She wanted to know if in that article we are referring only to transformers and items containing 500 and greater ppm PCBs. She asked: If I dispose of a transformer with 54 ppm PCB-contaminated oil in it, am I required to keep an annual log? Is this log submitted to EPA or GA EPD?
To clarify, in this article I am generally referring to recordkeeping for users, storers, and commercial disposers of PCB waste.
Users would not have to keep an annual log, as 40 CFR 761.180(a) requires an annual document log if any of the following apply:
- The generator uses, stores or disposes of 46 kilograms (99.4 lbs) or more of PCBs equal to or greater than 50 ppm in containers, such as drums, tanks and tanker trucks
- The generator uses, stores or disposes of one or more transformers that contain more than 500 ppm PCBs
- The generator uses, stores or disposes of 50 or more PCB capacitors.
The transformer with 54 ppm PCB-contaminated oil would be considered a PCB–Contaminated Transformer (50-499 ppm PCBs) and not a PCB Transformer as defined under 40 CFR 761.3. If you were to dispose of it, assuming you are talking about one transformer, you would likely contract with a commercial PCB disposer, who would be bound by the annual log and report requirements.
Please note that this discussion only pertains to the requirement for annual logs and reporting. There’s a wealth of information available about PCB requirements on the PCB Management topic page at Enviro.BLR.com.
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