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
Capital Reporting Company

Meeting 05-18-2010

(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
Capital Reporting Company

Meeting 05-18-2010

(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
Capital Reporting Company

Meeting 05-18-2010

(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.
Capital Reporting Company

Meeting 05-18-2010

(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.
Capital Reporting Company

Meeting 05-18-2010

(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
Capital Reporting Company

Meeting 05-18-2010

(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
Capital Reporting Company

Meeting 05-18-2010

(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.
Capital Reporting Company

Meeting 05-18-2010

(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,
Capital Reporting Company

Meeting 05-18-2010

(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
Capital Reporting Company

Meeting 05-18-2010

(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
Capital Reporting Company

Meeting 05-18-2010

(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
Capital Reporting Company

Meeting 05-18-2010

(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
Capital Reporting Company

Meeting 05-18-2010

(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
Capital Reporting Company

Meeting 05-18-2010

(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
Capital Reporting Company

Meeting 05-18-2010

(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
Capital Reporting Company

Meeting 05-18-2010

(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
Capital Reporting Company

Meeting 05-18-2010

(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
Capital Reporting Company

Meeting 05-18-2010

(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
Capital Reporting Company

Meeting 05-18-2010

(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
Capital Reporting Company

Meeting 05-18-2010

(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
Capital Reporting Company

Meeting 05-18-2010

(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
Capital Reporting Company

Meeting 05-18-2010

(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
Capital Reporting Company

Meeting 05-18-2010

(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
Capital Reporting Company

Meeting 05-18-2010

(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
Capital Reporting Company

Meeting 05-18-2010

(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
Capital Reporting Company

Meeting 05-18-2010

(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
Capital Reporting Company

Meeting 05-18-2010

(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
Capital Reporting Company

Meeting 05-18-2010

(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
Capital Reporting Company

Meeting 05-18-2010

Page 1

(866) 448 - DEPO

www.CapitalReportingCompany.com

 © 2010

$

$52 18:23

$6 19:5

0

084-003957 1:24

1

1 24:15 25:19

1.4 8:24

1:00 1:15

1:34 28:12

10 7:6

10-minute 6:22

10-year 15:21

12th 1:14

13 3:13

14.1 21:18

18 3:4 29:10

18th 1:13

1929 9:1

195 22:17

1970s 17:22 18:1

1976 15:15

1977 9:1

1978 10:5 15:16

1979 11:3

1982 18:23 19:3,10

1984 15:17

1998 18:11

2

2 15:16

2.1 15:7

20 13:20

2005 15:20

2006 17:18

2010 1:13 3:4 5:9

6:4 13:3 21:9,17

24:2 29:10

2020 25:18 26:21

27:12,19

2025 17:12,15

209 8:20

20th 23:4

22 3:14

22,000 15:23

3

3 15:1

3:00 6:23

30 5:22 11:18

15:11

4

4 3:7 15:19

40 22:14

40,000 15:10

400,000 15:9

5

5 2:5 4:3,8 10:23

11:3 13:22

5:00 6:19

50 8:23 16:6 18:9

19:15 24:14

25:18

500 17:11

6

6 6:4

6(e 10:3

6(e)(2)(B 10:14

600,000 16:1

64 22:22

6th 12:21

7

7 3:10 5:9 24:2

70 22:19

761 22:14 24:24

25:4

77 1:13

7th 5:15 6:15

8

80 16:22

9

90 27:22

91 22:21

A

ability 5:20 20:14

accelerate 26:20

accepting 6:3

access 15:18

achieve 20:15

25:21

achievement 16:20

across 6:2 18:21

19:8

actively 25:24 26:2

activities

10:17,21,23

16:19

actual 11:13

acute 9:20

add 7:20 24:15

added 23:4,17

adding 4:24

addition 5:24 6:16

14:15 19:17 25:9

26:14

additional 5:1

27:22

address 24:17

addresses 6:14

adjourned 28:12

administrative

19:17

advance 1:4,10

8:18 14:4 27:21

advanced 5:6 24:1

advocate 22:23

affected 23:24

aforesaid 29:12

afternoon 13:13

22:11

AGA 22:16,17,23

27:17,20

agency 17:18

24:3,12 25:5,12

Agency's 5:10

ago 18:18 23:16

allow 27:22

alone 18:22 22:1

already 8:8

alternatives 12:11

am 4:6 14:3 22:15

America 28:4

American 16:24

22:10,11

among 16:14

amount 25:23

amounts 23:10

27:6,7,15

ample 7:7

analysis 21:20

analytical 21:2

and/or 5:6 14:24

announced 24:3
Capital Reporting Company

Meeting 05-18-2010

Page 2

(866) 448 - DEPO

www.CapitalReportingCompany.com

 © 2010

ANPR 5:8 6:20

ANPRM 14:17

20:12

answer 5:13 13:7

anticipate 13:3

anticipated 8:19

17:4

anything 13:3

applications 9:5

applied 18:15

applies 12:7

appreciate 5:17

appreciates 22:12

approach 14:9

16:13

approximately

1:15 6:22 8:24

16:22

April 5:9,15 6:15

24:2

arbitrary 11:9

20:11

areas 15:19

assessment

11:4,22

associated 21:10

Association 16:24

17:1 22:10,12

28:4

assumption 18:14

assumptions

18:12,15

assured 21:13

astronomical

26:23

attendance 7:21

attending 4:19

7:22

attention 12:13

audits 13:21

author 10:10

authority 8:13

10:2

authorization

11:6,8,11,13,14,

17

authorizations

1:3,10 4:22 5:11

10:10 11:2 14:6

15:12 22:14

authorize 10:15,22

authorized 5:23

9:11 12:2

available 5:13

7:10 25:3

away 7:18

awkwardly 23:19

B

background 6:20

7:16 8:10

balance 25:11

ban 15:12,16

bans 10:3

bar 18:6

based 10:6 14:1

27:24

BEAL 28:5

become 17:6

begin 6:19

beginning 1:15

15:15

behalf 22:5

believe 25:20

benefit 21:6 22:3

benefits 17:17

best 12:23

better 5:20 16:19

bill 22:2

billion 8:24 19:5

billions 18:20

bills 21:24

Biphenyls 1:2,9

board 6:11

borne 21:14

Boulevard 1:14

Bradley 2:14

branch 2:4,8

4:7,8,15

break 6:22

brief 8:6,7

briefly 24:17

broad 20:5

broadly 12:18

brought 12:10

burden 11:12,14

19:18 22:2

burdens 25:13

Bureau 21:16

burn 20:9

burning 9:21

business 15:1 21:6

29:8

businesses 14:20

27:1

C

C.F.R 22:14

cap 15:17

capacitors

15:18,22,23

capacity 12:9

13:20

capricious 11:9

carbonless 9:15

carcinogen 10:1

carried 23:8

case 4:1

caulk 9:16 12:15

cause 26:15

ceased 15:15

century 15:4 23:4

certain 10:20

11:17 17:19 18:2

26:9

Certified 29:18

challenge 23:23

challenges 19:20

changed 11:19

changes 24:4

characterization

25:2

characterize 24:24

charged 18:23

chemical 4:16 7:15

8:21

Chemicals 2:3,4,9

4:7

Chicago 1:14 4:2

29:8

Chief 2:3,7 4:7,14

children 22:1

chloracne 9:22

choice 20:14

chronic 9:20,22

citizens 21:23

City 29:8

clarifying 5:14

13:6

clean 22:18 26:4
Capital Reporting Company

Meeting 05-18-2010

Page 3

(866) 448 - DEPO

www.CapitalReportingCompany.com

 © 2010

cleaned 27:11

Coast 5:1

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 8:22

22:20

Commissions

20:18

committed 16:12

communication

13:22

companies 14:22

16:22 22:17,24

company 13:17,21

14:18 15:15

company's 15:22

completed 15:20

compliance

13:18,21

compounds 8:21

compressor 23:6

compressors

23:8,15,18

compromise 20:14

concentration

10:13 18:11

concentrations

12:19 16:5

17:11,19,23

concerns 20:8

24:20 25:15

condensates 27:15

conditions 10:11

conduct 19:12

21:1

conductivity 9:8

congeners 8:21,23

consequence 20:5

consider 4:24 5:19

consideration

12:23

considering 8:14

24:3,7,12

Consolidated

14:22

consortium 16:21

contain 8:22

contained 26:1

containing 18:9

23:7

contains 16:4

29:13

contaminants

17:20

contamination

23:22

contemplates 14:5

content 5:14 18:20

continue 26:18

continued 20:22

continuing 11:2

convention 17:5,7

Cook 1:12 2:17

3:13 13:10,13,14

Cooperative 16:24

copy 9:16

core 20:15

correct 29:11

cost 19:1,4 20:21

21:1,9,14,19

22:2 26:23

costs 12:4,5,9

18:24 21:8 25:13

Counsel 22:16

country 6:2 16:15

County 1:12 29:3

court 7:9 11:7

29:7

creating 17:16

crew 21:1

critical 19:23

CRR 1:23

CSR 1:23

current 4:22 11:16

14:5 21:9 27:13

currently 12:2

customer 21:21

26:14

customers 14:14

15:2,7 19:24

20:16 21:2

22:21,22,24

25:14

cutting 9:15

D

Daemian 2:12

damage 26:15

data 5:6 12:16,17

13:4 27:23

date 10:24

day 1:13 28:9,10

days 27:22

day-to-day 18:15

deadline 15:19

19:16 26:21

deadlines 20:11

dealing 23:21

decades 23:16,18

decision 27:24

Decisions 21:19

declined 17:21,24

decompose 9:5

decontaminate

26:10

de-energizing

19:24 20:7

define 25:9

deliver 5:5 22:18

delivered 6:17

delivery 6:13

demonstrate 17:3

Deralyn 1:11,23

29:6

destroyed 16:1

21:4

destroying 20:24

detailed 25:3

determine 11:17

18:19

determined 10:20

17:9

Detroit 13:16

14:21

15:5,8,12,17,20

16:7,12 17:9

18:5,22

19:7,12,21

developing 21:9
Capital Reporting Company

Meeting 05-18-2010

Page 4

(866) 448 - DEPO

www.CapitalReportingCompany.com

 © 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

disorders 9:23

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

docket 6:5 7:10

12:24

documented 14:10

done 9:19 13:19

downstream 23:9

drips 26:19

DTE 13:11,15

14:9,16,18 22:5

duly 29:6

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

either 25:18

elasticity 9:7

electric 16:23

20:16 22:1

electrical 9:8

12:3,8 14:24

15:9 18:13,20

19:23

electricity 15:6

electrocution

20:10

electronically

12:24

elimination 24:13

e-mail 7:23

employees 14:13

enclosed 10:17,21

encourage 6:15

endeavoring 17:14

endorsements

4:10

energy 13:11,15

14:16,18,20

22:5,17 23:2

Energy's 14:9

Engineer 13:11,15

engines 23:6

ensure 19:14

entrained 23:11

environment 5:21

9:3 10:8,19

11:20 14:11

18:17 21:7 22:16

environmental

12:11 17:17 18:2

EPA 2:5,10,14 3:9

4:3,12,24 5:12

6:3,13 10:14,20

11:1,8 13:19

18:11

24:2,7,8,19 25:3

27:21,23

EPA-HQOPPT-2009-075

7 6:6

EPA's 4:21 10:6

14:3,17 17:17

22:13 27:18

equal 16:6 24:13

equipment

12:1,2,3,5,8

14:7,14 15:9,16

16:3,8,11,14

17:11,15

18:9,13,21,24

19:14,21

20:1,6,22

establish 11:14

established 13:24

15:13

estimate 9:2

estimated 19:3

events 12:6

everybody 7:7

everyone 13:13

EXAMINATION

3:6

examine 11:1

example 12:9

exceeded 15:13

except 13:4

exceptions 10:6,9

excerpt 29:13

existing 11:8 27:14

expert 13:18

exposure 19:9 27:2

extend 12:22

27:21

eyes 9:21

F

face 9:21

facilities 13:21

failure 12:4

farther 7:4

fatal 20:9

feasible 18:19

Federal 5:15 6:15

feed 21:24

Fibers 2:7 4:14

field 19:18,19

figures 21:9

file 27:20

filters 26:20

final 10:24 20:20

finding 10:6 11:10

fire 23:5

first 4:14 11:21

20:7 21:5

24:7,18 29:6

fish 17:21
Capital Reporting Company

Meeting 05-18-2010

Page 5

(866) 448 - DEPO

www.CapitalReportingCompany.com

 © 2010

fit 23:21

Floor 1:14

flow 26:14

fluids 9:14

force 20:13

foregoing 29:11

form 10:10

formerly 21:3

formulations 8:22

frame 8:19

fulfillment 17:4

functioning 20:23

future 7:24

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

gather 4:21

general 16:3

generally 10:3

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

grocery 21:24

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

hard 26:21

haven't 7:20 8:2

having 4:4 21:23

headquartered

13:15

headquarters 5:13

6:13

health 8:13

10:7,19 11:20

25:22

Hearing 4:4

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

hydrocarbon

26:19

hydrocarbons

23:10

I

I'd 13:6

identification 19:4

identify 17:10,14

identifying 18:7

I'll 8:11

Illinois 1:12,14 4:2

29:1

I'm 4:11 6:7,8 7:1

8:5 13:14,23

impact 12:5 14:12

21:21 22:7

impacts 12:11

implement 19:18

implementing

14:6 19:8

important 9:4

22:8 25:9

importantly 8:17

imposed 20:17

imposing 25:13

impossible 20:13

27:12

improvement

14:11

Inc 2:12

include 9:23 21:20

included 10:11

includes 9:10

including 17:20

inconvenience

21:2

indicates 21:17

industrial 9:4 15:1

22:20

industry 19:4

inform 5:20

information

5:6,19 7:23 8:17

11:22,24 21:11

24:18 25:6,12

informed 27:24

initiated 5:9

initiatives 17:13

injected 26:11

injuries 20:9

injury 10:7,18

inks 9:17

in-service 19:13

inside 27:17

inspection 25:4

Institute 16:23

insurance 12:4

integrity 20:23

interested 12:12

Internet 7:11

interpretation

13:18

interruption 19:1

interruptions 20:3

Interstate 28:3

introduce 4:12

inventories 19:22

inventory 16:9

18:7 19:12,21

involve 8:15

involved 14:19

irritation 9:21

Isn't 7:11
Capital Reporting Company

Meeting 05-18-2010

Page 6

(866) 448 - DEPO

www.CapitalReportingCompany.com

 © 2010

issue 4:21 23:3

issued 5:8

issues 26:16

item 20:24

it's 5:22 6:19 9:24

11:16

J

Jackson 1:13

jeopardize

20:18,22 21:3

joined 4:11

July 6:4 12:21

justify 27:2

K

key 14:12 18:2,4

kilograms 16:1

Klevs 2:3 3:7 4:1,6

6:10

known 15:21

16:19

L

Labor 21:17

Lacey 2:18 3:14

22:9,11,15

Lakes 17:18,24

Land 2:4

large 15:17

large-scale 20:2

largest 14:21

late 17:22

lately 12:13

later 6:18 11:18

leaked 23:8

least 5:22 27:22

legacy 23:3

lengthy 20:2

less 11:9,13

LICENSE 1:24

likely 20:4

limit 7:6

limited 5:23

limits 10:13

line 13:3 27:10

lines 26:13

27:11,13

liquid 12:12 23:10

liquids 26:19

LISA 28:5

list 8:3 9:10

listed 6:14

little 8:9 9:12 11:4

12:15

live 26:11

liver 9:23

local 22:17

locate 23:23

located 15:22

location 10:12

18:8

logistics 7:17

long 9:22

longstanding

18:14

lot 9:18 11:24

12:7,13,16,21

low 9:7 27:3

lower 19:10

low-pressure 27:8

lubricants 9:15

lubricating

23:5,7,17

lucky 23:14

Lynn 2:7 3:10

4:13 6:10

7:14,18

M

mail 6:13

mains 26:5,12

majority 19:20

managed 12:3

26:1

management 2:4

4:7 14:19 24:5

Managing 22:15

mandatory

14:7,13 19:11

21:10,19

manner 10:17

manufacture 10:4

manufacturing

10:15

March 21:17

Mardi 2:3 3:7 4:6

7:19 12:20

material 16:5

matter 13:17

may 1:13 3:4 5:2

6:4 8:8 11:18,19

29:10

measurable 17:17

measure 27:2

medium-pressure

27:8

meet 5:1 26:21

meeting 1:1,8 5:4

6:1,18 29:10,14

meetings 4:20 5:1

6:2 7:24

meets 23:1

member 16:18

27:5

members 2:21

22:23 26:18

men's 7:2,4

mentioned 12:20

metal 12:8

Michigan 13:16

14:22 15:2,7

21:16,23

mid 23:4

miles 15:10 26:22

milestones 15:13

16:20

million 15:1,7 16:6

17:12 18:10,23

19:15 22:19,22

24:14,16

25:18,19

millions 26:22,24

minutes 7:6

mission 20:15

mixtures 8:22

mobilize 21:1

monitored 17:21

25:24

move 27:3

mutual 14:1

N

namely 9:20

narrow 25:10

nation 19:8 21:18

National 2:8 16:23

nationwide 14:20

natural

22:18,20,24

23:1,3,9,11

24:5,19 27:4

28:3
Capital Reporting Company

Meeting 05-18-2010

Page 7

(866) 448 - DEPO

www.CapitalReportingCompany.com

 © 2010

necessary 25:22

necessitate 20:1

nice 28:10

nonliquid

12:14,19

non-PCB 15:24

16:7 21:5

nontotally

10:17,20

nor 25:21

normally 8:7

notary 1:12

notes 29:12

notice 1:4,10,16

5:7,15 8:18 14:4

24:1 27:21

notify 24:8

O

oath 29:7

object 24:18

objective 11:15

objectives 8:16

obligations 17:4

obtained 23:13

obviously 6:24

Office 2:9 4:16

7:14

offline 12:10

oil 20:9 23:5,17

27:5,6,7

oil-filled 18:9,13

oils 9:15 23:7

oily 23:10 27:15

Okay 7:18 8:5

13:9 28:7

one-fourth 23:2

ongoing 16:3

operating 14:21

16:22

operation 15:3

operations 18:16

opportunity 5:5

22:6,12 28:1

opposes 27:17

oral 14:15

order 11:7

Organic 17:6

Organics 2:8 4:15

Otherwise 13:7

overdue 11:4

overview 8:6

owner 24:10

P

p.m 1:15 6:19,23

28:12

paints 9:17 12:14

Pamela 2:18 3:14

22:9,15

paper 9:16

particular 15:5

particularly 12:3

passage 15:11

past 23:14,22 25:6

payer 21:21

payers 21:15

paying 21:24 22:1

PCB 5:10 8:6,22

10:21 11:17

13:19,21,23

14:7,10

15:12,14,16,17,2

2 16:5,9,16,20

17:11 18:11,20

21:20 22:13

23:19 27:12

PCBcontaminated

16:10 17:15

23:13

PCB-regulated

16:13

PCBs 1:2,9 4:23

5:21 8:11,13,20

9:4,19 10:5,16

12:11,12,14,19

16:1 17:12,20,23

18:2 19:15

23:3,4,7,16,17,2

0,23,24

24:5,8,10,13,19,

22 25:1,16,23

26:17 27:2,16,19

people 4:12 11:5

13:8 27:16

per 16:6 17:11

18:9 19:15

24:14,15

25:18,19

percent 21:18

22:21

perform 13:20

period 5:2 10:23

12:21 27:22

permits 10:14

Persistent 17:5

perspectives 22:7

Peter 4:15,17

phase 14:7

phase-down 17:13

phaseout 15:21

phase-out 14:13

16:14 20:11

21:10,20

physical 20:18

physically 25:20

piece 18:8

pieces 15:9 16:8

18:20 19:14

pigments 9:17

pigs 26:4,7

pipeline 23:6

24:9,11,15 25:17

27:15,19

pipes

26:5,10,15,23

27:17

plan 8:2

planned 19:1 20:2

28:6,8

plans 25:2,6 27:20

plastic 26:15

plasticizers 9:16

plastics 9:7

please 7:24 13:11

pleased 13:23

plus 11:3

podium 13:12

point 8:1 13:22

18:4 20:20

points 14:12

policies 18:14

policy 16:3

Pollutants 17:6

Pollution 2:9 4:16

7:15

Polychlorinated

1:2,8

population 12:1

pose 11:19

poses 20:7

positive 13:24

possible 21:10

25:21 26:3

possibly 9:2 14:6
Capital Reporting Company

Meeting 05-18-2010

Page 8

(866) 448 - DEPO

www.CapitalReportingCompany.com

 © 2010

20:24

potential 5:10

24:21 25:16

potentially 20:2,9

21:4

pounds 8:24

Power 16:24

practical 18:19

practice 4:9

practices 27:13

preregistered 8:3

presence 5:17

present 2:1,20

10:18,21 12:20

27:5 28:4,5

presentation 3:9

6:20 7:6

presentations 6:21

PRESENTATION

S/PUBLIC 3:12

preserves 16:8

pressures 27:3

Prevention 2:10

4:17 7:15

Principal 13:11,14

prior 20:1

proactive 14:9

16:13 19:6

probable 9:24

problems 7:18

proceeding 6:21

proceedings 28:11

29:9,13

process 21:9 26:21

processing 10:4,15

produced 9:1

program 2:8 4:9

8:6 13:23 14:13

16:2 17:22

19:11,19

21:11,20

progress 17:18

18:1

promoted 16:21

proposal 27:18

propose 10:22

proposed 1:4,10

5:7 7:16 8:18

14:4 24:1

prospective 25:8

protect 5:21 25:22

27:16

protective 18:16

provide 5:4,18 6:4

7:7 8:9 9:6 14:23

22:6 27:23

provided 10:5

14:15

provides 25:12

providing 14:16

20:15 24:18

provision 19:23

public 1:1,8,12

2:16,21 3:12

4:4,20 5:5

6:2,3,21,23

7:7,10 11:23

15:18 20:17

25:22 26:16

29:10,14

publicly 7:9

published 24:2

pump 9:15

purchasing 15:15

purpose 5:4 27:1

pursuant 1:15

putting 4:5

Q

QuanTech 2:12

questions 5:14

7:17 13:6

quite 25:3

R

ranging 20:8

rate 21:15,18,21

rates 12:4

re 11:21

reach 25:11

real 18:1

really 23:20,21

reassess 11:16

reassessment 1:3,9

4:22 5:10 22:13

Rebekah 2:17 3:13

13:10,14

recapture 26:7

receive 13:5 22:22

receiving 6:1

receptors 18:3

reclassifying 16:10

Recognizing 19:6

recycling 12:9

reducing 16:9

reduction 14:10

16:20 17:1,16

18:2 19:7,11

22:3

reductions 15:14

16:16

refer 25:5

refers 23:19

refuses 23:19

regarding 5:6

regardless 21:13

24:9

regards 5:21

region 2:5 4:3,8

13:22 16:15

Register 5:15 6:15

regulate 5:20

regulated 14:23

regulations 13:19

23:19 24:4 27:14

Regulations.gov

6:12 7:11 13:1

regulatory 15:19

19:16

related 14:20

relationship 13:24

released 9:3

reliability 20:17

reliable 19:23

20:15

remain 25:23

27:17

remaining 6:2

removal 12:4

15:14 18:24

27:18

remove 11:6,7,12

17:10,14 23:24

25:16 26:18,22

27:6,14

removed 15:17,24

16:4 19:15

26:2,10,18

removing 14:5

repair 10:12

replace 26:22

replaced 15:24

16:7 19:16 27:13

replacement 12:5
Capital Reporting Company

Meeting 05-18-2010

Page 9

(866) 448 - DEPO

www.CapitalReportingCompany.com

 © 2010

Report 17:18

reported 1:23

25:10 29:9

reporter 7:9

29:7,18

reporting 24:21

25:7

represent 17:9

representative

5:12

represents 22:17

reproductive 9:23

requests 12:22

require 19:12 24:8

27:11,18

required 25:4,6

requirement 24:21

25:8,16

requirements

20:12,17 24:24

requisite 22:3

residential 15:1

22:20

residual 23:22

27:16

resistant 9:6

resources 20:21

respect 14:1

respective 14:1

response 14:3

responsibilities

14:2

rest 21:13

restrictions 10:12

restrooms 6:23

result 18:24

resulting 14:10

25:2

results 25:7

retardant 23:5

retrofilling 16:10

reviewing 13:4

risk 10:7,18,22

11:10,20 19:9

22:3 27:2

risks 19:20 21:19

robotic 26:3

roles 14:1

RPR 1:23

rubber 9:17

rule 4:4 8:14,16,18

10:15,24

ruled 11:7

rulemaking 1:4,11

5:7 7:17 10:2

11:15 14:4 22:8

24:2

run 6:18

Rural 16:23

S

safety 4:16 7:15

20:8,19 21:3

26:16

sampling 20:20,21

scale 20:5

Schreiber 2:12

13:10 22:9

28:2,7

science 27:24

scope 24:21 25:10

scrapped 16:6

scrubbers 26:19

sealants 9:16

second 4:20 24:12

25:15

Section 10:3,14

seeing 18:1

seeking 8:18

senior 22:15

sense 18:15 21:6

serious 20:7 24:20

25:15 26:16

serve 13:17

served 13:22

service 16:4 18:21

19:1,24

20:3,7,16

26:13,24 27:10

services 14:20,24

several 8:7 11:23

23:16

severe 12:6

severely 20:14

shared 16:21

shareholder

21:15,22

she's 4:14

shorthand

29:9,12,18

signatory 17:7

signed 7:20

significant 17:2

24:4

simultaneously

16:9

situation 23:21

small 23:10 25:23

26:5 27:6,7,15

smart 26:3

solicit 11:22

Solid 16:18

solvent 26:8,9,11

solvents 26:15

source 24:10

speak 7:5 8:2 13:9

speaker 4:14 28:3

speakers 28:8

Speaking 21:8

species 17:21

specific 10:11

specifically 17:8

18:7

spills 12:6

spoken 6:17 7:8

SS 29:2

staff 13:23

stakeholders 27:23

star 9:12

starting 10:5

state 21:16 29:1

statement 28:6

states 17:19 22:19

23:2

Statistics 21:17

step 11:21

Stockholm 17:5

story 16:16

street 26:6

strongly 27:17

studies 9:19

subject 13:17

submit 6:16 12:24

subsidiaries 14:21

substances 17:23

substations 15:23

success 14:8

successfully 15:8

suggest 19:9 25:5

suggested 20:12
Capital Reporting Company

Meeting 05-18-2010

Page 10

(866) 448 - DEPO

www.CapitalReportingCompany.com

 © 2010

supplier 23:14

supplies 23:13

sure 6:7

sworn 29:6

system 18:8 24:9

26:2

systems 23:9,24

24:6,15,20,23

25:1,18,24

26:4,12

27:4,7,8,19

T

taking 5:17 12:22

26:12

talk 8:11

term 9:22 23:20

terminology 23:18

terms 13:2

test 21:3

testimony 14:15

testing 18:23

19:19 20:1,5,6

25:7

thank 5:16 7:13,19

13:9 22:6,8,9

27:24 28:2,7,10

That's 13:5

there's 6:11 7:21

9:18,19 12:13

they've 9:13

Thirty 18:18

threshold 25:19

throughout 15:2

22:18

thus 26:13

tight 26:6

titled 11:16

today 4:11 6:17

7:8,13 8:14 14:3

19:9 21:24 23:1

today's 6:1,18

topics 11:23

tops 21:18

towards 17:3

Toxics 2:10

traces 27:12,19

transcript 29:11

transfer 9:14

transformers

12:10 15:18

18:12

transmission

25:17

transmits 15:6

traps 26:7

true 29:11

trying 7:2

TSCA 4:9 10:3,14

Tuesday 3:4

turbines 23:6

turn 7:14 8:4 13:8

24:17

turns 26:6

type 18:7

types 8:17,23

12:18 26:9

U

U.S 2:10 9:1

17:3,6 18:21

21:16 22:21

ultimately 14:14

15:23 21:14

undetectable 27:9

undo 11:10

unemployment

21:18

unique 19:20

unit 21:4,5

United 22:19 23:2

units 15:24 16:7

unless 27:5,12

28:9

unlucky 23:12

unnecessary 25:13

Unplanned 20:4

unreasonable

10:7,18,22

11:10,19

untenable 22:4

upstream 23:14

urban 26:5,6

urge 27:21

USWAG 16:19,21

19:3

utilities 14:23 15:3

17:8 18:6

19:8,22 20:13

23:3,12 24:8,22

25:14 27:6

utility 16:14,18,22

19:4 20:18 22:24

utilizes 15:8

V

valuable 5:19 16:8

vandalism 12:7

vast 19:20

velocities 27:4

Vendinello 2:7

3:10 4:13 6:8

7:19

via 6:5,13

viewing 7:11

violate 20:16

virtually 27:18

VOLUME 3:2

voluntary 14:9

15:14,21

16:13,16 19:6

W

Washington 6:14

wasn't 18:19

Waste 16:18

wave 4:17

weather 12:6

we'd 7:22 12:15,17

welcome 3:6 8:5

we'll 6:21 13:7

well-contained

20:23

we're 4:4,5,20

5:24 6:24

8:14,17 11:3

12:12 13:15 18:1

21:8 28:5

West 1:13 5:1

we've 12:21

whatever 7:24

Whereupon 28:11

whether 11:18

24:7

wire 15:10

women's 7:3

wonderful 7:12

workers 20:8,19

21:3

working 13:24

17:3 27:14

write 6:8,10

written 6:3,16

14:16 21:12
Capital Reporting Company

Meeting 05-18-2010

Page 11

(866) 448 - DEPO

www.CapitalReportingCompany.com

 © 2010

27:20

Y

you'll 8:4