Question # 195

195. A covered manufacturing facility removes PCB-laced oil that was contained in its on-site transformers. Would this activity be considered processing or an otherwise use of the PCBs, a listed toxic chemical, if the facility only extracts the PCB to dispose of it off-site?
If the PCB-laced oil is removed from an on-site transformer for disposal and is not replaced with clean PCB-laced oil, this would not be considered processing or an otherwise use. Removal of a toxic chemical from an article for disposal does not constitute a process or otherwise use activity. Therefore, this activity would not be subject to threshold determinations and release and other waste management reporting under EPCRA section 313.