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Environmental

Protection Agency

40 CFR Part 761

Polychlorinated Biphenyls in Electrical

Transformers; Final Rule

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HeinOnline -- 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 of an existing EPA rule

concerning the use of polychlorinated

biphenyls (PCBs) by placing additional

restrictions and conditions on the use of

PCB Transformers (Electrical

transformers containing 500 parts per

million or greater PCBs). This rule: (1)

Prohibits the use of higher secondary

voltage (480 volts and above) network

PCB Transformers in or near commercial

buildings after October 1, 1990, (2)

requires. by October 1, 1990, the

installation of enhanced electrical

protection on lower secondary voltage

network PCB Transformers and higher

secondary voltage radial PCB

Transformers in use in or near

, commercial buildings, (3) prohibits

further installation of PCB Transformers

in or near commercial buildings after

October 1. 1985, (4) requires the

registration. by December 1. 1985. of all

PCB Transformers with fire response

personnel and building owners. (5)

requires the marking, by December 1.

1985. of the exterior of all PCB

Transformer locations, and (6) requires

the removal, by December 1, 1985. of

stored combustibles located near PCB

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 of PCB'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 of judicial

review at 1 p.m. Eastern Daylight Time

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) of the Toxic Substances

Control Act (TSCA) generally prohibits

the use of PCBs after January 1, 1978.

The statute does, however, set forth two

exceptions under which EPA may, by

rule. allow a particular use of PCBs to

continue. Under section 6(e)(2) of TSCA.

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 of human beings or

the environment to a polychlorinated

biphenyl will be insignificant. as

determined by the Administrator by

rule." TSCA also allows EPA to

authorize the use of PCBs in a manner

other than a totally enclosed manner if

the Agency finds that the use "will not

present an unreasonable risk of injury to

health or the environment."

EPA promulgated a rule. which was

published in the Federal Register of May

31, 1979 (44 FR 31514), to implement

section 6(e) (2) and (3) of TSCA. This

rule is listed in the Code of Federal

Regulations under 40 CFR Part 761. The

rule, among other provisions, 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 of Columbia

Circuit to review a number of provisions

of the rule. including the portion of the

rule that designated all intact and

nonleaking capacitors, electromagnets,

and transformers as "totally enclosed"

(Environmental Defense Fund. Inc. v.

Environmental Protection Agency. 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 of the rule,

as well as other provisions, and

remanded the rule to EPA for further

action.

As a consequence of the October 1980

decision. EPA undertook a number of

rulemaking actions. The rule relevant to

the subject of today'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 of PCB

Transformers (electrical transformers

containing greater than 500 ppm PCBs)

in facilities involved in handling of food

or feed items until October 1, 1985, and

by authorizing the use of all other

categories of non-railroad eleotrical

transformers containing or

contaminated with PCBs for the

remainder of their 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 if it did not

authorize the use of PCBs in

transformers, the costs to the public and

United States industry would be bl\lions

of dollars, primarily as a result of the

disruption of electrical 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

under the rule reasonably reduced the

exposure risks associated with the use

of PCBs in PCB Transformers, and the

servicing conditions prevented further

PCB contamination of transformers.

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 of all the PCBs used in

tranformers and release less than one

half of a percent of these PCBs on

annual basis.

4. EPA determined that the costs

associated with other risk reduction

measures such as accelerated phase-out,

reducing the PCB concentration in the

dielectric fluid, or providing

containment for tranformers were not

reasonable when compared to the

potential reduction in release of PCBs

achieved.

In evaluating the risks posed by the

continued use of electrical transformers

containing PCBs for the August 1982

PCB Electrical Use Rule, EPA

considered exposures resulting from

leaks and spills of PCB-containing

dielectric fluid as constituting the

principal route of release of PCBs to the

environment from this equipment.

However, EPA has learned that fires

involving transformers also can be

responsible for the release of PCBs. and.

that PCBs released from transformers in

fire situations can be volatilized and

converted into materials which are

orders of magnitude more toxic than

PCBs. For example, on February 5, 1981.

in the Binghamton State Office Building

in Binghamtom. New York, a PCB
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Transformer was involved in a fire in

the basement of the building. PCBs and

oxidation products were distributed

throughout the 18-story office building

via two vertical ventilation shafts that

ran the length of the building and

opened into the transformer vault in the

basement. Monitoring. completed after

the fire, indicated that PCBs. .

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 interior of the building.

From laboratory studies. it appears that

PCDFs are formed from both the

oxidation of PCBs and the oxidation of

chlorinated benzenes in combustion

situations. PCDDs. however. appear to

be formed only from the oxidation of

chlorinated benzenes. (Tri- and Tetrachlorinated benzenes often make up 30-

35 percent of PCB askarel dielectic fluid.

and can be present at low levels as

contaminants in other fluids.)

At the time of promulgation of the

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 of electrical

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 of implementing risk

reduction measures to mitigate the risks

posed by fires involving this equipment

or factor into its economic assessment

certain now-identified costs associated

with the continued use of these ..

transformers. principally. the very high

costs of cleanup following more serious

incidents. These costs reduce the

benefits associated with the continued

use of these transformers.

After the promulgation of the PCB

Electrical Use Rule. additional

information came to EPA's attention

that indicated that PCB Transformer

fires may occur more frequently than

previously expected, and that

transformer fire-related hazards are not

restricted solely to transformers located

inside buildings. On May 15. 1983. in the

One Market Plaza complex in San

Francisco. California. a PCB

Transformer was involved in a smoky

transformer vault fire. Monitoring

completed after the fire indicated the

presence of PCBs, PCDFs. and PCDDs.

in soot from this fire. Although the vault

housing the transformer was 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 San Francisco incident. and four

more recent incidents, in the First.

National Bank Building in Chicago,

Illinois. in September 1983; in Tulsa,

Oklahoma. in December 1983 and May

1984; and in Miami, Florida, in May 1984,

have prompted EPA to reassess its

earlier position on the expected

frequency of fire-related incidents

involving transformers that contain

PCBs.

EPA issued an Advance Notice of

Proposed Rulemaking (ANPR). which

was published in the Federal Register of

March 23, 1984 (49 FR 11070), to solicit

additional information on the risks

posed by fires involving transformers

containing PCBs, their frequency of

occurrence. the costs of cleanup

following these incidents, and the

effectiveness and costs associated with

regulatory control measures. At that

time. EPA indicated that it would use

the new information to reconsider the.

use authorization issued in the August

1982 PCB Electrical Use Rule for the

continued use of most electrical

transformers containing PCBs.

In the ANPR, EPA solicited comments

on a wide range of potential regulatory

control measures. including the

phaseout of PCB 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 Transformer fires in

commercial buildings such as office

buildings, versus the risks posed by fires

in industrial facilities and outdoor

electrical substations. EPA suggested in

the ANPR that the risks posed by PCB

Transformer fires in commercial

buildings may be greater than those

posed by transformer fires in industrial

facilities and outdoor electrical

substations.

EPA received over 50 comments on .•

the ANPR during the public comment

period. which closed on May 22. 1984.

EPA received information from a

number of different sources, including

~he insurance industry. fire departments.

building owners. industrial transformer

users, and utilities. (The comments on

the ANPR are summarized in: "PCB

Transformer Fires: Comments on the

Advance Notice of Proposed

Rulemaking" (September 1984).) Several

comments were received following the

close of the comment period. 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

after completing further analyses of

available data, EPA issued a Proposed

Rule. which was published in the

Federal Register of October 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 of PCB

Transformers. At the same time. EPA

reaffirmed its August 1982 determination

that the indefinite use of PCBContaminated transformers does not

present unreasonable risks to public

health or the environment. EPA's

determinations were based on analyses

of the risks posed by fires involving

electrical transformers containing PCBs,

the benefits of PCBs and the availability

of substitutes, and the costs and benefits

of control measures designed to mitigate

or eliminate the fire-associated risks

posed by the equipment.

EPA received over 130 comments on

the Proposed Rule during the public

comment period, which closed on

February 11, 1985. On January 14, 15.

and 16. 1985, EPA held a public hearing

in Washington. D.C., where 15 parties

provided testimony,on various

. provisions of the Proposed Rule.

EPA has considered all the comments

received in response to the Proposed

Rule (as well as the comments received

after the close of the ANPR comment

period). and has modified the rule where

appropriate. Further. EPA has prepared

a support document for this rulemaking

which addresses all substantive

comments on the Proposed Rule and

includes EPA's responses to comments

which did not result in the actual

modification of the rule. This document,

entitled: "Response to Comments on the

PCB Transformer Fires Proposed Rule

(July 1985)." is available by contacting

the Toxic Substances Control Act

Assistancce Office (see FOR FURTHER

INFORMATION CONTACT).

II. Summary of the Final Rule

Under section 6(e)(2)(B) of TSCA, EPA

can authorize a use of PCBs provided

that the use "will not present an unreasonable risk of injury 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 of leaks and spills of PCBs

from this equipment compared to the

high costs associated with replacing this

equipment with substitute transformers
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29172 Federal Register / Vol. 50, No. 137 / Wednesday. July 17. 1985 / Rules and Regulations _,~~~~~~~~~~~~~~~~~~~~~

or requiring secondary containment to

limit the spread of spilled materials:

EPA subsequently undertook an

evaluation of the fire-related risks posed

by the continued use of PCB

Transformers. and the costs and

benefits of measures designed to reduce

those risks. On October 11.1984. EPA

issued a Proposed Rule which contained

EPA's determination that PCB

Transformer fires (fires involving

transformers containing greater than 500

ppm PCBs). particularly fires which

occur in or near buildings, do present

risks to human health and the

environment. EPA reached this

determination after considering the

extreme toxicity of materials 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 of incidents over the

remaining useful life of this equipment.

EPA further determined that the

continued use of PCB Transformers

without additional restrictions does

present an unreasonable risk of injury to

health and the environment. EPA

reached this determination after

considering the risks posed. the costs of.

cleanup following these incidents. the

availability of adequate substitute

materials. and the costs and benefits

associated with risk reduction measures.

EPA did. therefore. propose additional

regulatory controls on the use of this

equipment.

EPA proposed to require: (1) The

immediate registration of all PCB

Transformers with appropriate fire

department jurisdictions. and the

immediate registration with building

owners of all PCB Transformers located

in or near buildings. (2) the immediate

marking of the exterior of the vault door.

machinery room door. means of egress,

or grate(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. of additional

electrical protective devices on PCB

Transformers in or near buildings in

high secondary voltage systems (480/277

volt systems). and (5) the isolation. by

July 1. 1988. of all PCB Transformers in

or near buildings 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 of a PCB

Transformer fire. In addition. to

facilitate monitoring compliance with

the isolation requirements, EPA

proposed that PCB Transformer owners

maintain records of tteir efforts in

isolating transformers through the

completion of PCB Smoke Spread

Reduction Plans (PCB-SSRPs).

Finally. in the event of a PCB

Transformer fire. EPA proposed to

require PCB Transformer owners to take

immediate measures to contain potential

water discharges. and to report all PCB

Transformer fire-related incidents to the

National Response Center (NRC) prior

to the initiation of cleanup efforts.

This final rule modifies and clarifies

some of the 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 Proposed Rule. EPA

evaluated the risks posed by PCB

Transformer fires in or near buildings by

using an office building setting to

evaluate generically the nature of an

potential for human and environmental

exposures to PCBs and incomplete

combustion products. EPA determined

that additional control measures.

principally the isolation of PCB

Transformers from building ventilation

equipment and ductwork. were

necessary to reduce the risks posed by

the continued use of this equipment.

During the public comment period 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 posed by the continued use of PCB

Transformers in industrial locations

versus the fire-related risks posed by the

use of PCB Transformers in or near

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 of PCB Transformers in or near

industrial buildings separately from the

use of PCB Transformers in or near

commercial buildings.

Second. many comments on the

Proposed Rule discussed the probability

of PCB Transformer failures and fires.

and suggested that certain types of PCB

Transformer installations. network

installations with higher secondary

voltages (secondary voltages of 480

volts and above. including 480/277 volt

secondaries). may be particularly likely

to be involved in fire-related incidents.

These comments suggest that if EPA

were to pursue additional restrictions on

the use of PCB 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 of failures and

fires in different types of PCB

Transformer installations and places

more stringent controls on those

transformers which EPA believes pose

higher risks of failures and fires.

Finally. in response to comments on

the Proposed Rule. in this final rule. EPA

has increased its emphasis of the

prevention of PCB Transformer fires

through increased electrical protection.

and decreased its emphasis on the use

of isolation measures to minimize the

spread of already formed and/or

released contaminants.

This final rule prohibits:

1. The continued use of higher

secondary voltage network PCB

Transformers (network PCB

Transformers with secondary voltages

at or above 480 volts, including 480/277

volt systems) in or near commercial

buildings beyond October 1. 1990.

2. The further installation of PCB

Transformers (which have been placed

into storage for reuse) in or near

commercial buildings.

This final rule also requires:

1. The installation. by October 1. 1990.

of enhanced 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 480 volts, including

480/277 volt systems) used in or near

commercial buildings.

2. The registration, by December 1,

1985 of all PCB Transformers with fire

departments or fire brigades with

primary response function. and the

registration. by December 1. 1985. of all

PCB Transformers located in or near

buildings with building owners.

3. The marking, by December 1, 1985.

of the exterior of all PCB Transformer

locations (excluding grates and manhole

covers).

4. The removal, by December 1, 1985.

of combustible materials stored within a

PCB Transformer enclosure, within 5

meters of a PCB Transformer enclosure.

or within 5 meters of an unenclosed PCB

Transformer.

This rule also requires the immediate

notification of the National Response

Center in the event of a PCB

Transformer fire-related incident; and,

that PCB Transformer owners 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.
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the blocking of floor drains. the

containment of water runoff, and the

control and treatment of cleanup water

prior to discharge.

Fire events involving the rupture of

PCB Transformers can lead to

contamination of sewers. sewage

treatment systems. sewage sludges and

bodies of water. 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 of the r:Jpture of water pipes.

Disruption of sewage 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 of receiving waters

presents a risk of long 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 of cleaning 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 of as 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 of water bodies and bottom

sediments. if possible. 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 of releases during PCB

Transformer fires.

For these reasons. it is important that

sewer systems and treatment plant

operators have as much notice as

possible of a PCB Transformer fire

event. The sooner this information is

available. the sooner action can be

taken to isolate or contain contaminants

(if possible). to limit their spread and to

assure proper handling.

Fire departments are required to be

notified pursuant to § 761.30(a)(1)(vi) of

this regulations as to the location of PCB

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 of PCB Transformer

fire events.

EPA also urges owners of PCB

Transformers and owners of buildings in

which those transformers are located to

'plan ahead for a fire event. Building

owners. working with other parties.

should plan their best course otaction to

prevent or limit release of PCBs and

other contaminants in the event of a fire.

These plans should give special

consideration to the location of

individual PCB Transformers. the

location of drains near these

transformers. and methods for closing

the drains in the event of a PCB

Transformer fire.

To support this voluntary cooperative

effort. EPA will develop guidance for

use by owners and operators of sanitary

sewer systems and treatment facilities.

pointing out the availability at local fire

departments of information on the

location of transformers and the

potential impact of the release of PCBs

and other contaminants into the sewer

system in the event of a fire. EPA will

also evaluate the possible roles of

organizations such as the Water

Pollution Control Federation. the

Association of State and Interstate

Water Pollution Control Authorities. the

American Public Works Association.

and the National Fire Protection

Association in distributing information.

and may request their cooperation in

this effort.

For purposes of this 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). For purposes of this rule. "in

or near" a commercial building is

defined as: (1) Within the interior of a

commercial building. (2) on the roof of a commercial building or attached to the

exterior wall of a commercial building.

(3) in the parking area of a commercial

building. or (4) located within 30 meters

of a 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

of power. the manufacture of products.

the mining of raw materials. and the

storage of textiles, petroleum'products.

wood and paper products. chemicals or

plastics. and metals.

EPA has determined that requiring the

removal of particularly 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 of PCB

Transformers. EPA has determined that

the continued use of PCBs in PCB

Transformers which comply with the

conditions and requiremeIJ.ts described

above do not present unreasonable risks

to public health or the environment.

Further. after considering the risks

posed by fires involving transformers

containing less than 500 ppm PCBs. and

the costs of regulatory 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 50 ppm 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

of the installation of protection against

transformer failures from sustained low

current faults. EPA has determined that

the enhanced protection of these PCB

Transformers is necessary to reduce the

fire-related risks posed by the continued

use of these transformers in commercial

locations. This protection will reduce

the frequency of PCB Transformer fires

in these types of transformers by

allowing for rapid deenergization in the

event of a sustained low current fault.

While EPA is aware of at least five

basic types of radial 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 of low

current fault-related failures would be

significantly different among these five

types of radial 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 of PCB

Transformer failure~and fires may
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result in the development of data by

industry which would indicate that there

are significant differences in the

probabilities of fault-related failures

among the different types of radial

systems. If these data are developed.

they should be submitted to EPA for

consideration. Based on the timely

submission of new information, that is,

within 2 years of the date of .

promulgation of this final rule, EPA may

choose to revisit this particular

requirement. .

The remainder of this preamble

describes the basis for the

determinations reached in this final rule.

III. Use Authorizations Under Section

6(e)

In order to authorize a use of PCBs

under section 6(e)(2)(B} of TSCA. EPA

must find that such use "will not present

an unreasonable risk of injury to health

or the environment." To determine

whether a risk is unreasonable. EPA

must balanc~ the probability that harm

will occur from the use against the

benefits to society of allowing the

continued use. In completing this

assessment for the use of PCB

containing electrical transformers, EPA

has considered the following factors for

each of four categories of electrical

transformers containing PCBs (PCB

Transformers located in or near

commercial buildings. PCB Transformers

located in or near industrial facilities,

PCB Transformers located outdoors

(away from commercial buildings), and

PCB .Contaminated transformers):

1. The effects of PCBs and their

incomplete combustion products on

human health and the environment.

2. The magnitude of human and

environmental exposure to PCBs and

their incomplete combustion products.

3. The benefits of using PCBs and the

availability of substitutes.

4. The economic impact resulting 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

must consider in deciding whether a

chemical presents an unreasonable risk

under section 6(a) of TSCA.

The remaining units of this preamble

will discuss these key factors in the

unreasonable risk determinations made

in this rule, and the basis for EPA's

determination to allow the continued

use of PCB-containing transformers with

certain additional conditions and

restrictions.

IV. Transformer Fire-Related Risks

A. Toxicity ofPCBs and Incomplete

Combustion Products

In earlier rulemakings, 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 for reproductive effects and

developmental toxicity as well as

oncogenicity in humans exposed to

PCBs. While fires involving PCBcontaining transformers have resulted in

the releaS'e of large quantities of PCBs,

these incidents have also resulted in the

formation of toxic products of

incomplete combustion.

Many other compounds of potential

toxicological significance, including

PCDFs, PCDDs. and polychlorinated

biphenylenes, were measured in soot

samples following fires involving PCB

Transformers. However. the bulk of

toxicity testing of PCDF and PCDD

congeners has been completed on what

are anticipated to be the most toxic

species, the 2,3,7,6 substituted PCDFs

and PCDDs. EPA has evaluated the risks

posed by PCB Transformer fires 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

of other PCDF and PCDD congeners; and

(3) the potential for exposure to these

materials as a result of a fire.

While the majority of toxicological

testing has been completed on PCBs,

2,3,7,6-TCDF and 2,3,7,8-TCDD, this does

not mean that human and environmental

exposures to other congeners of PCDFs

and PCDDs as well as polychlorinated

biphenylenes pose little risk of toxic

effects. For example, 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 similar in 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 also reduce

exposures to these other compounds 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 of the 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

microgram per kilogram (kg) body

weight (bw) for guinea pigs to 5,051

micrograms per kilogram body weight

for hamsters. The AWQC presents the

acceptable daily intake (ADI) value for

a 70 kg man as 2.2 X 10- 7 micromoles

2,3.7,6-TCDD per day. This ADI is based

on the lowest-observed-adverse-effect

levels (LOAEL) in rats. and has been

calculated in accordance with the

National Academy of Science'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 of human health.

This ADI level does not take into

account the demonstrated carcinogenic

effects of 2.3,7.8-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 of 2,3,7,8-

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 5X107 per millimole

(mmol) per kg per day (137 per ug per kg

per day), making 2,3,7,8-TCDD the most

potent carcinogen that the CAG has

evaluated. CAG ranks 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 other PCDD

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 of 0.88 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 of 0.94, 3.19, and 3.67

umol/kg, respectively.

Toxicological testing of PCDFs.

specifically, 2,3,7,8-TCDF, has been

more limited than testing of 2.3,7.8-

TCDD. The acute oral LD50 in the

guinea pig is reported to be 5
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micrograms per kg 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 per kg bw).

Subchronic testing of 2,3,7,8-TCDF in

rhesus macaques indicated that this

compound is extraordinarily toxic.

Based upon EPA's review of this study,

the No Observed Effect Level (NOEL)

for 2,3,7,8-TCDF is expected to be below

5.0 parts per billion (ppb). The author of

this study concluded that continued

daily oral intake of small amounts of

2,3,7,8-TCDF gave monkeys a disease

which is clinically and morphologically

similar to acute or chronic ingestion of

2,3,7,8-TCDD. The clinical course is

marked chiefly by weight loss, swelling

of the eyelids, dryness and granularity

of the skin, hair loss and reduced

physical activity. For most of the

observed biological effects. the potency

of the two compounds are within an

order of magnitude of each 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 2 to 33 percent less toxic

than 2,3,7,8-TCDD, depending upon the

particular endpoint in question. Further.

the toxicity of 2,3,7,8-TCDF in rhesus

macaques has been estimated to be

about 20 times that of 3,4,4'.5'-

tetrachlorobiphenyl and 1.000 times

more toxic than PCB Aroclor 1248.

Based on its assessment of available

literature on the toxicity of 2,3,7,8-TCDF

and the structural similarity of 2,3,7,8-

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 of similar toxic effects as

exposures to 2,3,7,8-TCDD. Further,

based on structure-activity relationships

and limited in-vitro studies. EPA assumes that other PCDF 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-HxCDF may also

pose risks of similar 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 of soot samples in guinea pigs.

Based on these studies, using

Binghamton State Office Building

(BSOB) soot, EPA has concluded that

exposures to soot from 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 weight gain. all effects of the

subchronic administration of the BSOB

soot, have been routinely demonstrated

in acute studies in guinea pigs using

PCDFs and PCDDs, In addition, the

group of guinea pigs dosed with 231.1

ppm BSOB soot (in feed) in the

subchronic study exhibited symptoms

characteristic of acute exposure to

2,3.7,8-TCDD and 2,3,7,8-TCDF, which

include skeletal muscle degeneration,

fatty changes in hepatocytes. and

degeneration of gastrointestinal tract

epithelium.

One paper stated that the oral LD50 of

the BSOB soot in guinea pigs is 410

milligrams per kilogram body weight,

which would classify this material as

very toxic.

For more in-depth analyses of the

toxicities of PCBs, PCDFs, and PCDDs

see documents 2, 3, 4, 5, 6, 8, and 13 in

Unit X.B.

B. The Formation ofOxidation Products

From PCBs

There is direct evidence of the

formation of PCDFs and PCDDs from

heating and burning commercial

mixtures of PCBs and diluents from: (1)

Chemical analyses of materials at the

sites where fires were known to involve

transformers that contained PCBs and

chlorinated benzenes, and (2) laboratory

experiments published in chemical and

other literature. PCBs, PCDFs. and

PCDDs were found in some soot

specimens from both the Binghamton

and San Francisco fires. Data submitted

to EPA following the issuance of the

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

of pure PCBs to PCDFs. In these studies,

a number of different PCB congeners

and mixtures of congeners have been

heated and the resulting materials

analyzed for PCDFs and PCDDs. A

specific PCB compound reacts to form a

limited number of PCDFs. The formation

of PCDFs involves intramolecular

elimination of three kinds of diatomic

molecules, with or without some

rearrangement of chlorine 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 of the two phenyl

rings in the original polychlorinated

biphenyl molecule. The optimum

temperature range for the published

laboratory experiments was 600 ·C.

Yields of PCDFs have been reported in

the literature to be as high as 10 percent

(calculated on the amount of PCB

decomposed) for 'reaction temperatures

from 550 ·C to 600 ·C, but drop off to

tenths of a percent at temperatures

below 500 ·C and above 650 ·C.

EPA-sponsored studies of the

formation of PCDFs and PCDDs indicate

that the optimum conditions for the

formation of PCDFs from (neat) PCBs

are 675 ·C for 0.8 second or longer, with

8 percent excess oxygen. Under these

conditions, a 3 percent conversion

efficiency (PCBs to PCDFs) was

observed for askarel fluid. Under the

same conditions, PCDFs were also

formed from PCBs present at

concentrations of 5, 50. and 500 ppm in

mineral oil and silicone oil. The EPA

study of the formation of PCDFs PCDDs

from PCB-containing mineral oil and

silicone oil indicates a 4 percent

conversion efficiency of PCBs to PCDFs

when PCBs are present in these

materials at concentrations of 5, 50, and

500 ppm. Statistical analysis showed a

linear relationship between the amount

of PCB present and the amount of

PCDFs formed,

PCB dielectric fluid may also contain

chlorina.ted benzenes as diluents or

contaminants, as a result of past

servicing activities. Laboratory

experiments in the published literature

have shown the formation of PCDDs in

addition to PCDFs from the pyrolysis of

mixtures of chlorobenzenes. Amounts of

PCDFs ranged as high as several tenths

of a percent for mixtures of

trichlorobenzenes. Tetrachlorobenzene

and pentachlorobenzene mixtures

formed amounts of PCOFs and PCDDs

which were two orders of magnitude

smaller than the amounts of these

compounds formed by trichlorobenzene.

These reactions are bimolecular and the

experimental concentrations of

chlorobenzenes were high.

EPA-sponsored studies of the

incomplete combustion of chlorinated

benezenes indicate that PCDFs, and to a

lesser extent PCDDs, 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 of which 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 or PCDDs under the

experimental conditions.

The presence of low concentrations of

chlorobenzenes as contaminants in
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dielectric fluids that also contain PCBs

are not expected to lead to substantial

increases in the amounts of PCDFs

formed from burning or heating 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 of chlorobenzenes in that fluid

as well.

For further discussions of the

formation of incomplete combustion

products from PCBs and other potential

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

of the chemical reactions occurring in a

fire in which aroclors (or any other

commercial mixtures of many PCB

compounds) are burned are far more

complex than the laboratory

experiments. However, EPA believes

that reactions observed in the

. laboratory should also occur in fire.

situations where the reactants and

reactions conditions are similar to

laboratory reaction conditions. Data

from actual PCB Transformer fires

confirm the relatively high rates of

conversion of PCBs 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 of PCBs in oil.

However, the levels of PCDFs and

PCDDs measured following high

temperature incineration have been

substantially less than those measured

following the above described

laboratory experiments. This is because

of high 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 of PCDFs

is optimized at around 600 ·C. It is

probable that yields of PCDFs from

PCBs are reduced at higher temperatures

because of increased destruction

efficiency and ease of combustion.

C. Causes ofPCB Transformer FireRelated Failures

PCB Transformer fire-related

incidents can occur from many causes,

including overloading. overheating,

electrical faults (overcurrent conditions

or low current faults eitherin the

transformer itself or external to the

transformer in associated electrical

equipment), and fires near transformers,

involving building components or stored

materials. PCB Transformer fires can

also occur as a result of mechanical

failures which can lead to electrical

faults, and then, to fires. Of the welldocumented PCB Transformer fires.

many have reportedly occurred as a

result of electrical faults, which led to

transformer failures and fires. Electrical

faults are of two 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 or in

associated electrical equipment. Faults

in associated electrical equipment are of

equal concern to faults inside

transformers. first, because these faults

can ultimately cause transformer failure,

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 of a fault occurring.

Further. electrical faults are more likely

to be self-sustained rather than selfextinguishing when voltages are higher.

1. Mechanisms offailure-a.

Excessive current flow. 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. If the 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 of the transformer casing and

loss of dielectric fluid. If the 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

transformer failure (rupture and release

of dielectric fluid).

According to comments on the

Proposed Rule, electrical faults which occur on the load side or secondary side

of a 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 higher voltage

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 of overcurrent conditions occur

when overcurrent electrical protective

devices (fuses and/or circuit breakers)

are not present; when overcurrent

protection is not set sensitive enough to

deenergize the transformer before high

temperatures or pressures are reached;

and when overcurrent protection simply

fails to operate when called upon.

b. Low current faults. 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

transformer itself, or external to a

transformer. in its associated electrical

equipment, and not activate

conventional overcurrent protective

devices (the fuses and circuit breakers

discussed earlier). For a 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 of a sustained high energy

(high current) arc to the reputure of a

transformer, low current faults may take

some time to release sufficient energy to

cause tank rupture.

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

of network transformers) and network

collector buswork. Sustained or

prolonged low current faults external to

a transformer can ultimately involve the

transformer itself, causing rupture and

release of PCBs.

As was the case for high current

faults, comments on the Proposed Rule

indicate that when the secondary

voltage of a transformer is higher, low

current faults which occur in the

secondary (in the low voltage winding,

low voltage leads, or associated

equipment) have a greater likelihood of
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being self-sustained rather than selfextinguishing. That is, low current faults

in 480 volt secondaries have a greater

likelihood of being sustained than low

current faults in 208 volt secondaries.

Protecting against sustained low

current arcing faults in a transformer

involves the use of appropriate 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

transformer winding. 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 transformer is rapidly

deenergized. either automatically or

manually (following the receipt of an

audio or visual signal at a control

center).

2. Protection currently provided

against common mechanisms offoultrelated failures. 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 of electrical protection

provided varies depending upon the

nature of the transformer installation.

Certain transformers and installations

are better protected against fault-related

failures than other types of transformers

and installations. For purposes of this

section, it is sufficient to divide the

applications into two types.

The first application includes all

arrangements in which the PCB'

Transformer can 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 or the

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 of network installations, grid

networks and spot networks.

Functionally, there are two types of

electrical protection devices. One type

interrupts the flow of current by

vaporizing a segment of the conductor if

the current exceeds a predet~rmined

level. Fuses and distribution cutouts

operate in this manner. The second type

of electrical protection device operates

by opening a switch. A circuit breaker

opens a switch in response to a

temperature rise in the device due to the

current flowing in the circuit. A ground

fault interrupter opens switch contacts

in response to an unbalanced current

flow. A network protector opens switch

contacts in response to a reversal of the

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 of pressure) exceeds a

predetermined level. Temperature

sensors and fluid level sensors operate

in a similar manner.

a. Radial PCB 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 or circuit

breaker, and, often, with fuses and/or

circuit breakers on the low voltage side

or the load side. The overcurrent

protection on the primary is set at a

predetermined level to clear high current

faults on the primary and is typically set

sensitive enough to clear downstream

high current faults in the secondary as

well. These fuses/ circuit breakers are

set to operate quickly enough to avoid

transformer failure in the event of high

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

occur in areas such as the secondary

winding and low voltage leads of radial

transformers and can progress 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 which is self-sustained than

radial transformers with lower

secondary voltages.

According to comments on the

Proposed Rule, many radial PCB

Transformers used in industrial

applications are equipped with

temperature and pressure relays and

circuit breakers on-site which can be

manually operated to actuate

transformer deenergization in the event

of a sustained fault. However, if on-site

control of a radial transformer is not

possible (through the use of a manually

operable circuit breaker), 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 of all transformers

served from that primary feeder. This

results in the loss of electric power to

many buildings served by this same

primary feeder.

b. Network PCB Transformers.

According to comments on the Proposed

Rule, network transformers are typically

equipped with the least sensitive

overcurrent protection of all utility

distribution transformers. While radial

transformers are typically equipped with

overcurrent protection on the 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 or energy-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 current faults in the

primary (allowing for deenergization),

deenergization may not occur quickly

enough to avoid switchgear and/or .

transformer rupture. Thus, switchgear

rupture and transformer failure can

occur in network transformers from high

current faults on the primary.

Unlike radial transformers. network.

transformers are equipped with network

protectors. which are circuit breakers

located on the secondary side of

network transformers. The network

protector is set to operate when it

senses a reverse power flow. Thus, it

operates to prevent power beIng fed

back into the transformer in the event

that the primary feeder breaker has

been activated. The network protector

operates in a coordinated fashion with

the substation breaker relays to isolate

a faulted network transformer. By

isolating the faulted network

transformer, service continues to be
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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 of higher

secondary voltage network transformers

(in the service's and in the network

protector). These fuses operate when

high current faults occur downstream

from these areas. However, the presence

of these 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

breaker or by 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 higher f?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

protector and (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 of a

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 of their desire

for continuity of service 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 of fault-related failures and

fires. Several comments on the Proposed

Rule discussed the role of high current

faults in PCB Transformer failures and

fires, the level of protection currently

provided against these faults in different

types of transformer installations, and

ways in which PCB Transformers could

be better protected to minimize the

chance of failure from these types of

faults. Network PCB Transformers are

currently the least well-protected

against high current faults of all

distribution class PCB Transformers in

use. According to comments submitted

in response to the Proposed Rule, the

Tulsa PCB Transformer fire was

associated with this type of fault in the

high voltage switchgear of a 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 of documented PCB

Transformer fires. These comments

discussed the level of protection

currently provided against these faults'

in PCB Transformer installations 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 of faults in 480/277 volt

network PCB Transformers.

Simply stated, sustained low current

arcing faults can occur in 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 of all

types of transformer installations, radial

transformers, lower secondary voltage

network transformers, and higher

secondary voltage network

transformers. They are, however, more

likely to occur in 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" or be sustained at

higher voltages than be selfextinguishing or self-clearing.

All types of PCB Transformers

typically lack the sensors (pressure and/

or temperature sensors) necessary for

the early detection of low 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 of commercial PCB,

Transformers (when disconnect '

equipment is not present on site)

typically requires the opening of the

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 of a 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. Potential for Exposure

Toxicity and exposure are the two

basic components of risk. In Unit IV.A,

EPA addressed the toxicity of PCBs,

PCDFs, and PCDDs. The following

summarizes EPA's evaluation of the

potential for human and environmental

exposures to PCBs, PCDFs, and PCDDs

from transformer fires.

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 of combustible or flammable

materials in a transformer location, can

all lead to the rupturing of a transformer,

the volatilization of PCBs, and the

formation of incomplete combustion

products. Sustained high temperatures

in the area of a ruptured transformer

increase the potential for the formation

of toxic products of incomplete

combustion, including PCDFs, 2,3,7,8-

TCDF;PCDDs, and 2,3,7,8-TCDD. These

high temperatures can either occur as a

result of the initial malfunction or as a

result of pr010nged arcing associated

with an inability to deenergize the

transformer completely. Smoke and soot

from a high temperature fire involving a

PCB Transformer can contain high

concentrations of volatilized 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 of 7,200 ppm

PCBs, 231 ppm 2,3,7,8-TCDF, and 2;9

ppm 2,3,7,8-TCDD. For a full description

of PCB, 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 of PCBs

and oxidation products measured in

soot samples following the Binghamton
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fire are values which are representative

of situations in which combustion

conditions are conducive to the

formation and/or release of PCBs 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 of human and

environmental exposures from

transformer fires in or near buildings by

analyzing likely exposures from a PCB

Transformer fire in or near an office

building. A number of comments

received in response to the Proposed

Rule suggested that EPA evaluate

separately the expected exposures from

transformer fires in or near industrial

facilities and the costs of control

measures for these transformers.

Comments suggested that the use of PCB

Transformers in industrial facilities pose

lower fire-related risks than the use of

PCB Transformers in commercial

buildings and that the costs of the

proposed transformer isolation

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 of PCB Transformer

fires: (1) A PCB Transformer fire in or

near a commercial building (both before

the implementation of risk reduction

measures and after the implementation

of risk 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 or near

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 of exposure to PCBs and oxidation

products in the event of a fire involving

a transformer containing PCBs. These

are: (1) Persons present in a building or

possibly in an adjacent building at the

time of a fire in or near a building: (2)

firemen and other emergency response

personnel responding to a fire: (3)

onlookers present during the

extinguishing of a fire and members of

the general public in the vicinity of the

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 occur principally through

the inhalation and dermal routes.

1. PCB Transformer fires in or near

commercial buildings-a. Nature of

installations and operation. PCB

Transformers serving commercial

buildings are typically located in

basements, in machinery rooms on the

first few floors of buildings, or in

sidewal~ or underground vaults

adjacent to buildings. Commercial PCB

Transformers may also be located on

roof-tops or near buildings in outside

locations such as parking areas or

loading docks. Electrical transformers

used in or near commercial buildings are

most typically located in areas which

are not easily accessible or visible to

building occupants. Based on the results

of the Equitable Life Assurance survey

of commercial transformer locations,

EPA estimates that 69 percent of

commercial transformers located on

lower floors of buildings are vaulted,

and that transformers located on interior

upper floors are gEmerallY located in

separate mechanical rooms. The

majority of transfoMJ: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 or monitored by trained

electrical engineers or technicians.

Maintenance and testing of these

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 if such equipment were provided.

Commentll on the Proposed Rule and

EPA's analysis of available information

indicates that there are approximately

77,568 PCB Transformers used in or near'

commercial buildings. Of these 77,568

PCB Transformers, EPA estimates that

approximately 29 percent are network

PCB Transformers and n percent are

radial PCB Transformers. Further, of the

estimated 7,600480 volt network PCB

Transformers in use (those transformers

with a particularly high probability of

fault-failure), EPA believes that over 97

percent of these transformers are used

in or nearcommercial buildings.

b. Frequency ofPCB Transformer

fires. In the Proposed Rule. EPA .

estimated that 0.003 to 0.004 percent of

nonsubstation PCB Transformers 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 of structure-related electrical

transformer fires, data from the NFIRS

on the frequency of structure-related

transformer fires with smoke spread

beyond the room of origin of the 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 of occurrence and other

indicating that EPA had significantly

overestimated the frequency of

occurrence). little additional

quantitative data were submitted to

support modifying EPA's estimate of the

frequency of occurrence of serious PCB

Transformer fires. Thus, EPA believes

that its estimate of 50 serious PCB

Transformer fires over the remaining

useful life of PCB Transformers is a

reasonable estimate of the future

frequency of serious PCB Transformer

fires.

Since many comments on the

Proposed Rule s'tiggested that EPA

evaluate separately the risks posed by

PCB Transformers in or near industrial

facilities, EPA has developed estimates

of the frequency of PCB Transformer

fires in industrial facilities and in

commercial buildings.

As discussed in Unit IV.C, EPA

believes that the probability of PCB

Transformer fault-related failure varies

depending upon the type of PCB

Tranoformel' installation (and includes

such considerations as the amount of

associated electrical equipment present,

the secondary voltage of the '

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 PCB
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Transformer fires. EPA has developed

estimates of the relative probabilities of

failure for different types of PCB

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 of these installation types in

commercial locations and industrial

locations to e<;t:mate the frequency of

serious PCB Transformer fires both in

commercial buildings and in industrial

facUitips.

EPA believes that 480 volt network

PCB Transformers would have a

particularly high probability of failure:

that lower secondary voltage network

PCB Transformers and 480 volt radial

PCB Transformers would have a lower

probability of failure (compared to 480

volt netwurk transformers): and that

lower secondary voltage radial PCB

Transformers would have the lowest

probability of fault-related failures.

EPA estimates that 44 of the 50

structure-related serious PCB

Transformer fires which will occur over

the remaining useful life of PCB

Transformers will occur in or near

commercial buildings. This estimate is

supported by electrical engineering

theory concerning the mechanisms of

PCB Transformer fault-related faUures

and the likelihood of failures in different

types of installations as well as by

available empirical data. The PCB

Transformer fires in Binghamton. San

Francisco, Chicago, Miami, and Tulsa all

occurred in or near commercial

buildings: specifically, in office

buildings.

Further, the San Francisco 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 involved 480 volt network

PCB Transfonners. A total of 6 out of 10

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. Exposure assessment. EPA has

evaluated likely exposures from a

serious PCB Transformer fire in or near

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 of the

transformer casing, the release of PCBs,

the volatilization of PCBs, and the

widespread distribution of PCBs and

oxidation products throughout the

interior of a 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 of visible traces of soot by

cleanup crews. EPA assumes that a PCB Transformer

fire in or near a commercial building

would involve the rupture of the

transformer and sustained high

temperatures in the transformer location

for up to 4 hours. EPA has assumed this

because trans~'ormers located in or near

commercial buildings are more likely to

be located in inaccessible, low visibility

areas, where malfunctions would not be

readily Identified. Fmther, EPA has

assumed that the transformer will not be

deenergized automatically and that the

transformer will not have 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 of the potential for

human exposures to PCBs and oxidation

products from a PCB Transformer fire in

a commercial building serves as the

baseline for subsequent assessments of

the expected effectiveness of fire hazard

risk reduction measures in these

locations. This assessment is also used

in assessing likely human exposures

from PCB Transformer fires in industrial

settings and in outdoor locations (away

from commercial and residential areas),

and for estimating likely human

exposures from PCB-Contaminated

transformer fires in or near commercial

buildings.

A PCB Transformer fire which occurs

in or near a commercial building during

a period of peak use may expose

hundreds to thousands of building

occupants to smoke and soot from the

fire during the evacuation of the

building. The potential for exposures of

large numbers of building occupants to

this smoke and soot is increased if the

transformer involved in a fire ill located

near building 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 of incomplete 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 of a PCB

Transformer fire. Dermal and inhalation

exposures of firefighters and other

emergency response personnel may

continue during the completion of

equipment maintenance procedures and

during the cleaning of personal clothing

and firefighting equipment after the fire.

EPA has developed quantitative

estimates of exposures by cleanup

crews, firefighters, building occupants,

and members of the general publ~{; to

PCBs, PCDFs, and PCDDs. EPA

developed these estimates primarily to

evaluate relative exposures among these

populations for different types of PCB

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 of PCBs, PCDFs, and

PCDDs present in soot, the amount of

soot generated. the distribution of soot

in the interior of a building, the duration

of exposure. the frequency of exposure,

and the expected routes of exposure. 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

of the exposure assessment.

EPA's quantitative estimates of

potential firefighter exposures (assuming

that respiratory protection is not worn

during a PCB Transformer fire of 4 hours

duration, as well as other assumptions

detailed in support document 1 in Unit

X.B.) in terms of estimated lifetime

average daily doses (LADD) is 8,006

picograms per kilogram per day (pg/kg/

day) PCBs, 98 pg/kg/day 2,3,7,8-TCDF,

56 pg/kg/day other TCDFs, 319 pg/kg/

day other FCDFs, 5.1 pg/kg/day 2,3,7,8-

TCDD, 0.98 pg/kg/day other TCDDs,

and 45 pg/kg/day other PCDDs.

Building occupants also may incur

additional exposures (above those

which may occur during building

evacuation), if these parties remain

nearby, as onlookers during the

extinguishing of the fire. Further, there is

an increased potential for these
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additional exposures when emergency

response personnel (the principal

authority figures at the scene of a fire)

are unaware of the nature of risks posed

by exposures to smoke and soot from

these fires.

The rupture of a PCB Transformer and

the release of potentially hundreds of

gallons of PCBs (and potentially PCDFs

and PCDDs) into floor drains in

transformer locations could result in the

contamination of waterways. Further, if

water is used to extinguish the fire, or if

water pipes rupture due to high

temperatures caused by the fire, water

runoff could ultimately result in

contalT'ination of surface waters and

drinking ""Hter. Members of the general'

public. in addition to fish and wildlife. in

the vicinity of a 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 of water

from the rupture of the transformer.

burst water pipes. the extinguishing of

ignited materials in the area (other than

electrical equipment) and from cleanup

efforts.

The presence of a 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

of firefighting operations, burst water

pipes, and cleanup operations. Very

large amounts of water can be used in

the cleanup process. For example,

during the first year of cleanup at the

Binghamton site, over 160,000 gallons of

water were used, treated by charcoal

filtration and secondary treatment, and

discharged to surface waters. The

nearest drinking water intake

downstream is 45 miles away and

serves 16.500 persons.

Atmospheric transport of PCBs and

oxidation products in an urban area

could also be responsible for exposing

many members of the general

population who live or w.ork in the

vicinity of a fire. In the Binghamton,

New York incident, 2,585 people lived

within 3 to 4 kilometers of the building.

While inhalation exposures by the

general public as a direct result of a PCB

Transformer fire would be unlikely to

occur for an extended period of time,

soot fallout from a PCB Transformer fire

may contaminate surface soil and

surface water, in addition to outdoor

furniture. automobiles. and other types

of materials which are commonly stored

. outside. Contamination of surface soil

and surface water may result in

exposures to fish and wildlife as well.

Thus. dermal. inhalation, and even oral

exposures to the general population in

the vicinity of a fire may occur on a

continuing basis long after the initial

incident.

Exposures at the site of a fire to soot

containing PCBs and oxidation products'

may also continue long after the

extinguishing of the fire. Cleanup crews,

dispatched to the scene by a building

owner who is unaware of the nature of

risks posed by a PCB Transformer fire.

may not be initially equipped with

respiratory protection or protective

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 of cleanup efforts. and would

be expected to be inhaled by workers. In

addition. because of the strenuous

nature of cleanup 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-hour fire. the lack of

protes;tive clothing, and the superficial.

cleanup of a building, as well as other

assumptions detailed in support

document 1 in Unit X.B.) is 13,784 pg/kg/

day PCBs. 34 pg/kg/day 2,3,7,8-TCDF,

19.9 pg/kg/day other TCDFs, 109 pg/kg/

day other PCDFs. 1.8 pg/kg/day 2.3.7,8-

TCDD , 0.33 pg/kg/day other TCDDs,

and 15.7 pg/kg/day other PCDDs.

Even if respiratory protection and

protective clothing are utilized by

cleanup crews, EPA expects that some

level of exposure to these materials may

occur both dermally and through

inhalation because of the expected

prolonged period of exposure. Cleanup

crews may work long hours for

extended periods of time. For example,

in the Binghamton incident, 40 to 70

workers were involved in cleanup

operations for 7 hours a day for over 250

days.

Finally, depending upon the level of

knowledge of the building owner,

emergency response personnel. the

utility, and local public health

authorities about the nature of risks

posed by PCB Transformer fires,

building occupants may be allowed to

return prematurely to a building

following the removal of only visible

traces of soot. Exposures may occur to

faces, hands, and lower arms for 8 hours

a day overthe course of 250 working

days in a year. EPA also expects that

inhalation exposures would occur as a

result of the circulation of airborne

contaminants by the building's

ventilation system. Further, these

exposures may continue for an

indefinite period of time because these

materials are expected to the quite

persistent, and resistant to degradation.

Residual concentrations may remain on

interior building surfaces for several

years. EPA's quantitative estimates of

potential building occupant exposures

(assuming that the fire burns for 4 hours,

that the building is occupied at the time

of the 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 Unit X.B.) is 39,593 pg/kg/

day PCBs, 65 pg/kg/day 2,3,7,8-TCDF, 65

pg/kg/day other TCDFs; 277 pg/kg/day

other PCDFs. 1.2 pg/kg/day 2,3,7,8-

TCDD, 0.76 p~/kg/ day other TCDDs,

and 35 pg/kg/day other PCDDs.

EPA has prepared additional

quantitative estimates of potential

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 Transformer fires in or near

commercial buildings with risk

reduction measures in place. In order to

evaluate the effectiveness of risk

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

of certain risk reduction measures.

In the Proposed Rule. EPA evaluated

the expected exposures associated with

a PCB Transformer fire in or near 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 water releases. the reporting of

the fire to the National Response Center.

the registration of the transformer with

the responding fire department and the

building owner. and the labeling of the

exterior of the transformer location. EPA

assumed that most PCB Transformers

could be daenergized within 15 minutes

of failure (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 of the

transformers.
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Thus, in evaluating the effectiveness

of transformer isolation, registration,

labeling, and reporting of PCB

Transformers fires. EPA assumed that

all but a subset of PCB Transformers

could be easily deenergized within 15

minutes of failure. For that subset, EPA

requirp<l increased electrical protection

on the secondary side of the

transformers.

Comments on the Propose!i Rule,

however, indicate that: (1) Many PCB

Transformers in commercial buildings

are not capable of being easily

deenergized after failures: (2) PCB

Transformers in commercial buildings

could be equipped with enhanced

electrical protection which would

reduce the probability of transformer

failures from electrical faults: and, (3)

while the proposed additional electrical

protective measures (for a subset of the

PCB Transformer population) would

have avoided some failures in this

equipment, failures in these

transformers from otber common

mechanisms of failure could still occur. Many comments on the Proposed Rule

suggested that EPA increase its

emphasis on the reduction of risk

through the prevention of PCB

Tra'nsformer fault-related failures and

decrease its emphasis on the use of

isolation measures to reduce structure

and environmental contamination.

These comments indicate that while

transformer isolation can reduce

exposures in the event of a PCB

Transformer fire (by reducing

widespread structure and environmental

contamination), if a transformer cannot

be easily deenergized after failure

occurs, then substantial quantities of

smoke and soot can be generated. The

longer a transformer remains energized,

the less likely it is that isolation will be

an effective risk reduction measure. EPA agrees that measures designed to

prevent PCB Transformer failures are

preferred over measures designed to

contain and control already released

and/or formed incomplete combustion

products. Further. EPA's evaluation of

mechanisms of transformer failure.

commercial installation characteristics

and operations, and the current levels of

electrical protection in commercial PCB

Transformer installations indicates that

many of these PCB Transformers could

be better protected electrically to reduce

the frequency of fault-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 of serious PCB

Transformer fires.

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 of increased 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 exterior of the

transformer location is marked with PCB

identification labels.

a. Frequency ofserious PCB

Transformer fires with risk reduction

measures in place. EPA has used data

from transformer and electrical

equipment reliability studies to evaluate

the probability of electrical protective

device malfunction; and thereby. to

estimate the effectiveness of electrical

protection in avoiding serious PCB

Transformer fires. For purposes of this

rule, EPA defines electrical protective

device malfunction as the failure of a

device to operate when called upon to

operate. It is difficult to develop a

precise estimate of the expected rate of

failure of specific combinations of

electrical protective devices such as

those which appear in this final rule.

However, based upon available

Information on the failure rate of circuit

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 of circuit breakers,

only 9 percent of circuit breaker failures

are failures to operate when' called upon

to open. The majority of circuit breaker

failures are characterized by the

operation of a circuit breaker when it

should not have operated or opened.

That is. circuit breaker failure typically

involves dcenergization without cause

rather than failure to deenergize when

called upon to open.

EPA has assumed that enhanced

electrical protective systems will

function to Hvoid between 97 and 99

percent of the serious PCB Transformer

fires (about 43 fires) which would be

expected to occur in commercial

buildings over the remaining useful life

of this equipment (this assumes that

electrical protection can be implemented

immediately). Electrical protection for

commercial transformers phased in over

a 5-year period is' expected to avoid

about 36 serious PCB Transformer fires.

EPA expects that one to two serious

PCB Transformer fires will occur over the remaining useful life of this

equipment as a result of the failure of

the enhanced electrical protective

systems to operate.

b. Exposure assessment. The potential

for the volatilization of large amounts of

PCBs, and the formation of products of

incomplete combustion from PCB

Transformer fires is reduced if efforts

are made to control combustion

conditions in the transformer location.

EPA believes that the removal of stored

combustibles from a PCB Transformer

location will reduce the likelihood of a

fire occurring external to a PCB

Transformer resulting in transformer

failure. More importantly, the

installation of enhanced electrical

protection on commercial PCB

Transformers is expected to reduce

substantially the frequency of PCB

Transformer fault-related failures in this

equipment.

Comparing the circumstances

surrounding well-documented PCB

Transformer fires indicates that the

sooner a faulted transformer is

deenergized, the less likely it is that

significant quantities of PCDFs and

PCDDs will be formed. Experience from

actual incidents indicates that EPA is

correct in Its belief that there are

practical means available for

successfully controlling combustion

conditions in PCB Transformer

locations. Certain measures. once

implemented, would reduce the

likelihood of fault-related failures and

sustained high temperatures. These

measures are expected to reduce

significantly the fire-related risks posed

by the continued use of these

transformers. \

Analyses of the levels of electrical

protection currently provided for many

commercial PCB Transformer locations

indicate that these PCB Transformers

could be better protected electrically to

reduce the frequency of transformer

failures from electrical faults. Comments

on the Proposed Rule suggest that many

of the well-documented PCB

Transformer fires could have been

avoided if transformer failure had been

avoided through the use of enhanced

electrical protection, such as currentlimiting devices, sensors, and disconnect

equipment.

Enhanced electrical protection. that is.

the installation of overcurrent protection

on transformers which lack such

protection, and sensors and disconnect

equipment to avoid sustained low

current faults will reduce the likelihood

of PCB Transformer fault-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 system
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in particular would also function to

avoid sustained high temperatures and

changes in internal pressure from other

causes as well. Finally, the final rule

requires the removal of stored

combustibles near PCB Transformers to

reduce the likelihood of'a PCB

Transformer fire occurring from an

external source of combustion.

If transformer failure and fire occurs

despite the presence of the required

electrical protection system and the

removal of stored combustibles, the

nature and magnitude exposures to

PCBs and oxidation products by

building occupants. firefighters, cleanup

crews, and members of the general

populat'on could be equivalent to that

described above, in Unit IV.C.l.c.

However. the presence of disconnect

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 of the 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 part of fire

departments and building owners about

the contents of a transformer and the

notification of EPA in the event of a fire

would be expected to reduce expQsures

to building occupants, in addition to

reducing exposures to firefighters and

other emergency response personnel.

EPAexpects that firefighters, aware of

the nature ofrisks posed by a

transformer fire. would be more likely to

wear respiratory protection and

protective clothing and would be more

protective of bystanders 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 involved building.

If PCB Transformer owners take

measures as soon as practically and

safely possible to contain any spilled

PCBs and or PCOFs!PCDDs (released as

a result of a fire-related incident} and

water potentially contaminated with

PCBs. PCDFs, and PCDOs, EPA expects

that potentfal releases to waterways

will be substantially reduced. The

blocking of floor draIns in a transformer

location as soon as practically and

.safely possible, and the containment of

all water associated with the incident

(including cleanup waterJ should reduce

the potential for the release of PCBs and

untreated water into surface waters.

Finally. by requiring the reporting of all

PCB Transformer fire-related incidents

to the National Response Center (NRC),

EPA will be able to monitor cleanup

efforts and the treatment and discharge

of water. to insure that safe levels are

not exceeded.

a.Industrial PCB Transformer firesa. Nature ofinstallations and

operations. PCB Transformers used in

industrial applications may be located .

indoors or outdoors, depending upon

varIables such as the service being

supplied by the unit, the size of the unit,

and the geographic location of the

facility. According to comments

submitted in response to the Proposed

Rule, many (but not all} 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 of their work. This IS in contrast

to the typical commercial PCB

Transformer installation, which is

generally Inaccessible and ress visIble toemployees.

Comments on the Proposed Rule

indicate that In many industrial

facilities. the performance of

transformers in monitored during

production shifts by engineers,

electricians, or other similarly trained

personnel. Further, comments indicate

that industrial transformer owners

reportedly utilize visuarinspections,

monitoring, and electrical testing of

. transformer function on a routine basis.

Electrical equipment failure and fire in

an industrial facility means loss of

production time. which.can have severe

economic Impacts. Thus, industrial

transformer owners have this incentive

to provide for transformer maintenance

and testing on a routine basis to avoid

fault-related failures and for providing

disconnect equipment on site to provide

for rapid deenergization in the event of a

fault-related failure.

EPA's analysis indicates that there are

approximately 26,700 PCBTransformers

used in or near industrial facilities. Of

these 26,700 PCB Transformers. EPA

estimates that 98 percenlare radial PCB

TransformerS', and, that 2 percent are

network PCB Transformers. Of the

estimated 7.600 480 volt network PCB

Transformers in use, EPA estimates that

only a percent (or 179 PCB

Transformers} are used in or near

industrial facilities.

b. Freq;uency ofPCB Transformer

fires. EPA estimates that 6 out of the

expected 50 serious PCB Transformer

fires which will oecm aver the

remainIng useful life of PCB

Transformers will occur in or near

industrial facilities. Four of these fires

are expected to occur after October 1,

1990. This estimate was derived by

considering available information on the

number and type of PCB Transformers

used in or near industrial facilities and

available information on the probability

of PCB Transformer fault-related failure

for each type of transformer installation.

EPA has. very little data on PCB

Transformer fires.: which have actually

occurred in industrial facilities. Limited

data were'submitted by the American

Paper Institute (API) regarding two PCB

Transformer fire-related incidents in

forest industry facilities. AccordIng to

the results of an API survey. during an

8.5 year period. between January 1976

and March 1984. there were two PCB

Transformer fires (which involved .

smoke spread into buildings} out of an

estimated 3,509 PCB Transformers used

by the surveyed companies. API

indicates: that none of these incidents

approached "Binghamton" proportions.

and could be classified as moderate

incidents: on the spectrum of PCB

Transformers fires.

c. Exposure assessment. EPA has little

data on the circumstances surrounding

actual PCB Transformer fires in

industrial facilities-. However, EPA has

used environmentally conservative yet

reasonable assumptions in evaluating

likely human and environmental

exposures from a PCBTransformer fire

in a typical industrial facility. EPA

recognizes: that PCB Transformer fires

may occur in atypical industrial

facilities. where the exposures may be

somewhat greater- than those described

here. However; based On comments on

the Proposed Rule. EPA believes. that

there are fundamental differences

between the potential for human

exposures to PCBs, PCDFs and PCOOs

from the: use of PCB Transformers in

industrial facilities versus their use in

commercial buildings.

EPA assumes that a PCB Transformer

fire in an industrial facility would

involve an indoor PCB Transformer.

sustained high temperatures in the

transformer location,. the rupture of the

transformer~the release of PCBs. the

volatilization ofPCBs. and the

distribution of PCBs and oxidation

products into the interior of an industrial

facility, into the ambient all~ and into

waterways. EPA assumes that smoke

and soot containing PCBs. and oxidation

products are spread throughout the

interior of an industrial facmty dwring.

peak use hoUts, worker evacuation'

occurs during the early stages: of the fue.

an on-site fille brigade makes file initial
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response, and, that reoccupancy of the

facility by workers occurs after the

removal pf visible traces of soot.

EPA assumes that a PCB Transformer

fire in an industrial facility wi1l involve

the rupture of the transformer and

sustained high temperatures in the

transformer location for up to 0.5 hour

(in contrast to a 4-hour burn 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 or near industrial

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 or visible to employees.

Further. EPA has assumed that once a

malfunction has been identified, the

transformer can be 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 monitor electrical

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 of peak

use may expose hundreds of workers to

smoke and soot from the fire during the

evacuation of the facility. However. EPA

expects that worker evacuation 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 of fire in an

industrial location, and about proper

evacuation procedures. EPA has

assumed that exposures by workers to

residual levels of PCBs and oxidation

products would, however. continue

following reoccupancy. EPA's estimate

'of potential exposures to industrial

workers (assuming a 0.5 hour burn time

and cleanup to visible traces of soot, 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 other TCDFs, 22

pg/kg/day other PCDFs, 0.36 pg/kg/day

2,3,7,8-TCDD, 0.06 pg/kg/day other

TCDDs. and 3.1 pg/kg/day other PCDDs.

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 of the

transformer, the capability to deenergize

the equipment on site, and the level of

site-specific training of industrial fire

brigades.

EPA assumes that a 10-man fire

brigade would respond to a PCB

Transformer fire 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 of potential 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 other TCDFs, 0.37 pg/kg/day other

PCDFs, 0.006 pg/kg/day 2,3,7,8-TCDD,

0.001 pg/kg/day other TCDDs, and 0.05

pg/kg/day other PCDDs. Additional

exposures following the fire may.

however. occur during the cleanup of

turnout gear and firefighting equipment.

EPA expects that industrial fire brigade

personnel would take appropriate

precautions to limit further exposures.

If water is used to extinguish the fire,

or if water pipes rupture due to high

temperatures, water runoff could

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 of PCBs and oxidation products

to waterways.

Atmospheric transport of PCBs and

oxidation products in a metropolitan

area could also be responsible for

exposing many people who live or work

in the vicinity of an 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 shorter burn time for the fire would

decrease the total amount of PCBs

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 of valuable machinery

and equipment would be very timeconsuming. The cleanup of the structure

itself may 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 of smoke 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 of PCBs volatilized and

the amount of incomplete 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 Transformer fire 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 Transformer fire could progress

in much the same manner as a PCB

Transformer fire in a commercial

building. Deenergization of the

transformer, even when on-site

disconnect equipment is available,

would take longer in 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 of the

general population in the vicinity of the

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 of the building, from

contact with residual materials on

building surfaces and in the air.

4. Outdoorfires involving PCB ,

Transformers-a. Nature of
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installations and operations. PCB

Transformers which are used in outdoor

applications may-be located on the tops

of utility poles, pad-mounted in urban.

metropolitan. and rural areas. or in

electric utility substations. The

operatilm of these transformers i8 not

typically monitored by on-site

personnel. Electric utility substation

PCB Transformers are typically fenced

off to 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 that there are about

17.000 PCB Transformers used in

outdoor applications. EPA expects that

the majority of these transformers are in

radial installations.

b. Frequency ofPCB Transformer

fires. Based on estimates of the

frequency of "serious" PCB Transformer

fires in radial transformer installations,

and the estimated number of PCB

Transformers located in outdoor

electrical substations. EPA estimates

that outdoor PCB Transformer fires with

smoke generation will occur at a

frequency of about 0.0014 percent per

year, or. about 3 incidents over the

remaining useful life of this equipment c. Exposure assessment. Fires

involving PCB Transformers located in

outdoor locations, away from

commercial buildings, are expected to

result in lower human exposures to

PCBs and oxidation products in fire

situations than transformer fires in or

near buildings. First. because

combustion conditions in an outdoor

PCB Transformer fire are not expected

to be as conducive to the volatilization

of spilled PCBs and the formation of

large quantities of PCDFs, 2,3.7.S-TCDF.

PCDDs. or 2,3,7.8-TCDD as would be the

case with transformers located in

machinery rooms or vaults. Generally,

combustible materials are not present

near outdoor PCB Transformers and

some of the heat generated 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 the number of people

at immediate risk of exposure in the

event of a fire. In contrast to the smoke

and soot produced from transformer

fires in or near buildings. any smoke or soot produced in an outdoor transformer

fire. away from commercial buildings. is

expected to be more widely dispersed in

the environment. EPA has developed a model for the release of PCBs and the

formation of PCDFs and/or PCDDs from an outdoor PCB Transformer fire. EPA

has estimated the expected exposures

from releases to air from an outdoor fire

and has found that exposures decrease

with increasing distance. and that at a distance of 200 meters from a fire,

inhalation exposures from a typical fire

would be expected to be relatively low.

While there is a potential that

emergency response personnel 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. Firefighting equipment and

protective clothing may become

contaminated with PCBs. and may result

in exposures to firefighters during

equipment cleanup and maintenance.

Fires involving outdoor PCB

Transformers near commercial buildings

(i.e.. within 30 meters of commercial

buildings) could result in more people

being exposed to higher levels of PCBs

and any oxidation products produced.

For this reason, EPA has included

outdoor PCB Transformers located

within 30 meters of commercial

buildings within the definition of PCB

Transformers-located in or near commercial buildings. .

5. Fires involving transformers

containing less than 500 ppm PCBs-a.

Nature ofinstallations and operations.

EPA estimates that there are over 20

million mineral oil transformers in the

electric utility industry and about 5

million in all other applications. These

mineral oil transformers may contain

low levels of PCBs (less than SOD ppm

PCBs) as a result of contamination from

past servicing activities. EPA estimates

that approximately 1S million of these

mineral oil transformers are used in

nonsubstation applications, in or near

commercial buildings. industrial

facilities and outdoors on utility poles.

These transformers are installed in both

radial and network configurations.

b. Exposure assessment. PCB

Transformers typically contain 65

percent PCBs. or about 1.300 times the

maximum amount of PCBs present in

PCB Contaminated transformers (and

13.000 times the amount of PCBs 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

involving PCB-Contaminated equipment

by assuming that the transformer

present in the Binghamton State Office

Building was a PCB-Contaminated

transformer. and, by assuming

reasonable worst-case values for other

parameters. Based on the results of

EPA's study ofthe incomplete

combustion of PCB-Contaminated

transformer fluids, EPA has assumed

that the formafion of PCDFs and PCDDs

in a PCB-Contaminated transformer

would be Ifnearly related to the amount

of PCBs present in 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 to be reduced by a factor of

1.300. compared to levels actually

measured in Binghamton. Similarly•.

human exposures to these materials are

assumed to be reduced by the same

factor.

6. Conclusions-Risks posed by fires

involving transformers !hat contajn

PCBs. Toxicity c:nd exposure are the

two basic components of risk. In earlier

units of this preamble, EPA evaluated

the toxicity of PCBs, PCDFs, 2,3,7,8- .

TCDF. PCDDs. and 2.3.7.8-TCDD and

presented assessments of the potential

for human exposure to these materials

from transformer fires. EPA concluded

that both 2,3,7,8-TCDD and PCBs are

probable human 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 exists in 2.3.7.S-TCDF and

perhaps in other PCDD and PCDF

congeners as well

EPA has determined that relatively

large quantities of these compounds can

be formed and released during a PCB

Transformer fire~particularly a fire

which occurs in 01" near a commercial

building. Sustained high temperatures in

these transformer locations are more

likely than in industrial or outdoor

locations because of the 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 visibility areas, and because

these locations typically lack on-site

electrical technicians and necessary

disconnect equipment to insure

complete deerrergization in the event of

a sustained fault or failure.

Finally, there are many routes through

which commercial building occupants,

emergency response personnel, cleanup

·crews. onlookers. and the general public

can be exposed to these materials. once

generated. Building evacuation times for

large commercial buildings can'be

relatively long. reoccupancy may occur before adequate cleanup has been

completed. emergency response

personnel may lack necessary protective

equipment. cleanup crews may be

dispatched without proper protection.
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onlookers may be un'aware of the risks

posed. and members of the general

population in the vicinity of the fire may

incur inhalation exposures and dermal

exposures during the fire. and for

extended periods after the fire from

contamination of waterways. drinking

water supplies and outdoor materials

with PCBs. PCDFs. and PCDDs.

EPA has concluded that fires

involving PCB Transformers in or near

commercial buildings can pose

significant risks of human and

environmental exposures to PCBs and

oxidation products. EPA believes that 44

of the estimated 50 structure-related

serious' incidents over the remaining

useful life of PCBs Transformers will

occur in or near these buildings. Further,

based on its analysis of the relative

probabilities of PCB Transformer

failures and fires. EPA has concluded

that many of these fires will involve 480

volt network PCB Transformers.

Given that a single serious PCB

Transformer fire in or near a commercial

building can potentially expose

thousands of people to PCBs and

oxidation products in soot in air. water.

or on surfaces. EPA has concluded that

PCB Transformer fires in or near

commercial buildings can pose

significant risks to human health and the

environment. However. EPA also

believes that reducing the potential for

the release of PCBs and the potential for

the formation and release of PCB

oxidation products from PCB

Transformers substantially reduce the

fire-related risks posed by the continued

use of this 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 of the nature of

these installations. Many of these

transformers are radial transformers

(which are typically better protected

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 of the location of

these transformers in higher visibility

areas. and because industrial facilities

reportedly have on-site electrical

engineers and technicians and

necessary disconnect equipment to

provide for complete deenergization.

Finally. the suggested higher frequency

of maintenance. inspection, and testing

of industrial transformers and utility

substation' transformers would further

decrease the likelihood of fire-related

failures in this equipment.

EPA estimates that up to 6 out of the

expected 50 serious PCB Transformer

fires over the remaining useful life of

PCB Transformers will occur in or near

industrial facilities, and that less than 3

PCB Transformer fires with smoke

distribution will occur in outdoor PCB

Transformer locations.

While exposures to workers.

emergency response personnel, cleanup

crews and the general population may

occur from an industrial PCB

Transformer fire, the magnitude of

exposure associated with a PCB

Transformer fire in a typical industrial

facility would be anticipated to be '

greatly reduced (when compared to a

commercial PCB Transformer fire) as a

result of several factors. First, EPA

expects that the duration of industrial

PCB Transformer fire-related incidents

would be significantly less than the

duration of commercial PCB

Transformer fires. because of the

presence of trained personnel and

disconnect equipment on site. The

reduced duration would reduce

exposures to all populations potentially

at risk of exposures. Second, there are

generally fewer workers present in

industrial facilities than in commercial

buildings. and worker evacuation times

would be expected to be less for

industrial facilities than for commercial

buildings. This is because of the singlestory nature of many industrial facilities,

and the expected increased level of

education of industrial 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 volunteer or salaried municipal

firefighters. Emergency response

personnel as a group, then, would be

expected to incur lower exposures in

responding to industrial PCB

Transformer fires than would be the

case for commercial PCB Transformer

fires.

A comparison of estimated exposures

from a commercial PCB Transformer fire

to an industrial PCB Transformer fire

indicates that exposures by building

occupants to PCRs. 2.3.7,8-TCDF, other

TCDFs. other PCDFs. 2.3.7.8-TCDD.

other TCDDs, and other PCDDs could be

as much as an order of magnitude 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 of the frequency of industrial

PCB Transformer fires is 6 fires over the

remaining useful life of industrial PCB

Transformers. Even if EPA were to

assume that all 6 of these fires resulted

in individual exposures of the same

,order of magnitude suggested for

commercial PCB Transformer fires. there

are fewer people at risk of these

exposures'in industrial locations when

compared to commercial buildings.

One could consider the overall firerelated risk posed by the continued use

of PCB Transformers and compare the

different frequencies of occurrence 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 Transformer fires are

equivalent). This analysis indicates that

88 percent of the fire-related risk posed

by the continued use of PCB

Transformers (in locations in or near

buildings) are associated with their use

in or near commercial buildings and 12

percent of the total risks are associated

with their use in industrial locations.

EPA has further determined that

outdoor PCB Transformer fires, (away

from commercial buildings) and fires

involving PCB-Contaminated

transformers pose lower risks than PCB

Transformer fires in or near commercial

buildings. While EPA expects that

outdoor PCB Transformer fires may

result in the release of PCBs, EPA

expects that outdoor PCB Transformer

fires would be less likely to result in the

volatilization of large amounts of PCBs

and less likely to lead to the formation

and release of large amounts of PCDFs

and PCDDs. Further, PCBs and

oxidation products released from

outdoor PCB Transformer fires would be

expected to be more widely dispersed in

the environment. Although PCBs may be

released and oxidation products may be

formed during the PCB-Contaminated

transformer fires, the amounts of these

materials formed and released are

expected to be significantly reduced

compared to the amounts formed and

released from PCB Transformers.

IV. Benefits of PCB-Transformers and

the Availability ofSubstitutes

As part,of the unreasonable risk

determination. EPA must consider both

the benefits of PCBs and the availability

of substitute materials. The

unreasonable risk determination

requires EPA to balance the risks posed

by the use of PCBs against the

availability of adequate substitute

materials and the costs associated with

regulatory control measures.
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A. Benefits ofPCBs

PCBs were originally used as

dielectric fluid in electrical transformers

primal'ily because of their 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 superior electrical properties to

PCBs. but their fire resistance properties

are not liS good as PCBs.

Monsanto Company has had in

progress for over a year a study

assessing and comparing fire risks of

PCBs and of mineral oil. The Monsantosponsored study indicates that the

average frequency of a fire spreading

beyond the transformer room 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 of transformers. fluidfilled and dry. There are six general

types _of fluid-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 of chlorinated benzenes.

Similarly. an EPA-sponsored study

indicates that PCDFs can be formed

from the incomplete combustion of

tetrachloroethylene (perchloroethylene).

The replacement of PCB dielectric

fluid with substitute fluids which in fire

situations may also lead to the

formation of PCDFs and PCDDs should

be carefully considered in light of the

Agency's decision in this rule to place

additional conditions and restrictions on

the use of PCB Transformers. EPA's

evaluation of the risks posed by the

incomplete combustion of PCB dielectric

fluid and the frequency of occurrence of

PCB Transformer fires indicate that the

fire-related risks posed by the use of a

dielectric fluid which can be

tran::;formed into PCDFs and/or PCDDs

can be significant. EPA will study this

issueJurther and evaluate the need for

additional EPA action.

C. Retrofi/ling PCB 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 of retrofill

versus the value of the 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 of toxic

products of incomplete combustion from

the retrofill fluid' and remaining residual

concentration of PCBs. Other fluids.

such <!s chlorinated hydrocarbons.

fluorocarbon. and mineral oil. are used

in new transformers but arEi

inappropriate fur retrofilling because the

design of the PCB Transformers does not

fit the properties of the fluids.

Experience with retrofilling to date

Indicates that reclassification of askarel

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 'of askarel

PCB Transformer units. Testimony at the

public hearing. however. indicates that

retrofill technology continues to evolve.

and. that cost-effective reclassification

of askarel 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 of the

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. if the

transformer were fully loaded. a

derating not exceeding 5 percent could

be necessary. (Derating means lowering

the maximum level of electrical 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 of expansion of

silicone fluids is 50 percent greater than

that of PCBs. In actual practice.

however. the silicone gaskets are.

replaced during retrofilling. (Further.

even though the coefficient of expansion

is grp-atel' than that for PCBs. the greater

solubility of the 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 of the 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 of these 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 of Regulatory

Options

A. Introduction

This unit presents a'n analysis of the

effectiveness and economic impact of .

various regulatory options for reducing

the fire-related risks posed by the

continued use of PCB Transformers. For

a full analysis.of the 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

of five major regulatory control options

for four categories of PCB Transformers:

(1) PCB Transformers in or near

commercial buildings. (2) PCB

Transformers in or near industrial

locations. (3) PCB Transformers in

outdoor electrical substations. and (4)

PCB Contaminated Transformers. The

regulatory control measures considered

are: (1) Placing no additional conditions

or restrictions on the use of PCB

Transformers; (2) requiring the

registration and additional labeling of

PCB Transformers. the removal of stored

combustibles. the containment of,

potential waterreleases and,the
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TABLE 1.-COSTS AND BENEFITS OF CONTROL

MEASURES FOR COMMERCIAL PCB TRANS·

FORMERS

No action ...•...........•..... N/A 44 0 1$399

labeling and

registration ............... $7.3 44 ·0 7.3

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 of transformer isolation

requirements would be, in general, more

complex than providing enhanced

electrical protection in a transformer

installation. This is because the

isolation of transformers 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 either phaseout/retrofill

or increased electrical protection.

The registration of PCB Transformers

with building owners and fire

departments, the labeling of the exterior

of PCB Transformer locations, the

containment of potential water releases.

and the reporting of PCB Transformer

fires to the NRC are measures which are

expected to reduce exposures in the

event of a serious PCB Transformer fire.

However, these measures will not be

effective in avoiding any of projected 50'

serious building fires, or the estimated 3

outdoor PCB Transformer fires from

occurring. The effectiveness of these risk

reduction measures depends. to a large

extent, on the implementation of

voluntary measures based on

knowledge about the contents of a

transformer involved in a fire-related

incident. These measures are the least

costly control measures that EPA

considered.

C. Regulatory Options and Economic

Impacts

1. PCB Transformers in or near

commercial buildings-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) of the major regulatory control

measures considered for commercial

PCB Transformers. For a full discussion

of the assumptions made for this

analysis, see support document 7 in Unit

X.B.

reporting of PCB Transformer fires to the

National Response Center; (3) requiring

the isolation of PCB Transformers to

reduce widespread structure and

environmental contamination with PCBs

and products of incomplete combustion;

(4) requiring,the installation of increased

electrical protection on PCB

Transformers to avoid PCB Transformer

failures; and. (5) requiring the removal

or retrofill of PCB Transformers. The

analysis includes a consideration of the

expected savings in cleanup costs as a

result of implementing these measures. Given the well-established toxicity of

PCBs, and the presence of materials that

are much more toxic than PCBs in the

soot from a fire involving a PCB

Transformer, owners of PCB

Transformers involved in PCB

Transformer fires have invested more

than $20 million dollars each to ensure

the safety of persons returning to occupy

these buildings. These costs, for

sampling. cleanup and removal of

contaminated materials containing

PCBs, PCDFs, and PCDDs can be

factored into the economic analysis of

the benefits of the continued use of PCB

Transformers. Earlier analyses of the

benefits of the continued use of these

transformers, completed in support of

the August 1982 PCB Electrical Use Rule,

did not take into consideration the costs

of cleanup in the event of PCB

Transformer fires.

B. Summary ofBenefits and Costs

The removal or retrofill of PCB

Transformers is both the most effective,

and. the most costly measure for

reducing the frequency of serious PCB

Transformer fires. This measure, once

implemented, gives the greatest

assurance that PCB Transformer fires

~iI1 be avoided. regardless of initiating

cause. However, it is also the measure

which. as a practical matter, would

require the longest time for

implementation. Concerns such as the

availability of PCB disposal capacity,

transformer manufacturing capacity.

and avoiding the disruption of electrical

service make phaseout and/or retrofill

more difficult to implement quickly than

other risk reduction measures. Based

upon EPA's analysis of the frequency of

PCB Transformer fires, it is likely that

serious PCB Transformer fires will occur

in the interim, between the date of

promulgation of any phaseout

requirement and the actual date of the

removal of PCB Transformers from use.

Providing enhanced electrical

protection is anticipated to be very

effective in avoiding serious PCB

Transformer fires, through the

prevention of PCB Transformer faultrelated failures. Studies of the causes of

PCB Transformer failures and fires and

the level of protection currently

provided indicate that many PCB

Transformers could be better protected

1'0 avoid fires caused by more common

mechanisms of failure, electrical faults.

The effectiveness of increased electrical

protection is expected to approach that

of phaseout/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 of failure. Requiring a

certain level of redundancy in the type

of sensors used and the placement of

sensors provide increased assurance of

a higher level of effectiveness. Further,

as a practical matter, this control

measure could be implemented more

quickly than phaseout/retrofill, because

availability of PCB 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 other risk

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 transformer is

mistakenly deenergized when a

sustained fault condition does not in

fact exist. While EPA acknowledges the

potential economic impact of false

outages, EPA has not attempted to

quantify this impact.

The isolation of PCB Transformers is

expected to be effective in avoiding

serious PCB Transformer fires by

avoiding widespread structure and

environmental contamination. The

effectiveness of isolation in actually

avoiding more serious PCB Transformer

fires depends, however, to a great

degree on the capability of a failed

transformer to be deenergized within 15

minutes of failure. 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 of PCBs and

incomplete combustion products in

circumstances where a transformer has

the capability to be deenergize'd within

15 minutes of failure.

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

of PCB disposal capacity and

Option

Real

cost

(m,l·

lions)

Ex·

pected

lIres

Avoid·

ed

fires

Net

cost

(mil.

lions)
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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 additional action. The first

regulatory option that EPA considered

for PCB 'Tnnsformers located in or near

commercial buildings was to take no

further regulatory action at this time to

restrict the use of these transformers.

This would allow the continued use of

PCBs in or near buildings such as office

buildings, shopping centers, apartment

buildings, and hospitals without

additional restrictions above the

requirements of the August 1982 PCB

Electrical Use Rule. That rule authorized

the continued use of transfonners

containing PCBs (that pose no exposure

risk to human food or animal feed) for

the remainder of their useful lives

subject to certain recordkeeping and

inspection requirements. based on the

concentration of PCBs in the equipment.

There are no costs to transformer

owners associated with EPA's allowing

the continued use of these transformers,

other than the potential future costs

associated with cleanup and liability

suits following fires involving this

equipment. If the use of PCB

Transformers in or near commercial

buildings were authorized indefinitely,

without additional restrictions. EPA

expects that 44 additional incidents will

occur over the remaining useful life of

this equipment.

For purposes of this analysis. these 44

incidents would be expected to require

cleanup efforts whose cost would

approach $20 million each (1985 dollars)

or an estimated $399 million over the

remaining useful life of this equipment.

c. Labeling and registration programs.

The registration of PCB Transformers

located in or near commercial buildings

with fire departments and building

owners. in combination with the

labeling of the exterior of transformer

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

of taking no additional action), the cost

of this option is relatively low. EPA

believes that in addition to registration

with fire departments, the labeling of the

exterior of transformer locations is

necessary to insure that emergency

response personnel arriving at the scene

of a fire know that the fire involves a

transformer that contains PCBs. EPA

expects that the costs of labeling the

exterior of PCB Transformer locations

will be about $76.00 per location. EPA

estimates that the total cost of labeling

the exterior of commercial PCB

Transformer installations will be about

$3.5 million.

The costs of registering comm"ercial

PCB Transformers are also expected to

be minimal. since the location of all PCB

Transformers should already be known

by the owners of this equipment. 'The

costs to transformer owners of

forwarding this information to all

building owners and to fire departments

with primary jurisdiction is expected to

be minimal. on the order of $50.00 per

transformer. EPA estimates that total

costs of this registration program for

commercial PCB Transformers would be

approximately $3.8 million. The total

real costs of registration and labeling of

commercial PCB Transformers would be

on the order of $7 million.

While transformer registration and

labeling programs would be expected to

reduce human and environmental

exposures to PCBs. and oxidation

products, they will not reduce the

frequency of serious PCB Transformer

fires. .

d. Smoke control technologies.

Certain design techniques or changes in

commercial PCB Transformer locations

may be effective in reducing the

likelihood of widespread structure and

environmental contamination from a

failed PCB Transformer. The

effectiveness of transformer isolation as

a control measure depends to a large

extent, however. on the type of PCB

Transformer installation and the ease of

actuating deenergization.

Unlike the ventilation systems for

other oil-filled transformers, the

ventilation systems for PCB

Transformers were not designed for the

purpose of fire isolation but rather were

designed only to keep the ambient

temperature at or below 30· Centigrade

(C). However. the removal or alteration

of existing ventilation systems could

result in higher operating temperatures

whieh shorten transformer operating

lives and may increase the likelihood of

equipment failure.

Thus, the design of alternative

ventilation or cooling systems may be

necessary to reduce the potential for

building contamimltion. Ventilation

alternatives include air conditioners.

redirected venting, and heat exchangers.

or simply limiting the contamination

potential of the existing system by

reducing the ventilation cooling

effectiveness.

The objective of isolation 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

modification of the 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 of building ventilation

systems. building ductwork. and

openings in construction in transformer

locations have been responsible for the

dispersion of toxic contaminants into

buildings.

While transformer isolation can

reduce exposures in the event of a

failure and fire involving a PCB

Transformer (by reducing the spread of

contaminants), if a transformer cannot

be easily deenergized within 15 minutes

after a sustained fault occurs, then

substantial quantities of smoke and soot

can be generated. Tne longer a

transformer remains 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 of isolation 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 of all cases where isolation is

the desired alternative. the cosAs are

about $8.000 per transformer location.

For purposes of the cost-effectiveness

analysis, an average cost of $8,000 per

location is assumed for all locations

where some form of suitable 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 of written PCB Smoke

Spread Reduction Plans (PCB-SSRPs).

The development of PCB-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 Transformer owners (above the

burden created by requiring transformer

isolation procedures).
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29190 Federal Register I Vol. 50, No. 137 I Wednesday, July 17, 1985 I Rules and Regulations

The total real costs of isolation

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 of commercial transformers

which can be rapidly deenergized (i.e.,

which currently have the capability to

be deenergized within 15 minutes of a

sustained fault); these transformers

would be the group most likely to derive

benefits from isolation in the event of

PCB Transformer failure. Available data

suggest that most commercial PCB

Transformers are not capable of being

rapidly deenergized in the event of a

sustained fault. This severely reduces

the effectiveness of PCB Transformer

isolation alone. witliout increased

electrical protection. as a mechanism for

avoiding serious PCB Transformer fires

in or near commercial buildings.

e. increased electrical protection.

Avoidance of serious PCB Transformer

fires in commercial buildings through

increased electrical protection involves

the installation of appropriate sensors

and disconnect equipment to detect

common causes of transformer failures

and to allow for deenergization. The

disconnect equipment would either be

automatically activated in response to

sensed abnormal conditions (with a

provision for manual deenergization). or,

manually opened following the receipt

of an audio or visual 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 of faultrelated transformer failures: Low current

fault protection in the form of hest and

pressure sensors and associated

disconnect equipment would also

provide deenergization following high

temperatures and changes in pressure

from other causes. such as mechanical

failures or external fires.

As discussed in Unit IV.C. transformer

failures can occur as a result of

excessive current flow of a transformer.

Of the 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

of the 77.568 PCB Transformers in or

near commercial 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 of a primary circuit breaker or

equivalent technology) on site to allow

for rapid dr.energization. and. EPA

expects that many of the 55,000

commercial radial PCB Transformers do

not utilize primary circuit breakers for

high current fault protection.

The installation of certain sufety

equipment to detect sustained high

current and low current faults on PCB

Transformers which currently lack such

protection would reduce the probability

of failures. 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 Transformer fires.

The highest reduction in the

probability of PCB Transformer faultrelated failure is attained when

protection is provided against both basic

mechanisms of transformer fault-related

failures. Installation of overcurrent

protection without protection against

low current faults will avoid only those

PCB Transformer fires which occur as a

result of overcurrent 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 of transformers); 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 of a

transformer is higher, any faults which

occur in the secondary are more likely

to be sustained rather than self-clearing

or self-extingui&hing. Sustained faults

cause PCB Transformer failures and

fires. Thus. higher secondary voltage

network PCB Transformers would have

the highest probability of failure from

faults. Using the same logic. low

secondary voltage radial PCB

Transformers would have the lowest

probability of failure from faults.

According to comments on the

Proposed Rule. historically. utilities

have installed high current fault

protection on the primaries and

secondaries of radial transformer

installations. Network installations,

however, have been less well protected

against high current faults.

The cost of installing increased

protection on commercial PCB

Transformers depends both on the form

of protection seleoted. and. whether the

device involves a retrofit of the

transformer. High current fault

protection is much less costly than low

current fault protection. Low current

fault protection involves the installation

of disconnect equipment as well as the

installation of appropriate sensors. High

current fault protection involves the

installation of current-limiting or energy

limiting fuses.

Since comments on the Proposed Rule

and EPA's analysis indicate that the

probability of a transformedailure from

electrical faults is influenced by the type

of transformer installation, not all oCthe

above protection would be warranted

on a cost/benefit basis for all types of

commercial PCB Transformer

installations.

Under the option of increased

electrical protection. EPA would require

that all commercial PCB Transformers

be equipped with overcurrent protection

to avoid transformer failures as a result

of high current faults. Current-limiting

fuses are relatively inexpensive. and

would avoid failures from high current

faults in the primary and secondary

areas of transformers. 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 of these 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 network PCB

Transformers may have a particularly

high probability of sustained low current

faults (because of the high secondary

voltage and the presence of more

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 of these higher

secondary voltage commercial PCB

Transformers, protection against failures

from low current faults would mean the

installation of a primary circuit breaker

on site as well as the installation of nonelectrical sensors. such as pressure

sensors and temperature sensors in the

transformer. For high secondary voltage
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network PCB Transformers, fault

sensors would also be needed in the

network protector 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 protector and network

bus of high secondary voltage network

PCB Transformers provides a level of

redundancy in the protection system:

this increases the reliability of electrical

protection, and provides increased

assurance that increased electrical

protection would actually avoid PCB

Transformer failures and fires.

The cost of protection against low

current faults is principally the cost

associated with the installation of

disconnect equipment such as circuit

breakers on site. The cost of the

indicated sensors is a fraction of the

cost of the installation of a primary

circuit breaker.

The total real costs associated with

requiring the installation of high current

fault protection on all commercial PCB

Transformers and low current fault

protection on higher secondary voltage

commercial PCB Transformers over a 5-

year period is estimated at $590 million.

EPA expects that the installation of .

these electrical protection systems will

avoid about 97 percent of serious PCB

Transformer fires in commercial

buildings which would have otherwise

occurred, or, 35 serious PCB

Transformer fires over the remaining

useful life of this equipment. The net

cost of this 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 October I, 1988. Based on

comments submitted in response to the

Proposed Rule concerning the type of

electrical protection needed, the higher

costs of this protection (compared to the

proposed electrical protection

requirement and the proposed isolation

requirement), and the larger number of

PCB Transformers which require

additional electrical protection, EPA

believes that it is reasonable to allow a

longer phasein period for this control

measure than was proposed. Further.

EPA recognizes that Il\any PCB

Transformer owners may choose PCB

Transformer removal in lieu of

enhanced electrical protection, and that

this will place additional burdens on .

PCB disposal capacity. Requiring the

installation of enhanced electrical

protection on a schedule which

recognizes both the fact that many PCB

Transformer owners have chosen or will

choose removal rather than electrical

protection and that there are constraints

on PCB disposal capacity will encourC!ge

PCB Transformer owners who have

voluntary 5-year phaseout programs in'

place to continue and may stimulate

other owners to initiate such programs.

Thus, EPA has allowed 5 years for the

implementation of the 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 oxidation products in the event of

a fire. This' would be accomplished

through a substantial reduction in the

amount of PCBs present in the

transformers. EPA has completed an

analysis 'of the costs of retrofilling •

commercial PCB Transformers to reduce

PCB concentrations to below 500 ppm.

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 of disposal of PCB fluid. but do not

include any consideration of a loss of

efficiency or derating as a result of the

retrofill.

An estimate of the total resource costs

of retrofilling all commercial PCB

Transformers (77,568 at end of 1984) to

below 500 ppm is about $1.2 billion.

Although the retrofilling of PCB

Transformers reduces the risks to

humans posed by the transformer in the

event of a fire (by reducing the amount

of PCBs present. the amount of PCBs

released. and the amount of PCDF

formed and released). it is difficult to

estimate the effectiveness of this option

in avoiding cleanup costs from fire

incidents, since pcm,'s and PCDDs may

still be formed.

g.PhaseoutofcoInInericalPCB

TransforIners. The removal of all PCB

Transformers from locations in or near

comll}ercial buildings or the removal of

particularly high risk PCB Transformers

from locations in or near commercial

buildings would give increased

assurance that future serious PCB

Transformer fires from all causes will be

avoided. The following table uses a

population of 77,568 units (EPA's

estimate of the number of PCB

Transformers in or near commercial

buildings that will be in use at the end of

1984) and a population of 7,420 units

(EPS's estimate of the number of high

secondary network PCB Transformers in

use). EPA uses an estimate of equipment

life of 30 years, and presents total real

costs of phase-out over 5· and lo-year

periods of all commercial PCB

Transformers, and phaseout over a 5-

year period of higher secondary network

PCB Transformers, as well as estimates

of the number of PCB Transformer fires

avoided, and the net costs, after a

consideration of avoided 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 of the assumptions used in

the following analysis, and for a more

detailed analysis of phaseout 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 or near

industrial facilities-a. SUInInary table.

The following table (Table 3)

summarizes the real costs, the benefits,

and the net costs (after deducting

avoided cleanup costs) of the 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. Take no additional action. This

option would allow the continued use of

PCB Transformers in or near facilities

such as chemical manufacturing plants.

electric power generating 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, other than the

potential future costs associated with

cleanup and liability suits following

fires involving this equipment. If the use

of PCB Transformers in or near

industrial facilities were authorized

indefinitely, without additional

restrictions, EPA expects that up to six

PCB Transformer fires with smoke
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----..,-

spread will occur over the remaining

useful life of this equipment.

c. Labeling and registration programs.

The registration of PCB 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 of the

exterior of PCB Transformer locations

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 of a PCB

Transformer fire. they will not reduce

the frequency of occurrence ofthese

fires.

d. Smoke control technologies. 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 or near

commercial buildings. For purposes of

the cost-effectiveness analysis. EPA

assumes that the cost of the 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. 2 PCB

Transformers per location. the total cost

of the isolation of industrial PCB

Transformers over a 5-year period is

estimated at $109 million.

The isolation of industrial PCB

Transformers (which are typically

capable of being more rapidly

deenergized than commercial PCB

Transformers) would be effective in

reducing the relatively low fire-related

risks posed by the use of PCB

Transformers in industrial facilities even

further. Since the majority of PCB

Transformers located in or near

industrial facilities are capable of being

deenergized from an on-site location,

isolation of these transformers would be

expected to be effective in reducing the

spread of any volatilized PCBs or

oxidation products released before

deenergization could occur.

e. Increosed electrical protection. For

industrial PCB Transformers. increased

electrical protection would (typically)

involve the installation of appropriate

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 of abnormal

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 of increased electrical protection

of these transformers would be the costs

of installing heat senso\'s in the

secondary winding, and pressure

sensors in the transfmmer tank and

connecting these sensors to provide

automatic or rapid manual

deenergization of the equipment.

For some industrial PCB

Transformers. new circuit breakers

would have to be installed to allow for

the use of these sensors and automatic

deenergization.

During plant operating hOllrs, these

sensors would reduce the time between

the occurrence of a low cunent fdUlt (or

mechanical failure) and the .

deenergization of the transformer. and,

during plant off-hours/non-operational

periods. would reduce the probability of

a serious incident occurring. Increased

electrical protection of industrial

transformers (phased-in over a 5-year

period) would be expected to avoid four

serious PCB Transformer fires which

would otherwise occur in these

facilities.

The costs associated with the

installation of this 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 ofindustrial PCB

Transformers. Retrofilling of Industrial

PCB Transformers would be expected to

reduce even further the fire-related risks

posed by the continued use of PCB

Transformers in industrial facilities, by

reducing the amount of PCBs present for

potential release and for conversion to

oxidation products. The costs associated

with immediately retrofilling the 26,700

Industrical PCB Transformers for

purposes of reclassification to PCB

Contaminated status is estimated at

$489 million.

g.PhaseoutofindustrialPCB

Transformers. Th!') removal of PCB

Transformers from industrial facilities

would eliminate the relatively low flrerelated risks posed by the continued use

of these transformers. Phaseout of

Industrial PCB Transformers over a 5-

year period 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 of industrial

PCB Transformers over a lO-year period

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

additional action. EPA has few data on

PCB Transformer fires which have

occurred in outdoor electrical

substations. However, EPA has

evaluated the potential risks posed by

such fires and has developed an

estimate of the frequency of these fires.

This estimate is based on available

information on the probability of serious

PCB Transformer fires in or near

buildings. and the probability of failures

In different types of installations. EPA

estimates that up to three outdoor

electrical substation fires (with some

PCB volatilization and smoke

distribution) will occur over the

. remaining useful life Df this equipment.

Since EPA believes that an outdoor

PCB Transformer fire will not typically

result in the formation of large amounts

of Incomplete combustion products

which would require cleanup. EPA has

assumed that cleanup from these

Incidents will involve primarily the

cleanup of spilled PCBs. This type of

cleanup operation is significantly less

costly than cleanup following a PCB

Transformer fire In or near. a building.

b. Labeling and registration programs.

The labeling of the exterior of outdoor

PCB Transformer locations, and the

registration of these transformers with

appropriate fire department jurisdictions

is expected to reduce exposures to

firefighters and cleanup crews. The cost

associated with this registration and

labeling program for 17,000 outdoor PCB

Transformers is approximately $1.6

million.

c. Isolation ofoutdoor PCB

Transformers. Outdoor PCB

Transformers could be enclosed to

reduce the spread of PCBs and any

incomplete combustion products formed.

However. enclosing these transformers

could create conditions more conducive

to the formation of incomplete

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

of PCBs following fire-related failures. It

could Increase the amount of PCBs

converted into dibenzofurans from

outdoor PCB Transformer fires.

The costs associated with enclosing

17,000 outdoor PCB Transformers over a

5-yeal' period would be on the order of

$69 million. .

d. Increased. electrical protection.

Outdoor PCB Transformers are typically

radial installations, which are already

equipped with current-limiting fuses.
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The cost of the installation of low

current fault protection on the higher

secondary voltage outdoor PCB

Transformers (over a 5-year period)

would be on the order of $108 million.

Increased electrical protection would be

expected to avoid up to three outdoor

PCB Transformer fires..

c. Retrofilling. EPA has estimated the

costs associated with requiring the

immediate retrofilling of the

approximately 17,000 outdoor PCB

Transformers. These costs are estimated

to be $270 million.

£. Phaseout. EPA has estimated the

costs associated with requiring the

removal of an estimated 17,000 PCB

Transformers in outdoor locations, over

5- and 10-year periods. A 5-year

phaseout is estimated to cost $203

million, and a lO-year ph·aseout is

estimated to cost $137 million.

4. PCB Contaminated transformers.

EPA has also estimated the costs

associated with requiring additional

-controls on the use of PCB

Contaminated transformers. The costs

range from over $8 billion for the testing

of transformer fluids for PCB

concentration and the registration and

labeling of PCB Contaminated

transformers, to over $263 billion for

removal within 5 years. Registration and

labeling of PCB Contaminated

transformers would reduce the low PCB

fire-related risks posed by the use of this

equipment; and, removal would

eliminate these risks.

VI. Risk/Benefit Assessment

1. Use ofPCB Transformers in or near

commercial buildings. PCBs can be

released in fires involving PCB

Transformers, and. (depending upon the

contents of the 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 of PCDFs from PCBs. and

PCDDs from chlorinated benzenes, as

well as sampling data from actual PCB

Transformer fire sites confirm that PCBs

can be released and 2,3,7,8-TCDF and

2,3.7.8-TCDD (as well as other PCDF and

PCDD congeners) can be formed and

released from fires involving PCB

Transformers.

EPA believes that PCBs are both toxic

and persistent, and, that PCDFs and

PCDDs are orders of magnitude more

toxic than PCBs. PCB Transformers that

remain energized after sustained faults

or following failures as a result of fires

from external sources are more likely to

result in the volatilization of large

amounts of PCBs and the formation of

large amounts of PSDFs, 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 or fault occurs. PCB Transformers can become

involved in fires from many causes

including sustained low current faults,

sustained high current faults, and fires

external to transformers involving

stored combustibles or building

materials followed by an inability to

deenergize the transformer. The firerelated risks posed by the continued use

of PCB Transformers in or near

commercial buildings are much higher

than the fire-related risks posed by the

continued use of PCB Transformers in

outdoor locations and industrial

facilities. The overall probability of PCB

Transformer fault-related failure is

higher in commercial buildings than in

other PCB Transformer locations and

the risks posed are also higher in the

event of a PCB Transformer fire.

The fire-related risks posed by the

continued use of higher secondary

voltage network PCB Transformers in

commercial buildings are particularly

high. because these transformers have

the highest probability of failure 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 that PCB

Transformer fires will no longer occur in

or near commercial buildings. Serious

PCB Transformer fires which would

have otherwise occurred will definitely

be avoided. PCB Transformer fires in or

near commercial buildings pose

particularly high risks to human health,

because sustained high temperatures are

more likely in these locations (leading to

the volatilization of large amounts of

PCBs and the formation of large

amounts of incomplete combustion

products), and building occupants,

cleanup crews, and fire response

personnel are more likely to incur these

higher exposures. In addition. the lack of

knowledge on the part of commercial

building occupants, firefighters, and

cleanup crews about the potential risks

posed make exposures even more likely.

There are an estimated 77.568 PCB

Transformers located in or near

commercial buildings, and 7,420 of these

transformers are expected to be higher

secondary voltage network PCB

Transformers. The 77.568 PCB

Transformers used in commercial

buildings represent 64 percent of all PCB

Transformers in use. The immediate

removal of these transformers from use

is not possible because of

considerations such as PCB disposal

capacity, transformer manufacturing

capability, and disruption of electrical

service. The cost of removing all of

these PCB Transformers from use over

the next 5 years is estimated at $953

million. Five years may not be an

adequate amount of time for the removal

and disposal of this 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 of PCB disposal has

significantly jumped (almost doubled)

over the last year. Disposal capacity will

continue to be of concern over the next

few years. since existing EPA

regulations require the removal of PCB

Transformers in use in food and feed

processing facilities by October 1, 1985

and a limited phaseout of PCB

Capacitors by October I, 1988.

The removal of all commercial PCB

Transformers by 1990 would. however,

avoid an estimated 36 serious PCB

Transformer fires in commefl;:ial

locations. The removal of all commercial

PCB Transformers by 1995 is estimated

to cost on the order of $640 million for

the avoidance of an expected 29 serious

PCB Transformer fires.

The costs of removing 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 of these particularly high risk

PCB Transformers from use by 1990

would be expected to avoid an

estimated 25 serious PCB Transformer

fires, or about 70 percent of all PCB

Transformer fires in commercial

buildings which EPA expects would

otherwise occur. The removal of higher

secondary voltage network PCB

Transformers from use by October 1.

1990 will avoid an estimated 70 percent

of serious commercial PCB Transformer

fires for about 17 percent of the cost

associated with the removal of all

commercial PCB Transformers from use

by this same date.

EPA believes that it is prudent to

require the removal of commercial

higher secondary voltage network PCB

Transformers from use as soon as

possible, taking into consideration

factors such as PCB disposal capacity

and continuity of electrical service. EPA

believes that the soonest practical date

for requiring the removal of this

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 of particularly high risk. EPA

expects that 25 serious commercial PCB
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Transformer fires will be avoided by the

removal of these PCB Transformers

(over a 5-year period) for a total real

cost of less 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 of these 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 of other commercial

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 of failure and the

rapid deenergization of transformers.

EPA is requiring all commercial PCB

Transformers to be protected against

failures from sustained high current

faults in the primary and secondary

areas of the 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 of requiring registration,

labeling, and removal of stored

combustibles for all commercial PCB

Transformers and enhanced electrical

protection for 56,605 commercial PCB

Transformers (over a 5-year period) is

estimated at $459 million. The expected

incremental benefit of these measures

(for other than higher secondary voltage

network PCB Transformers) is the

avoidance of an addilional10 serious

PCB Transformer fires which would

have otherwise occurred. or about 30

percent of all commercial PCB

Transformer fires which EPA expects

would otherwise occur over the

remaining useful life of these

transformers.

Increased electrical protection and the

removal.of stored 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 of incomplete combustion

products. Reducing the likelihood of PCB

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 of malfunction. The

requirement for the registration and

labeling of commercial PCB

Transformers will reduce exposures in

the event that sustained high

temperatures occur despite the presence

of increased electrical protection.

EPA has selected the option of the

removal of commercial 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 of the remaining

70.000 commercial PCB Transformers

currently in use. EPA is also requiring

the reporting of all 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 of a PCB

Transformer fire-related incident. The

total real cost of this program to reduce

the fire-related risks posed by the

continued use of PCB Transformers in

commercial locations is estimated at

$635 million and is expected to avoid 35

serious PCB Transformer fires which

would have otherwise occurred over the

remaining useful life of commercial PCB

Transformers. or about $17 million per

serious PCB Transformer fire avoided.

The net cost, after deducting for avoided

cleanup costs, is estimated at $390

million,or about $10 million per serious

PCB Transformer fire avoided.

EPA has also banned the further

installation of PCB Transformers in

locations in or near commercial

buildings. EPA recognizes that the costs

associated with PCB Transformer

removal include tfie costs of physically

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 of risk

posed by the use of PCB Transformers in

or near commercial buildings. While

EPA has selected increased electrical

protection for many commercial PCB

Transformers, it has determined that the

installation of PCB Transformers (which

have been placed into storage for reuse)

in or near commercial buildings presents

an unreasonable risk. Thus, EPA has

banned the new installation of PCB

Transformers in or near commercial

buildings.

2. Use ofPCB rransformers in or near

industrial facilities. 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 of fires external to the PCB

Transformers are more likely to result in

the volatilization of PCBs and the

formation of incomplete 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 or near

industrial facilities are less likely to be

involved in fires involving sustained

high temperatures than PCB

Transformers located in or near

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 of industrial PCB

T"annformer fault-related failure and

fire is lower in industrial facilities than

in commercial buildings, and the risks

posed in the event of a 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 of the

frequency of industrial PCB Transformer

fires indicates that up to 6 PCB

Transformer fires (with smoke spread

into industrial facilities) are expected to

occur over the remaining useful life of

this equipment. Four industrial PCB

Transformer fires would be expected to

occur after October 1.1990. Even if EPA

were to assume as a worst-case that the

risks posed by PCB Transformer fires in

industrial facilities were equivalent to

the risks posed by PCB Transformer

fires in commercial buildings. EPA

expects that only 4 serious industrial
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PCB Transformer fires could be avoided

by requiring the removal or enhanced

electrical protection of industrial PCB

Transformers by 1990.

The costs. however, of the removal of

these in.dustrial PCB Transformers from

use by 1990 is estimated at $319 million.

The removal of industrial 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 of these transformers by 1990

would be expected to avoid about the

same number of incidents at a total real

cost of $170 million, or, $43 million per

avoided incident. Isolation of these

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 per incident.

The benefit of removing these

transformers or protecting these

transformers by 1990 is the avoidance

of up 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

near commercial 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 of the general

population are less likely to incur high

exposures. Further. there are generally

fewer people at risk of incurring these

exposures from fires in industrial

facilities than from fires in commercial

buildings.

The cost of requiring 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 of serious

industrial PCB Transformer fires, they

should reduce any exposures to

workers. cleanup crews, and fire

response personnel.

EPA has selected the option of the

registration, external labeling, and

removal of stored 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 of a PCB Transformer fire. EPA is also'

requiring the reporting of all 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 ofPCB Transformers in

outdoorlocations. EPA's evaluation of

the risks posed by PCB Transformer

fires indicates that the use of PCB

Transformers in outdoor locations away

from commercial areas poses less risk to

public health and the environment than

the use of this equipment in or near

buildings. First, combustion conditions

in outdoor locations may not be so

conducive to the volatilization of PCBs

and the formation of incomplete

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

outdoor PCB Transformer locations.

and. that many of these areas are fenced

in to restrict access to authorized

personnel. Further, if PCBs 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 or near buildings. EPA expects

fewer than three outdoor PCB

Transformer fires (with smoke spread)

over the remaining useful life of this

equipment.

There are an estimated 17,000 PCB

Transformers in outdoor locations. The

total real cost of the removal of these

PCB Transformers from use by 1990 is

estimated at $207 million. or, $69 million

per avoided incident. The total real cost

of installing 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 of outdoor PCB

Transformers. the containment of all

potential releases to water, and the

reporting of all 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 of these materials into the

environment.

4. PCB Contaminated transformers. A

fire involving a PCB Contaminated

transformer can result in the formation

and/or release of PCBs and oxidation

products. Thus, the us'e of these

transformers does pose some level of

risk in a fire-related incident. However.

the level of risk 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 of PCB

Contaminated transformers. would cost

more than $8 billion.

Thus, EPA has determined that the '

continued use of PCB Contaminated

transformers without additional controls

will not present unreasonable risks to

public health or the environment.

VII. Findings on the Use of PCBs in

Electrical Transformers

1. Based on the analyses presented in

Unit VI, EPA has determined that the

use of PCBs in electrical transformers

, does not pose unreasonable risks to

public health or the environment,

provided. that in addition to the

inspection, recordkeeping. and servicing

requirements of the August 25, 1982

Electrical Equipment Rule:

a. Higher secondary voltage network

PCB Transformers (network PCB

Transformers with secondary voltage at

or above 480 volts, including 480/277

volt network PCB Transformers) in or

near commercial 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 or near commercial 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 or near buildings are also

registered with building owners.

a. The vault door, machinery room

'door, or means of access (other than

grates and manhole covers) to PCB

Transformers are labeled with PCB

identification labels.

e. PCB Transformer locations are

cleared of stored combustibles.

f. In the event of a PCB Transformer

fire, measures are taken to contain

water releases.

g. In the event of a PCB Transformer nre. the National Response Center is

immediately notified. , ,

2. The use of PCBs in transformers

that comply with: (1) The inspection,

recordkeeping. and servicing
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29196 Federal Register I Vol. 50, No. 137 I Wednesday, July 17, 1985 I Rules and Regulations

requirements of the 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. If EPA immediately banned the

continued use of PCB Transformers it

would cost the public and-United States

industry billions of dollars, primarily as

a result of the disruption of electrical

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 the required removal of

commercial higher secondary voltage

network PCB Transformers from use by

October 1, 1990) reasonably reduce the

exposures associated with the use of

PCBs in PCB Transformers. The required

fire hazard risk reduction measures and

the required 5-y~ar phaseout of

commercial higher secondary voltage

network PCB Transformers are

measures which are much less costly

than a total ban on the use of PCBs but

are of similar effectiveness in reducing

the overall fire-related risks posed by

the use of these transformers.

c. The costs of phaseout and

retrofilling of all PCB Transformers are

not reasonable when considering the

potential reduction in release of PCBs

and the reduction in the risks posed by

PCB Transformer fires if these measures

were required for all PCB Transformers.

EPA has targeted phaseout requirements

for those PCB Transformers which EPA

has concluded pose particularly high

risks of failure and fire.

d. Releases of PCBs to the

environment and exposures to humans

and biota from the use of PCBContaminated 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 of any

control measures to reduce these low

risks further are very high.

VIII. Amendments to the PCB Electrical

Equipment Rule

A. Registration/Labeling/Removal of

Stored ComblJstibles

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 Transformer in 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 nearest building for PCB

Transformers located near buildings, or,

the nearest intersection for outdoor PCB

Transformers); the location of the

transformer within the building or near

the building (e.g., third floor east end, or,

west side of the building); arId the"

principal constituent of the dielectric

fluid in the transformer (e.g., PCBs,

mineral oil, silicone oil). For industrial

PCB Transformers, this may mean only

the registration of the transformers with

the industrial fire brigade on site.

EPA has also required the registration,

by December 1. 1985, of PCB

Transformers located in or near

buildings with building owners. Each

owner of a PCB Transformer(s) is

responsible for registering the

transformer(s). This means that all PCB

Transformers located in or near

buildings must be registered with

appropriate building owners. For PCB

Transformers located inside buildings,

this means the registration of the

transformer(s) with the building owner

of record. For PCB Transformers located

"near" buildings, this means the

registration of the PCB Transformer(s)

with all building owners whose

buildings are located within 30 meters of

the PCB Transformer(s). .

EPA has required the labeling of the

exterior of all PCB Transformers with

the Mark ML • This means that doors,

fences, hallways, and other easily

markable means of access to PCB

Transformer locations must be marked

with PCB identification labels. These

labels must be prominently displayed

and visible to emergency response

personnel in the event of a fire involving

this equipment. The exterior of sidewalk

and underground vaults, that is, grates

and manhole covers, are not required to

be marked (because of difficulties in

maintaining the mark over time).

EPA has required the removal of

stored combustibles from all PCB

Transformer locations. 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 of a PCB

Transformer enclosure, or within 5

meters of a 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 of requiring the removal

of stored combustibles is to &void, to the

extent possible and practical. PCB

Transformer involvment in fires initiated

by the combustion of stored materials

and to eliminate a potential source of

fuel for a fire initiated by an electrical

fault or malfunction in a transformer.

B. Phaseout ofCommercial Higher

Secondary Voltage Network PCB

Transformers

EPA has prohibited the use of all

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 other network PCB

Transformers with secondary voltages

at or above 480 volts) in or near

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 or non PCB

status).

Commercial buildings are defined as

non industrial (non substation) buildings

which are generally or typically

accessible to both members of the

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

or technically productive enterprises..

Industrial buildings are not generally or

typically readily accessible to other than

workers. Industrial buildings include

buildings used directly in the production

of power, the manufacture of products,

the mining of raw materials, and the

storage of textiles. petroleum products,
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Federal Register I Vol. 50. No. 137 I Wednesday, July 17, 1985 I Rules and Regulations 29197

wood and paper products, chemicals or

plastics, and metals.

A PCB Transformer located in or near

a commercial building is located within

the interior of the building, on the roof of

the building or attached to the exterior

wall of the building, in the parking area

serving the building, or located within 30

meters of the building.

EPA has required the removal of PCB

Transformers located near commercial

buildings (in addition to those lo'cated

inside commercial buildings) because

incidents like the San Francisco fire

indicate that PCB Transformers located

near commercial 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 of a

commercial building. EPA recognizes the

desirability of defining 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 of commercial building

contamination is covered by the rule.

EPA is somewhat hesitant to dictate an

absolute distance at which a PCB

Transformer would be considered to

pose little risk of significant building

contamination. Local climactic and

geographic conditions could greatly

influence the potential for building

contamination from PCB Transformer

fires in locations such as sidewalk and

underground vaults. However, the

benefits of establishing a numerical

standard. in terms of ease of compliance

with the rule and ease of enforcement, 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 of commercial buildings are also

covered within the definition of PCB

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 of 30

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 of building contamination. EPA

suggests that owners of vaulted 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. Increased Electrical Protection

EPA has required the installation of

enhanced electrical protection on many

of the 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

of PCB Transformers prior to failure

(rupture and/or release of PCBs). The

installation of current-limiting fuses or

other equivalent energy limiting devices

on PCB Transformers is intended to

avoid failures from high current faults.

In order to be effective in avoiding PCB

Transformer failures 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 of a second of the occurrence of a

sustained high current fault.

The installation of heat 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 of detection of a

sustained low current fault. In addition,

if these sensors are electrically

powered, they must be provided with a

secondary source of power configured to

deenergize the transformer on failure

(fail-safe).

The disconnect equipment may be set

either to open automatically upon the

sensing of abnormal conditions (e.g.,

temperature or pressure), or, it may be

set to send a signal to an on-site manned

control center where deenergization

must occur (during facility operating

hours) within 1 minute of the receipt of

an audio or visual signal indicating

abnormal conditions. Automatically

operated circuit breakers must also have

the capability to be opened manually.

EPA received several'comments on

the Proposed Rule which suggested that

EPA should give PCB Transformer

owners the option of implementing risk

reduction measures on shorter schedule

(such as enhanced electrical protection

by 1990) or PCB Transformer removal on

a longer schedule (such as PCB

Transformer removal by 1992). EPA did

not adopt this suggestion because,

without additional reporting

requirements (including the reporting to

EPA of the address and location of each

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 ofPCB

Transformers

EPA has prohibited the new

installation of PCB Transformers in or

near commercial 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 of storage for reuse

and placed in use in or near commercial

buildings. .

While EPA has placed restrictions on

the installation of PCB Transformers (by

prohibiting the placement of the

equipment in or near commercial

buildings), owners of PCB Transformers

which are in storage for reuse still have

many available options. Owners of PCB

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 of commercial building
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29198 Federal Register I VoL 50, No. 137 I Wednesday, July 17, 1985 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 ofFire-Related Incidents

and Containments ofPotential Water

Releases

EPA has required the reporting of all

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 of a transformer andl

or the release of PCBs. PCB Transformer

fire-related incidents must be

immediately reported to the NRC. The

information to be reported must include

the type of PCB Transformer installation

involved in the fire-related incident, and

reasonably ascertainable information on

the cause of the fire-related incident

EPA has required that owners of PCB

Transformers involved in fire-related

incidents take measures as soon as

practically and safely possible to

contain any potential releases of PCBs

and oxidation products to waterways.

This means that measures must be taken

to prevent further environmental release

and contamination of waterways as

soon as there is no immediate danger of

injury from the fire itself. These

measures indude, but are not limited to

the blocking of flour drains, the

containment of runoff, and the

containment and treatment of cleanup

water prior to release. If there is

evidence of the release of PCBs, PCDFs,

and PCDDs down floor drains, the PCB

Transformer uwner 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 of electrical protection

systems. Thus, EPA has allowed some

flexibility on the part of transformer

owners in the selection of appropriate

enhanced electrical protection systems.

Further, by requiring electrical

protection for GOmmercial PCB

Transformers, EPA implicitly allows the

replacement of all commercial PCB

Transformers with substitute equipment,

and the retrofilling and reclassification

of PCB Transformers to PCB

Contaminated or non-PCB status.

EPA has, however, required the

installation of protection against failures

from high current faults and low current

faults in all commercial higher

secondary voltage radial PCB

Transformer installations. The

installation of protection against high

current faults alone without protection

against low current faults in these

installations constitutes a violation of

the PCB Transformer use 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

engineering judgment, 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 Record of Rulemaking

A. Previous Rulemaking Records

(1) Official rulemaking record from

"Polychlorinated Biphenyls (PCBs)

Manufacturing, Processing, Distribution

in Commerce and Use Prohibition Rule"

published in the Federal Register of May

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

"Polychlorinated Biphenyls (PCBs);

Manufacture, Processing, Distribution,

and Use in Closed and Controlled

Waste Manufacturing Processes"

published in the Federal Register of

October 21, 1982, (47 FR 46980).

. (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 of August 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 of Proposed 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

of October 11, 1984, (49 FR 39966).

B. Support Documents

(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) Transformer Fires

Rulemaking" (August 1. 1984).

(3) USEPA, OPTS, HERD. "Addendum

to August I, 1984 HERD Work for

Proposed PEllychlorinated Biphenyl

(PCB) Transformer Fires Rulemaking"

(October 1. 1984).

(4) USEPA, OPTS HERD, "Response

to Comments on Health Effects of PCBs

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 of the Final Rule for

PCB Transformers" (June 1985).

(8) Kimbrough, Renate, D., et al.

"Health Implications of 2,3,7,8-

TetracWorodibenzodioxin (TeDD)

Contamination of Residential Soil,"

Journal of Toxicology and

Environmental Health (in press).

(9) USEPA, OPTS, EED, "NFIRS Data

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 of Thermal

Degradation of Dielectric Fluids"

(January 28, 1985).

(12) National Bureau of Standards,

"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

Other Than 2,3,7,8-TeDD" (October

1984).

(14) USEPA, EED, Versar, "Summary

of Comments 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 must judge
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•

•

"On site" means within the

boundaries of a contiguous property

unit.

3. In § 761.30, the introductory text of

paragraph (a) and paragraph (a)(l) are

revised and OMB Control Number 2070-

0073 is added to read as follows:

§ 761.30 Authorizations.

•

"Rupture of a PCB Transformer"

means a violent or non-violent break in

the integrity of a PCB Transformer

caused by an overtemperature and/or

overpres.sure condition that results in

the release of PCBs. .

(a) Use in and servicing of

transformers (other than railroad

transformers). PCBs at any

concentration may be used in

transformers (other than in railroad

locomotives and self-propelled railroad

cars) and may be used for purposes of .

servicing including rebuilding these

transformers for the remainder of their

useful lives. subject to the following

conditions:

(1) Use conditions. (i) As of October I,

1985, the use and storage for reuse of

PCB Transformers that pose an

exposure risk to food or feed is

prohibited.

(ii) As of October 1. 1990, the use of

network PCB Transformers with higher

secondary voltages (secondary voltages

equal to or greater than 480 volts,

including 480/277 volt systems) in or

near commercial buildings is prohibited.

Network PCB 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 of October 1. 1985. the

installation of PCB Transformers (which

have been placed into storage for reuse

or which have been removed from

another location) in or near commercial

buildings is prohibited.

(iv) As of October 1. 1990. all radial

PCB Transformers and lower secondary

voltage network PCB Transformers

(network transformers with secondary

voltages below 480 volts) in use in or

near commercial buildings must be

equipped with electrical protection to

completely within 1 minute of the

receipt of a 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

of Management and Budget has

approved the information collection

requirements of this rule under OMB

Control Number: 207lH)073.

List of Subjects in 40 CFR Part 761

Hazardous substances, Labeling,

Polychlorinated biphenyls,

Recordkeeping and reporting

requirements, Environmental protection.

Dated: July 1. 1985.

A. James Barnes,

Acting Administrator.

"In or Near Commercial Buildings"

means within the interior of. on the roof

of. attached to the exterior wall of, in

the parking area serving, or within 30

meters of a non-industrial nonsubstation building. Commercial

buildings are typically accessible to

both members of the 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, or train

stations).

"Manned Control Center" means an

electrical power distribution control

room where the operating conditions of

a PCB Transformer are continuously

monitored during the normal hours of

operation (of the facility), and, where

the duty engineers. electricians. or other

trained personnel have the capability to

deenergize a PCB Transformer

PART 761-{AMENDED]

Therefore. 40 CFR Part 761 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

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

of power. the manufacture of products.

the mining of raw materials. and the

storage of textiles, petroleum products.

wood and paper products. chemicals.

plastics, and metals.

• •

• •

.whether a rule is a "major rule" 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)

of the 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 of PCBs in electrical transformers

that would otherwise be prohibited by

section 6(e) of TSCA. This rule avoids

the severe disruption of electric service

to the public and industry that would

occur if the use of this equipment were

immediately prohibited. It also avoids

the economic impact that would result

from a requirement to replace the

equipment as soon as possible.

This rule was submitted to the Office

of Management and Budget (OMB), as

required by the Executive Order.

XII. Regulatory Flexibility Act

Under section 605(b) of the Regulatory

Flexibility Act,S U.S.C. 605(b), the

Administrator may certify that a rule

will not, if promulgated have a

significant impact on·a substantial

number of small entities and, therefore,

does not require a regulatory flexibility

analysis.

In general. this rule will reduce the

burden on small businesses that would

otherwise be encountered if an

immediate ban on PCB-containing

transformers were to take effect. If an

immediate ban on the use of PCBs in

transformers were imposed, large costs

would be incurred by all producers and

users of electricity, including small

businesses.

I certify that this rule will not have a

significant economic impact on a

substantial number of small entities.

XIII. Paperwork Reduction Act

The information collection

requirements of this rule have been

submitted for approval to the Office of

Management and Budget (OMB) under

the Paperwork Reduction Act of 1980, 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 EPA has reduced the burdens by

limiting the rule's applicability to

transformers which because of location

or installation type are of higher risk.

Based on this comment and other

comments made during the public

comment period, EPA has segmented
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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 of the transformer within

several tenths of a second of detection,

before transformer failure occurs. The

installation, setting, and maintenance of

current-limiting fuses or other equivalent

technology to avoid PCB Transformer

failures from sustained high current

faults must be completed in accordance

with good engineering practices.

(v) As of October 1,1990, all radial

PCB Transformers with higher

secondary voltages (480 volts and

above, including 480/277 volt systems)

in use in or near commercial buildings

must (in addition to the requirements of

paragraph (a)(1)(iv) of this section) be

equipped with protection to avoid

transformer failures caused by sustained

low current faults.

(A) Pressure and temperature sensors

(or other equivalent technology which

has been demonstrated to be effective in

the early detection of sustained 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 of the transformer in the

event of a sensed abnormal condition

(e.g., an overpressure or

overtemperature condition in the

transformer), caused by a sustained low

current fault. The disconnect equipment

must be configured to operate

automatically within 30 seconds to 1

minute of the receipt of a signal

indicating an abnormal condition from a

sustained low current fault, or can be

configured to allow for manual

deenergization from a manned on-site

control center upon the receipt of an

audio or visual signal indicating an

abnormal condition caused by a

sustained low current fault. Manual

deenergization from a manned on-site

control center must occur within 1

minute of the receipt of the audio or

visual signal indicating an abnormal

condition caused by a sustained low

current fault. If automatic operation is

selected and a circuit breaker is utilized

for disconnection, it must 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

Transformer rupture (either violent or

non violent rupture) and release of

PCBs.

(iv) As of December 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). Information required to

be provided to fire response personnel

includes:

(A) The location of the PCB

Transformer(s) (the addressees) of the

building(s) and the physical location of

the PCB Transformer(s) on the building

site(s) and for outdoor PCB

Transformers, the location of the

outdoor substation).

(B) The principal constituent of the

dielectric fluid in the transformer(s) (e.g.,

PCBs. mineral oil. or silicone oil).

(C) The name and telephone number

of the person to contact in the event of a fire involving the equipment.

(vii) As of December 1,1985, PCB

Transformers in use in or near

commercial buildings must be registered

with building owners. For PCB

Transformers located in commercial

buildings. PCB Transformer owners

must register the transformers with the

building owner of record. For PCB

Transformers located near commercial

buildings. PCB Transformer owners

must register the transformers with' all

owners of buildings located within 30

meters of the 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 of the PCB

Transformer{s).

(B) The principal constituent of the

dielectric fluid in the transformer(s) (e.g.,

PCBs, mineral oil, or silicone oil).

(C) The type of transformer

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 of December 1. 1985,

combustible materials. including. but not

limited to paints, solvents. plastics,

paper. and sawn wood must not be

stored within a PCB Transformer

enclosure (i.e., in a transformer vault or

in a partitioned area housing a

transformer); within 5 meters of a

transformer enclosure, or. if unenclosed

(unpartitioned), within 5 meters of a PCB

Transformer.

(ix) A \(isual inspection of each 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 of 30 days

between inspections. The visual

inspection must include investigation for

any leak of dielectric fluid on or around

the transformer. The extent of the visual

inspections will depend on the physical

constraints of each transformer

installation and should not require an

electrical shutdown of the transformer

being inspected.

(x) If a PCB Transformer is found to

have a leak which results in any

quantity of PCBs running off or about to

run off the external surface of the

transformer, then the transformer must

be repaired or replaced to eliminate the

source of the leak. In all cases any

leaking material must be cleaned up and

properly disposed of according to

disposal requirements of § 761.60.

Cleanup of the released PCBs must be

initiated as soon as possible, but in no

case later than 48 hours of its discovery.

Until appropriate action is completed,

any active leak of PCBs 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 of proper

containment measures.

(xi) If a PCB Transformer is involved

in a fire-related incident, the owner of

the transformer must immediately report

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/or pressure (by any

source) to result in the violent or nonviolent rupture of a PCB Transformer

and the release of PCBs. Information

must be provided regarding the type of

PCB Transformer installation involved

in the fire-related incident (e.g., high or

low secondary voltage network

transformer. high or low secondary

voltage simple radial system. expanded

radial system, primary selective system.

primary loop system, or secondary

selective system or other systems) and

the readily ascertainable cause of the

fire-related incident (e.g., high current

fault in the primary or secondary or low

current fault in secondary). The owner

of the PCB Transformer must also take

measures as soon as practically and

safely possible to contain and control

any potential releases of PCBs and

incomplete combustion products into
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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 of all floor drains in

the vicinity of the transformer.

(B) The containment of water runoff.

(C) The control and treatment (prior to

release) of any water used in

subsequent cleanup operations.

(xii) Records of inspection and

maintenance history shall be maintained

at least 3 years after disposing of the

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 of each visual inspection

and the date that leak was discovered, if

different from the inspection date.

(C) The person performing the

inspection.

(D) The location of any leak(s).

(E) An estimate of the amount of

dielectric fluid released from any leak.

(F) The date of any cleanup,

containment, repair, or replacement.

(G) A description of any cleanup,

containment, or repair performed.

(H) The results of any containment

and daily inspection required for

uncorrected active leaks.

(xiii) A reduced visual inspection

frequency of at least once every 12

months applies to PCB Transformers

that utilize either of the following risk

reduction measures. These inspections

may take place any time during the

calendar year as long as there is a

minimum of 180 days between

inspections.

(A) A PCB Transformer which has

impervious, undrained, secondary

containment capacity of at least 100

percent of the total dielectric fluid

volume of all 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 if the transformer has

been serviced for purposes of reducing

the PCB concentration).

(xiv) An increased visual inspection

frequency of at least once every w!!ek

applies to any PCB Transformer in use

or stored for reuse which poses an

exposure risk to food or feed. The user

of a PCB Transformer posing 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 or feed. Following

such notification, it is the owner's

ultimate responsibility to determine

whether the PCB Transformer poses an

exposure risk to food or feed.

(The recordkeeping requirements of

paragraphs (aJ(l) (vi), (vii), and (xi) were

approved by the Office of Management and

Budget under OMB Control Number 2070-

0073. The recordkeeping requirements of

paragraph (xii) were approved by the Office

of Management 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 of December 1, 1985, the vault

door, machinery room door, fence,

hallway, or means of access (others than

grates and manhole covers) to a PCB

Transformer must be marked with the

mark ML• The mark must be placed so

that it can be easily read by firemen

fighting a fire involving this equipment.

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

BILLING CODE 6S6o-So-M