At Brandon & Clark, Inc., our facility is an EPA approved generator of Polychlorinated Biphenyls (PCBs) and we work in conjunction only with EPA approved disposal facilities. We rigorously follow the rules and regulations created by the Environmental Protection Agency (EPA) in regards to handling, marking, and disposal of PCBs. If oil analysis shows the unit’s PCB concentration to be ≥50 ppm, we immediately relocate it to our isolated, EPA approved, containment area. The unit is kept in this area until the customer decides to either work towards reclassifying the unit to non-PCB status, or simply disposes of the unit.
Q&A
Q: Can I send my PCB contaminated units in to your shop for repair purposes?
A: Yes, Brandon & Clark, Inc. can service PCB contaminated units by retrofilling and reclassifying the contaminated units with new mineral oil or FR3 fluid so that it can be put back into service.
Q: Can Brandon & Clark, Inc. transport a PCB contaminated unit?
A: Brandon & Clark, Inc. can transport a PCB contaminated unit if the unit is being transported for repair/evaluation purposes, or if the status of the unit is unknown at the time of transport.
Q: What happens if I send my transformers to Brandon & Clark, Inc. and it is found to be PCB contaminated?
A: Brandon & Clark, Inc. will first send and oil sample off to a testing lab for a more thorough analysis. once the oil analysis is complete, Brandon & Clark will notify you of the units status and provide you with your options. If the unit must be disposed of Brandon & Clark will use an EPA approved disposal service facility to dispose of the contaminated units. Once the unit has been disposed of Brandon & Clark will send you a summary status report and certificate of disposal. If you choose to reclassify the unit Brandon & Clark will retrofill it with new mineral oil or FR3 Fluid.
Q: Does equipment that I send to your shop have to be manifested?
A: No, equipment does not have to be manifested as long as it is sent in for evaluation/repair purposes.
Q: How long will it be before I receive the certificate of disposal for my contaminated unit?
A: You will receive your certificate of disposal from Brandon & Clark within 365 days from the date the decision is made to dispose of the contaminated unit.
Q: My transformer is contaminated can you retrofill onsite?
A: No, retrofilling a contaminated transformer requires many washouts which can only be performed safely inside our shop.
Q: Can you rewind my PCB contaminated unit?
A: Yes, we can if the contamination level is ≤500 ppm
Q: Do I need copies of the manifest and certificate of disposal on file
A: No, Brandon & Clark, Inc. declares itself the Generator of the material once you have decided you want to dispose of your contaminated unit.
Q: Do I need to report the disposals to the EPA?
A: No, Brandon & Clark, Inc., as Generator of the material reports the disposal to the EPA.
Q: How are units reclassified?
| If pretest results show the PCB concentration (ppm) in the unit prior to retrofill is... | we retrofill the unit with new non-PCB oil and then... | if test results show the PCB concentration (ppm) after retrofill is... | the unit is reclassified as... |
|---|---|---|---|
| ≥1,000 | operate the transformer electrically under loaded conditions for a minimum of 90-continuous days after retrofill, and then test the oil for PCBs. | ≥50 but <500 | PCB-Contaminated |
| <50 | Non-PCB | ||
| ≥500 but <1,000 | test the oil for PCBs at least 90 days after retrofill. | ≥50 but <;500 | PCB-Contaminated |
| <50 | Non-PCB | ||
| ≥50 but <500 | (no need to test or energize) | (not applicable) |
Please feel free to call Brandon & Clark with any additional questions that you have.
Transformers Division
4605 Locust Avenue
Lubbock, Texas 79404
TEL 806-771-3509 OR 800-289-2224 Ext. #1
FAX 806-762-0163
www.brandonclark.com
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