Question # 197

197. PCBs are removed and stored while the transformer undergoes routine maintenance, and then put back into the transformer. Should the facility consider the amount of PCBs returned into the transformer when making its threshold determinations?
The facility must consider any amount of PCBs added to a transformer towards its otherwise use threshold for that chemical if the transformer is to be used on-site or towards the processing threshold if the transformer is to be sent off-site to another facility. The facility is not required to consider the amount of PCBs that are removed then returned to a transformer towards a reporting threshold. Any releases or other waste management of the PCBs during this activity must be reported on the Form R if the facility meets any reporting threshold for PCBs.