Testimony ofMary E. Davis

American Electric Power

Polychlorinated Biphenyls (PCBs); Reassessment of UseAuthorizations

Public Meeting - EPA Region 2

290 Broadway, New York, New York

May 4,2010
Good afternoon. My name is Mary Davis. I am the principal environmental specialist at

American Electric Power (AEP) in Shreveport, Louisiana. During the course ofmy 3 l-year

career at AEP, I have served as an internal PCB auditor for the company and currently am the

senior subject matter professional responsible for PCB compliance and operational guidance for

AEP system-wide. Also, since 2001 I have served as Chair ofthe PCB Committee for the Utility

Solid Waste Activities Group ("USWAG"), a trade association of power generation, transmission

and distribution companies. The USWAG PCB Committee has interacted closely with EPA for

the past 30 years regarding all aspects ofthe PCB regulations as they relate to electric and gas

company operations. Over the past three decades, I have come to know many ofthe dedicated

EPA professionals who work diligently to administer the day-to-day aspects ofthe PCB

program.

While I am Chair ofthe USWAG PCB Committee, my testimony today is on behalf of

my company, AEP. Given my limited time and the broad scope and magnitude ofthe ANPRM, I

am going to limit my testimony to three critical issues: the need to extend the comment period to

provide adequate time for a thoughtful response from the regulated community; the problematic

assumption that utilities have already or can easily identify all PCB-regulated equipment within

their systems; and the misconception that equipment is more likely to release PCBs as it ages.

AEP would like to respectfully state:

1. We need more time. The ANPRM raises an overwhelming number of complex issues

and asks over 200 questions on a wide array ofPCB-inventory, management and related matters.

AEP staffmust work this voluminous data response into our already full-time responsibilities

and it is simply not practical to effectively and thoroughly respond to such an immense and

varied array ofissues in such a short time period. Given the importance ofthis rulemaking
Testimony ofMary E. Davis, American Electric Power

EPA Public Meeting - Reassessment ofUse Authorizations for PCBs

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initiative, it is critical that EPA give everyone potentially affected enough time to gather and

provide the Agency with accurate information. Too much is at stake to rush this rulemaking, so

an extension ofthe comment period clearly is warranted and needed.

* * * * *

2. Identifying all PCB-regulated equipment is problematic. The ANPRM assumes that

measures like mandatory phase-out or marking of all known or assumed PCB Articles should not

be that burdensome because companies should be able to readily identify all ofthe PCBregulated equipment in their systems; however, it will be.

The existing PCB regulations have never required owners to identify PCB- regulated

equipment, precisely because EPA recognized that it would be too difficult and cost too much.

EPA now believes that owners already should have implemented a plan to locate any regulated

equipment through the use of bar codes, scanning equipment, global positioning systems or other

means. Over the last 30 years since the PCB regulations were implemented, AEP has made

significant strides in reducing the number of PCB-regulated articles in our system, including

identifying and removing the most accessible equipment. However, AEP cannot state at this

time where every piece of PCB-regulated equipment in the system is located.

AEP does take PCB equipment phase-out seriously though. AEP has been working on a

voluntary and proactive basis to identify PCB-regulated equipment and remove it from service.

In fact, AEP received multiple awards this year and another in 2008 from EPA's National

Partnership for Environmental Priorities for voluntarily removing a combined total of over

96,000 pounds ofPCBs from service at two AEP coal-fired power plants - the Amos plant in

Saint Albans, West Virginia, and the Clinch River plant in Cleveland, Virginia, through the early

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retirement ofPCB Transformer/rectifier sets at these plants. While AEP is obviously proud of

these efforts, we believe that it is important for EPA to understand that the early removal ofjust

these 62 discrete pieces of equipment cost approximately $2.6 million and took over a year of

planning and execution to ensure against compromising our obligation to provide reliable electric

service for the thousands of customers who rely on these facilities for power. In order to sample

all pieces of electrical equipment throughout AEP's 197,500 square mile service territory to

identify what items in fact contain regulated levels of PCBs would be a burdensome, expensive,

and unnecessary undertaking, posing safety, physical, logistical, and reliability hurdles.

AEP knows where certain regulated pieces of electrical equipment are located - such as

known PCB transformers and large PCB capacitors. However, this is not the case for remaining

assumed PCB-Contaminated transformers (such as pole-top and pad-mount transformers) and

other assumed PCB-regulated equipment still in service in AEP's large electrical distribution

system.

As EPA correctly reasoned in 1979 when it established the PCB assumption rules for

electrical equipment, it simply wasn't practical or even readily feasible to determine the PCB

content in the tens ofmillions of pieces of equipment in service across the United States. Such

an undertaking would have come at a massive cost - estimated by USWAG at that time to be

over $6 billion, in 1982 dollars.

The same challenges that EPA recognized in identifying every piece ofPCB-regulated

electrical equipment nearly three decades ago remain today; but today it will be even more

difficult and more expensive. This is because the total number of electrical equipment items in

service has grown dramatically as the AEP system has expanded, while the number of PCBcontaining units has dwindled due to the 1979 ban on PCB production, the subsequent change-

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out of equipment, and our voluntary phase-out efforts. Now the percentage of equipment that

contains PCBs is far less than in 1982. In our opinion, that declining percentage makes it an

even more inefficient use ofresources to search out PCB-regulated equipment before the end of

its useful life. Thirty years ago EPA agreed that such a search would not be necessary, and the

case for not implementing such a search is even stronger today.

In addition to cost concerns, the practical and operational challenges ofidentification are

problematic. As a practical matter, determining what equipment definitively contains PCBs

would require AEP to visually examine most every one ofthe millions of pieces of equipment in

the AEP system and, in many cases, to sample the dielectric fluid in the equipment. We believe

that such an effort would show that only a very small percentage of equipment in service

contains regulated levels of PCBs. To undertake this massive effort will require hundreds of

thousands ofman-hours, millions of dollars in sampling, disposal, and replacement costs, and

outages that would directly impair our obligation to provide continued, reliable power to AEP's

over 5.2 million customers. AEP also has safety concerns about sampling energized equipment.

We would like to point out that the act ofsampling can destroy some equipment, as in the

case of bushings and light ballasts, or compromise its integrity, as would be the case with inservice, energized distribution transformers. To sample fluid in energized distribution pole-top

transformers we would have to use a power activated Ampact-type cartridge gun to puncture an

otherwise intact, perfectly functioning piece of equipment to obtain a sample of dielectric fluid.

Anytime you puncture a piece of equipment, you greatly increase the odds for premature failure

and also increase the odds for releases that would not otherwise have occurred. All padmount

transformers must be de-energized to be sampled.

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Even assuming that it is possible to identify in a practical, cost-effective way every piece

of PCB-regulated equipment, the costs, risks to workers, and service interruptions would far

outweigh any potential environmental benefit.

To the point that the universe of PCB-regulated equipment is declining, in 2008 the AEP

operating subsidiaries disposed/recycled 31,149 distribution transformers and less than half of

one percent were found to contain 500 ppm PCBs or greater. Also in 2008, AEP

disposed/recycled 3,356 large capacitors; only 0.2% ofthose were found to contain 500 ppm

PCBs or greater.

AEP believes that the risk ofreleases from PCB-regulated equipment is far, far less today

than it was in 1982. We believe that it makes no sense to incur enormous costs to track down the

small percentage ofremaining PCB-regulated equipment when the overall risk ofPCB 'releases

from this equipment is much less than the risks were in 1982. Even then, EPA determined there

was no "unreasonable risk" for continuing to use what was then a much larger universe ofPCBregulated equipment. Ifit did not make economic or practical sense to require utilities to identify

a much larger universe ofPCB-regulated equipment in 1982, then why now?

* * * * *

3. Lastly, there is not a correlation between the failure of electrical equipment due to age

and a release ofPCBs. Based on AEP data, there is no basis to say that equipment is more likely

to cause a spill - let alone a release ofPCBs - simply because it is aging. Oftentimes equipment

failure due to age does not result in any spill, and is simply replaced with equipment that

contains no PCBs. In addition to AEP's voluntary and proactive efforts, this natural attrition is

contributing to the ultimate phase-out of PCB-regulated equipment. The integrity of "vintage"

equipment would be compromised by any sampling done to satisfy the suggested identification

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requirements. Those measures would greatly increase the risk ofspills resulting from the

destructive sampling required for PCB analyses of otherwise perfectly intact and non-leaking

equipment.

* * * * *

On behalf ofAmerican Electric Power, thank you again for the opportunity to participate

in this process and to present some of our views on this important rulemaking effort.

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