Mr. Ken Djukic
Division of Air Pollution Control
State of Ohio Environmental Protection Agency
Northeast District Office
2110 E. Aurora Road
Twinsburg, OH 44087-1969



Dear Mr. Djukic:

     We appreciate your attention to the application of 40 CFR Part 63, Subpart T to the
cleaning of PCB contaminated transformers.   As described in your letter dated February 8, 1999,
we understand Safety-Kleen operates a facility which de-contaminates electrical transformers that
previously contained PCB oils in accordance with a PCB permit authorized by US EPA Region
V.  The de-contaminating operations used at Safety-Kleen include the use of two
trichloroethylene (TCE) cold cleaners which are subject to 40 CFR Part 63, Subpart T, National
Emission Standards for Halogenated Solvent Cleaning.   As noted in your letter, a conflict exists
between the de-contamination operations and operational practice standards specified in
§63.462(c)(8) and the US EPA PCB permit.  Section 63.462(c)(8) prohibits the cleaning of
"sponges, fabric, wood, and paper products" in batch cold cleaning machines subject to Subpart
T, while the US EPA PCB permit includes a de-contamination cycle in which the internal porous
components of the transformer are "cleaned" in a batch cold cleaning machine.  We understand
the US EPA PCB permit procedures were designed to limit the exposure of Safety-Kleen
personnel to PCBs.

     The intent of the halogenated solvent NESHAP is to regulate the surface cleaning of
materials.  40 CFR section 63.463(d)(8) states that "[s]ponges, fabric, wood, and paper products
shall not be cleaned."   The intent of this requirement is to prohibit the use of solvent cleaning
machines to clean solvent laden rags, sponges, etc.  EPA did not intend to prohibit the de-
contamination operations of PCB laden transformers such as those specified in the US EPA PCB
permit issued to Safety-Kleen.  Pursuant to Safety-Kleen's PCB permit, the transformer's internal 
parts (paper, foil, insulation, plates, etc.) must be removed for "further draining and pressure
extraction of dielectric fluid residuals, as needed, and then stored for final disposal in a TSCA
approved incinerator."    We believe the de-contamination cycle provided in the US EPA Region
V permit, as well as other US EPA PCB approved permits, will sufficiently protect against the
off-gassing of halogenated solvents to the atmosphere.  

     EPA proposes to clarify the intent of 40 CFR section 63.463(d)(8) through an upcoming
amendment to the rule.  Through this rule amendment, EPA will clarify that the prohibition in
63.463(d)(8) does not extend to porous material that are part of PCB laden transformers, so long
as such materials are handled and disposed of in compliance with an approved PCB permit issued
under the Toxics Substance Control Act or §761.79, PCB de-contamination standards and
procedures.   EPA anticipates proposing this amendment to Subpart T in the spring of 1999, and
promulgating the amendment in the summer of 1999.   If you have any questions, please contact
Tracy Back at (202) 564-7076.



                                                                      Sincerely, 



                                   Elliott Gilberg, Director
                                   Chemical, Commercial Services and 
                                     Municipal Division


cc:

Paul Almodovar, OAQPS
Charlie Garlow, ORE
Patricia Embrey, OGC
John Smith, OPPTS
Priscilla Fonseca, Region V