### Capital Reporting Company Meeting 05-18-2010

(866) 448 - DEPO www.CapitalReportingCompany.com © 2010 1 PUBLIC MEETING FOR THE POLYCHLORINATED BIPHENYLS (PCBs): REASSESSMENT OF USE AUTHORIZATIONS ADVANCE NOTICE OF PROPOSED RULEMAKING

The Public Meeting for the Polychlorinated Biphenyls (PCBs): Reassessment of Use Authorizations Advance Notice of Proposed Rulemaking, taken before DERALYN GORDON, a notary public of Cook County, Illinois, on the 18th day of May, 2010, at 77 West Jackson Boulevard, 12th Floor, Chicago, Illinois, beginning at approximately 1:00 p.m., pursuant to Notice.

REPORTED BY: DERALYN GORDON, CSR, RPR, CRR LICENSE NO: 084-003957

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(866) 448 - DEPO www.CapitalReportingCompany.com © 2010 2 1 A P P E A R A N C E S 2 3 Ms. Mardi Klevs, Chief, Chemicals 4 Management Branch Land and Chemicals 5 Division US EPA, Region 5 6 7 Ms. Lynn Vendinello, Chief, Fibers and 8 Organics Branch National Program 9 Chemicals Division Office of Pollution 10 Prevention and Toxics U.S. EPA 11 12 Mr. Daemian Schreiber, QuanTech Inc. 13 14 Mr. Bradley Grams, EPA 15 16 Public Comments by: 17 Ms. Rebekah Cook 18 Ms. Pamela Lacey 19 20 Also Present: 21 Members of the Public 22 23 24

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(866) 448 - DEPO www.CapitalReportingCompany.com © 2010 3 1 I N D E X 2 VOLUME I 3 4 Tuesday, May 18, 2010 5 6 WELCOME EXAMINATION 7 MARDI KLEVS 4 8 9 EPA PRESENTATION 10 LYNN VENDINELLO 7 11 12 PUBLIC PRESENTATIONS/PUBLIC COMMENT 13 REBEKAH COOK 13 14 PAMELA LACEY 22 15 16 17 18 19 20 21 22 23 24

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(866) 448 - DEPO www.CapitalReportingCompany.com © 2010 4 1 P R O C E E D I N G S 2 MS. KLEVS: In case you don't know it, 3 you're in Chicago, Illinois. This is the home of 4 Region 5 EPA. And you're all here, I hope, for 5 a Public Hearing we're having on a new rule that 6 we're thinking about putting out. 7 My name is Mardi Klevs. I am the 8 Branch Chief for the Chemicals Management Branch 9 here in Region 5. And in our branch we have the 10 TSCA and practice program, both the program part 11 and the endorsements part. 12 And today I'm joined by some of our 13 other people from EPA. I want to introduce 14 Lynn Vendinello, who I think is going to be our 15 first speaker, she's Chief of the Fibers and 16 Organics Branch, and Peter Gimlin is also with 17 our Office of Chemical Safety and Pollution 18 Prevention. Peter, do you want to wave? There we 19 go. 20 So what you're attending right now is 21 the second of four public meetings that we're 22 holding to gather comments on the issue of EPA's 23 reassessment of its current authorizations for 24 PCBs, both use and distribution in commerce.

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(866) 448 - DEPO www.CapitalReportingCompany.com © 2010 5 1 EPA is going to consider adding 2 additional meetings to meet on the West Coast 3 during the comment period. So there may be more 4 than four. I don't know. 5 The purpose of the meeting is to provide 6 an opportunity for the public to deliver comments, 7 information and/or data regarding the advanced 8 notice of proposed rulemaking. 9 We issued this, what we call an ANPR, 10 on April 7, 2010, and that initiated the 11 Agency's potential reassessment of the PCB use 12 authorizations. 13 Our EPA representative here from 14 headquarters will be available to answer any kind 15 of clarifying questions on content of the 16 April 7th Federal Register Notice. 17 We want to thank you for coming here. And 18 we very much appreciate your presence and taking 19 the time to provide us with what we always 20 consider very valuable information that will 21 better inform us on our ability to regulate and 22 protect the environment in regards to PCBs in use 23 now that it's been at least 30 years 24 since the limited uses were authorized.

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(866) 448 - DEPO www.CapitalReportingCompany.com © 2010 6 1 In addition to the comments that we're 2 going to be receiving at today's meeting and the 3 remaining public meetings across the country, 4 EPA will also be accepting written public comments 5 through July 6, 2010. You may provide those 6 comments via docket number 7 EPA-HQ-OPPT-2009-0757 -- 8 I'm sure you all got that, right? 9 MS. VENDINELLO: I'm going to write it on 10 this thing. 11 MS. KLEVS: Lynn will write it on the 12 board for you and there's also handouts. 13 -- through Regulations.gov, g-o-v, or 14 via mail or hand delivery to EPA Headquarters in 15 Washington at the addresses listed in the 16 April 7th Federal Register. We encourage you 17 to submit written comments in addition to your 18 spoken comments delivered here today. 19 Today's meeting will run no later than 20 5:00 p.m., and it's going to begin with a 21 background on the presentation of the ANPR and 22 then proceeding to public presentations. We'll 23 have one 10-minute break at approximately 24 3:00 p.m. And the public restrooms, if you should

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(866) 448 - DEPO www.CapitalReportingCompany.com © 2010 7 1 need them -- obviously we're all grownups here, 2 go when you need to -- are down the hall. I'm 3 trying to think. I think the think the men's 4 comes before the women's. The women's is much 5 farther down than the men's is. 6 We ask that when you do speak that you 7 limit your presentation to 10 minutes so that 8 everybody will have ample time to provide public 9 comments. Your spoken comments today, we have a 10 court reporter, are going to go to the publicly 11 available docket and will be available for public 12 viewing at Regulations.gov. Isn't the Internet 13 wonderful? It makes it so much easier. 14 Again, thank you for coming today. Let 15 me now turn things over to Lynn in the Office of 16 Chemical Safety and Pollution Prevention who 17 will give you some background on this proposed 18 rulemaking. Any questions about logistics or any 19 problems? Okay. Take it away, Lynn. 20 MS. VENDINELLO: Thank you, Mardi. I 21 was just going to add if you haven't signed in, 22 there's an attendance. Even if you're just 23 attending, we'd like to have your name and 24 e-mail so we can give you more information about

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(866) 448 - DEPO www.CapitalReportingCompany.com © 2010 8 1 future meetings, whatever. Please do so at any 2 point. 3 And if you plan to speak and you haven't 4 preregistered, also put your name on the list, 5 and you'll be called in turn. 6 Okay. Well, welcome. I'm going to give 7 a very brief overview of the PCB program, very 8 brief because it would normally take several 9 hours. But -- and some of this you may already 10 know about, but I just wanted to provide a little 11 background. 12 What I'll talk about is what are PCBs, 13 what were they used for, what are some of the 14 health effects from PCBs, what is the authority 15 for the rule making that we're considering today, 16 and what does that involve, what are some of 17 the objectives of the rule making, and, most 18 importantly, what types of information we're 19 seeking in this advance notice of proposed rule 20 making, and then our anticipated time frame. 21 PCBs or -- are a group of about 209 22 chemical compounds called congeners. And the 23 PCB commercial formulations contain mixtures of 24 around 50 different types of congeners.

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(866) 448 - DEPO www.CapitalReportingCompany.com © 2010 9 1 Approximately 1.4 billion pounds were 2 produced in the U.S. between 1929 and 1977. And 3 it is our estimate that possibly half were 4 released into the environment. 5 PCBs were important in industrial 6 applications because they do not decompose 7 over time, they are heat resistant, they provide 8 elasticity to plastics, and they have low 9 electrical conductivity. 10 So what were they used for? Many 11 different uses. And the list here includes 12 the authorized and then some of the not authorized 13 uses that have a little star next to them. 14 So they've been used in dielectric 15 fluids, hydraulic fluids, transfer fluids, 16 cutting oils, lubricants, pump oils, carbonless 17 copy paper, plasticizers, caulk and sealants, 18 paints and coatings, rubber, inks and pigments. 19 What we know, and there's been a lot 20 of studies done of PCBs, we know that there's 21 both acute and chronic effects, acute namely 22 irritation, burning of the eyes and face and 23 chloracne, and then chronic, or long term, 24 include liver disorders, reproductive effects,

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(866) 448 - DEPO www.CapitalReportingCompany.com © 2010 10 1 developmental effects, and it's a probable human 2 carcinogen. 3 The authority from the rulemaking comes 4 out of Section 6(e) of TSCA, generally bans the 5 manufacture, processing, distribution in commerce, 6 and use of PCBs starting after 1978, but provided 7 for exceptions based on the EPA's finding of 8 "no unreasonable risk of injury to health or 9 the environment." 10 And most of the exceptions take the 11 form of author- -- use authorizations, which 12 included specific conditions for use, such as 13 location restrictions, repair restrictions, 14 and concentration limits. 15 Section 6(e)(2)(B) of TSCA permits EPA to 16 authorize by rule the manufacturing, processing, 17 distribution in commerce, and use of PCBs in a 18 nontotally enclosed manner if these activities 19 will not present an unreasonable risk of injury 20 to health or the environment. 21 EPA has determined that certain nontotally 22 enclosed PCB use activities will not present an 23 unreasonable risk and propose to authorize these 24 use activities for a period of 5 years after the

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(866) 448 - DEPO www.CapitalReportingCompany.com © 2010 11 1 effective date of the final rule. And then 2 at that time EPA was to examine the need for 3 continuing these authorizations. So that was 4 1979 and there out plus 5 years. So we're a 5 little overdue in doing this assessment. 6 And people have asked well, what do we 7 need to do to remove the use authorization? The 8 Court has ruled that in order to remove an 9 existing use authorization, EPA just needs to be 10 less than arbitrary and capricious. We don't 11 have to do an unreasonable risk finding to undo 12 a use authorization. 13 So the burden to remove a use 14 authorization is much less than the actual 15 burden to establish a use authorization. 16 The objective of the rulemaking is 17 to, as it's titled, is to reassess the current 18 authorization for certain PCB uses to determine 19 whether now, over 30 years later, things may 20 have changed, and they may pose an unreasonable 21 risk to human health and the environment. 22 So our first step in this re- -- 23 assessment is to solicit information from the 24 public on several topics. We are asking for a

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(866) 448 - DEPO www.CapitalReportingCompany.com © 2010 12 1 lot of information. We would like to know more 2 about the population of the equipment that is 3 currently authorized, how this equipment is being 4 managed, particularly with electrical equipment 5 failure rates and insurance costs, removal and 6 replacement costs for equipment, the impact 7 of severe spills, weather events, and 8 vandalism, which a lot of this applies to 9 electrical equipment, disposal and metal 10 recycling capacity and costs, for example, 11 for transformers brought offline, the 12 environmental impacts of alternatives to PCBs, 13 and we're also interested not just in liquid PCBs, 14 but there's been a lot of attention lately on 15 nonliquid PCBs, which are being used in paints 16 and caulk, and we'd like -- we have very little 17 data about that. We have a lot of hit-or-miss 18 data that we found out about, but we'd like to 19 know more broadly about the types and 20 concentrations for nonliquid PCBs. 21 As Mardi mentioned, at present the comment 22 period ends July 6th. I know we've gotten a lot 23 of requests to extend that, and we are taking that 24 under consideration. And you -- the best way to

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(866) 448 - DEPO www.CapitalReportingCompany.com © 2010 13 1 submit comments is electronically into the docket 2 under Regulations.gov. 3 And for this year in terms of our time 4 line, we don't anticipate doing anything in 2010 5 except reviewing all of the comments and the data 6 that we receive. That's it. 7 If there are any clarifying questions, I'd 8 be happy to answer that now. Otherwise, we'll 9 turn it over to the people that would like to 10 speak. Great. Okay. Thank you. 11 MR. SCHREIBER: Hi. Would Rebekah Cook, 12 Principal Engineer of DTE Energy, please come to 13 the podium. 14 MS. COOK: Good afternoon, everyone. My 15 name is Rebekah Cook, and I'm the Principal 16 Engineer at DTE Energy. We're headquartered in 17 Detroit, Michigan. 18 I serve the company as a subject matter 19 expert for compliance and interpretation of the 20 EPA PCB regulations and have done so for more 21 than 20 years now. In this capacity I perform 22 PCB compliance audits of company facilities and 23 served as a communication point to Region 5 24 PCB program staff. I'm pleased to say that we

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(866) 448 - DEPO www.CapitalReportingCompany.com © 2010 14 1 have established a positive working relationship 2 based on mutual respect for our respective roles 3 and responsibilities. 4 I am here today to response to EPA's 5 Advance Notice of Proposed Rulemaking which 6 contemplates removing the current use 7 authorizations and possibly implementing a 8 mandatory phase down of PCB equipment. 9 I want to tell you about the success 10 of DTE Energy's proactive, voluntary approach 11 to PCB reduction and the documented resulting 12 improvement to the environment. I also want to 13 make a few key points about the impact of the 14 mandatory phase-out program on our employees, 15 our equipment and ultimately our customers. In 16 addition to the oral testimony provided here, 17 DTE Energy will also be providing written comments 18 for EPA's ANPRM. 19 DTE Energy is a diversified energy company 20 involved in the development and management of 21 energy related businesses services nationwide. 22 Our largest operating subsidiaries are Detroit 23 Edison and Michigan Consolidated Gas Companies. 24 Together these regulated utilities provide

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(866) 448 - DEPO www.CapitalReportingCompany.com © 2010 15 1 electrical and/or gas services to more than 2 3 million residential, business and industrial 3 customers throughout Michigan. Both these 4 utilities have been in operation for over a 5 century. 6 Detroit Edison in particular generates, 7 transmits and distributes electricity to over 8 2.1 million customers in Michigan. To do this 9 successfully Detroit Edison utilizes over 10 400,000 pieces of electrical equipment and over 11 40,000 miles of wire. 12 In the 30 years since the passage of 13 the PCB Ban and use authorizations, Detroit Edison 14 has established and exceeded many milestones of 15 voluntary PCB removal and use reductions. 16 Beginning in 1976 the company ceased purchasing 17 PCB equipment 2 years before the ban in 1978. In 18 1984 Detroit Edison removed all PCB large cap 19 capacitors and transformers from public access 20 areas 4 years before the regulatory deadline. 21 In 2005 Detroit Edison completed a 22 10-year voluntary phaseout of all known 23 PCB capacitors located at the company's 24 substations. Ultimately 22,000 capacitors were

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(866) 448 - DEPO www.CapitalReportingCompany.com © 2010 16 1 removed and replaced with non-PCB units. Over 2 600,000 kilograms of PCBs were destroyed during 3 that program. 4 As an ongoing general policy, equipment 5 removed from service that contains dielectric 6 material with PCB concentrations greater than or 7 equal to 50 parts per million were scrapped and 8 replaced with no or non-PCB units. Detroit Edison 9 preserves valuable pieces of equipment while 10 simultaneously reducing PCB inventory through 11 retrofilling and reclassifying of PCB-contaminated 12 equipment. 13 Detroit Edison is committed to a 14 proactive, voluntary approach to PCB-regulated 15 equipment phase-out. We are one utility among 16 many in this region and in this country. This is 17 our story about voluntary PCB reductions, but 18 there are many more. 19 As a member of the Utility Solid Waste 20 Activities Group, or better known as USWAG, 21 PCB reduction milestones and achievement are 22 shared and promoted. USWAG is a consortium of 23 approximately 80 utility operating companies, 24 the Edison Electric Institute, the National Rural

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(866) 448 - DEPO www.CapitalReportingCompany.com © 2010 17 1 Cooperative Association and the American Power 2 Association. Our combined reduction 3 efforts are significant because they help 4 demonstrate that the U.S. is working towards 5 fulfillment of its anticipated obligations 6 under the Stockholm Convention on Persistent 7 Organic Pollutants, if the U.S. were to become 8 signatory to the convention. 9 Specifically the efforts of utilities 10 like those of Detroit Edison represent determined 11 efforts to identify and remove from use 12 PCB equipment with concentrations of 500 part per 13 million PCBs or more by the year 2025. Through 14 these phase-down initiatives we are also 15 endeavoring to identify and remove from use 16 PCB-contaminated equipment by the year 2025. 17 And these reduction efforts are creating 18 measurable environmental benefits. In EPA's 19 2006 Great Lakes Progress Report, the Agency 20 states that concentrations of certain 21 contaminants, including PCBs, have generally 22 declined in most of the fish species monitored 23 under the program since the late 1970s. 24 Concentrations of PCBs and other substances

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(866) 448 - DEPO www.CapitalReportingCompany.com © 2010 18 1 have also declined in gull eggs in the Great Lakes 2 since the 1970s. We're seeing real progress in 3 the reduction of PCBs in certain key environmental 4 receptors. 5 Another key point that I would like 6 to make is that Detroit Edison, like most 7 utilities, does not have a bar coded or other 8 specifically identifying type of inventory of 9 the location in our system on every piece of 10 oil-filled equipment containing 50 part per 11 million or greater. 12 In 1998 EPA set the PCB concentration 13 assumptions for use of transformers and other 14 oil-filled electrical equipment codifying its 15 longstanding assumption policies. The use 16 assumptions make day-to-day sense when applied 17 to our operations and are protective of the 18 environment. 19 Thirty years ago it was thought that 20 it wasn't practical or feasible to determine the 21 PCB content in billions of pieces of electrical 22 equipment in service across the U.S. 23 Detroit Edison alone was -- would be 24 charged $52 million in 1982 just for testing

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(866) 448 - DEPO www.CapitalReportingCompany.com © 2010 19 1 costs. Removal of the equipment would result in 2 much greater cost and planned service interruption 3 time. 4 In 1982 USWAG estimated just the 5 identification cost to the utility industry would 6 be over $6 billion. 7 Recognizing the proactive, voluntary 8 reduction efforts that Detroit Edison and 9 utilities across this nation are implementing, 10 I suggest that today the exposure risk is even 11 lower than it was in 1982. 12 A mandatory reduction program would 13 require Detroit Edison to conduct an inventory 14 of all of its in-service, dielectric-filled 15 equipment to ensure that all pieces of equipment 16 with 50 part per million PCBs or more are removed 17 and replaced by any set regulatory deadline. 18 In addition to this huge administrative 19 burden, we would have to implement a field 20 testing program. Field testing has its own 21 unique challenges and risks. The vast majority 22 of equipment in Detroit Edison's inventory, as 23 in the inventories of all other utilities, is 24 critical to the provision of reliable electrical

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(866) 448 - DEPO www.CapitalReportingCompany.com © 2010 20 1 service to our customers. De-energizing this 2 equipment prior to testing will necessitate 3 large-scale and potentially lengthy planned 4 service interruptions. 5 Unplanned disruptions are a likely 6 consequence of testing on such a broad scale. At 7 the same time testing the equipment that is in 8 service without first de-energizing poses serious 9 safety concerns for our workers, ranging from 10 burn injuries from hot oil to potentially fatal 11 electrocution. 12 The arbitrary phase-out deadlines 13 and other requirements suggested in the ANPRM 14 would force utilities to make an impossible 15 choice: severely compromise our ability to 16 achieve our core mission of providing reliable 17 electric service to our customers and violate 18 reliability requirements imposed by the Public 19 Utility Commissions or jeopardize the physical 20 safety of our own workers. 21 One final point about sampling, efficient 22 use of resources and cost effectiveness. Sampling 23 equipment for continued use will often jeopardize 24 the integrity of a well-contained functioning

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(866) 448 - DEPO www.CapitalReportingCompany.com © 2010 21 1 item, possibly destroying the item all together. 2 The cost to mobilize a crew, conduct the 3 analytical, inconvenience to our customers, and 4 jeopardize workers' safety to test a formerly 5 good unit, now potentially destroyed, only to 6 find out the unit was non-PCB in the first place 7 just doesn't make good business sense or benefit 8 the environment. 9 Speaking of costs, we're still in the 10 process of developing current 2010 cost figures 11 associated with a possible mandatory phase-out 12 program. We will have some information on that 13 in our written comments. 14 Regardless, we can rest assured that 15 the cost is going to be huge and ultimately borne 16 by the shareholder and the rate payers. 17 In the state of Michigan the U.S. Bureau 18 of Labor Statistics indicates the March 2010 19 unemployment rate tops the nation at 14.1 percent. 20 Decisions about risks and the cost of a mandatory 21 PCB phase-out program have to include an analysis 22 of the impact to the customer, the rate payer and 23 the shareholder. 24 Michigan citizens are having difficulties

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(866) 448 - DEPO www.CapitalReportingCompany.com © 2010 22 1 today paying their grocery bills to feed their 2 children, let alone paying for their electric 3 bill. To place another cost burden on them 4 without the benefit of a requisite risk reduction 5 would be untenable. 6 On behalf of DTE Energy, I would 7 like to thank you for the opportunity to provide 8 some of our perspectives on the impact of this 9 important rulemaking effort. Thank you 10 MR. SCHREIBER: Thank you. Pamela Lacey, 11 American Gas Association 12 MS. LACEY: Good afternoon. The American 13 Gas Association appreciates the opportunity to 14 comment on EPA's reassessment of the PCB 15 use authorizations under 40 C.F.R. Part 761. My 16 name is Pamela Lacey. I am senior Managing 17 Counsel Environment for the AGA. 18 AGA represents 195 local energy companies 19 that deliver clean natural gas throughout the 20 United States. There are more than 70 million 21 residential, commercial and industrial natural 22 gas customers in the U.S., of which 91 percent -- 23 more than 64 million customers -- receive their 24 gas from AGA members. AGA is an advocate for

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(866) 448 - DEPO www.CapitalReportingCompany.com © 2010 23 1 natural gas utility companies and their customers. 2 Today natural gas meets almost 3 one-fourth of the United States' energy needs. 4 PCBs are a legacy issue for natural gas utilities. 5 In the mid 20th century PCBs were added as a 6 fire retardant to the lubricating oil used in 7 some pipeline compressor engines and turbines. 8 Lubricating oils containing PCBs sometimes 9 leaked from the compressors and could be carried 10 downstream into natural gas distribution systems 11 by small amounts of oily liquid hydrocarbons 12 entrained in the natural gas. 13 Some gas utilities were unlucky and 14 obtained PCB-contaminated gas supplies from their 15 upstream supplier in the past. Some were lucky 16 and did not. A few had their own compressors and 17 used PCBs in them several decades ago. 18 No one has added PCBs to lubricating oil 19 and compressors in many decades. The terminology 20 of the PCB regulations awkwardly refuses -- refers 21 to the use of PCBs, but that term does not really 22 fit the situation. We are really dealing with 23 residual contamination left over from the past 24 use of PCBs. And our challenge is to locate and

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(866) 448 - DEPO www.CapitalReportingCompany.com © 2010 24 1 remove the PCBs in affected systems. 2 In the Advanced Notice of Proposed 3 Rulemaking published on April 7, 2010, EPA 4 announced that the Agency is considering 5 significant changes in the regulations governing 6 the management of PCBs in natural gas distribution 7 systems. 8 First, EPA is considering whether to 9 require gas utilities to notify EPA "when PCBs 10 are found in any pipeline system, regardless of 11 the source of the PCBs or the owner of the 12 pipeline." 13 Second, the agency is considering the 14 elimination of all PCBs at greater or equal 15 to 50 parts per million in all distribution or 16 pipeline systems or I should add or 1 part per 17 million. 18 I will briefly address each in turn. 19 First, we do not object to providing information 20 to EPA about PCBs in natural gas distribution 21 systems, but we have serious concerns about the 22 potential scope of the reporting requirement. 23 Gas utilities that have found PCBs 24 in their systems have been following their

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(866) 448 - DEPO www.CapitalReportingCompany.com © 2010 25 1 requirements under Part 761 to characterize 2 where they have found PCBs in their systems. 3 The resulting characterization plans are 4 quite detailed and are available to EPA now 5 for inspection, as required by Part 761. 6 We suggest that the agency refer to these 7 plans for information required -- about past 8 testing results, and that any new reporting 9 requirement would be prospective. 10 In addition, it is important to define 11 and narrow the scope of what would be reported and 12 when. The goal should be to reach a balance that 13 provides the information the Agency needs without 14 imposing unnecessary burdens and costs on gas 15 utilities and their customers. 16 Second, we have serious concerns about 17 your potential requirement to remove PCBs 18 from transmission and distribution pipeline 19 systems by 2020, either at a 50 part per million 20 or 1 part per million threshold. We do not 21 believe it is physically or economically 22 possible to achieve this goal, nor is it 23 necessary to protect the public health. 24 The small amount of PCBs that remain in

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(866) 448 - DEPO www.CapitalReportingCompany.com © 2010 26 1 the distribution systems are actively monitored 2 and managed so that they are contained within the 3 system and actively removed when found. 4 It is not possible to use robotic smart 5 pigs to clean distribution systems because the 6 pipes are too small, the gas mains under urban -- 7 the urban street grid have too many tight turns, 8 and there are no traps to recapture the pigs or 9 the solvent. 10 Certain types of solvent can be used to 11 decontaminate pipes that have been removed for 12 disposal, but solvent cannot be injected in live 13 distribution systems without taking the mains and 14 service lines out of service, thus disrupting the 15 flow of gas to the customer. In addition, 16 solvents can damage plastic pipes and cause 17 serious public safety issues. 18 Over time PCBs have been and will 19 continue to be removed as our members remove 20 hydrocarbon liquids from scrubbers, drips and 21 filters. But the only way to accelerate this 22 process to meet a hard 2020 deadline would be 23 to remove and replace millions of miles of 24 distribution pipes at astronomical cost and

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(866) 448 - DEPO www.CapitalReportingCompany.com © 2010 27 1 disrupting service to millions of homes and 2 businesses. And for what purpose? There is 3 no exposure risk to justify this measure. PCBs 4 do not move within the low pressures and low 5 velocities of natural gas distribution systems 6 unless oil is present, and our member gas 7 utilities remove the small amounts of oil from 8 their systems. Small amounts of oil in 9 low-pressure and medium-pressure systems are 10 undetectable and are only discovered when the 11 line is taken out of service. 12 To require the lines to be cleaned of 13 these traces of PCB by 2020 is impossible unless 14 all lines are replaced. Current practices under 15 the existing regulations are working to remove 16 the small amounts of oily pipeline condensates 17 and to protect people from the residual PCBs that 18 remain inside the pipes. AGA strongly opposes 19 EPA's proposal to require the removal of virtually 20 all traces of PCBs from pipeline systems by 2020. 21 AGA plans to file written comments on the 22 Advance Notice. We urge EPA to extend the comment 23 period by at least an additional 90 days to allow 24 stakeholders to provide the data EPA will need to

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(866) 448 - DEPO www.CapitalReportingCompany.com © 2010 28 1 make an informed decision based on science. Thank 2 you for the opportunity to comment. 3 MR. SCHREIBER: Thank you. Is there 4 a speaker from the Interstate Natural Gas 5 Association of America present? 6 MS. LISA BEAL: We're present, but we 7 hadn't planned on making a statement at this time. 8 MR. SCHREIBER: Okay. Thank you very 9 much. Those are all of our planned speakers for 10 the day. So unless there were any other comments, 11 then thank you all for coming and have a nice day. 12 (Whereupon proceedings were 13 adjourned at 1:34 p.m.) 14 15 16 17 18 19 20 21 22 23 24

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(866) 448 - DEPO www.CapitalReportingCompany.com © 2010 29 1 STATE OF ILLINOIS ) 2 ) SS: 3 COUNTY OF C O O K ) 4 5 6 Deralyn Gordon, being first duly sworn, 7 on oath says that she is a court reporter doing 8 business in the City of Chicago; and that she 9 reported in shorthand the proceedings of said 10 public meeting on May 18, 2010, and that the 11 foregoing is a true and correct transcript of 12 her shorthand notes so taken as aforesaid, and 13 contains the excerpt of proceedings given at 14 said public meeting. 15 16 17 _______________________________ 18 Deralyn Gordon Certified Shorthand Reporter 19 20 21 22 23 24

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© 2010 cleaned 27:11 Coast5:1 coatings 9:17 coded 18:6 codifying 18:13 combined 17:1 comes 7:3 10:2 coming 5:16 7:13 28:10 comment 3:12 5:2 12:20 22:13 27:21 28:1 comments 2:16 4:21 5:5,24 6:3,5,16,17 7:8 12:24 13:4 14:16 21:12 27:20 28:9 commerce 4:23 10:4,16 commercial

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© 2010 development 14:19 developmental 9:24 dielectric 9:13 16:4 dielectric-filled 19:13 different 8:23 9:10 difficulties 21:23 discovered 27:9 disorders9:23 disposal 12:8 26:11 disrupting 26:13,24 disruptions 20:4 distributes 15:6 distribution 4:23 10:4,16 23:9 24:5,14,19 25:17,24 26:4,12,23 27:4 diversified 14:18 Division 2:5,9 docket6:5 7:10 12:24 documented 14:10 done 9:19 13:19 downstream23:9 drips 26:19 DTE 13:11,15 14:9,16,18 22:5 duly29:6 during 5:2 16:1 E easier 7:12 economically 25:20 Edison 14:22 15:5,8,12,17,20 16:7,12,23 17:9 18:5,22 19:7,12 Edison's 19:21 effective 10:24 effectiveness 20:21 effects 8:13 9:20,23,24 efficient 20:20 effort 22:8 efforts 17:2,8,10,16 19:7 eggs 17:24 either25:18 elasticity9:7 electric16:23 20:16 22:1 electrical 9:8 12:3,8 14:24 15:9 18:13,20 19:23 electricity15:6 electrocution 20:10 electronically 12:24 elimination 24:13 e-mail 7:23 employees 14:13 enclosed 10:17,21 encourage6:15 endeavoring 17:14 endorsements 4:10 energy13:11,15 14:16,18,20 22:5,17 23:2

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© 2010 fit23:21 Floor 1:14 flow26:14 fluids 9:14 force 20:13 foregoing 29:11 form 10:10 formerly 21:3 formulations 8:22 frame8:19 fulfillment 17:4 functioning 20:23 future7:24 G gas 14:22,24 22:10,12,18,21,2 3,24 23:1,3,9,11,12,1 3 24:5,8,19,22 25:13 26:5,14 27:4,5 28:3 gather4:21 general 16:3 generally10:3 17:20 generates 15:5 Gimlin 4:15 given 29:13 goal 25:11,21 Gordon 1:11,23 29:6 gotten 12:21 g-o-v 6:12 governing 24:4 Grams 2:14 Great 13:9 17:18,24 greater 16:5 18:10 19:1 24:13 grid 26:6 grocery21:24 group 8:20 16:19 grownups 6:24 gull 17:24 H half 9:2 hall 7:1 hand 6:13 handouts 6:11 happy 13:7 hard26:21 haven't 7:20 8:2 having 4:4 21:23 headquartered 13:15 headquarters5:13 6:13 health 8:13 10:7,19 11:20 25:22 Hearing4:4 heat 9:6 help 17:2 Hi 13:10 hit-or-miss 12:16 holding 4:21 home 4:2 homes 26:24 hope 4:3 hot 20:9 hours 8:8 huge 19:17 21:14 human 9:24 11:20 hydraulic 9:14

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© 2010 27:20 Y you'll 8:4