NIOSH Comments to EPA on the Environmental Protection Agency Proposed Rule on Polychlorinated Biphenyls in Electrical Transformers by R. A. Lemen, October 2, 1987

摘要

The testimony discusses the concerns of NIOSH on the proposed rule from the Environmental Protection Agency (EPA) regarding polychlorinated biphenyls (PCBs) in electrical transformers. NIOSH suggests that the rule is directed primarily toward allowing the use of PCB containing transformers as replacements for existing non PCB containing transformers in certain emergency situations where a non PCB containing transformer is not available. The proposed rule also allows the use of retrofilled transformers that may be contaminated with PCBs so that they may accrue sufficient in service time to allow the unit to be reclassified as a non PCB containing transformer. NIOSH views these conditions as reasonable and as not placing the workers or emergency crews who may respond to a failure, rupture, or fire at increased risk. Recommendations are made for wording which will improve on the use of the words failure or rupture by replacing them with the phrase release of PCBs from a PCB containing transformer. Suggestions were also made regarding labeling of PCB transformers.