estimate of50 serious PCB Transformerfires over the remaining useful life ofPCB Transformers is a reasonable estimate ofthe future frequency ofserious PCB Transformer fires.

Since many comments on the Proposed Rule s'tiggested that EPA evaluate separately the risks posed by PCB Transformers in ornearindustrial facilities, EPA has developed estimates ofthe frequency ofPCB Transformer fires in industrial facilities and in commercial buildings.

As discussed in Unit IV.C, EPA believes that the probability ofPCB Transformer fault-related failure varies depending upon the type ofPCB Tranoformel' installation (and includes such considerations as the amount of associated electrical equipment present, the secondary voltage ofthe ' transformers, and the current level of protection provided against sustained high current faults and sustained low
current faults). Based on this analysis, and available empirical data on

. installation types in documented PCBHeinOnline -- 50 Fed. Reg. 29180 1985 

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## I Rules and'Regulations

Transformer fires. EPA has developed estimates ofthe relative probabilities of failure for different types ofPCB Tranr;former installations (high and low secondary voltage network transformers

versus high and low secondary voltage radial tra!JRfnrmeJ""). EPA has used these estimates B:1d aVH:.1able data on the distribution ofthese installation types in commercial locations and industrial locations to e<;t:mate the frequency of serious PCB Transformerfires both in commercial buildings and in industrial facUitips.

EPA believes that480 voltnetwork PCB Transformers would have a particularly high probability offailure: that lower secondary voltage network PCB Transformers and 480 volt radial PCB Transformers would have a lower probability offailure (compared to 480 volt netwurk transformers): and that lower secondary voltage radial PCB Transformers would have the lowest probability offault-related failures.

EPA estimates that44 ofthe 50 structure-related serious PCB Transformer fires which will occurover the remaining useful life ofPCB Transformers will occurin or near commercial buildings. This estimate is supported by electrical engineering theory concerning the mechanisms of PCB Transformerfault-related faUures and the likelihood offailures in different types ofinstallations as well as by available empirical data. The PCB Transformer fires in Binghamton. San Francisco, Chicago, Miami, and Tulsa all occurred in ornear commercial buildings: specifically, in office buildings.

Further, the SanFrancisco fire. the Chicago fire, and the Miami fire all reportedly occurred in 480 volt network PCB Transfonners. Three other firerelated incidents in commercial buildings in the Boston area also reportedly involved480 volt network PCB Transfonners. A total of6 out of10 known PCB Transformer fires have occurred in higher secondary voltage network PCB Transformers (in 480 volt network installations). This is particularly dramatic when one considers that there are only an estimated 7,600 480 volt network PCB Transformers in use.

c. 

### Exposureassessment. EPA has evaluated likely exposures from a serious PCB Transformer fire in ornear

a commercial building by using reasonable yet environmentally conservative assumptions. EPA assumes that a PCB Transfonner fire in a commercial building would involve sustained high temperatures in the transformer location. the rupture ofthe transformercasing, the release ofPCBs, the volatilization ofPCBs, and the widespread distribution ofPCBs and oxidation products throughout the interior ofa densely populated building (Le., an office building), into the ambient air, and into waterways. EPA assumes that smoke and soot containing PCBs and oxidation products are spread throughout a large office building dt.:ring peak use hours, that emergency response personnel are unaware that certain precautions should be taken to minimize exposures, and, that
reoccupancy occurs only after the removal ofvisible traces ofsoot by cleanup crews.

EPA assumes that a PCB Transformer fire in ornear a commercial building would involve the rupture ofthe transformer and sustained high temperatures in the transformerlocation for up to 4hours. EPA has assumed this because**trans~'ormers** located in ornear commercial buildings are more likely to be located in inaccessible, low visibility

areas, where malfunctions would notbe readily Identified. Fmther, EPA has assumed that the transformer will not be deenergized automatically and that the transformer will nothave the capability
to be deenergized manually from an onsite location. EPA made these assumptions because many PCB Transformers located in or near commercial buildings are network transformers, which are currently less well-protected electrically, and, are less likely to be able to be deenergized manually from an on-site location.

EPA's assessment ofthe potential for human exposures to PCBs and oxidation products from a PCB Transformerfire in

a commercial building serves as the baseline for subsequent assessments of the expected effectiveness offire hazard risk reduction measures in these locations. This assessment is also used in assessing likely human exposures from PCB Transformerfires in industrial settings and in outdoorlocations (away from commercial and residential areas), and for estimating likely human
exposures from PCB-Contaminated transformerfires in ornearcommercial buildings.

A PCB Transformerfire which occurs in ornear a commercial building during

a period ofpeak use may expose hundreds to thousands ofbuilding occupants to smoke and soot from the fire during the evacuation ofthe building. The potential for exposures of large numbers ofbuilding occupants to this smoke and soot is increased ifthe transformer involved in a fire ill located

nearbuilding ventilation equipment and ductwork. EPA estimates that evacuation times will be on the order of 6 to 8 minutes, and, that during these 6 to 8 minutes, building occupants will be exposed to smoke and soot, primarily through inhalation.

Emergency response personnel,

unaware that the smoke and soot from the fire may contain PCBs and toxic products ofincomplete combustion. may be exposed to these materials through inhalation, and may incur some dermal
exposure to facial an'as. EPA estimates that 30 to 60 emergency response personnel may be exposed for up to 4 hours during the**extingui~hing** ofa PCB Transformer fire. Dermal and inhalation
exposures offirefighters and other
emergency response personnel may continue during the completion of equipment maintenance procedures and during the cleaning ofpersonal clothing and firefighting equipment after the fire.

EPA has developed quantitative estimates ofexposures by cleanup

crews, firefighters, building occupants, and members ofthe general**publ~{;** to PCBs, PCDFs, and PCDDs. EPA developed these estimates primarily to evaluate relative exposures among these populations for different types ofPCB Transformer fires and not to define in an absolute sense expected human
exposures. In developing quantitative
exposure estimates. EPA must.make assumptions about parameters such as the concentration ofPCBs, PCDFs, and PCDDs present in soot, the amount of
sootgenerated. the distribution ofsoot in the interior ofa building, the duration ofexposure. the frequency ofexposure, and the expected routes ofexposure. As would be expected, the assumptions selected for use in quantitative exposure assessments can strongly influence the final exposure estimates. Recognizing this. EPA tends to routinely adopt more environmentally conservative assumptions for the different parameters ofthe exposure assessment.

EPA's quantitative estimates of potential firefighter exposures (assuming that respiratory protection is not worn during a PCB Transformerfire of4 hours duration, as well as other assumptions detailed in support document 1 in Unit X.B.) in terms ofestimated lifetime
average daily doses (LADD) is 8,006 picograms perkilogram perday (pg/kg/ day) PCBs, 98 pg/kg/day 2

,3,7,8-TCDF, 56 pg/kg/day otherTCDFs, 319 pg/kg/ day otherFCDFs, 5.1 pg/kg/day 2,3,7,8- TCDD, 0.98 pg/kg/day otherTCDDs, and45 pg/kg/day otherPCDDs.

Building occupants also may incur additional exposures (above those which may occur during building evacuation), ifthese parties remain nearby, as onlookers during the extinguishing ofthe fire. Further, there is

an increased potential for theseHeinOnline -- 50 Fed. Reg. 29181 1985 

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### Wednesday, July 17, 1985 / 

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additional exposures when emergency response personnel (the principal authority figures at the scene ofa fire)

are unaware ofthe nature ofrisks posed by exposures to smoke and soot from these fires.

The rupture ofa PCB Transformer and the release ofpotentially hundreds of gallons ofPCBs (and potentially PCDFs and PCDDs) into floor drains in transformer locations could result in the contamination ofwaterways. Further, if
water is used to extinguish the fire, or if
waterpipes rupture due to high temperatures caused by the fire, water runoffcould ultimately result in contalT'ination ofsurface waters and drinking ""Hter. Members ofthe general' public. in addition to fish and wildlife. in the vicinity ofa PCB Transformer fire
may be exposed to PCBs and oxidation products through the ingestion of residues. While comments on the ANPR suggest that water is not frequently used in extinguishing an electrical transformer fire, EPA believes that there is a potential for contamination ofwater from the rupture ofthe transformer. burst waterpipes. the extinguishing of ignited materials in the area (other than electrical equipment) and from cleanup efforts.

The presence ofa floor drain leading
to a storm sewer in a transformer location provides a readily accessible pathway for the contamination of surface waters, and potentially, drinking
water supplies. Water contaminated with soot containing PCBs, PCDFs, and PCDDs can enter these drains as a result offirefighting operations, burst water pipes, and cleanup operations. Very large amounts ofwater can be used in the cleanup process. Forexample, during the first year ofcleanup at the Binghamton site, over 160,000gallons of
water were used, treated by charcoal filtration and secondary treatment, and discharged to surface waters. The
nearest drinking waterintake downstream is 45 miles away and

serves 16.500 persons.

Atmospheric transport ofPCBs and oxidation products in an urban area could also be responsible for exposing
many members ofthe general population who live or w.ork in the vicinity ofa fire. In the Binghamton, New York incident, 2,585 people lived within 3 to 4kilometers ofthe building. While inhalation exposures by the general public as a direct result ofa PCB Transformer fire would be unlikely to

occur for an extended period oftime,
soot fallout from a PCB Transformer fire
may contaminate surface soil and surface water, in addition to outdoor furniture. automobiles. and other types ofmaterials which are commonly stored

.outside. Contamination ofsurface soil and surface watermay result in
exposures to fish and wildlife as well. Thus. dermal. inhalation, and even oral
exposures to the general population in the vicinity ofa fire may occuron a continuing basis long after the initial incident.

Exposures at the site ofa fire to soot containing PCBs and oxidation products'
may also continue long after the extinguishing ofthe fire. Cleanup crews, dispatched to the scene by a building

owner who is unaware ofthe nature of risks posed by a PCB Transformerfire.
may not be initially equipped with respiratory protection orprotective clothing. Inhalation and dermal
exposures would be expected to occur

as these crews work to remove soot from surfaces inside the building. Soot particles are likely to become airborne

as a result ofcleanup efforts. and would be expected to be inhaled by workers. In addition. because ofthe strenuous
nature ofcleanup work. these workers would be expected to have a high respiration rate, further increasing
exposures to PCBs and oxidation products through inhalation.

EPA's quantitative estimates of potential exposures to cleanup crews (assuming a 4-hourfire. the lack of protes;tive clothing, and the superficial. cleanup ofa building, as well as other assumptions detailed in support document 1 in UnitX.B.) is 13,784 pg/kg/ day PCBs. 34 pg/kg/day 2,3,7,8-TCDF, 19.9 pg/kg/day otherTCDFs, 109 pg/kg/ day otherPCDFs. 1.8 pg/kg/day 2.3.7,8- TCDD

,0.33 pg/kg/day otherTCDDs, and 15.7 pg/kg/day other PCDDs.

Even ifrespiratory protection and protective clothing are utilized by cleanup crews, EPA expects that some level ofexposure to these materials may

occurboth dermally and through inhalation because ofthe expected prolonged period ofexposure. Cleanup

crews may work long hours for extended periods oftime. For example, in the Binghamton incident, 40 to 70 workers were involved in cleanup operations for 7hours a day for over 250 days.

Finally, depending upon the level of knowledge ofthe building owner, emergency response personnel. the utility, and local public health authorities about the nature ofrisks posed by PCB Transformer fires, building occupants may be allowed to
return prematurely to a building following the removal ofonly visible
traces ofsoot. Exposures may occur to faces, hands, and lower arms for 8hours

a day overthe course of250 working days in a year. EPA also expects that inhalation exposures would occur as a result ofthe circulation ofairborne contaminants by the building's ventilation system. Further, these
exposures may continue for an indefinite period oftime because these materials are expected to the quite persistent, and resistant to degradation. Residual concentrations may remain on interiorbuilding surfaces for several
years. EPA's quantitative estimates of potential building occupant exposures (assuming that the fire burns for 4hours, that the building is occupied at the time ofthe fire. and that reoccupancy occurs following cleanup to visible traces of
soot in the buildings, as well as other assumptions detailed in support document 1 in UnitX.B.) is 39,593 pg/kg/ day PCBs, 65 pg/kg/day 2,3,7,8-TCDF, 65 pg/kg/day otherTCDFs; 277 pg/kg/day otherPCDFs. 1.2 pg/kg/day 2,3,7,8- TCDD, 0.76**p~/kg/** day otherTCDDs, and 35 pg/kg/day otherPCDDs.

EPA has prepared additional quantitative estimates ofpotential human exposures to PCBs, PCDFs. 2.3,7.8-TCDF, PCDDs, and 2.3,7.8-TCDD from a reasonable worst-case PCB Transformer fire in a commercial building. These estimates are presented in support document 1 in Unit X.B.



### 2. PCB Transformerfires in ornear commercialbuildings with risk reduction measures inplace. In order to evaluate the effectiveness ofrisk reduction measures in reducing
exposures to PCBs and oxidation products, EPA has assessed expected
exposures to these materials from a PCB Transformer fire in a commercial building. assuming the implementation ofcertain risk reduction measures.

In the Proposed Rule. EPA evaluated the expected exposures associated with

a PCB Transformerfire in ornear a commercial building with certain risk reduction measures in place. The risk reduction measures addressed in the Proposed Rule were transformer isolation from building ventilation equipment and ductwork. the control of potential waterreleases. the reporting of the fire to the National Response Center. the registration ofthe transformer with the responding fire department and the building owner. and the labeling ofthe exterior ofthe transformerlocation. EPA assumed that most PCB Transformers could be daenergized within 15 minutes offailure (without the installation of additional protection). and. for those transformers that EPA believed could
not be deenergized completely. EPA proposed requiring additional electrical protection on the secondary side ofthe transformers.HeinOnline -- 50 Fed. Reg. 29182 1985 

### 29182 Federal Register / Vol. 50, No. 137 / Wednesday, July 17, 1985 / Rules and Regulations

Thus, in evaluating the effectiveness oftransformer isolation, registration, labeling, and reporting ofPCB Transformers fires. EPA assumed that all but a subsetofPCB Transformers could be easily deenergized within 15 minutes offailure. For that subset, EPA requirp<l increased electrical protection

on the secondary side ofthe transformers.

Comments on the Propose!i Rule, however, indicate that: (1) Many PCB Transformers in commercial buildings

are not capable ofbeing easily deenergized afterfailures: (2) PCB Transformers in commercial buildings could be equipped with enhanced electrical protection which would reduce the probability oftransformer failures from electrical faults: and, (3) while the proposed additional electrical protective measures (for a subset ofthe PCB Transformerpopulation) would have avoided some failures in this equipment, failures in these transformers from otber common mechanisms offailure could still occur.

Many comments on the Proposed Rule suggested that EPA increase its emphasis on the reduction ofrisk through the prevention ofPCB Tra'nsformerfault-related failures and decrease its emphasis on the use of isolation measures to reduce structure and environmental contamination. These comments indicate that while transformerisolation can reduce
exposures in the event ofa PCB Transformer fire (by reducing widespread structure and environmental contamination), ifa transformercannot be easily deenergized afterfailure

occurs, then substantial quantities of smoke and soot canbe generated. The longer a transformerremains energized, the less likely it is that isolation will be

an effective riskreduction measure.

EPA agrees thatmeasures designed to prevent PCB Transformerfailures are preferred overmeasures designed to contain and control already released and/or formed incomplete combustion products. Further. EPA's evaluation of mechanisms oftransformer failure. commercial installation characteristics and operations, and the current levels of electrical protection in commercial PCB Transformerinstallations indicates that
many ofthese PCB Transformers could be better protected electrically to reduce the frequency offault-related failures and fires. Thus, in this final rule, EPA has focused on increased electrical protection rather than transformer isolation as the preferred measure for reducing the frequency ofserious PCB Transformerfires.

Since electrical protective devices arc subject to malfunction, EPA has also assessed expected exposures to PCBs and oxidation products in the event that transformer failure occurs despite the
presence ofincreased electrical protection; but, has assumed that

measures arc taken to control water releascs; that the incident is reported to the National Response Center: and, that the transformer is registered with both the responding fire department and the building owner. In addition, EPA

assumes that the exteriorofthe transformerlocation is marked with PCB identification labels.

a. 

### Frequency of serious PCB Transformerfires with riskreduction

measures inplace. EPA has used data from transformerand electrical equipment reliability studies to evaluate the probability ofelectrical protective device malfunction; and thereby. to estimate the effectiveness ofelectrical protection in avoiding serious PCB Transformer fires. Forpurposes ofthis rule, EPA defines electrical protective device malfunction as the failure ofa device to operate when called upon to operate. Itis difficult to develop a precise estimate ofthe expected rate of failure ofspecific combinations of electrical protective devices such as those which appear in this final rule. However, based upon available Information on the failure rate ofcircuit br,tJakers, current-limiting fuses, and heat and fluid level sensors. EPA expects the failure rate to be low. below 3 percent. Further, according to data on the failure modes ofcircuit breakers, only 9 percent ofcircuit breaker failures

are failures to operate when'called upon to open. The majority ofcircuit breaker failures are characterized by the operation ofa circuit breaker when it should not have operated or opened. That is. circuit breakerfailure typically involves dcenergization without cause rather than failure to deenergize when calledupon to open.

EPA has assumed that enhanced electrical protective systems will function to Hvoid between 97 and 99 percent ofthe serious PCB Transformer fires (about 43 fires) which would be expected to occurin commercial buildings over the remaining useful life ofthis equipment (this assumes that electrical protection can be implemented immediately). Electrical protection for commercial transformers phased in over

a 5-yearperiod is'expected to avoid about 36 serious PCB Transformerfires. EPA expects that one to two serious PCB Transformerfires will occur over the remaining useful life ofthis equipment as a result ofthe failure of the enhanced electrical protective systems to operate. b. 

### Exposure assessment. The potential for the volatilization oflarge amounts of PCBs, and the formation ofproducts of incomplete combustion from PCB Transformer fires is reduced ifefforts

are made to control combustion conditions in the transformer location. EPA believes that the removal ofstored combustibles from a PCB Transformer location will reduce the likelihood ofa fire occurring external to a PCB Transformerresulting in transformer failure. More importantly, the installation ofenhanced electrical protection on commercial PCB Transformers is expected to reduce substantially the frequency ofPCB Transformer fault-related failures in this equipment.

Comparing the circumstances surrounding well-documented PCB Transformerfires indicates that the

soonera faulted transformeris deenergized, the less likely it is that significant quantities ofPCDFs and PCDDs will be formed. Experience from actual incidents indicates that EPA is
correct in Its beliefthat there are practical means available for successfully controlling combustion conditions in PCB Transformer locations. Certain measures. once implemented, would reduce the likelihood offault-related failures and sustained high temperatures. These

measures are expected to reduce significantly the fire-related risks posed by the continued use ofthese transformers. \

Analyses ofthe levels ofelectrical protection currently provided for many commercial PCB Transformer locations indicate that these PCB Transformers could be better protected electrically to reduce the frequency oftransformer failures from electrical faults. Comments

on the Proposed Rule suggest that many ofthe well-documented PCB Transformerfires could have been avoided iftransformer failure had been avoided through the use ofenhanced electrical protection, such as currentlimiting devices, sensors, and disconnect equipment.

Enhanced electrical protection. that is. the installation ofovercurrent protection

on transformers which lack such protection, and sensors and disconnect equipment to avoid sustainedlow
current faults will reduce the likelihood ofPCB Transformerfault-related failures. These systems are intended to actuate complete deenergization of transformers when abnormal conditions

are sensed. While abnormal conditions

are expected to be typically caused by sustained high and low current faults, the low current fault protection systemHeinOnline -- 50 Fed. Reg. 29183 1985 

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in particular wouldalso function to avoid sustained 

### high temperatures and changes ininternal pressure from other

causes as well. Finally, thefinal rule requires the removal ofstored combustibles near PCB Transformers to reduce the likelihood of'aPCB Transformer fire occurring from an external source ofcombustion.

Iftransformerfailure and fire occurs despite the presence ofthe required electrical protection system and the removal ofstored combustibles, the
nature and magnitude exposures to PCBs and oxidation products by building occupants. firefighters, cleanup

crews, and members ofthe general populat'on could be equivalent to that described above, in Unit IV.C.l.c. However. the presence ofdisconnect equipment on site (which can be manually operated} formany PCB Transformers will provide for more rapid deenergization than is currently the case.

Registration. labeling, containment of potential water releases, and notification ofthe National Response Center would also be expected to reduce exposures to these populations in the event that transformer failure occurred despite the presence of increased electrical protection. Advance knowledge on the partoffire departments and building owners about the contents ofa transformer and the notification ofEPA inthe event ofa fire would be expectedto reduce expQsures
to building occupants, in addition to reducing exposures to firefighters and other emergency response personnel. EPAexpects thatfirefighters, aware of the nature ofrisks posed by a transformerfire. wouldbe more likely to

wearrespiratory protection and protective clothing andwouldbe more protective ofbystanders and onlookers. Building owners who are aware that a transformer fire involves a PCB Transformer would be less likely to dispatch unprotected cleanup crews to the site, and would be less likely to allow building occupants to return unprotected to an involvedbuilding.

IfPCB Transformer owners take

measures as soon as practically and safely possible to contain any spilled PCBs and or PCOFs!PCDDs (releasedas

a result ofa fire-related incident} and
water potentially contaminatedwith PCBs. PCDFs, and PCDOs, EPA expects that potentfal releases to waterways will be substantially reduced. The blocking offloor draIns in a transformer location as soon as practically and

.safely possible, and the containmentof all water associated with the incident (including cleanup waterJ shouldreduce the potential for the release ofPCBs and untreated waterinto surfacewaters. Finally. by requiring the reporting ofall PCB Transformer fire-related incidents
to the NationalResponse Center (NRC), EPAwillbe able to monitor cleanup efforts andthe treatment and discharge ofwater. to insure that safe levels are not exceeded.



### a.IndustrialPCB Transformerfiresa. 

### Nature ofinstallations and operations. PCB Transformers usedin industrial applications may be located

. indoors or outdoors, depending upon varIables such as the service being supplied by the unit, the sizeofthe unit, and the geographiclocation ofthe facility. According to comments submitted in response to theProposed Rule, many (butnotall} industrial transformers are rocated in production

areas, near motors, machinery, and other equipment. These transformers are typically unvaulted and readily visible
to facility workers during the routine conduct oftheir work. This IS in contrast to the typicalcommercialPCB Transformerinstallation, which is generallyInaccessible and ress visIble toemployees.

Comments on the Proposed Rule indicate that In many industrial facilities. theperformance of transformers in monitored during production shifts by engineers, electricians, or othersimilarly trained personnel. Further, comments indicate that industrial transformerowners reportedlyutilize visuarinspections, monitoring, and electrical testingof

. transformerfunction on a routinebasis. Electrical equipment failure and fire in

an industrial facilitymeans loss of production time. which.canhave severe economic Impacts. Thus, industrial transformer owners have this incentive
to provide for transformer maintenance and testingon a routine basis to avoid fault-related failures and forproviding disconnect equipment on site to provide for rapid deenergization in the eventofa fault-related failure.

EPA's analysis indicates that there are approximately 26,700PCBTransformers used in ornearindustrial facilities. Of these 26,700 PCBTransformers. EPA estimates that98percenlareradialPCB TransformerS', and, that2percentare networkPCB Transformers. Ofthe estimated7.600 480 volt network PCB Transformers in use, EPA estimates that only

## apercent (or 179 PCB Transformers} are usedin ornear industrial facilities.

b. 

### Freq;uencyof PCB Transformer fires. EPAestimates that6 out ofthe expected 50 serious PCB Transformer fires which will oecm averthe remainIng useful life ofPCB Transformerswill occurinornear industrialfacilities. Fourofthese fires

areexpected to occur after October 1, 1990. This estimate was derived by considering availableinformation on the numberand type of

### PCB Transformers used in ornear industrial facilities and availableinformationon the probability ofPCB Transformer fault-related failure for each type 

### oftransformerinstallation.

EPAhas. very little data on PCB Transformerfires.: which have actually occurred in industrial facilities. Limited data were'submittedby theAmerican PaperInstitute (API) regarding two PCB Transformerfire-related incidents in forest industry facilities. AccordIng to the results ofanAPI survey. during an 8.5 yearperiod. betweenJanuary 1976 and March 1984. there were two PCB Transformerfires (which involved

. smoke spreadinto buildings} out ofan estimated 3,509 PCB Transformers used by the surveyedcompanies. API indicates: that none ofthese incidents approached "Binghamton" proportions. and could be classifiedas moderate incidents: onthe spectrumofPCB Transformersfires.

c. 

### Exposure assessment. EPA has little data on the circumstances surrounding actual PCBTransformer fires in industrialfacilities-. However, 

### EPA has used environmentally conservative yet reasonable assumptions in evaluating likelyhuman and environmental
exposuresfrom 

### a PCBTransformerfire in a typical industrial facility. EPA recognizes: that

### PCBTransformerfires
may occurin atypical industrial facilities. where theexposures maybe somewhatgreater-than those described here. However; based On comments on the ProposedRule. EPAbelieves. that there arefundamental differences between the potential for human
exposures to PCBs, PCDFs and PCOOs from the: use ofPCB Transformers in industrial facilities versus theiruse in commercial buildings.

EPA assumes thata PCB Transformer fire in anindustrialfacility would involve an indoorPCBTransformer. sustainedhightemperatures inthe transformer location,. therupture ofthe**transformer~** the release ofPCBs. the volatilization ofPCBs. and the distributionofPCBs and oxidation products into the interior 

### ofan industrial facility, into the ambient**all~** andinto waterways. EPA assumes thatsmoke and sootcontainingPCBs. and oxidation products arespread throughoutthe interiorofanindustrial facmtydwring. peakusehoUts, worker evacuation'

occurs during the early stages: ofthe fue.

an on-sitefille brigademakes file initialHeinOnline -- 50 Fed. Reg. 29184 1985 

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response, and, that reoccupancy ofthe facility by workers occurs after the removalpfvisible traces ofsoot.

EPA assumes that a PCB Transformer fire in an industrial facility wi1l involve the rupture ofthe transformer and sustained high temperatures in the transformer location for up to 0.5 hour (in contrast to a 4-hourburn time assumed for commercial buildings). EPA has assumed this reduced burn time because comments on the Proposed Rule and available data indicate that transformers used in ornearindustrial facilities are more likely to be located in higher visibility areas, where malfunctions would be more rapidly identified. This is in contrast to the typical commercial PCB Transformer installation. which is not readily accessible orvisible to employees. Further. EPA has assumed that once a malfunction has been identified, the transformercanbe more easily deenergized in industrial facilities by on-site trained personnel. EPA made this assumption because comments indicate that industrial use PCB Transformers are typically equipped with primary disconnect equipment on site. Further, comments indicate that
many industrial facilities employ electrical engineers or technicians during duty hours to monitorelectrical equipment operations. This too is in
contrast to the typical commercial installation, which is not equipped with primary disconnect equipment on site. Further, commercial PCB Transformer operations are not typically monitored.

An industrial PCB Transformer fire which occurs during a period ofpeak

use may expose hundreds ofworkers to smoke and soot from the fire during the evacuation ofthe facility. However. EPA expects that workerevacuation times
may be quicker than those assumed for commercial buildings. First. industrial facilities are not typically high-rise buildings. Second. there are typically fewer people to be evacuated. Finally, industrial workers would be expected to be more educated about the potential risks posed by any type offire in an industrial location, and about proper evacuation procedures. EPA has assumed that exposures by workers to residual levels ofPCBs and oxidation products would, however. continue following reoccupancy. EPA's estimate 'ofpotential exposures to industrial workers (assuming a 0.5 hourburn time and cleanup to visible traces ofsoot, as well as other assumptions detailed in support document 1 in Unit X.B.) is 2,888 pg/kg/day PCBs, 6.7 pg/kg/day 2.3.7,8- TCDF, 3.8 pg/kg/day otherTCDFs, 22 pg/kg/day otherPCDFs, 0.36 pg/kg/day 2,3,7,8-TCDD, 0.06 pg/kg/day other TCDDs. and 3.1 pg/kg/day otherPCDDs.

Many industrial facilities have fire brigades on site to handle initial
emergency response situations. According to comments on the Proposed Rule, these fire brigades are typically well-trained and well-equipped to handle industrial accidents and fires, including PCB Transformer fires. A PCB Transformer located in an industrial facility would likely be less confined than in a commercial building, and. therefore, would provide easier access to firefighters than a commercial location. Firefighting time may be reduced by the accessibility ofthe transformer, the capability to deenergize the equipment on site, and the level of site-specific training ofindustrial fire brigades.

EPA assumes that a 10-man fire brigade would respond to a PCB Transformerfire in an industrial facility,

. and that brigade members would be

more likely to wear appropriate protective clothing and respirators. (Other assumptions are detailed in support document 1 in Unit X.B.) EPA's estimate ofpotential exposures to these firefighters is 45 pg/kg/day PCBs. 0.11 pg/kg/day 2.3,7,8-TCDF, 0.068 pg/kg/ day otherTCDFs, 0.37 pg/kg/day other PCDFs, 0.006pg/kg/day 2,3,7,8-TCDD, 0.001 pg/kg/day otherTCDDs, and 0.05 pg/kg/day otherPCDDs. Additional
exposures following the fire may. however. occurduring the cleanup of
turnout gear and firefighting equipment. EPA expects that industrial fire brigade personnel would take appropriate precautions to limit further exposures.

Ifwater is used to extinguish the fire,

orifwaterpipes rupture due to high temperatures, waterrunoffcould ultimately result in contamination of surface waters and drinking water supplies. Industrial facilities typically have many floor drains, which are readily accessible pathways for the release ofPCBs and oxidation products
to waterways.

Atmospheric transport ofPCBs and oxidation products in a metropolitan

area could also be responsible for exposing many people who live orwork in the vicinity ofan industrial plant to PCBs and oxidation products. Higher ventilation rates' in industrial facilities
may lead to more rapid distribution of PCBs and oxidation products into the ambient air than would be the case for a fire in a commercial building. However, the shorterburn time for the fire would decrease the total amount ofPCBs volatilized and incomplete combustion products formed and released. Cleanup following an industrial PCB. Transformer fire could be as timeconsuming as an indoQr commercial PCB Transformer fire. The cleaning and decontamination ofvaluable machinery and equipment would be very timeconsuming. The cleanup ofthe structure itselfmay be less involved than for a high-rise office building. Industrial facilities are more open and building surfaces are generally more accessible
to cleaning and decontamination. In addition, higher ventilation rates in industrial facilities would encourage the distribution ofsmoke and soot into the ambient air outside the facility. Further, the ability to deenergize the transformer from an on-site location would reduce both the amount ofPCBs volatilized and the amount ofincomplete combustion products formed llJld released.



### In facilities which operate around the clock (24 hours per day operations), electrical equipment operations would be expected to be monitored during the entire operating time. However, smaller industrial facilities may operate only 8 hours per day. leaving electrical equipment operations unmonitored for 16 hours per day.

A PCB Transformerfire in an industrial facility after normal hours of operation could, therefore, burn longer than the assumed 0.5 hour. Electrical equipment operations are not typically monitored by operating personnel during off-shift hours. While occasional security patrols would inspect the area,

a PCG Transformerfire could progress in much the same manner as a PCB Transformer fire in a commercial building. Deenergization ofthe transformer, even when on-site disconnectequipment is available, would take longerin these cases, because personnel trained in disconnecting the equipment would
most likely not be on site during off-shift hours.

An industrial PCB Transformer fire during off-hours would be more likely to expose volunteer and**municip~l** salaried firefighters than fires during normal operating hours. when company fire brigades would have primary responsibility for initial emergency response. Exposures to members ofthe general population in the vicinity ofthe fire would be expected to be higher for fires during off-hours. as would
exposures to cleanup crews. Exposures
to workers, however, would only be expected to occur following

. reoccupancy ofthe building, from
contact with residual materials on building surfaces and in the air.

4. 

### Outdoorfires involving PCB

, 

### Transformers-a. Nature ofHeinOnline -- 50 Fed. Reg. 29185 1985 

### Federal Register 

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## I Rules and Regulations 

### 29185

installationsandoperations. PCB Transformers which are used in outdoor applications may-be located on the tops ofutility poles, pad-mounted in urban. metropolitan. and rural areas. orin electric utility substations. The operatilm ofthese transformers i8 not typically monitored by on-site personnel. Electric utility substation PCB Transformers are typically fenced offto restrict access to authorized personnel. and their operation may be monitored by personnel in control rooms at utility transmission stations and/or generating stations.

EPA estimates thatthere are about 17.000 PCB Transformers used in outdoor applications. EPA expects that the majority ofthese transformers are in radial installations.

b. 

### Frequencyof PCB Transformer fires. Based on estimates ofthe frequency of"serious" PCB Transformer fires in radial transformer installations, and the estimated numberofPCB Transformerslocated in outdoor electrical substations. EPA estimates that outdoorPCB Transformerfires with smoke generationwill occur at a frequency ofabout0.0014 percentper year, or. about 3 incidents over the remaining useful life ofthis equipment

c. 

### Exposure assessment. Fires involving PCB Transformers located in outdoor locations, away from commercial buildings, are expected to result in lowerhuman exposures to PCBs and oxidation products in fire situations than transformerfires in or

nearbuildings. First. because combustion conditions in an outdoor PCB Transformer fire are not expected
to be as conducive to the volatilization ofspilled PCBs and the formation of large quantities ofPCDFs, 2,3.7.S-TCDF. PCDDs. or2,3,7.8-TCDD as would be the

case with transformers locatedin machinery rooms orvaults. Generally, combustible materials are notpresent

near outdoorPCB Transformers and

some ofthe heatgenerated from arcing

or fires would be expected to dissipate in the environment.

Further, outdoor utility substations in particular are generally fenced to restrict access to authorized personnel only. thus limiting thenumberofpeople
at immediate risk ofexposure in the
event ofa fire. In contrast to the smoke and soot produced from transformer fires in ornearbuildings. any smoke or soot produced in an outdoortransformer fire. away from commercial buildings. is expected tobemore widelydispersedin the environment. EPA has developed a model for the release ofPCBs and the formation ofPCDFs and/orPCDDs from

an outdoorPCBTransformer fire. EPA has estimated theexpectedexposures from releases to airfrom an outdoor fire and has found that exposures decrease with increasing distance. and that at a distance of200 meters from a fire, inhalation exposures from a typical fire would be expected to be relatively low.

While there is a potential that
emergencyresponsepersonnel and cleanup crews responding to such fires
may be exposed to some PCDFs. 2,3.7.8- TCDF, PCDDs. and 2,3,7.S-TCDD.
exposures to PCBs would be more likely
to occur. Firefightingequipment and protective clothingmaybecome contaminatedwith PCBs. and mayresult in exposures to firefighters during equipment cleanup and maintenance.

Fires involvingoutdoorPCB Transformers near commercial buildings (i.e

.. within 30 meters ofcommercial buildings) could result inmore people being exposedto higherlevels ofPCBs and any oxidationproductsproduced. For this reason, EPAhas included outdoorPCB Transformers located within 30 meters ofcommercial buildings within the definition ofPCB Transformers-located inornear commercial buildings.

.



### 5. Fires involvingtransformers containing less than 500

### ppmPCBs-a. Nature of installationsandoperations. EPA estimates that there are over20 millionmineraloil transformers in the electric utility industry and about5 million in 

### all otherapplications. These mineral oil transformers may contain low levels ofPCBs (less than SOD 

### ppm PCBs) as a result ofcontamination from past servicing activities. EPA estimates that approximately 1Smillion ofthese mineral oil transformers are used in nonsubstationapplications, inornear commercial buildings. industrial facilities and outdoors onutility poles. These transformers are installed in 

### both radial and network configurations.

b. 

### Exposure assessment. PCB Transformers typically contain 65 percentPCBs. orabout 1.300 times the maximum amount ofPCBs present in PCB Contaminated transformers (and 13.000 times the amount ofPCBs present in transformers containing 50 ppm PCBs). EPA has assessed the potential for exposures to PCBs. PCDFs. 2,3.7.8- TCDF. PCDDs. 2,3.7,ScTCDD from fires involvingPCB-Contaminated equipment by assuming that the transformer present in the Binghamton State Office Building was a PCB-Contaminated transformer. and, by assuming reasonableworst-case values for other parameters. Based on the results of EPA's studyofthe incomplete combustion ofPCB-Contaminated transformer fluids, EPA has assumed that the formafion ofPCDFs and PCDDs in a PCB-Contaminatedtransformer would beIfnearly related to the amount ofPCBs presentin the transformer. Given this situation. PCB. PCDF. 2.3.7.8- TCDF. PCDD. and 2,3.7,S-TCDD levels in the soot from such a fire would be expected tobe reduced by a factor of 1.300. compared to levels actually measured inBinghamton. Similarly•. human exposures to these materials are assumed to bereduced by the same factor.



### 6. Conclusions-Risksposed

### byfires involving transformers !hatcontajn PCBs. Toxicityc:nd exposure are the
twobasic components ofrisk. In earlier units ofthis preamble, EPA evaluated the toxicity ofPCBs, PCDFs, 2,3,7,8-

. TCDF. PCDDs. and 2.3.7.8-TCDD and presented assessments ofthepotential for human exposure to thesematerials from transformer fires. EPA concluded that both 2,3,7,8-TCDD and PCBs are probablehuman carcinogens, based
upon studies in laboratory animals. Further, since 2,3,7,8-TCDF is structurally and chemicany similar to 2.3,7.S-TCDD. EPA has concluded that it 

### is prudent to assume that an oncogenic potential existsin2.3.7.S-TCDF and perhaps inotherPCDD and PCDF
congeners as well

EPAhas determined thatrelatively large quantities ofthese compounds can be formed andreleased during a PCB Transformer**fire~particularly** 

### a fire whichoccurs in 01"

### near a commercial building. Sustained high temperatures in these transformer locations are more likely thaninindustrial oroutdoor locationsbecause ofthe nature of commercial PCB Transformer installations. Many commercial transformers are network transformers (which are the least well protected distribution (transformers}. Further. malfunctions in commerical PCB Transformers are more likely to progress into more serious incidents because these transformers are typically located in low visibilityareas, and because these locationstypically lack on-site electricaltechnicians and necessary disconnect equipmentto insure complete deerrergization in the event of

a sustainedfault orfailure.

Finally, there are many routes through which commercial buildingoccupants, emergency response personnel, cleanup

·crews. onlookers. and the generalpublic

can be exposedto these materials. once generated. Building evacuation times for large commercial buildings can'be relativelylong. reoccupancymay occur before adequatecleanup has been completed. emergencyresponse personnel maylacknecessaryprotective equipment. cleanup crews may be dispatched without properprotection.HeinOnline -- 50 Fed. Reg. 29186 1985 

### 29186 Federal Register 

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## I Rules and Regulations

onlookers may be un'aware ofthe risks posed. and members ofthegeneral population in the vicinity ofthe fire may incur inhalation exposures and dermal
exposures during the fire. and for extended periods afterthe fire from contamination ofwaterways. drinking
water supplies and outdoor materials with PCBs. PCDFs. and PCDDs.

EPA has concluded that fires involving PCB Transformers in ornear commercial buildings can pose significant risks ofhuman and environmental exposures to PCBs and oxidation products. EPA believes that44 ofthe estimated 50 structure-related serious'incidents over the remaining useful life ofPCBs Transformers will

occur in ornear these buildings. Further, based on its analysis ofthe relative probabilities ofPCB Transformer failures and fires. EPA has concluded that many ofthese fires will involve 480 volt network PCB Transformers.

Given that a single serious PCB Transformer fire in ornear a commercial building can potentially expose thousands ofpeople to PCBs and oxidation products in soot in air. water.

oron surfaces. EPA has concluded that PCB Transformerfires in ornear commercial buildings can pose significantrisks to human health and the environment. However. EPA also believes that reducing the potential for the release ofPCBs and the potential for the formation and release ofPCB oxidation products from PCB Transformers substantially reduce the fire-related risks posed by the continued

use ofthis equipment.

EPA has determined that sustained high temperatures in industrial PCB Transformerlocations and in outdoor substation PCB Transformers are less likely than for commercial PCB Transformers because ofthe nature of these installations. Many ofthese transformers are radial transformers (which are typically betterprotected against sustained faults and failures than network transformers). Further. malfunctions in industrial PCB Transformers which go undetected by existing electrical protection are less likely'to progress into more serious incidents because ofthe location of these transformers in highervisibility

areas. and because industrial facilities reportedly have on-site electrical engineers and technicians and
necessary disconnect equipment to provide for completedeenergization. Finally. the suggested higherfrequency ofmaintenance. inspection, and testing ofindustrial transformers and utility substation'transformers would further decrease the likelihood offire-related failures in this equipment.

EPA estimates that up to 6out ofthe expected 50 serious PCB Transformer fires over the remaining useful life of PCB Transformers will occurin ornear industrial facilities, and that less than 3 PCB Transformer fires with smoke distribution will occur in outdoorPCB Transformer locations.

While exposures to workers.
emergency response personnel, cleanup

crews and the general population may

occurfrom an industrial PCB Transformerfire, the magnitude of
exposure associated with a PCB Transformerfire in a typical industrial facility would be anticipated to be ' greatly reduced (when compared to a commercial PCB Transformer fire) as a result ofseveral factors. First, EPA expects that the duration ofindustrial PCB Transformerfire-related incidents would be significantly less than the duration ofcommercial PCB Transformer fires. because ofthe
presence oftrained personnel and disconnect equipment on site. The reduced duration wouldreduce
exposures to all populations potentially
at risk ofexposures. Second, there are generally fewer workers present in industrial facilities than in commercial buildings. and worker evacuation times would be expectedto be less for industrial facilities than for commercial buildings. This is because ofthe singlestory nature ofmany industrial facilities, and the expected increased level of education ofindustrial workers about workplace hazards. Third, according to comments on the Proposed Rule, industrial facilities often utilize welltrained, well-equipped fire brigades'for initial emergency response. rather than local volunteeror salaried municipal firefighters. Emergency response personnel as a group, then, would be expected to incurlower exposures in responding to industrial PCB Transformer fires than would be the

case for commercial PCB Transformer fires.

A comparison ofestimated exposures from a commercialPCB Transformerfire
to an industrial PCB Transformer fire indicates that exposures by building occupants to PCRs. 2.3.7,8-TCDF, other TCDFs. otherPCDFs. 2.3.7.8-TCDD. otherTCDDs, and otherPCDDs could be

as much as an order ofmagnitude higher for commercial building fires than for industrial building fires.

EPA recognizes that exposures from PCB Transformer fires in atypical industrial facilities could be higher than described earlier. However, EPA's estimate ofthe frequency ofindustrial PCB Transformer fires is 6fires over the remaining useful life ofindustrial PCB Transformers. Even ifEPA were to

assume that all 6ofthese fires resulted in individual exposures ofthe same

,orderofmagnitude suggested for commercial PCB Transformer fires. there

are fewer people at risk ofthese exposures'in industrial locations when compared to commercial buildings.

One could consider the overall firerelated risk posed by the continued use ofPCB Transformers and compare the different frequencies ofoccurrence of fires in commercial buildings versus industrial facilities (assuIt:ling as a worst-case. that the risks posed by commercial PCB Transformer fires and industrial PCB Transformerfires are equivalent). This analysis indicates that 88 percent ofthe fire-related risk posed by the continued use ofPCB Transformers (in locations in ornear buildings) are associated with theiruse in ornear commercial buildings and 12 percent ofthe total risks are associated with theiruse inindustrial locations.

EPAhas further determined that outdoorPCB Transformerfires, (away from commercial buildings) and fires involving PCB-Contaminated transformers pose lowerrisks than PCB Transformerfires in ornear commercial buildings. While EPA expects that outdoorPCB Transformer fires may result in the release ofPCBs, EPA expects that outdoorPCB Transformer fires would be less likely to result in the volatilization oflarge amounts ofPCBs and less likely to lead to the formation andrelease oflarge amounts ofPCDFs and PCDDs. Further, PCBs and oxidation products released from outdoorPCB Transformer fires wouldbe expected to be more widely dispersed in the environment. Although PCBs may be released and oxidation products may be formed during the PCB-Contaminated transformerfires, the amounts ofthese materials formed and released are expected to be significantlyreduced compared to the amounts formed and released from PCB Transformers.

IV. Benefits ofPCB-Transformers and the Availability ofSubstitutes

As part,ofthe unreasonable risk determination. EPA must considerboth the benefits ofPCBs and the availability ofsubstitute materials. The unreasonable risk determination requires EPA to balance the risks posed by the use ofPCBs against the availability ofadequate substitute materials and the costs associated with regulatory control measures.HeinOnline -- 50 Fed. Reg. 29187 1985 

### Federal Register / Vol. 50. 

### No. 137 / 

### Wednesday. July 17. 1985 / 

### Rules and Regulations 

### 29187

A. Benefits of PCBs

PCBs were originally used as dielectric fluid in electrical transformers primal'ily because oftheir fire-resistance properties. Generally. PCB Transformers

were placed in locations where concerns for fire safety were paramount. Other dielectric fluids. such as mineral oil. have superiorelectrical properties to PCBs. but their fire resistance properties

are not liS good as PCBs.

Monsanto Company has had in
progress for over a yeara study assessing and comparing fire risks of PCBs and ofmineral oil. The Monsantosponsored study indicates that the
average frequency ofa fire spreading beyond the transformerroom is 300 times greater for a mineral oil transformer than for a PCB Transformer containing 50 percent PCBs nnd 50 percent chlorinated benzenes. The report further indicates that there is a significant decrease in the risk of fatalities when a mineral oil transformer is replaced by a PCB Transformer containing 50 percent PCBs and 50 percent chlorinated benzenes.



### B. Substitute Tronsformers

In its August 1982 PCB Electrical Use Rule. EPA concluded that adequate substitutes exist for PCBs in indoor transformer locations. There are two basic categories oftransformers. fluidfilled and dry. There are sixgeneral types_offluid-filled substitutes for PCBs in transformers: Silicones: hightemperature hydrocarbon (HTH): chlorinated hydrocarbons: non-PCB askarels: fluorocarbons: and mineral oil. EPA summarized available data on these substitute fluids in the Proposed Rule and concluded that adequate substitutes exist for PCBs for indoor transformer locations. including silicone-filled transformers and dry transformers.

As discussed earlier. EPA-sponsored studies indicate that PCDFs and PCDDs

can be formed from the incomplete combustion ofchlorinated benzenes. Similarly. an EPA-sponsored study indicates that PCDFs can be formed from the incomplete combustion of tetrachloroethylene (perchloroethylene).

The replacement ofPCB dielectric fluid with substitute fluids which in fire situations may also lead to the formation ofPCDFs and PCDDs should be carefully considered in light ofthe Agency's decision in this rule to place additional conditions and restrictions on the use ofPCB Transformers. EPA's evaluation ofthe risks posed by the incomplete combustion ofPCB dielectric fluid and the frequency ofoccurrence of PCB Transformer fires indicate that the fire-related risks posed by the use ofa dielectric fluid which can be tran::;formed into PCDFs and/orPCDDs

can be significant. EPA will study this issueJurther and evaluate the need for additional EPA action.

C. 

### Retrofi/lingPCB Transformers

1. Introduction. Two general types of substitutes for PCBs in transformers stand ont as the best retrofill candidates. These fluids are silicones and high temperature hydrocarbons (liTH). The principal questions to be considered are the cost ofretrofill

versus the value ofthe remaining life of the transformer and the qualification of the fluid as "less flammable" for insurance purposes. A related question is the potential for the formation oftoxic products ofincomplete combustion from the retrofill fluid'and remaining residual concentration ofPCBs. Other fluids. such <!s chlorinated hydrocarbons. fluorocarbon. and mineral oil. are used in new transformers but arEi inappropriate fur retrofilling because the design ofthePCB Transformers does not fit the properties ofthe fluids.

Experience with retrofilling to date Indicates that reclassification ofaskarel PCB Transformers to non PCB status is often not cost-effective. Reclassification
to PCB Contaminated status. however. has been accomplished in a costeffective manner for a number'ofaskarel PCB Transformer units. Testimony at the public hearing. however. indicates that retrofill technology continues to evolve. and. that cost-effective reclassification ofaskarel PCB Transformers to non PCB
status may be on the horizon.



### 2. Silicones. There are six silicone fluids sold by six different companies for use as dielectric fluid. Four ofthe six fluids have been approved by Factory Mutual Research Corporation (FMRC) as "less flammable" fluids. Silicones have a higher viscosity than PCBs and are therefore not quite comparable to PCBs as a coolant. For this reason. it is possible that transformers retrofilled with silicone would have to be derated. According to

one silicone fluid manufacturer. ifthe transformer were fully loaded. a derating not exceeding 5 percent could be necessary. (Derating means lowering the maximum level ofelectrical load that the transformer can handle.)

It has been mentioned in the literature that a leaking problem could be created because silicone,fluids,are not compatible with silicone rubber gaskets and the coefficient ofexpansion of silicone fluids is 50 percentgreater than that ofPCBs. In actual practice. however. the silicone gaskets are. replaced during retrofilling. (Further. even though the coefficient ofexpansion is grp-atel' than that for PCBs. the greater solubility ofthe filler gas (nitrogen) in silicone eliminates the expected increase in pressure.)

3. 

### HTHs. There are six HTlI fluids sold by five companies that may be used

as transformer dielectric fluids. There

are also two products sold by two other companies that when mixed with other products may be used as HTH transformer fluids. Three ofthe six fluids are paraffinic based oils and three

are esters. As mentioned earlier. the three esters are more specialized for use In railroad transformers.

The other three fluids are more, ' viscous than the silicones at lower temperatures. but thin more rapidly at higher temperatures. According to an HTH manufacturer; this property allows the transformers to be retrofilled with liTH without any derating. At lower normal load temperatures. however. the transformers do run hotter. These fluids

are completely compatible with the materials that make up PCB Transformers. and they are soluble in PCBs. two ofthese fluids are approved by FMRC as "less flammable ' transformer fluids," and the fire point of the third is over 300 ·C.

'Because the paraffinic HTHs have high convective and radiant heat release
rates. the owner's insurance company may recommend more stringent installation requirements.

V. Benefits and Costs ofRegulatory Options



### A. Introduction

This unit presents a'n analysis ofthe effectiveness and economic impact of

. various regulatory options for reducing the fire-related risks posed by the continued use ofPCB Transformers. For

a full analysis.ofthe expected economic Impacts see the regulatory analysis for this final rule. support document 7 in Unit X.B. The analysis considers separately. the effectiveness and costs offive majorregulatory control options for four categories ofPCB Transformers: (1) PCB Transformers in ornear commercial buildings. (2) PCB Transformers in ornear industrial locations. (3) PCB Transformers in outdoorelectrical substations. and (4) PCB Contaminated Transformers. The regulatory control measures considered

are: (1) Placing no additional conditions

orrestrictions on the use ofPCB Transformers; (2) requiring the registration and additional labeling of PCB Transformers. the removal ofstored combustibles. the containment of, potential waterreleases and,theHeinOnline -- 50 Fed. Reg. 29188 1985 

### 29188 Federal Register / Vol. 50, No. 137 / Wednesday, July 17, 1985 

## ! Rules and Regulations

TABLE 1.-COSTS AND BENEFITS OF CONTROL

MEASURES FOR COMMERCIAL PCB TRANS·

FORMERS

No action ...•...........•..... N/A 44 0 1$399 labeling and ·0 7.3

registration

............... $7.3 44 Enhanced E.

protection. 5·years

.. 590 9 35 343 Removal:

5·years

...................... 953 8 36 704 10-years

.............

_..•. 640 15 29 470 Removal 01 480

natworl< 5-years

....... 168 19 25 • -4.7 transformer manufacturing capacity are not primary concerns. However, implementation oftransformer isolation requirements would be, in general, more complex than providing enhanced electrical protection in a transformer installation. This is because the isolation oftransformers would typically require negotiation between building

owners and transformer owners for
necessary structural changes to buildings. While transformer isolation is costly, it would be in many cases less expensive than eitherphaseout/retrofill

or increased electrical protection.

The registration ofPCB Transformers with building owners and fire departments, the labeling ofthe exterior ofPCB Transformer locations, the containment ofpotential waterreleases. and the reporting ofPCB Transformer fires to the NRC are measures which are expected to reduce exposures in the
event ofa serious PCB Transformer fire. However, these measures 

### will not be effective in avoiding any ofprojected 50' serious building fires, or the estimated 3 outdoorPCB Transformerfires from occurring. The effectiveness ofthese risk reduction measures depends. to a large extent, on the implementation of voluntary measures based on knowledge about the contents ofa transformerinvolved in a fire-related incident. These measures are the least costly control measures thatEPA considered.



### C. Regulatory Options andEconomic Impacts

1. PCB Transformers in ornear commercialbuildings-a. Summary table. The following table (Table 1) summarizes the real costs, benefits. and
net costs [after a consideration of savings in cleanup costs from avoided fires) ofthe majorregulatory control

measures considered for commercial PCB Transformers. For a full discussion ofthe assumptions made for this analysis, see support document 7 in Unit 

### X.B. reporting ofPCB Transformerfires to the National Response Center; (3) requiring the isolation ofPCB Transformers to reduce widespread structure and environmental contamination with PCBs and products ofincomplete combustion; (4) requiring,the installation ofincreased electrical protection on PCB Transformers to avoid PCB Transformer failures; and. (5) requiring the removal

orretrofill ofPCB Transformers. The analysis includes a consideration ofthe expected savings in cleanup costs as a result of implementing these measures.

Given the well-established toxicity of PCBs, and the presence ofmaterials that

are much more toxic than PCBs in the
soot from a fire involving a PCB Transformer, owners ofPCB Transformers involved in PCB Transformer fires have invested more than $20 million dollars each to ensure the safety ofpersons returning to occupy these buildings. These costs, for sampling. cleanup and removal of contaminated materials containing PCBs, PCDFs, and PCDDs canbe factored into the economic analysis of the benefits ofthe continued use ofPCB Transformers. Earlier analyses ofthe benefits ofthe continued use ofthese transformers, completed in support of the August 1982 PCB Electrical Use Rule, did not take into consideration the costs ofcleanup in the event ofPCB Transformer fires.



### B. Summary of Benefits andCosts
The removal or retrofill ofPCB Transformers is both the most effective, and. the most costly measure for reducing the frequency ofserious PCB Transformer fires. This measure, once implemented, gives the greatest

assurance that PCB Transformer fires**~iI1** be avoided. regardless ofinitiating

cause. However, it is also the measure which. as a practical matter, would require the longest time for implementation. Concerns such as the availability ofPCB disposal capacity, transformermanufacturing capacity. and avoiding the disruption ofelectrical service make phaseout and/orretrofill

more difficult to implement quickly than other riskreduction measures. Based
upon EPA's analysis ofthe frequency of PCB Transformer fires, it is likely that serious PCB Transformer fires will occur in the interim, between the date of promulgation ofany phaseout requirement and the actual date ofthe removal ofPCB Transformers from use.

Providing enhanced electrical protection is anticipated to be very effective in avoiding serious PCB Transformer fires, through the preventionofPCB Transformerfaultrelated failures. Studies ofthe causes of PCB Transformer failures and fires and the level ofprotection currently provided indicate that many PCB Transformers could be betterprotected 1'0 avoid fires caused by more common mechanisms offailure, electrical faults. The effectiveness ofincreased electrical protection is expected to approach that ofphaseout/retrofill, although EPA recognizes that ele<;tricul protective devices are subject to some (low) rate of malfunction, and, that PCB Transformer fires can also result from less .common mechanisms offailure. Requiring a certain level ofredundancy in the type ofsensors used and the placement of

sensors provide increased assurance of

a higher level ofeffectiveness. Further,

as a practical matter, this control

measure could be implemented more quickly than phaseout/retrofill, because availability ofPCB disposal capacity and transformer manufacturing capacity

are not primary concerns. Further, this

measure would be less disruptive to electrical service than phaseout/ retrofilI.

Increased electrical protection can be costly, however, compared to otherrisk reduction measures (other than phaseout/retrofill). Further, while electrical protection systems are expected to have a high degree of reliability in avoiding failures, there is the potential for false outages. These are circumstances in which a transformeris mistakenly deenergized when a sustained fault condition does not in fact exist. While EPA acknowledges the potential economic impact offalse outages, EPA has not attempted to quantify this impact.

The isolation ofPCB Transformers is expected to be effective in avoiding serious PCB Transformer fires by avoiding widespread structure and environmental contamination. The effectiveness ofisolation in actually avoiding more serious PCB Transformer fires depends, however, to a great degree on the capability ofa failed transformer to be deenergized within 15 minutes offailure. Isolation is not expected to be very effective for transformers which cannot be easily deenergized after failure occurs. Isolation is expected to be effective in minimizing the distribution ofPCBs and incomplete combustion products in circumstances where a transformerhas the capability to be deenergize'd within 15 minutes offailure.

As was the case for the installation of increased electrical protection. isolation

measures can be implemented more quickly than PCB Transformer phaseout/retrofill. because availability ofPCB disposal capacity and Option Real cost (m,l· lions) Ex· pected lIres Avoid· ed fires Net cost (mil. lions)HeinOnline -- 50 Fed. Reg. 29189 1985 

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## I Vol. 50. 

### No. 137 

## I Wednesday, July 17, 1985 

## I Rules. and Regulations 

### 29189

TABLE 1.-CoSTS AND BENEFITS OF CONTROL

MEASURES FOR CoMMERCIAL P.CB TRANSFORMERS-Continued

Real Ex. Avoid- Net OptiOn cost pected ed cost**(ml~** fIres**f~es** (millions) liOns)

Removal of 480

network & E. protection of remaining (5· years)

........................ 626 9 35 390

I FIf( ,cla!nd cleanup expense over remaining useful life.

• Would b" expected to reduce exposures

.
• Avoided cleanup costs exceed real cost of measure.
b. 

### Take no additionalaction. The first regulatory option that EPA considered for PCB 'Tnnsformers located in ornear commercial buildings was to take no furtherregulatory action at this time to restrict the use ofthese transformers. This would allow the continued use of PCBs in ornearbuildings such as office buildings, shopping centers, apartment buildings, and hospitals without additional restrictions above the requirements ofthe August 1982PCB Electrical Use Rule. That rule authorized the continueduse oftransfonners containing PCBs (that pose no exposure risk to human food or animal feed) for the remainder oftheir useful lives subject to certain recordkeeping and inspection requirements. based on the concentration ofPCBs in the equipment.

There are no costs to transformer

owners associated with EPA's allowing the continued use ofthese transformers, other than the potential future costs associated with cleanup and liability suits following fires involving this equipment. Ifthe use ofPCB Transformers in ornearcommercial buildings were authorized indefinitely, without additional restrictions. EPA expects that44 additional incidents will

occuroverthe remaining useful life of this equipment.

Forpurposes ofthis analysis. these 44 incidents wouldbe expected to require cleanup efforts whose cost would approach $20 million each (1985 dollars)

or an estimated $399 million over the remaining useful life ofthis equipment.

c. 

### Labeling andregistrationprograms. The registration ofPCB Transformers located in ornear commercial buildings with fire departments and building

owners. in combination with the labeling ofthe exterioroftransformer locations with PCB identification labels
may be effective in reducing exposures to firemen. building occupants. and bystanders. Compared to the other regulatory alternatives under consideration (other than the alternative oftaking no additional action), the cost ofthis option is relatively low. EPA believes that in addition to registration with fire departments, the labeling ofthe exterior oftransformerlocations is
necessary to insure that emergency response personnel arriving at the scene ofa fire know that the fire involves a transformer that contains PCBs. EPA expects that the costs oflabeling the exterior ofPCB Transformer locations will be about $76.00 perlocation. EPA estimates that the total cost oflabeling the exterior ofcommercial PCB Transformer installations will be about $3.5 million.

The costs ofregistering comm"ercial PCB Transformers are also expected to be minimal. since the location ofall PCB Transformers should already be known by the owners ofthis equipment.'The
costs to transformer owners of forwarding this information to all building owners and to fire departments with primaryjurisdiction is expected to be minimal. on the order of$50.00 per transformer. EPA estimates that total
costs ofthis registration program for commercial PCB Transformers would be approximately $3.8 million. The total real costs ofregistration and labeling of commercial PCB Transformers would be

on the order of$7 million.

While transformerregistration and labeling programs would be expected to reduce human and environmental
exposures to PCBs. and oxidation products, they will notreduce the frequency ofserious PCB Transformer fires.

.

d. 

### Smoke controltechnologies. Certain design techniques or changes in commercial PCB Transformer locations
may be effective in reducing the likelihood ofwidespread structure and environmental contamination from a failed PCB Transformer. The effectiveness oftransformer isolation as

a control measure depends to a large extent, however. on the type ofPCB Transformerinstallation and the ease of actuating deenergization.

Unlike the ventilation systems for otheroil-filled transformers, the ventilation systems for PCB Transformers were not designed for the
purpose offire isolation but rather were designed only to keep the ambient temperature at orbelow 30· Centigrade (C). However. the removal or alteration ofexisting ventilation systems could result in higher operating temperatures whieh shorten transformer operating lives and may increase the likelihood of equipment failure.

Thus, the design ofalternative ventilation orcooling systems may be
necessary to reduce the potential for building contamimltion. Ventilation alternatives include airconditioners. redirected venting, and heat exchangers. or simply limiting the contamination potential ofthe existing system by reducing the ventilation cooling effectiveness.

The objective ofisolation is to reduce the widespread contamination of
structures and the environment by smoke and soot from a transformer fire. These techniques often inclu.de the modificationofthe ventilation system serving the transformer location and/or sealing cracks or openings which would permit smoke to escape freely into occupied areas and the environment. In the more serious transformer incidents. the presence ofbuilding ventilation systems. building ductwork. and openings in construction in transformer locations have been responsible for the dispersion oftoxic contaminants into buildings.

While transformerisolation can reduce exposures in the event ofa failure and fire involving a PCB Transformer (by reducing the spread of contaminants), ifa transformer cannot be easily deenergized within 15 minutes after a sustained fault occurs, then substantial quantities ofsmoke and soot

can be generated. Tne longer a transformerremains energized after a serious fault occurs. the less likely it is that isolation will be effective iii reducing exposures to PCBs and incomplete combustion products.

Although specific design changes and
costs ofisolation techniques are dependent on the individual transformer location. EPA has developed some general cost estimates. A firm involved in survey and design projects for PCB Transformers estimates th.at in 85 to 90 percent ofall cases where isolation is the desired alternative. the cosAs are about $8.000 per transformer location.

Forpurposes ofthe cost-effectiveness analysis, an average cost of$8,000 per location is assumed for all locations where some form ofsuitable transformer enclosure is already present. For nonenclosed transformers, an estimated
cost of$15,000 is assumed for retrofit of

an enclosure that provides for smoke containment.

In order to facilitate compliance monitoring efforts. EPA would require the development ofwritten PCB Smoke Spread Reduction Plans (PCB-SSRPs). The development ofPCB-SSRPs involves documenting measures taken to isolate PCB Twnsformers from building ventilation equipment. ductwork. and openings in construction. EPA expects that maintaining these records would
create a minimal additional burden on PCB Transformerowners (above the burden created by requiring transformer isolation procedures).HeinOnline -- 50 Fed. Reg. 29190 1985 

### 29190 Federal Register 

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## I Rules and Regulations

The total real costs ofisolation procedures for commercial PCB Transformers implemented over a 5-year period are $318 million. Avoidance of cleanup costs through transformer isolation depends to a great extent on the aLility to deenergize a transformer rapidly. EPA has limited data on the number ofcommercial transformers which can be rapidly deenergized (i.e., which currently have the capability to be deenergized within 15 minutes ofa sustained fault); these transformers would be the group most likely to derive benefits from isolation in the event of PCB Transformerfailure. Available data suggest that most commercial PCB Transformers are not capable ofbeing rapidly deenergized in the event ofa sustained fault. This severely reduces the effectiveness ofPCB Transformer isolation alone. witliout increased electrical protection. as a mechanism for avoiding serious PCB Transformer fires in ornear commercial buildings.



### e. increasedelectricalprotection. Avoidance ofserious PCB Transformer fires in commercial buildings through increased electrical protection involves the installation ofappropriate sensors and disconnect equipment to detect

common causes oftransformer failures and to allow for deenergization. The disconnect equipment would eitherbe automatically activated in response to sensed abnormal conditions (with a provision for manual deenergization). or, manually opened following the receipt ofan audio orvisual signar(indicating abnormal conditions) at an on-site manned control center. Devices which· respond to overcurrent conditions and

sensors which respond to low current faults would protect against failures from two basic mechanisms offaultrelated transformer failures: Low current fault protection in the form ofhest and
pressure sensors and associated disconnect equipment would also provide deenergization following high temperatures and changes in pressure from othercauses. such as mechanical failures or external fires.

As discussed in Unit IV.C. transformer failures can occur as a result of excessive current flow ofa transformer. Ofthe 77.568 PCB Transformers used in

or near commercial buildings. approximately 21.000 PCB Transformers (the network transformers) are currently without overcurrent protection on the primary side (the high voltage side) of the transformers. Second. virtually none ofthe 77.568 PCB Transformers in or

nearcommercial buildings are currently equipped with sensors to detect low
current faults. Finally, virtually none of the 21.000 network PCB Transformers in use have disconnect equipment (in the form ofa primary circuit breaker or equivalent technology) on site to allow for rapid dr.energization. and. EPA expects that many ofthe 55,000 commercial radial PCB Transformers do
not utilize primary circuit breakers for high current fault protection.

The installation ofcertain sufety equipment to detect sustained high
current and low current faults on PCB Transformers which currently lack such protection would reduce the probability offailures. fires. and explosions in commercial PCB Transformers. particularly events resulting from electrical malfunctions. Electrical malfunctions. specifically electrical fuults. have been implicated in many known PCB Transformerfires.

The highest reduction in the probability ofPCB Transformer faultrelated failure is attained when protection is provided against both basic mechanisms oftransformerfault-related failures. Installation ofovercurrent protection without protection against low current faults will avoid only those PCB Transformer fires which occur as a result ofovercurrent conditions.

Electrical faults in general are more likely in network transformers than radial transformers because network transformers have more associated electrical equipment (on the secondary side oftransformers); network transformers have network protectors and network buswork for faults to occur in. This does not mean that faults will
not occur in radial transformers; it simply means that when radial installations are compared to network installations. one would expect more electrical faults in general to occur in network installations.

When the secondary voltage ofa transformeris higher, any faults which

occurin the secondary are more likely
to be sustained rather than self-clearing

or self-extingui&hing. Sustained faults

cause PCB Transformerfailures and fires. Thus. higher secondary voltage network PCB Transformers would have the highest probability offailure from faults. Using the same logic. low secondary voltage radial PCB Transformers would have the lowest probability offailure from faults.

According to comments on the Proposed Rule. historically. utilities have installed high current fault protection on the primaries and secondaries ofradial transformer installations. Network installations, however, have been less well protected against high current faults.

The cost ofinstalling increased protection on commercial PCB Transformers depends both on the form ofprotection seleoted. and. whether the device involves a retrofit ofthe transformer. High current fault protection is much less costly than low
current fault protection. Low current fault protection involves the installation ofdisconnect equipment as well as the installation ofappropriate sensors. High
current fault protection involves the installation ofcurrent-limiting or energy limiting fuses.

Since comments on the Proposed Rule and EPA's analysis indicate that the probability ofa transformedailure from electrical faults is influenced by the type oftransformer installation, not all oCthe above protection wouldbe warranted

on a cost/benefit basis for all types of commercial PCB Transformer installations.

Under the option ofincreased electrical protection. EPA would require that all commercial PCB Transformers be equipped with overcurrentprotection
to avoid transformer failures as a result ofhigh current faults. Current-limiting fuses are relatively inexpensive. and would avoid failures from high current faults in the primary and secondary

areas oftransformers. The cost of installing current-limiting fuses (on the estimated 22,191 commercial network PCB Transformers which currently lack such protection) is estimated at $53 million. The installation ofthese devices

on the approximately 15.072 lower secondary voltage network transformers is estimated at $35 million.

EPA would also require that all commercial PCB Transformers with higher secondary voltages be equipped with protection against sustained low
current faults. This is because transformers with higher secondary voltages are more likely to experience sustained rather than self-clearing faults. While 480 volt networkPCB Transformers may have a particularly high probability ofsustained low current faults (because ofthe high secondary voltage and the presence ofmore associated electrical equipment). when a low current fault occurs in a higher secondary voltage radial PCB Transformer (in the voltage winding, low voltage leads. or other equipment), it too will be sustained and can result in transformer failure.

For the majority ofthese higher secondary voltage commercial PCB Transformers, protection against failures from low current faults would mean the installation ofa primary circuit breaker

on site as well as the installation ofnonelectrical sensors. such as pressure

sensors and temperature sensors in the transformer. For high secondary voltageHeinOnline -- 50 Fed. Reg. 29191 1985 

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### 29191

network PCB Transformers, fault

sensors would also be needed in the networkprotector and the network bus

as well. Requiring the installation of both pressure and temperature sensors in the transformer tank and fault sensol's in the network protectorand network bus ofhigh secondary voltage network PCB Transformers provides a level of redundancy in the protection system: this increases the reliability ofelectrical protection, and provides increased

assurance that increased electrical protection would actually avoid PCB Transformer failures and fires.

The cost ofprotection against low
current faults is principally the cost associated with the installation of disconnect equipment such as circuit breakers on site. The costofthe indicated sensors is a fraction ofthe
costofthe installation ofa primary circuit breaker.

The total real costs associated with requiring the installation ofhigh current fault protection on all commercial PCB Transformers and low current fault protection onhigher secondary voltage commercial PCB Transformers overa 5-
yearperiod is estimated at$590million. EPA expects that the installation of

. these electrical protection systems will avoid about 97 percent ofserious PCB Transformerfires in commercial buildings which would have otherwise occurred, or, 35 serious PCB Transformerfires over the remaining useful life ofthis equipment. The net cost ofthis control measure, after adjusting for avoided cleanup costs is estimated at $343 million.

The increased electrical protection requirement which appeared in the Proposed Rule required installation in 3
years, by OctoberI, 1988. Based on comments submitted in response to the Proposed Rule concerning the type of electrical protection needed, the higher
costs ofthis protection (compared to the proposed electrical protection requirement and the proposed isolation requirement), and the largernumber of PCB Transformers which require additional electrical protection, EPA believes that it is reasonable to allow a longerphasein period for this control

measure than was proposed. Further. EPA recognizes that Il\any PCB Transformerowners may choose PCB Transformerremoval in lieu of enhanced electrical protection, and that this will place additional burdens on

. PCB disposal capacity. Requiring the installation ofenhanced electrical protection on a schedule which recognizes both the fact that many PCB Transformer owners havechosen orwill choose removal rather than electrical protection and that there are constraints

on PCB disposal capacity will encourC!ge PCB Transformerowners who have voluntary 5-yearphaseout programs in' place to continue and may stimulate otherowners to initiate such programs. Thus, EPA has allowed 5years forthe implementation ofthe requirement for enhanced electrical protection.

f. 

### Retrofilling. Retrofilling of commercial PCB Transformers to reduce the PCB concentration to below 500 ppm would be expected to reduce human and environmental exposures to PCBs and their oxidationproducts in the event of

a fire. This'would be accomplished through a substantial reduction in the
amount ofPCBs present in the transformers. EPAhas completed an analysis 'ofthe costs ofretrofilling • commercial PCB Transformers to reduce PCB concentrations to below 500ppm. EPA estimates that retrofill costs will
range from $15,505 for a 50 KVA transformer to $32,034 for a 3,000 KVA transformer. These estimates include the
costs ofdisposal ofPCB fluid. but do not include any consideration ofa loss of efficiency orderating as a result ofthe retrofill.

An estimate ofthe total resource costs ofretrofilling all commercialPCB Transformers (77,568 at end of1984) to below 500ppm is about$1.2 billion. Although the retrofilling ofPCB Transformers reduces the risks to humans posed by the transformerin the
event ofa fire (by reducing the amount ofPCBs present. the amount ofPCBs released. and the amount ofPCDF formed and released). it is difficult to estimate the effectiveness ofthis option in avoiding cleanup costs from fire incidents, since pcm,'s and PCDDs may still be formed.



### g.PhaseoutofcoInInericalPCB TransforIners. The removal ofall PCB Transformers from locations in ornear comll}ercial buildings orthe removal of particularly high risk PCB Transformers from locations in ornearcommercial buildings wouldgive increased

assurance that future serious PCB Transformerfires from all causes will be avoided. The following table uses a population of77,568 units (EPA's estimate ofthe number ofPCB Transformers in ornearcommercial buildings that will be in use at the end of 1984) and a population of7,420 units (EPS's estimate ofthe number ofhigh secondary networkPCB Transformers in use). EPA uses an estimate ofequipment life of30 years, and presents total real
costs ofphase-out over 5· and lo-year periods ofall commercial PCB Transformers, and phaseout over a 5- year period ofhighersecondary network PCB Transformers, as well as estimates ofthe number ofPCB Transformer fires avoided, and the net costs, after a consideration ofavoided cleanup costs. (EPA did not evaluate an immediate ban because comments indicated that manufacturing capacity was insufficient
to allow for this option.) For a full description ofthe assumptions used in the following analysis, and for a more detailed analysis ofphaseout costs

versus cleanup costs avoided, see the regulatory analysis for the final rule, support document 7 in Unit X.B.

TABLE 2-PHASEOUT COST COMPARISON

Cost ($

, PCB Net Regular fires cost ($ Group option md- avo,d· ITlll· lions)

. ed lions)

All 

## . 10·year 640 29 470

commercial. phaseout All 5·year 953 36 704

commercial. phaseout. Commercial 5-year 168 25 -4.7

480 phaseout. Nelwor!<.



### 2. PCB TransfarIners in ornear industrialfacilities-a. SUInInary table. The following table (Table 3) summarizes the real costs, the benefits, and the net costs (afterdeducting avoided cleanup costs) ofthe major regulatory options for.industrial PCB Transformers.

TABLE 3-COSTS AND BENEFITS OF CONTROL

MEASURES FOR INDUSTRIAL PCB TRANS·
FORMERS

Real Ex- Avoid- Net

Option cost pected ed cost (mil· (mil. lions) fores fires lions)

No action

.........

_......... N/A 8 0 $64 Labe!ing &

Registrat!on

.............. $2.5 6 0 2.5
Enhanced E.



## -

protection 5-years

... 170 2 4 136
Removal 5·years

......... 319 2 4 285

b. 

### Takeno additionalaction. This option would allow the continued use of PCB Transformers in ornearfacilities such as chemical manufacturing plants. electric powergenerating plants, forest products processing plants. and warehouses without additional restrictions above the requirements of the August 1982 PCB Electrical Use Rule. There are no costs associated with EPA's allowing the continued use of these transformers, otherthan the potential future costs associated with cleanup and liability suits following fires involving this equipment. Ifthe use ofPCB Transformers in ornear industrial facilities were authorized indefinitely, without additional restrictions, EPA expects that up to six PCB Transformer fires with smokeHeinOnline -- 50 Fed. Reg. 29192 1985 

### 29192 . I,..,

. 

### Federal Register / 

### Vol. 50, No. 137 / Wednesday, July 17, 1985 / Rules and Regulations 

# ----..,-
spread will occur over the remaining useful life ofthis equipment.

c. 

### Labeling andregistrationprograms. The registration ofPCB Transformers located in or near industrial facilities with fire departments or fire brigades and the registration with building

owners (when the PCB Tmnsformer is
not owned by the building owner), in combination with the labeling ofthe exterior ofPCB Transformerlocations would cost approximately $2.5 million, assuming that there are about 26,700 industrial PCB Transformers.

While labeling and registration
programs would be expected to reduce exposU"CS in the event ofa PCB Transformer fire. they will not reduce the frequency ofoccurrence ofthese fires.

d. 

### Smoke controltechnologies. Since
many industrial PCB Transformers are currently unenclosed, the costs associated with industrial PCB Transformer isolation would be. on the
average. higher than for PCB Transformers located in ornear commercial buildings. Forpurposes of the cost-effectiveness analysis. EPA

assumes that the cost ofthe isolation of industrial PCB Transformers will approach $30.000 per transformer location. Assuming that there are 26,700 industrial PCB Transformers, and that there are, on average. 2PCB Transformers perlocation. the total cost ofthe isolation ofindustrial PCB Transformers over a 5-yearperiod is estimated at $109 million.

The isolation ofindustrial PCB Transformers (which are typically capable ofbeing more rapidly deenergized than commercial PCB Transformers) would be effective in reducing the relatively low fire-related risks posed by the use ofPCB Transformers in industrial facilities even further. Since the majority ofPCB Transformers located in or near industrial facilities are capable ofbeing deenergized from an on-site location, isolation ofthese transformers would be expected to be effective in reducing the spread ofany volatilized PCBs or oxidation products released before deenergization could occur.

e. 

### Increosedelectricalprotection. For industrial PCB Transformers. increased electrical protection would (typically) involve the installation ofappropriate heat and pressure level sensors to detect low current faults and the connection of these sensors to existing primary circuit breakers to allow for automatic

. deenergization in the event ofabnormal conditions. Since industrial PCB Transformers reportedly have primary circuit breakers which provide these transformers with the capability to be deenergized from an on-site location. the
costs ofincreased electrical protection ofthese transformers would be the costs ofinstalling heat senso\'s in the secondary winding, and pressure

sensors in the transfmmer tank and connecting these sensors to provide automatic orrapid manual deenergization ofthe equipment.

For some industrial PCB Transformers. new circuit breakers would have to be installed to allow for the use ofthese sensors and automatic deenergization.

During plant operating hOllrs, these

sensors would reduce the time between the occurrence ofa low cunent fdUlt (or mechanical failure) and the

. deenergization ofthe transformer. and, during plant off-hours/non-operational periods. would reduce the probability of

a serious incident occurring. Increased electrical protection ofindustrial transformers (phased-in over a 5-year period) would be expected to avoid four serious PCB Transformerfires which would otherwise occur in these facilities.

The costs associated with the installation ofthis protection on industrial PCB Transformers would be approximately $170million for the estimated 26,700 industrial PCB Transformers (phased In over a 5-year period). After adjusting for avoided cleanup costs. the net costs would be estimated at $136 mil\ion.

f. 

### Retrofilling of industrialPCB Transformers. Retrofilling ofIndustrial PCB Transformers would be expected to reduce even further the fire-related risks posed by the continued use ofPCB Transformers in industrial facilities, by reducing the amount ofPCBs present for potential release and for conversion to oxidation products. The costs associated with immediately retrofilling the 26,700 Industrical PCB Transformers for
purposes ofreclassification to PCB Contaminated status is estimated at $489 million.



### g.PhaseoutofindustrialPCB Transformers. Th!') removal ofPCB Transformers from industrial facilities would eliminate the relatively low flrerelated risks posed by the continued use ofthese transformers. Phaseout of Industrial PCB Transformers over a 5-
yearperiod would avoid up to four Industrial PCB Transformer fires with smoke spread at a total cost of$319 million. After adjusting for avoided cleanup costs, the total net cost would be $286 million. Phaseout ofindustrial PCB Transformers over a lO-yearperiod would avoid about three serious PCB Transformer fires at a total cost of$215 million. After adjusting for avoided cleanup costs, the total net cost would be $192 million.



### 3. PCB Transformers in outdoor electricalsubstations-a. Take no additionalaction. EPA has few data on PCB Transformerfires which have occurred in outdoor electrical substations. However, EPA has evaluated the potential risks posed by such fires and has developed an estimate ofthe frequency ofthese fires. This estimate is based on available information on the probability ofserious PCB Transformerfires in or near buildings. and the probability offailures In different types ofinstallations. EPA estimates that up to three outdoor electrical substation fires (with some PCB volatilization and smoke distribution) will occur over the

. remaining useful life Dfthis equipment. Since EPA believes that an outdoor PCB Transformerfire will not typically result in the formation oflarge amounts ofIncomplete combustion products which would require cleanup. EPA has assumed that cleanup from these Incidents will involve primarily the cleanup ofspilled PCBs. This type of cleanup operation is significantly less costly than cleanup following a PCB Transformerfire In ornear.a building.



### b. 

### Labeling andregistrationprograms. The labeling ofthe exterior ofoutdoor PCB Transformer locations, and the registration ofthese transformers with appropriate fire departmentjurisdictions is expected to reduce exposures to firefighters and cleanup crews. The cost associated with this registration and labeling program for 17,000 outdoorPCB Transformers is approximately $1.6 million.



### c. Isolation of outdoorPCB Transformers. OutdoorPCB Transformers could be enclosed to reduce the spread ofPCBs and any incomplete combustion products formed. However. enclosing these transformers could create conditions more conducive
to the formation ofincomplete combustion products. Heat is more likely to be retained rather than dissipated when transformers are enclosed. Thus, while enclosing these transformers would decrease the spread ofPCBs following fire-related failures. It could Increase the amount ofPCBs converted into dibenzofurans from outdoorPCB Transformer fires.

The costs associated with enclosing 17,000 outdoorPCB Transformers over a 5-yeal' period would be on the order of $69 million.

.



### d. 

### Increased.electricalprotection. OutdoorPCB Transformers are typically radial installations, which are already equipped with current-limiting fuses.HeinOnline -- 50 Fed. Reg. 29193 1985 

### Federal Register 

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The cost ofthe installation oflow
current fault protection on the higher secondary voltage outdoorPCB Transformers (over a 5-yearperiod) would be on the orderof$108 million. Increased electrical protection would be expected to avoid up to three outdoor PCB Transformerfires

..

c. Retrofilling. EPAhas estimated the
costs associated with requiring the immediate retrofilling ofthe approximately 17,000 outdoorPCB Transformers. These costs are estimated
to be $270 million.

£. 

### Phaseout. EPA has estimated the
costs associated with requiring the removal ofan estimated 17,000PCB Transformers in outdoor locations, over 5- and 10-yearperiods. A5-year phaseoutis estimated to cost$203 million, and a lO-yearph·aseout is estimated to cost$137 million.

4. PCB Contaminatedtransformers. EPA has also estimated the costs associated withrequiring additional

-controls on the use ofPCB Contaminated transformers. The costs range from over$8 billion for the testing oftransformer fluids forPCB concentration and the registration and labeling ofPCB Contaminated transformers, to over$263 billion for removal within 5 years. Registration and labeling ofPCB Contaminated transformers would reduce the low PCB fire-related risks posedby the use ofthis equipment; and, removal would eliminate these risks.

VI. Risk/BenefitAssessment

1. Use of PCB Transformers in ornear commercialbuildings. PCBs can be released in fires involving PCB Transformers, and. (depending upon the
contents ofthe transformer and the combustion conditions), 2,3,7,8-TCDF, PCDFs, 2,3.7.8-TCDD, and PCDDs can be formed. Laboratory studies on the formation ofPCDFs from PCBs. and PCDDs from chlorinated benzenes, as well as sampling data from actual PCB Transformerfire sites confirm thatPCBs

can be released and 2,3,7,8-TCDF and 2,3.7.8-TCDD (as well as otherPCDF and PCDD congeners) canbe formed and released from fires involvingPCB Transformers.

EPA believes that PCBs are both toxic and persistent, and, thatPCDFs and PCDDs are orders ofmagnitude more toxic than PCBs. PCB Transformers that remain energized after sustained faults

orfollowing failures as a result offires from external sources are more likely to result in the volatilization oflarge
amounts ofPCBs and the formation of large amounts ofPSDFs, 2,3,7,8-TCDF, PCDDs and 2,3,7,8-TCDD through incomplete combustion than PCB Transformers that are able to be deenergized rapidly and completely when an arc orfault occurs.

PCB Transformers can become involved in fires from many causes including sustained low current faults, sustained high currentfaults, and fires external to transformers involving stored combustibles orbuilding materials followed by an inability to deenergize the transformer. The firerelated risks posed by the continued use ofPCB Transformers in ornear commercial buildings are much higher than the fire-related risks posed by the continued use ofPCB Transformers in outdoorlocations and industrial facilities. The overall probability ofPCB Transformerfault-related failure is higherin commercial buildings than in otherPCB Transformerlocations and the risks posed are also higher in the
event ofa PCB Transformerfire.

The fire-related risks posedby the continued use ofhigher secondary voltage network PCB Transformers in commercial buildings are particularly high. because these transformers have the highest probability offailure from both high and low current faults, and, they are typically used in more densely populated commercial buildings. specifically. in locations such 

### as**high~** 

### rise office buildings.

The benefit ofremoving commercial PCB Transformers from use is the complete assurance thatPCB Transformerfires will no longeroccurin

ornear commercialbuildings. Serious PCB Transformerfires which would have otherwise occurred will definitely be avoided. PCB Transformer fires in or

nearcommercial buildings pose particularlyhighrisks to human health, because sustainedhigh temperatures are

more likely in these locations (leading to the volatilization oflarge amounts of PCBs and the formation oflarge
amounts ofincomplete combustion products), andbuilding occupants, cleanup crews, and fire response personnel are more likely to incur these higherexposures. In addition. the lack of knowledge on the part ofcommercial building occupants, firefighters, and cleanup crews aboutthepotential risks posed make exposures even more likely.

There are an estimated77.568 PCB Transformers located in ornear commercial buildings, and 7,420 ofthese transformers are expected to behigher secondary voltage network PCB Transformers. The 77.568 PCB Transformers used in commercial buildings represent 64 percent ofall PCB Transformers in use. The immediate removal ofthese transformers from use is not possible because of considerations such as PCB disposal capacity, transformer manufacturing capability, and disruption ofelectrical service. The cost ofremoving all of these PCB Transformers from use over the next 5years is estimated at $953 million. Five years may not be an adequate amount oftime for the removal and disposal ofthis many transformers. There are currently only four EPAapproved commercial PCB incinerators. According to comments on the Proposed Rule. PCB disposal capacity is such that the cost ofPCB disposal has significantlyjumped (almost doubled)

over the lastyear. Disposal capacity will continue to be ofconcern over the next few years. since existing EPA regulations require the removal ofPCB Transformers in use in food and feed processing facilities by October 1, 1985 and a limited phaseout ofPCB Capacitors by October I, 

### 1988.

The removal ofall commercial PCB Transformers by 1990 would. however, avoid an estimated 36 serious PCB Transformer fires in commefl;:ial locations. The removal ofall commercial PCB Transformers by 1995 is estimated
to cost on the order of$640 million for the avoidance ofan expected 29 serious PCB Transformer fires.

The costs ofremoving the particularly high risk 7,420 commercial higher secondary voltage network PCB Transformers from use over the next 5
years is estimated at $168 million. The removal ofthese particularly high risk PCB Transformers from use by 1990 would be expected to avoid an estimated25 serious PCB Transformer fires, orabout 70percent ofall PCB Transformer fires in commercial buildings which EPA expects would otherwise occur. The removal ofhigher secondary voltage networkPCB Transformers from use by October 1. 1990will avoid an estimated 70 percent ofserious commercial PCB Transformer fires for about 17 percent ofthe cost associated with the removal ofall commercial PCB Transformers from use by this same date.

EPA believes that it is prudent to require the removal ofcommercial higher secondary voltage network PCB Transformers from use as soon as possible, taking into consideration factors such as PCB disposal capacity and continuity ofelectrical service. EPA believes that the soonest practical date for requiring the removal ofthis equipment is by October 1. 1990. Testimony at the public hearing,
comments on the Proposed Rule. and EPA's analysis overwhelmingly support

a determination that these transformers

are ofparticularly high risk. EPA expects that 25 serious commercial PCBHeinOnline -- 50 Fed. Reg. 29194 1985 

### 29194 Federal Register / 

### Vol. 50, 

### No. 137 / 

### Wednesday, July 17, 1985. / 

### Rules and Regulations

Transformer fires will be avoided by the removal ofthese PCB Transformers (over a 5-yearperiod) for a total real
cost ofless than $7 million per avoided incident. Cleanup costs alone for a single incident in a commercial building would be expected to exceed this $7 million figure substantially.

While EPA has decided to require the removal ofthese particularly high risk PCB Transformers from use. it believes that less costly yet highly effective

measures can be implemented to reduce the remaining fire-related risks posed by the continued use ofothercommercial PCB Transformers. Namely, EPA has determined that enhanced electric.al protection systems will be effective in avoiding many fires in these remaining commercial installations. Electrical protection can be very effective in avoiding PCB Transformer failures and fires through the early detection of

common mechanisms offailure and the rapid deenergization oftransformers.

EPA is requiring all commercial PCB Transformers to be protected against failures from sustained high current faults in the primary and secondary

areas ofthe transformers. Further. EPA Is requiring that all commercial higher secondary voltage radial PCB Transformers be equipped with protection against sustained low current faults as well.

EPA has determined that all commerdal PCB Transformers should be registered with fire departments and

.building owners and that commercial PCB Transformer locations should be labeled on the exterior. Finally, EPA has determined that stored combustible materials should be removed from all commercial PCB Transformer locations, that all fire-related incidents should be reported to the National Response Center. and that measures be taken to contain all potential releases to water associated with a fire-related incident.

The real cost ofrequiring registration, labeling, and removal ofstored combustibles for all commercial PCB Transformers and enhanced electrical protection for 56,605 commercial PCB Transformers (over a 5-yearperiod) is estimated at $459 million. The expected incremental benefit ofthese measures (for other than higher secondary voltage network PCB Transformers) is the avoidance ofan addilional10 serious PCB Transformer fires which would have otherwise occurred. or about 30 percent ofall commercial PCB Transformerfires which EPA expects would otherwise occur over the remaining useful life ofthese transformers.

Increased electrical protection and the removal.ofstored combustibles is expected to avoid sustained high temperatures in commercial PCB Transformer locations; thus. significantly reducing the likelihood of PCB volatilization and the formation of large amounts ofincomplete combustion products. Reducing the likelihood ofPCB Transformer failures in commercial locations reduces potential exposures to building occupants. cleanup crews, and
emergency response personnel. PCB Transformer fires may occur through less likely mechanisms and electrical protection systems are subject to some (low) rate ofmalfunction. The requirement for the registration and labeling ofcommercial PCB Transformers will reduce exposures in the event that sustained high temperatures occurdespite the presence ofincreased electrical protection.

EPA has selected the option ofthe removal ofcommercial higher secondary voltage network PCB Transformers from

use by October 1,1990, the immediate registration. labeling, and removal of stored combustibles for all commercial PCB Transformers, and enhanced electrical protection (by October 1, 1990) for a.large majority ofthe remaining 70.000 commercial PCB Transformers currently in use. EPA is also requiring the reporting ofall PCB Transformer fire-related incidents to the National Response Center, and, that measures be taken as soon as practically (and safely) possible to contain any potential releases to water in the event ofa PCB Transformer fire-related incident. The total real cost ofthis program to reduce the fire-related risks posed by the continued use ofPCB Transformers in commercial locations is estimated at $635 million and is expected to avoid 35 serious PCB Transformerfires which would have otherwise occurred over the remaining useful life ofcommercial PCB Transformers. or about $17 million per serious PCB Transformerfire avoided. The net cost, after deducting for avoided cleanup costs, is estimated at $390 million,or about $10 million per serious PCB Transformerfire avoided.

EPA has also banned the further installation ofPCB Transformers in locations in ornearcommercial buildings. EPA recognizes that the costs associated with PCB Transformer removal include tfie costs ofphysically removing PCB Transformers as well as providing replacement transformers. The
costs associated with not installing a PCB Transformer (which has been placed into storage for reuse) in a commercial building are minimal. Further, even with increased electrical protection, there is some level ofrisk posed by the use ofPCB Transformers in

ornear commercial buildings. While EPA has selected increased electrical protection for many commercial PCB Transformers, it has determined that the installation ofPCB Transformers (which have been placed into storage for reuse) in ornear commercial buildings presents

an unreasonable risk. Thus, EPA has banned the new installation ofPCB Transformers in ornear commercial buildings.



### 2. Use of PCB rransformers in ornear industrialfacilities. PCBs can be released in fires involving industrial PCB Transformers. and. depending upon combustion conditions. incomplete combustion products can be formed. PCB Transformers that remain energized for prolonged periods after sustained faults occur or following failures as a result offires external to the PCB Transformers are more likely to result in the volatilization ofPCBs and the formation ofincomplete combustion products than PCB Transformers that

are able to be deenergized rapidly and completely when

## afault or failure

occurs.

Based on comments on the Proposed Rule, EPA believes that PCB Transformers located in ornear industrial facilities are less likely to be involved in fires involving sustained high temperatures than PCB Transformers located in ornear commercial buildings. This is because these transformers, as a group, are typically equipped with more protection from failures than commercial PCB Transformers, and. are typically able to be deenergized from an on-site location. Thus, the probability ofindustrial PCB T"annformerfault-related failure and fire is lowerin industrial facilities than in commercial buildings, and the risks posed in the event ofa fault-related failure and fire are also expected to be less.

EPA recognizes that exposures from PCB Transformer fires in atypical Industrial facilities (where deenergization does not occur as rapidly) could be higher than the
exposure previously described. However. EPA's estimate ofthe frequency ofindustrial PCB Transformer fires indicates that up to 6PCB Transformer fires (with smoke spread into industrial facilities) are expected to

occurover the remaining useful life of this equipment. Fourindustrial PCB Transformerfires would be expected to

occur after October 1.1990. Even ifEPA

were to assume as a worst-case that the risks posed by PCB Transformerfires in industrial facilities were equivalent to the risks posed by PCB Transformer fires in commercial buildings. EPA expects that only 4 serious industrialHeinOnline -- 50 Fed. Reg. 29195 1985 Federal Register / Vol. 50, No. 137 / Wednesday, July 17, 1985 / Rules and Regulations 

### 29195

PCB Transformer fires could be avoided by requiring the removal or enhanced electrical protection ofindustrial PCB Transformers by 1990.

The costs. however, ofthe removal of these in.dustrial PCB Transformers from

use by 1990 is estimated at $319 million. The removal ofindustrial PCB Transformers from use by 1990 would avoid about four PCB Transformer fires involving smoke spread into buildings. The real cost per avoided serious fire is almost $80 million. Enhanced electrical protection ofthese transformers by 1990 would be expected to avoid about the

same number ofincidents at a total real
cost of$170 million, or, $43 million per avoided incident. Isolation ofthese transformers by 1990 would be expected
to reduce building contamination; thereby, reducing potential exposures to workers, cleanup crews. and fire
response personnel at a total cost of $109 million. or. $27 million perincident.

The benefit ofremoving these transformers or protecting these transformers by 1990 is the avoidance ofup to four industrial PCB Transformer fires. PCB Transformer fires involving the formation oflarge'amounts of incomplete combustion products are less likely in industrial facilities than in or

nearcommercial buildings. Sustained high temperatures are less likely in these locations due to equipment visibility and deenergization capability, and. as a result. building occupants (workers). cleanup crews. fire response personnel, and members ofthe general population are less likely to incurhigh
exposures. Further. there are generally fewer people at risk ofincurring these
exposures from fires in industrial facilities than from fires in commercial buildings.

The cost ofrequiring the registration. increased labeling, and removal of stored combustibles from industrial PCB Transformer locations is estimated at $1.9 million. While these measures will
not rerluce the frequency ofserious industrial PCB Transformer fires, they should reduce any exposures to workers. cleanup crews, and fire
response personnel.

EPA has selected the option ofthe registration, external labeling, and removal ofstored combustibles from industrial PCB Transformer locations for the estimated 26,700 industrial PCB Transformers in use or in storage for

reuse in industrial locations. This is a relatively inexpensive measure which will reduce exposures in the event ofa PCB Transformer fire. EPA is also' requiring the reporting ofall PCB

. Transformer fire-related incidents to the National Response Center. and. that

measures be taken as soon as practically and safely possible to contain any potential release to waterways. These requirements are not burdensome. and will reduce further any human and environmental exposures following industrial PCB Transformer fires.

3. Use of PCB Transformers in outdoorlocations. EPA's evaluation of the risks posed by PCB Transformer fires indicates that the use ofPCB Transformers in outdoor locations away from commercial areas poses less risk to public health and the environment than the use ofthis equipment in ornear buildings. First, combustion conditions in outdoor locations may not be so conducive to the volatilization ofPCBs and the formation ofincomplete combustion products as combustion conditions in enclosed areas such as sidewalk vaults and machinery rooms.

Second. EPA believes that fewer people are generally present near outdoorPCB Transformerlocations. and. that many ofthese areas are fenced in to restrict access to authorized personnel. Further, ifPCBs were volatilized and dispersed into the environment. individual human
exposures to PCBs and potential oxidation products from such a fire are expected to be much lower than from fires in ornearbuildings. EPA expects fewer than three outdoorPCB Transformer fires (with smoke spread)

over the remaining useful life ofthis equipment.

There are an estimated 17,000PCB Transformers in outdoor locations. The total real cost ofthe removal ofthese PCB Transformers from use by 1990 is estimated at $207 million. or, $69 million
per avoided incident. The total real cost ofinstalling increased electrical protection on these transformers is $36 million. or. $12 million per avoided incident.

EPA believes. however. that it is prudent to require registration and increased labeling ofoutdoorPCB Transformers. the containment ofall potential releases to water, and the reporting ofall PCB Transformer firerelated incidents to the NRC. These

measures will reduce exposures of
emergency response personnel to spilled PCBs (which is anticipated to be the

more prevalent situation in outdoor locations) and would serve to limit the spread ofthese materials into the environment.

4. PCB Contaminatedtransformers. A fire involving a PCB Contaminated transformercan result in the formation and/or release ofPCBs and oxidation products. Thus, the us'e ofthese transformers does pose some level of risk in a fire-related incident. However. the level ofrisk posed is considerably less than the risks posed by the use of PCB Transformers. Further. there are an estimated 20 million PCB Contaminated transformers in use. Even the least costly regulatory alternative, the registration and external labeling ofPCB Contaminated transformers. would cost

more than $8 billion.

Thus, EPA has determined that the ' continued use ofPCB Contaminated transformers without additional controls will not present unreasonable risks to public health or the environment.

VII. Findings on the Use ofPCBs in Electrical Transformers

1. Based on the analyses presented in Unit VI, EPA has determined that the

use ofPCBs in electrical transformers

, does not pose unreasonable risks to

public health orthe environment, provided. that in addition to the inspection, recordkeeping. and servicing requirements ofthe August 25, 1982 Electrical Equipment Rule:

a. Higher secondary voltagenetwork PCB Transformers (network PCB Transformers with secondaryvoltage at

or above 480 volts, including 480/277 volt network PCB Transformers) in or

nearcommercial buildings are removed from use, reclassified, placed into storage for disposal or disposed by October 1, 1990.

b. By October 1. 1990, higher secondary voltage radial PCB Transformers (radial PCB Transformers with secondary voltages at or above 480 volts, including 480/277 volts radial PCB Transformers) and lower secondary**voltag~** network PCB Transformers used in ornearcommercial buildings are equipped with sensors to detect electrical faults and insure rapid deenergization prior to transformer failure.

c. All PCB Transformers are registered with appropriate fire response organizations and PCB Transformers located in ornearbuildings are also registered with building owners.



# a. The vault door, machinery room 'door, ormeans ofaccess (other than grates and manhole covers) to PCB Transformers are labeled with PCB identification labels.

e. PCB Transformerlocations are cleared ofstored combustibles.

f. In the event ofa PCB Transformer fire, measures are taken to contain
water releases.

g. In the event ofaPCB Transformer

nre. the National Response Center is immediately notified.

, ,

2. The use ofPCBs in transformers that comply with: (1) The inspection, recordkeeping. and servicingHeinOnline -- 50 Fed. Reg. 29196 1985



### 29196 Federal Register 

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## I Rules and Regulations

requirements ofthe August 25, 1982 Electrical Use Rule; and (2) the fire hazard risk reduction meflsures described above, does not pose unreasonuble risks to public health or the environment for the following

reasons:

a. IfEPA immediately banned the continued use ofPCB Transformers it would cost the public and-United States industry billions ofdollars, primarily as

a result ofthe disruption ofelectrical service. There are over 120,000 PCB Transformers currently in use and an estimated 20 million PCB Contaminated transformers currently in use. The resulting reduction in risk from an immediate ban, after considering both the risks posed by spills and leaks of PCBs as well as the risks posed by fires involving this equipment, would not outweigh these substantial costs.

b. The required inspection, maintenance, and servicing requirements under the August 25, 1982 Electrical Use Rule, and the fire hazard risk reduction measures listed above (including therequired removal of commercial higher secondary voltage network PCB Transformers from use by October 1, 1990) reasonablyreduce the
exposures associatedwith the use of PCBs in PCB Transformers. The required fire hazard risk reduction measures and the required**5-y~ar** phaseout of commercial highersecondary voltage network PCB Transformers are

measures which are much less costly than a total ban on the use ofPCBs but

are ofsimilareffectiveness in reducing the overall fire-related risks posed by the use ofthese transformers.

c. The costs ofphaseout and retrofilling ofall PCB Transformers are not reasonable when considering the potential reduction in release ofPCBs and the reduction in the risks posed by PCB Transformer fires ifthese measures

were required for all PCB Transformers. EPA has targeted phaseoutrequirements for those PCB Transformers which EPA has concluded pose particularly high risks offailure and fire.

d. Releases ofPCBs to the environment and exposures to humans and biota from the use ofPCBContaminated and non-PCB transformers are minimal. Further, the risks posed by fires involving thiS equipment are substantially less than the risks posed by fires involving PCB Transformers, and the costs ofany control measures to reduce these low risks further are very high. VIII. Amendments to the PCB Electrical Equipment Rule

A. 

### Registration/Labeling/Removalof StoredComblJstibles

EPA has reqClired the**re~istration** of all PCB Transformers by December 1, 1985, with fire departments with primary
response jurisdiction. This means that each PCB Transformerin use or in storage for"reuse must be registered with the fire department(s) which would be called upon for the initial response to a fire involving the equipment. The information to be supplied to the fire department(s) includes the address of the building in which the transformer is located (or the nearestbuilding for PCB Transformers located near buildings, or, the nearestintersection for outdoorPCB Transformers); the location ofthe transformer within the building or near the building (e.g., third floor east end, or, west side ofthe building); arId the" principal constituent ofthe dielectric fluid in the transformer (e.g., PCBs, mineral oil, silicone oil). For industrial PCB Transformers, this may mean only the registration ofthe transformers with the industrial fire brigade on site.

EPA has also required the registration, by December 1. 1985, ofPCB Transformers located inornear buildings with building owners. Each

owner ofa PCB Transformer(s) is responsible for registering the transformer(s). This means that all PCB Transformers located in ornear buildings mustbe registered with appropriate building owners. For PCB Transformers located inside buildings, this means the registration ofthe transformer(s) with the building owner ofrecord. ForPCB Transformers located "near" buildings, this means the registration ofthe PCB Transformer(s) with all building owners whose buildings are located within 30 meters of the PCB Transformer(s).

.

EPA has required the labeling ofthe exteriorofall PCB Transformers with the Mark ML•This means that doors, fences, hallways, and other easily markable means ofaccess to PCB Transformer locations must be marked with PCB identification labels. These labels mustbe prominently displayed and visible to emergency response personnel in the event ofa fire involving this equipment. The exteriorofsidewalk and underground vaults, that is, grates and manhole covers, are not required to be marked (because ofdifficulties in maintaining the mark overtime).

EPA has required the removal of stored combustibles from all PCB Transformerlocations. This means that materials such as paints, solvents,
paper, rubber, and sawn wood must not be stored within a PCB Transformer enclosure, within 5 meters ofa PCB Transformer enclosure, or within 5
meters ofa PCB Transformer. A PCB Transformer enclosure is defined as a confined area such as a vault. machinery room, partitioned area or fenced-in area that contains a PCB Transformer.

The objective ofrequiring the removal ofstored combustibles is to &void, to the
extent possible and practical. PCB Transformer involvment in fires initiated by the combustion ofstored materials and to eliminate a potential source of fuel for a fire initiated by an electrical fault ormalfunction in a transformer.



### B. PhaseoutofCommercialHigher Secondary Voltage NetworkPCB Transformers

EPA has prohibited the use ofall network PCB Transformers with secondary voltages at or above 480 volts (this includes 480 volt network PCB Transformers. 480/277 volt network PCB Transformers and othernetworkPCB Transformers with secondary voltages
at or above480 volts) in ornear commercial buildings beyond October 1, 1990, and has required that these transformers be placed into storage for disposal or disposed (or be reclassified
to PCB Contaminated ornon PCB status).

Commercialbuildings are defined as

non industrial (non substation) buildings which are generally or typically accessible to both members ofthe general public and employees. These buildings include: public assembly" properties (e.g., arenas, stadiums, libraries, museums, restaurants, theaters, etc.); educational properties (e.g., schools, colleges, universities, etc.); institutional properties (e.g., nursing homes, hospitals, prisons, etc.); residential properties (e.g., apartments, hotels, dormitories, etc.); stores (e.g., supermarkets, clothing stores, malls, etc.); offices (e.g., general business offices (including those located on industrial sites), banks, municipal office buildings, etc.); and, transportation
centers (e.g., airport terminal buildings, subway stations, bus stations, train stations. etc.).

An industrial building is defined as a building directly used in manufacturing

ortechnically productive enterprises

.. Industrial buildings are not generally or typically readily accessible to other than workers. Industrial buildings include buildings used directly in the production ofpower, the manufacture ofproducts, the mining ofraw materials, and the storage oftextiles. petroleum products,HeinOnline -- 50 Fed. Reg. 29197 1985 

### Federal Register 

## I Vol. 50. 

### No. 137 

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### 29197

wood and paperproducts, chemicals or plastics, and metals.

A PCB Transformer located in ornear

a commercial building is located within the interior ofthe building, on the roofof the building or attached to the exterior wall ofthe building, in the parking area serving the building, or located within 30
meters ofthe building.

EPA has required the removal ofPCB Transformers located nearcommercial buildings (in addition to those lo'cated inside commercial buildings) because incidents like the San Francisco fire indicate that PCB Transformers located

nearcommercial buildings can result in building contamination. Several
comments on the Proposed Rule requested that EPA define the term "near" in a more quantitative manner; such as, within 25. 50 or 100 feet ofa commercial building. EPA recognizes the desirability ofdefining the term "near" in a quantitative manner-this would facilitate monitoring compliance with the rule and make the rule more easily understood by the regulated community.

In adopting this suggestion. EPA has three objectives: (1) to facilitate compliance by industry with the rule, (2)
to facilitate EPA's monitoring of compliance with the rule, and (3) to insure that any PCB Transformer which
poses a real risk ofcommercial building contamination is covered by the rule. EPA is somewhat hesitant to dictate an absolute distance at which a PCB Transformerwould be considered to pose little risk ofsignificant building contamination. Local climactic and geographic conditions couldgreatly influence the potential for building contamination from PCB Transformer fires in locations such as sidewalk and underground vaults. However, the benefits ofestablishing a numerical standard. in terms ofease ofcompliance with the rule and ease ofenforcement,

are great.

In urban locations, sidewalk vaults and underground vaults are typically located within 15 to 30 meters of buildings, with many located immediately adjacent to exterior walls. It is EPA's intent to include all ofthese transformers within the definition of PCB Transformers located "near" commercial buildings. Further, outdoor pad-mounted and pole top PCB Transformers located within 15 to 30
meters ofcommercial buildings are also covered within the definition ofPCB Transformers located "near" commercial buildings.

.

EPA expects that in general very few vaulted PCB Transformers in urban and metropolitan areas are located at distances greater than 30 meters from commercial buildings. However, EPA has also evaluated the potential for building contamination from vaulted PCB Transformers located at distances greater than 30 meters from commercial buildings. EPA believes that the potential for commercial building contamination from a PCB Transformer fire in a vault located more than 30
meters from a building can be greatly influenced by factors such as wind velocity, wind direction, and plume height. While EPA has defined the term "near" by establishing a distance of30
meters from commercial buildings, EPA recognizes that in certain geographic locales, vaulted PCB Transformers located more than 30 meters from a commercial building could also present

a risk ofbuilding contamination. EPA suggests that owners ofvaulted PCB Transformers located more than 30
meters from commercial buildings individually evaluate the potential for commerical building contamination from fires involving these transformers as well. Factors considered in this evaluation could include average wind velocity for the region and normal wind direction.

C. IncreasedElectricalProtection

EPA has required the installation of enhanced electrical protection on many ofthe remaining commercial PCB Transformers (i.e., other than higher secondary voltage network PCB Transformers) by October 1,1990. The electrical protection requirements are intended to avoid PCB Transformer fires by allowing for the early detection of faults and the complete deenergization ofPCB Transformers prior to failure (rupture and/orrelease ofPCBs). The installation ofcurrent-limiting fuses or otherequivalent energy limiting devices

on PCB Transformers is intended to avoid failures from high current faults. In orderto be effective in avoiding PCB Transformerfailures from high current faults. these current-limiting devices
must (in accordance with good engineering practices) be properly installed, appropriately placed, maintained, and set sensitive enough to provide for complete deenergization within several power cycles or several tenths ofa second ofthe occurrence ofa sustained high current fault.

The installation ofheat and pressure sensitive detectors in higher secondary voltage commercial radial PCB Transformers (and appropriate disconnect equipment) is intended to avoid PCB Transformer failures from sustained low current faults. Equivalent technology that accomplishes the same goal, that is. the early detection of sustained low current faults and complete deenergization prior to failure. is acceptable. In order to be effective in avoiding PCB Transformer failures, these devices must be maintained, and
set sensitive enough to allow for complete deenergization within 30 seconds to 1 minute ofdetection ofa sustained low current fault. In addition, ifthese sensors are electrically powered, they must be provided with a secondary source ofpowerconfigured to deenergize the transformer on failure (fail-safe).

The disconnect equipment may be set either to open automatically upon the sensing ofabnormal conditions (e.g., temperature orpressure), or, it may be
set to send a signal to an on-site manned control centerwhere deenergization
must occur (during facility operating hours) within 1 minute ofthe receipt of

an audio or visual signal indicating abnormal conditions. Automatically operated circuit breakers must also have the capability to be openedmanually.

EPA received several'comments on the ProposedRule which suggested that EPA should give PCB Transformer

owners the option ofimplementing risk reduction measures on shorter schedule (such as enhanced electrical protection by 1990) orPCB Transformerremoval on

a longer schedule (such as PCB Transformerremoval by 1992). EPA did
not adopt this suggestion because, without additional reporting requirements (including the reporting to EPA ofthe address and location ofeach PCB Transformer and the option selected by the owner). EPA believes that its ability to effectively enforce the shorter term risk reduction measures would be compromised.

D. Prohibition on the Installation of PCB Transformers

EPA has prohibited the new installation ofPCB Transformers in or

nearcommercial buildings. PCB Transformers must not be newly installed in or near commercial buildings after October 1, 1985. This

means that PCB Transformers which have been placed into storage for reuse cannot be taken out ofstorage for reuse and placed in use in ornearcommercial buildings.

.

While EPA has placed restrictions on the installation ofPCB Transformers (by prohibiting the placement ofthe equipment in ornearcommercial buildings), owners ofPCB Transformers which are in storage for reuse still have
many available options. Owners ofPCB Transformers which are in storage for

reuse may use these transformers in industrial applications and in any outdoor location where there is no real risk ofcommercial buildingHeinOnline -- 50 Fed. Reg. 29198 1985 

### 29198 Federal Register 

## I VoL 50, No. 137 

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## I Rules and Regulations

contamination. These transformers may also be reclassified to PCB Contaminated status or non-PCB status and be placed in any desired location.



### E. Reporting of Fire-RelatedIncidents andContainments of Potential Water Releases

EPA has required the reporting ofall PCB Transformer fire-related incidents
to the National Response Center. A firerelated incident is defined as any incident in which high temperatures or high pressures in a transformer location lead to the rupture ofa transformer 

### andl

or the release ofPCBs. PCB Transformer fire-related incidents must be immediately reported to the NRC. The information to be reported mustinclude the type ofPCB Transformer installation involved in the fire-related incident, and reasonably ascertainable information on the cause ofthe fire-related incident

EPA has required that owners ofPCB Transformers involved in fire-related incidents take measures as soon as practically and safely possible to contain any potential releases ofPCBs and oxidation products to waterways. This means that measures must be taken
to prevent further environmentalrelease and contamination ofwaterways as

soon as there is no immediate danger of injury from the fire itself. These

measures indude, but are not limited to the blocking offlour drains, the containment ofrunoff, and the containment and treatment ofcleanup
waterprior to release. Ifthere is evidence ofthe release ofPCBs, PCDFs, and PCDDs down floor drains, the PCB Transformeruwner should also notify the sewer system and water treatment system operators as soon as possible to prevent further environmental release.

IX. Compliance,and Enforcement

EPA recognizes that technology is constantly evolving in areas such as the development ofelectrical protection systems. Thus, EPA has allowed some flexibility on the part oftransformer

owners in the selection ofappropriate enhanced electrical protection systems. Further, by requiring electrical protection for GOmmercial PCB Transformers, EPA implicitly allows the replacement ofall commercial PCB Transformers with substitute equipment, and the retrofillingand reclassification ofPCB Transformers to PCB Contaminated or non-PCB status.

EPA has, however, required the installationofprotection against failures from high current faults and low current faults in all commercial higher secondary voltage radial PCB Transformerinstallations. The installation ofprotection againsthigh current faults alone without protection against low current faults in these installations constitutes a violation of the PCB Transformeruse authorization. For lower secondary voltage commercial PCB Transformer installations, EPA has required protection against failures from high current faults.

Failure to install properly and maintain protection which is set sensitive enough, based un good engineeringjudgment, to prevent PCB Transformer failures from sustained high and low current faults (for higher secondary voltage radial PCB Transformers) and PCB Transformer failures from high current faults (for lower secondary voltage PCB Transformers) constitutes a violation of the PCB Transformer use authorization.

X. Official RecordofRulemaking

A. 

### PreviousRulemakingRecords

(1) Official rulemaking record from "Polychlorinated Biphenyls (PCBs) Manufacturing, Processing, Distribution in Commerce and Use ProhibitionRule" published in the Federal Register ofMay 31, 1979, (44 FR 31514).

(2) Official rulemaking record from "Polychlorinated Biphenyls (PCBs); Disposal and Marking Final Regulation" published in the Federal Register of February 17, 1978, (43 FR 7150).

(3) Official rulemaking record from "PolychlorinatedBiphenyls (PCBs); Manufacture, Processing, Distribution, and Use in Closed and Controlled Waste Manufacturing Processes" published in the Federal Register of October 21, 1982, (47 FR46980).

. (4) Officiall'ulemaking record from "Polychlorinated Biphenyls (PCBs); Manufacturing, Processing, Distribution in Commerce and Use Prohibitions; Use in Electrical Equipment" published in the Federal Register ofAugust 25, 1982, (47 FR 37342).

(5) Official record from "Polychlorinated Biphenyls (PCBs); Manufacturing, Processing, Distribution in Commerce and Use Prohibitions; Use in Electrical Transformers" Advance Notice ofProposed Rulemaking, published in the Federal Register of March 23. 1984, (49 FR 11070).

(6) Official record from "Polychlorinated Biphenyls (PCBs) Manufacturing, Processing, Distribution in Commerce and Use Prohibitions; Use in Electrical Transformers" Proposed Rule. published in the Federal Register ofOctober 11, 1984, (49 FR 39966).



### B. SupportDocuments

(1) USEPA, OPTS, EED, Versar, Inc., "Exposure Assessment for Polychlorinated Biphenyls (PCBs), Polychlorinated Dibenzofurans (PCDFs), and Polychlorinated Dibenzodioxins (PCDDs) Released During Transformer Fires" (June 1985).

(2) USEPA, OPTS. HERD, "HERD Work for Proposed Polychlorinated Biphenyl (PCB) TransformerFires Rulemaking" (August 1. 1984).

(3) USEPA, OPTS, HERD. "Addendum
to August I, 1984 HERD Work for Proposed PEllychlorinated Biphenyl (PCB) TransformerFires Rulemaking" (October 1. 1984).

(4) USEPA, OPTS HERD, "Response
to Comments on Health Effects ofPCBs Submitted by the Chemical Manufacturers Association and the Edison Electric Institute" (August 19. 1982).

(5) ltSEPA, OW, "Ambient Water Quality Criteria for 2,3,7,8- Tetrachlorodibenzo-p-dioxin" (February 1984).

(6) USEPA, ORD, OHEA, ECAO, "(DRAFT) Health Assessment Document for Polychlorinated Dibenzop-dioxins" (May 1984).

(7) USEPA, OPTS, ETD, Putnam, Hayes and Bartlett, Inc. "Regulatory Impact Analysis oftheFinal Rule for PCB Transformers" (June 1985).

(8) Kimbrough, Renate, D., 

### etal. "Health Implications of2,3,7,8- TetracWorodibenzodioxin (TeDD) Contamination ofResidential Soil," Journal ofToxicology and Environmental Health (in press).

(9) USEPA, OPTS, EED, "NFIRSData for 1982" (April 1984).

(10) USEPA, OPTS, EED, Midwest Research Institute, "Thermal Degradation Products from Dielectric Fluids" (December 1984).

(11) USEPA, OPTS, EED, Midwest Research Institute, "Products ofThermal Degradation ofDielectric Fluids" (January 28, 1985).

(12) National Bureau ofStandards, "Factors To Be Considered Regarding Hazard Reduction Stlategies for Fires Involving Electrical Transformers Containing Polychlorinated Biphenyls" (March 1985).

(13) USEPA, Barnes and Bellin, "Health Hazard Assessment for Chlorinated Dioxins and Dibenzofurans OtherThan 2,3,7,8-TeDD" (October 1984).

(14) USEPA, EED, Versar, "Summary ofComments on the PCB Transformer Fires Proposed Rule" (June 1985).

(15) USEPA, EED, "Response to Comments on the PCB Transformer Fires Proposed Rule" (June 1985)

XI. Executive Order 12291

Under Executive Order 12291, issued February 17, 1981', EPA mustjudgeHeinOnline -- 50 Fed. Reg. 29199 1985 

### Federal Register 

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## I Rules and Regulations 

### 29199

• • "On site" means within the boundaries ofa contiguous property unit.

3. In § 

### 761.30, the introductory text of paragraph (a) and paragraph (a)(l) are revised and OMB Control Number2070- 0073 is added to read as follows:

§ 761.30 Authorizations. 

## •

"Rupture ofa PCB Transformer"

means a violent or non-violent break in the integrity ofa PCB Transformer caused by an overtemperature and/or
overpres.sure condition that results in the release ofPCBs.

.

(a) 

### Use in andservicingof transformers (otherthan railroad transformers). PCBs at any concentration may be used in transformers (otherthan in railroad locomotives and self-propelled railroad cars) and may be used for purposes of

. servicing including rebuilding these transformers for the remainderoftheir useful lives. subject to the following conditions:

(1) 

### Use conditions. (i) As ofOctoberI, 

### 1985, the use and storage for reuse of PCB Transformers that pose an exposurerisk to food orfeed is prohibited.

(ii) 

### As ofOctober 1. 1990, the use of network PCB Transformers with higher secondary voltages (secondary voltages equal to orgreater than 480 volts, including 480/277 volt systems) in or

near commercial buildings is prohibited. NetworkPCB Transformers with higher secondary voltages which are removed from service iri accordance with this requirement must either,be reclassified
to PCB Contaminated or non PCB status. placed into storage for disposal. or disposed.

(iii) 

### As ofOctober 1. 1985. the installation ofPCB Transformers (which have been placed into storage for reuse

orwhich have been removed from anotherlocation) in ornearcommercial buildings is prohibited.

(iv) As ofOctober 1. 1990. all radial PCB Transformers and lower secondary voltage networkPCB Transformers (network transformers with secondary voltages below 480 volts) in use in or

nearcommercial buildings must be equipped with electrical protection to completely within 1 minute ofthe receipt ofa signal indicating abnormal operating conditions such as an overtemperature condition or overpressure condition in a PCB Transformer.



# . '. 

### transformers for variable treatment based on type and location. The Office ofManagement and Budgethas approved the information collection requirements ofthis rule under OMB Control Number: 207lH)073.

List ofSubjects in40 CFR Part761

Hazardous substances, Labeling, Polychlorinatedbiphenyls, Recordkeeping and reporting requirements, Environmental protection.

Dated: July 1. 1985. A. James Barnes, ActingAdministrator.



### "In orNearCommercial Buildings"

means within the interiorof. on the roof of. attached to the exteriorwall of, in the parking area serving, orwithin 30
meters ofa non-industrial nonsubstation building. Commercial buildings are typically accessible to both members ofthe general public and employees, and include: (1) Public assembly properties, (2) educational properties. (3) institutional properties. (4) residential properties. (5) stores. (6) office buildings, and (7) transportation
centers (e.g.• airport terminal buildings. subway stations, bus stations, ortrain stations).

"Manned Control Center" means an electrical power distribution control

room where the operating conditions of

a PCB Transformerare continuously monitored during the normal hours of operation (ofthe facility), and, where the duty engineers. electricians. orother trained personnel have the capability to deenergize a PCB Transformer PART 761-{AMENDED]



### Therefore. 40 CFR Part761 is amended as follows:

1. The authority citation for Part 761 is revised to read as follows:

Authority: 15 U.S.C. 2605. 2607, 

### and 2611.


### 2. In § 

### 761.3. the following paragraphs

are alphabetically added to read as follows:

§ 761.3 Definitions.



### "Industrial buildings" means a building directly used in manufacturing

ortechnically productive enterprises. Industrial buildings are notgenerally or typically accessible to other than workers. Industrial buildings include buildings used directly in the production ofpower. the manufacture ofproducts. the mining ofraw materials. and the storage oftextiles, petroleum products. wood and paper products. chemicals. plastics, and metals. 

### • • • • .whether a rule is a "majorrule" and, therefore, subject to the requirement that a Regulatory Impact Analysis be prepared. EPA believes that this amendment to the PCB rule is a major rule as the term is defined in section l(b) ofthe Executive Order. Therefore, EPA has prepared a Regulatory Impact Analysis.

While the rule places additional restrictions and conditions on the use of PCB Transformers, it is worth noting that this regulation allows the continued

uses ofPCBs in electrical transformers that would otherwisebeprohibited by section 6(e) 

### ofTSCA. This rule avoids the severe disruption ofelectric service
to the public and industry that would

occurifthe use ofthis equipment were immediately prohibited. It 

### also avoids the economic impact that would result from a requirement to replace the equipmentas soon as possible.

This rule was submitted to the Office ofManagement and Budget (OMB), as required by the Executive Order.

XII. Regulatory Flexibility Act

Under section 605(b) ofthe Regulatory Flexibility Act,S U.S.C. 605(b), the Administratormay certify that a rule will not, ifpromulgated have a significantimpact on·a substantial numberofsmall entities and, therefore, does not require a regulatory flexibility analysis.

Ingeneral. this rule will reduce the burden on small businesses that would otherwise be encountered ifan immediate ban onPCB-containing transformers were to take effect. If

### an immediateban on the use ofPCBs in transformers were imposed, large costs would be incurred by all producers and

users ofelectricity, including small businesses.

Icertify that this rule will not have a significant economic impact on a substantial numberofsmall entities.

XIII. PaperworkReduction Act

The information collection requirements ofthis rule have been submitted for approval to the Office of Management and Budget (OMB) under the Paperwork Reduction Act of1980, 44 U.S.C. 3501 et seq. In response to the information collection requirements associated with the proposed rule, OMB commented that the Agency should resubmit the information collection requirements with the final rule showing how EPAhas reduced the burdens by limiting the rule's applicability to transformers which because oflocation

or installation type are ofhigher risk. Based on this comment and other
comments made during the public
commentperiod, EPA has segmentedHeinOnline -- 50 Fed. Reg. 29200 1985 

### 29200 

### Federal Register / Vol. 50, No. 137 / Wednesday, July 17, 1985 / Rules and Regulations

avoid transformer failures caused by high current faults. Current-limiting fuses or other equivalent technology
must be used to detect sustained high
current faults and provide for complete deenergization ofthe transformer within several tenths ofa second ofdetection, before transformer failure occurs. The installation, setting, and maintenance of current-limiting fuses orotherequivalent technology to avoid PCB Transformer failures from sustained high current faults must becompleted in accordance with good engineering practices.

(v) As ofOctober 1,1990, all radial PCB Transformers with higher secondary voltages (480 volts and above, including 480/277 volt systems) in use in ornear commercial buildings
must (in addition to the requirements of paragraph (a)(1)(iv) ofthis section) be equipped with protection to avoid transformer failures caused by sustained low current faults.

(A) Pressure and temperature sensors (or otherequivalent technology which has been demonstrated to be effective in the early detection ofsustained low
current faults) must be used in these transformers to detect sustained low
current faults.

(B) Disconnect equipment must be provided to insure complete deenergization ofthe transformerin the
event ofa sensed abnormal condition (e.g., an overpressure or overtemperature condition in the transformer), caused by a sustained low
current fault. The disconnect equipment
mustbe configured to operate automatically within 30 seconds to 1 minute ofthe receipt ofa signal indicating an abnormal condition from a sustained low current fault, orcan be configured to allow for manual deenergization from a manned on-site control centerupon the receipt ofan audio or visual signal indicating an abnormal condition caused by a sustained low current fault. Manual deenergization from a manned on-site control centermust occurwithin 1 minute ofthe receipt ofthe audio or visual signal indicating an abnormal condition caused by a sustained low
current fault. 

### Ifautomatic operation is selected and a circuit breaker is utilized for disconnection, itmust also have the capability to be manually opened if
necessary.

(C) The enhanced electrical protective system required for the detection of sustained low current faults and the complete and rapid deenergization of transformers must be properly installed, maintained. and set sensitive enough (in accordance with good engineering practices) to detect sustained low
current faults and allow for rapid and total deenergization prior to PCB Transformerrupture (eitherviolent or

non violent rupture) and release of PCBs.

(iv) As ofDecember 1, 1985, all PCB Transformers (including PCB Transformers in storage for reuse) must be registered with fire response personnel with primary jurisdiction (that is, the fire department or fire brigade which would normally be called upon for the initial response to a fire involving the equipment). Informationrequired to be provided to fire response personnel includes:

(A) The location ofthe PCB Transformer(s) (the addressees) ofthe building(s) and the physical location of the PCB Transformer(s) on the building site(s) and for outdoorPCB Transformers, the location ofthe outdoor substation).

(B) The principal constituent ofthe dielectric fluid in the transformer(s) (e.g., PCBs. mineral oil. or silicone oil).

(C) The name and telephone number ofthe person to contact in the event ofa fire involving the equipment.

(vii) As ofDecember 1,1985, PCB Transformers in use in ornear commercial buildings must be registered with building owners. ForPCB Transformers located in commercial buildings. PCB Transformer owners must registerthe transformers with the building ownerofrecord. ForPCB Transformers located near commercial buildings. PCB Transformer owners must register the transformers with'all

owners ofbuildings located within 30
meters ofthe PCB Transformer(s). Information required to be provided to building owners by PCB Transformer

owners includes but is not limited to:

(A) The specific location ofthe PCB Transformer{s).

(B) The principal constituent ofthe dielectric fluid in the transformer(s) (e.g., PCBs, mineral oil, or silicone oil).

(C) The type oftransformer installation (e.g., 208/120 volt network, 280/120 volt radial, 208 volt radial, 480 volt network. 480/277 volt network, 480 volt radial, 480/277 volt radial).

(viii) As ofDecember 1. 1985, combustible materials. including. but not limited to paints, solvents. plastics,
paper. and sawn wood must notbe stored within a PCB Transformer enclosure (i.e., in a transformervault or in a partitioned area housing a transformer); within 5 meters ofa transformerenclosure, or. ifunenclosed (unpartitioned), within 5 meters ofa PCB Transformer.

(ix) A \(isual inspection ofeach PCB Transformer (as defined in the definition of"PCB Transformer" under § 761.3) in

use or stored for reuse shall be performed at least once every 3 months. These inspections may take place any time during the 3-month periods: January-March, April-June, JulySeptember. and October-December as long as there is a minimum of30 days between inspections. The visual inspection must include investigation for
any leak ofdielectric fluid on or around the transformer. The extent ofthe visual inspections will depend on the physical constraints ofeach transformer installation and should not require an electrical shutdown ofthe transformer being inspected.

(x) 

### Ifa PCB Transformeris found to have a leak which results in any quantity ofPCBs running offor about to

run offthe external surface ofthe transformer, then the transformermust be repaired orreplaced to eliminate the

source ofthe leak. In all cases any leaking material must be cleaned up and properly disposed ofaccording to disposal requirements of § 761.60. Cleanup ofthe released PCBs mustbe initiated as soon as possible, but in no

case later than 48 hours ofits discovery. Until appropriate action is completed,
any active leak ofPCBs must be contained to prevent exposure of humans or the environment and inspected daily to verify containment of the leak. Trenches, dikes, buckets, and
pans are examples ofproper containmentmeasures.

(xi) 

### Ifa PCB Transformeris involved in a fire-related incident, the ownerof the transformermust immediatelyreport the incident to the National Response Center (toll-free 1-800-424-8802; in Washington. D.C.**202-42~2675).** A firerelated incident is defined as any incident involving a PCB Transformer which involves the generation of sufficient heat and/orpressure (by any source) to result in the violent ornonviolent rupture ofa PCB Transformer and the release ofPCBs. Information
mustbe provided regarding the type of PCB Transformerinstallation involved in the fire-related incident (e.g., high or low secondary voltage network transformer. high orlow secondary voltage simple radial system. expanded radial system, primary selective system. primary loop system, or secondary selective system orother systems) and the readily ascertainable cause ofthe fire-related incident (e.g., high current fault in the primary or secondary orlow
current fault in secondary). The owner ofthe PCB Transformermust also take

measures as soon as practically and safely possible to contain and control
any potential releases ofPCBs and incomplete combustion products intoHeinOnline -- 50 Fed. Reg. 29201 1985 

### Federal Register / Vol. 50, No. 137 / Wednesday, July 17, 1985 / Rules and Regulations 

### 29201

water.These measures include, but are not limited to:

(A) The blocking ofall floor drains in the vicinity ofthe transformer.

(B) The containment ofwaterrunoff. (C) The control and treatment (prior to release) ofany water used in subsequent cleanup operations.

(xii) Records ofinspection and maintenance history shall be maintained
at least 3 years after disposing ofthe transformer and shall be made available for inspection, upon request by EPA. Such records shall contain the following information for each PCB Transformer:

(A) Its location. (B) The date ofeach visual inspection and the date that leak was discovered, if different from the inspection date.

(C) The person performing the inspection.

(D) The location ofany leak(s). (E) An estimate ofthe amount of dielectric fluid released from any leak.

(F) The date ofany cleanup, containment, repair, orreplacement.

(G) A description ofany cleanup, containment, orrepairperformed.

(H) The results ofany containment and daily inspection required for uncorrected active leaks. (xiii) A reduced visual inspection frequency ofat least once every 12 months applies to PCB Transformers that utilize either ofthe following risk reduction measures. These inspections
may take place any time during the calendaryear as long as there is a minimum of180 days between inspections.

(A) A PCB Transformer which has impervious, undrained, secondary containment capacity ofat least 100 percent ofthe total dielectric fluid volume ofall transformers so contained

or(B) A PCB Transformer which has been tested and found to contain less than 60.000 ppm PCBs (after 3 months of in servjce use ifthe transformer has been serviced for purposes ofreducing the PCB concentration).

(xiv) An increased visual inspection frequency ofat least once every w!!ek applies to any PCB Transformer in use

or stored for reuse which poses an exposure risk to food orfeed. The user ofa PCB Transformerposing an exposure risk to food is responsible for the inspection, recordkeeping, and maintenance requirements under this section until the user notifies the owner that the transformer may pose an exposure risk to food orfeed. Following such notification, it is the owner's ultimate responsibility to determine whether the PCB Transformerposes an exposure risk to food orfeed.

(The recordkeeping requirements of paragraphs (aJ(l) (vi), (vii), and (xi) were approved by the Office ofManagement and Budget under OMB Control Number 2070-
0073. The recordkeeping requirements of paragraph (xii) were approved by the Office ofManagement and Budget under OMB Control Number 2070-0007.)

4. In § 761.40, paragraph (j) is added to read as follows:

§ 761.40 Marking requirements.

(j) As ofDecember 1, 1985, the vault door, machinery room door, fence, hallway, or means ofaccess (others than grates and manhole covers) to a PCB Transformermust be marked with the markML•The mark must be placed so that it canbe easily read by firemen fighting a fire involving this equipment.

[FR Doc. 85-16851 Filed 7-1lHl5: 8:45 ami

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