PCB Transformers and PCB Activity

The federal PCB rule (40 CFR part 761) has owners of PCB Transformers register them. It has commercial storers, transporters and disposers of PCB waste, and some generators, notify EPA of their PCB waste activity, and it requires EPA's written approval for incinerators and chemical waste landfills that take PCBs and, with exceptions, for commercial storage of PCB waste. The standard's table of standard sources does not name these records (E1527-21, 8.2.2, Table 2).

What puts a property on this record

Transformer registration. A PCB Transformer is any transformer that contains 500 ppm PCBs or more (40 CFR 761.3). The rule reads: "No later than December 28, 1998 all owners of PCB Transformers, including those in storage for reuse, must register their transformers with the Environmental Protection Agency" (40 CFR 761.30(a)(1)(vi)(A)). The paragraph makes that duty subject to the limits of paragraph (a)(1). A registration gives the company's name and address, a contact, the address where the transformers are, their number, and the total weight of PCBs in them (40 CFR 761.30(a)(1)(vi)(B)). An owner who assumed a transformer was PCB-Contaminated, and finds after December 28, 1998 that it is a PCB Transformer, registers it within 30 days, unless that owner had already registered PCB Transformers at the same address (40 CFR 761.30(a)(1)(vi)(A)(1)). Building owners receive a second registration:

As of December 1, 1985, PCB Transformers in use in or near commercial buildings must be registered with building owners.

40 CFR 761.30(a)(1)(vii), edition revised as of July 1, 2025

A transformer in a commercial building is registered with the building owner of record, and one near a commercial building with the owners of all buildings within 30 meters of it (40 CFR 761.30(a)(1)(vii)).

Waste notifications. Commercial storers, transporters and disposers of PCB waste notify EPA of their PCB waste activities on EPA Form 7710-53, and EPA assigns or confirms an identification number (40 CFR 761.202(a), 761.205(a)). Generators of PCB waste need not notify, unless they own or operate PCB storage facilities subject to the storage requirements of 40 CFR 761.65(b) or (c)(7); those that do file a separate notification for each such facility (40 CFR 761.205(c)).

Approvals. An incinerator needs EPA's written approval before it burns PCBs and PCB Items, and a chemical waste landfill before it takes them (40 CFR 761.70(d), 761.75(c)). Commercial storage of PCB waste is approved in writing, on criteria that include a closure plan and financial responsibility for closure (40 CFR 761.65(d)(2)). A storer whose storage of others' PCB waste never exceeds 500 gallons need not seek that approval, nor need a generator that stores only its own waste (40 CFR 761.3).

What a listing shows, and what it does not

The regulation does not say which sites are on the record. A person who takes possession of a PCB Transformer after December 28, 1998 "is not required to register or re-register the transformer with the EPA" (40 CFR 761.30(a)(1)(vi)(A)(2)). The registration duty is for PCB Transformers. Mineral oil-filled electrical equipment made before July 2, 1979, whose concentration is not established, is assumed PCB-Contaminated, under 500 ppm, until its concentration is established by testing or by the manufacturer's label with service records (40 CFR 761.2(a)(2), (b)); a mineral oil transformer tested and found at 500 ppm or more becomes subject to all of part 761 (40 CFR 761.30(a)(1)(xv)). A transformer made before July 2, 1979 that holds 3 pounds or more of fluid other than mineral oil, with its concentration not established, must be assumed a PCB Transformer, as must one whose date and fluid are both unknown (40 CFR 761.2(a)(3)).

A notification shows that a facility named a PCB waste activity on the form. A generator without such a storage facility need not file one, so the absence of a notification does not show that no PCB waste was handled (40 CFR 761.205(c)). An approval shows that EPA authorized storage or disposal on its terms. None of these records says whether PCBs were released; spill reporting is separate (40 CFR 761.125(a)(1)).

In a Phase I ESA

Additional records are checked when the environmental professional judges them reasonably ascertainable, useful, accurate and complete enough for the purpose of the records review, and generally obtained in local practice for the kind of transaction. The standard's table of examples names local electric utility companies as a source of records relating to PCBs (E1527-21, 8.2.4, Table 3). Electrical or hydraulic equipment known or likely to contain PCBs is a site visit feature: described in the report if found at the subject property, and recorded as not found if it is not (E1527-21, 9.4, 9.4.18).

For a listing at the subject property, the answer turns on what equipment is or was there and at what concentration, whether it leaked, where it went when removed, and what was cleaned up. The rule has the owner keep records that EPA may inspect on request; ask the owner for them. Each PCB Transformer's inspection and maintenance records, kept at least 3 years after its disposal, include any leak, an estimate of the fluid released, and any cleanup, containment, repair or replacement (40 CFR 761.30(a)(1)(xii)). Since February 5, 1990, a facility other than a commercial storer or disposer that uses or stores at any one time one or more PCB Transformers, 50 or more PCB Large High or Low Voltage Capacitors, or at least 45 kilograms of PCBs in PCB Containers keeps an annual document log of the disposition of PCBs and PCB Items (40 CFR 761.180(a)). Ask the building owner whether it holds a transformer registration. See transformers and equipment that may hold PCBs.

If the professional concludes that hazardous substances or petroleum products are present or likely present at the subject property because of a release or a likely one, or present under conditions posing a material threat of a future release, then unless judged a de minimis condition or a historical REC, the REC is listed in the Conclusions, and the professional should give an opinion on additional investigation, if any (E1527-21, 3.2.20, 3.2.39, 3.2.73, 12.7, 12.8).

A listing of the subject property, or of another site inside the approximate minimum search distance, from any source the assessment uses gets the professional's judgment on its significance (E1527-21, 8.1.10).

What the federal rule says

The inquiry rule (40 CFR part 312) does not mention PCBs. For the subject property, its review of government records should include "Records of activities, conditions, or incidents likely to cause or contribute to releases or threatened releases" (40 CFR 312.26(b)(2)). The examples that paragraph gives name no PCB record. The rule lets the procedures of E1527-21 be used to comply with its sections 312.23 through 312.31 (40 CFR 312.11(a)).

Where the record is kept

Transformer registrations go to EPA's National Program Chemicals Division, and the owner keeps a record of each with the transformer's inspection and maintenance records (40 CFR 761.30(a)(1)(vi)(A), (C)). Form 7710-53 is filed with EPA. The facility details on it are not treated as confidential business information and are disclosed to the public without further notice, unless the submitter shows in writing extraordinary reasons for confidential treatment (40 CFR 761.205(a)(4)(viii)). Approvals come from an EPA Regional Administrator or EPA Headquarters (40 CFR 761.65(d)(2), 761.70(d), 761.75(c)). Annual document logs are kept at the facility or a central facility; a chemical waste landfill's water analyses and operations records, burial coordinates among them, are kept at least 20 years after it stops taking PCBs (40 CFR 761.180(a), (d)).

This page is general reference for environmental professionals. It does not classify any property. ASTM E1527-21 is the standard and is not reproduced here; the judgment of the environmental professional on the facts governs.