# Utility Solid Waste Activities Group

MemberCompany PCB Reduction Efforts

2006 Update

Since the last update in 2004, electric and gas utility membercompanies of the Utility Solid Waste Activities Group (USWAG) have continued with a wide range of voluntary PCB reduction efforts, both within the Great Lakes Basin and in other regions of the country. At the last USWAG PCB Committee meeting in Columbus, Ohio in April 2006, attendees reaffirmed that most USWAG companies have procedures in place to ensure that virtually all equipment containing PCBs in concentrations> 50 ppm identified during repair/servicing, are disposed and/or retrofilled and not returned to service as PCB-regulated equipment. These reduction efforts, combined with voluntary retrofill/reclassification programs, are resulting in the continued reduction of PCB-containing equipment from utility inventories across the country. The achievements of USWAG members are significant becausethey help demonstrate that the United States is fulfilling its obligations under the Stockholm Convention on Persistent Organic Pollutantsto "make determined efforts" to identify and remove PCB equipment (.;:: 500 ppm PCBs) from use by 2025, and to "endeavorto" identify and remove PCB-contaminated equipment (.;:: 50 but < 500 ppm PCBs) from use by 2025.

In addition to the systematic retirement of PCB-containing equipment identified during repair/servicing, USWAG member companies also undertake, where practical, dedicated efforts to identifyand remove PCB-containing equipmentfrom service.

For example, Ameren, which serves 2.4 million customers in Missouri and Illinois, has voluntarily removed all large PCB capacitors from its system. Large oil filled in-service electrical equipment 

### (i.e., substation, networktransformers and generating station equipment) have been tested for PCB concentration and either replaced or reclassified to at least below 499 ppm PCBs and in most cases below 49 ppm PCBs. Large equipment in-storagefor reuse has been reclassified to below49 ppm PCBs. Large spare bushings have been tested for PCB content, if possible. The majority of the spare bushings with aPCB contentover 49 ppm PCBs (tested and assumed) were sent for disposal. Distribution electrical equipment removed from service is not placed back into service

or in-storage for reuse unless it has a manufacturercertified non-PCB label. Only verified non-PCB distribution equipment is sent for repair.

American Electric Power (AEP), with more than 5 million customers and celebrating its 100th anniversary in 2006, continues to achieve excellent PCB use reductions in its 11-state service territory of Arkansas, Indiana, Kentucky, Louisiana, Michigan, Ohio, Oklahoma, Tennessee, Texas, Virginia, and West Virginia. Within the Great Lakes Basin, AEP has no known PCB Transformers or PCB large capacitors. In calendaryears 2005-2006, AEP removed from itsserviceterritories in EPA Regions 3 through 5 the following items: 207 PCB large capacitors, 544 PCB items containing 

### 2:. 500 ppm PCBs (211 being PCB Transformers), 3,046 PCB-contaminated articles (between 50 and499 ppm PCBs), 25,001 non-PCB items and 896 non-PCB large capacitors (between 2 and 49 ppm PCBs). In its EPA Region 6 territory AEP removed 586 PCB large capacitors and 132 PCB itemscontaining ::::: 500 ppm PCBs, 618 PCB-contaminated articles, 738 non-PCB large capacitors and 22,011 non-PCB articles of electric equipment.

Arizona Public Service ("APS") is Arizona's largest and longest-serving electric utility, serving more than one million customers in 11 of the State's 15 counties. APS owns, operates and maintains more than 40,000 miles oftransmission and distribution linesthroughoutArizona. Over the past seven years, APS has been successful in reducing the use of PCBs in electrical equipment by targeting suspected equipment based on manufacturer name and serial numbers. From 2000 through 2004, APS removed 3,212 pieces of PCB 

### (2:.

2 500 ppm) or PCB-contaminated 

### (2:. 50 to 499 ppm) equipmentfrom service, resulting in the disposal of425,336 kg. of PCB material. During2Q05 and 2006 APS hasremoved an additional 6,615 pieces of PCBcontaining equipmentfrom ourtransmission and distribution system representing 583,484 kg. of disposed material, including the following: 5,983 large PCB capacitors (317,458 kg), 287 PCB-contaminated and PCB bushings (29,965 kg), and 345 PCBcontaminated and PCBTransformers (236,061 kg).

Central Maine Power Company (CMP) has continued with its voluntary multi-year effort to remove PCB-containing equipment from its system. CMP has removed all of its known PCB Transformers and sources of PCB oil 2:. 500 ppm, as well as transformers suspected of being PCB-contaminated (50- 499 ppm PCBs) near schools and waterways. CMP continues to actively seek out and remove transformers it believes are most likely to be PCB-contaminated. Since 1999, CMP has removed over 11,000 targeted transformers (up from the 7,700 originally planned), of which approximately half were actually PCB-contaminated.

These PCB reduction efforts are not limited to USWAG members in the Great LakesBasin. For example, in 2005, New Yorkbased Consolidated Edison (ConEd), as part ofongoing maintenance and repair, removed 10,556 lb. of equipmentcontaining 

### 2:500 ppm PCBs and 217,054 lb. of equipmentcontaining 50 to 499 ppm PCBs. Through the third quarterof 2006, ConEd completed its 5-year phase-down project for rectifiers in Manhattan thatformerly contained over 500 ppm PCBs. This final stage removed and disposed of 49,168 lb. of equipment. Additionally, during 2006, as part of ongoing maintenance and repair, ConEd removed 8,325 lb. of equipment containing 

### 2:500 ppm PCBs and 53,874 lb.of equipmentcontaining 50 to 499 ppm PCBs.

Another USWAG member in the Great Lakes Basin, Consumers Energy, has made dramatic progress in voluntarily phasing out PCB-containing equipment. In 1994, Consumers Energy entered into an agreement with EPA Region 5 to phase-out known, large PCB capacitors and large PCB Transformers 

### (i.e., substation equipment) by 2005. Consumers Energy achieved this commitment in 2000. During the last twelve years, Consumers Energy has removed from service, detoxified, and reused approximately347,000 gallons of PCB oil, including approximately30,900 gallons in 2005. Consumers Energy achieved additional phase-outsuccesses in 2005, including removing 89 distribution transformers, approximately2,000 gallons of oil containing less than 500 ppm PCBs, 327 ballasts, 336 distribution capacitors, and 33 bushings from service.

Detroit Edison, a subsidiary of DTE Energy, serves more than 2.1 million customers in Southeastern Michigan. In 2005, during maintenance calls, storm response or reliability improvement, Detroit Edison removed and disposed 82 newly identified PCB Transformers and 459 pieces of PCB-contaminated equipmentfrom distribution and/orgeneration facilities. In 2006, Detroit Edison continues to remove and dispose newly identified equipment through these programs. Through the third quarter of 2006, 48 pieces of PCB equipment and 353 pieces of PCBcontaminated equipment have already been disposed. Detroit Edison also continues to pursue PCB reduction activitiesthrough retrofilling and reclassification of identified PCB-containing equipment.

Duke Energy, which serves 3.8 million electric customers in North Carolina, South Carolina, Ohio, Kentucky and

3 Indiana, has implemented a voluntary PCB phase-down program. Duke Energy has tested all large electrical equipment in its substations, power plants and vaults. Any equipmentcontaining 50ppm PCB oil that was identified in these areas have been removed and replaced with units containing no PCBs, or have been retrofilled to bring the PCB level to < 50 ppm PCBs, or have been upgraded with spill prevention controls to prevent any release to the environment. Because of these efforts, Duke Energy currently has only a few known PCB Transformers**(~500** ppm) in its system, and no PCB large capacitors. As a matter of general policy, when Duke Energy identifies any distribution type equipment containing 50 ppm PCBs, the Company either replaces the equipmentor retrofills the equipmentto bring the PCB level to < 50 ppm PCBs as soon as feasible. Further, in Indiana, Duke has tested all transformers on school properties (K through 

## tz" grade), and anytransformers containing 50 ppm found in these areas have been voluntarily removed and replaced with transformers containing no PCBs.

USWAG member Entergy also has invested substantial resources in implementing a successful PCB phase-out program. In 1998, Entergy dedicated approximately$2 million for the removal of PCB Transformersfrom its Fossil Generating Plants. From 1999-2001, Entergy voluntarily opted to phase out all PCB Transformers from its Fossil fleet. During that span, approximately 105 PCB Transformers were removed 

### fromservice as well as a number of PCB large capacitors. Of Entergy's Fossil Operations in EPA Regions 4 and 6, only 17 PCB large capacitors remain in service. Fossil Operations continues to phase out PCB electrical equipmentwhen possible. Based on analyses of PCB electrical equipment managed for repair or recycle in 2004,approximately 99% of this equipmentwas shown to be non-PCB.

Further, Entergy's Transmission and Distribution system has adopted the policy of many other USWAG members; specifically, no oil-filled electrical equipment brought in for service is returned to operation if it is found to be PCBcontaminated. Entergy'sTransmission and Distribution system also has an aggressive program for phasing out PCB large capacitors in its substations. Over the past 10 years, Entergy has replaced all large PCB capacitors in its Arkansas, Texas and Mississippi substations, and has significantly reduced the number in Louisiana. Entergy'sTransmission and Distribution system has replaced or taken out ofservice all of its known PCB Transformers (i.e., containing 

### 2:. 500 PCBs), with the exception of two units in Arkansas. During 2005, Entergy has taken out of service and disposed of 163,011 kilograms of PCB electrical equipmentcontaining 

### 2:. 50 ppm PCBs.

.

Exelon Energy Delivery (EED), through its subsidiaries ComEd and PECO, operates in Northern Illinois and Southeastern Pennsylvania respectively. EED's phaseout plan for equipmentcontaining PCBs, instituted more than a decade ago, has moved the companyfrom among the largest users of such equipmentto a position of operating only a few pieces. As of November 1, 2006, EED accelerated the PCB phase-out process, and removed 880 PCB large capacitors and 59 pieces of PCB/PCB contaminated equipmentfrom its system. In addition, EED is undergoing a voluntary multi-million dollar project to retire

a substation containing PCB equipment. The projectwas initiated to remove 10 askarel-filled transformers and regulators in the City of Chicago. This equipment contains approximately4,350 gallons of askarel. Through these voluntaryefforts,

4 EED has removed or replaced almostall PCB and PCB-contaminated sources, including all known PCBTransformers in commercial buildings, all known PCB distribution equipmentoutside of substations, 71 percent of all PCB capacitors in PECO substations, and 96 percent of all PCB large capacitors in ComEd substations. A limited number of PCBTransformers remain in service at several of Exelon's nuclear plants. This equipment is monitored and most equipment is scheduled to be replaced or retrofilled over the next five years.

When GRE was formed in 1999, with the consolidation of Cooperative Power Association and United Power Association, much of the PCB 

### (2:. 500 ppm) and PCBcontaminated 

### (2:. 50 to.$. 499) equipment in the system had already been removed or retrofilled. Since its formation, GRE has continued to evaluate and remove or retrofill PCB and PCB-contaminated equipment in its generation and transmission systems. At this time, GRE has evaluated more than 99 percentof its testable in-service equipment. As of 2005, most of the known PCB and PCB-contaminated equipment in theMinnesota system has been removed or retrofilled. The only remaining PCB and PCB-contaminated equipment on GRE's Minnesota system are 3,099 large capacitors at GRE's DC substation. Tnese capacitors will be removed according to a phase-out plan that is scheduled to begin in 2009 and be completed in 2011.

Kansas City Power and Light (KCP&L) has eliminated all known PCB equipment**(~** 500 ppm) from their plants and transmission and distribution systems. Based on experience from its field work, KCP&L estimates that 5% of its distribution equipment may be PCB-contaminated (50 to < 500 ppm PCBs). When these devices

are found, they are removed from service and disposed. KCP&L has been working to eliminate PCB equipment since 1980 and most recently pushed to remove the few remaining PCB-containing devices from service and inventory. All equipment not designated non-PCB is tested when taken out of'service to determine its reuse or disposal status.

National Grid continueswith its ongoing efforts to reduce the numberof PCB articles in its service territories in Massachusetts, NewYork, Rhode Island, and New Hampshire. As a resultof these efforts, National Grid, whose service territory in NewYork includes portions of the Great Lakes Basin, has retrofilled or removed from service all known PCB (:;:: 500 ppm PCBs) Transformers. Additionally, during calendar year2005, National Grid systematically retired or decommissioned approximately 750 pieces of PCB-contaminated or PCB electrical equipment (:;:: 500 ppm) fora PCB reduction totaling over 162,556 kg. National Grid also removed and disposed of approximately315,088 kg. of bulk PCBcontaminated transformeroil.

Northern Indiana Public Service Company (NIPSCO), a subsidiary of

5 NiSource, serves 400,000 customers in Indiana. NIPSCO has continued to implementa voluntary PCB phase-down program that began in1.994. Since the program's inception, NIPSCO has removed

over4,579 pieces of equipmentthat were suspected to contain PCBs, including 56 distribution transformers since 2004. Additionally, NIPSCO has removed from service over99.9% of the PCB quantity present in its electrical system. NIPSCO continues to address the small numberof transformers and capacitors in its system that are known or suspected to have PCB concentrations:;:: 50 ppm. In addition to removal and disposal, NIPSCO enhances its PCB reduction efforts by retrofilling and reclassifying large PCB or PCBcontaminated transformers to non-PCB status.

PNM Resources (PNMR), which serves

more than 680,000 customers in ourservice territory of EPA Region 6 through its subsidiaries Public Service Companyof New Mexico and Texas/New Mexico Power has implemented a voluntary PCB phasedownprogram since. the early 1990s. Since 2000, PNMR has removed the following

. itemsfrom service: three PCB large capacitors, 52 PCB Transformers and 28 other PCB articles (:;:: 500 ppm PCBs); 435 PCB-contaminated articles (:;:: 50 and 

### < 500 ppm PCBs); andan additional 1530nonregulated PCB-containing equipment (> 2 and <50 ppm PCBs).

In particular, during 2004, PNMR removed four PCBTransformers (:;:: 500 ppm PCBs); 38 PCB-contaminated articles**(~** 50 and < 500 ppm PCBs); and an additional 245 nonregulated PCB-containing equipment (> 2 and <50 ppm PCBs). During 2005, PNMR removed 11 PCB Transformers and one other PCB article (:;:: 500 ppm PCBs); 99 PCB-contaminated articles (:;:: 50 and < 500 ppm PCBs); and an additional 191 nonregulated PCB-containing equipment (> 2and< 50 ppm PCBs). During 2006, PNMR removed five PCBTransformers and one other PCB article (?.,500 ppm PCBs); 91 PCB-contaminated articles**(~** 50 and**<;~500** ppm PCBs); and an additional 268 nonregulated PCB-containing equipment (> 2 and < 50 ppm PCBs).

Potomac Electric Power Company (Pepco) is engaged in the transmission and distribution of electricity in Washington, D.C. and major portions of two counties in suburban Maryland. Pepco's service territory covers approximately 640 square miles and has a population of approximately 2 million. As of December 31, 2005, Pepco delivered electricityto approximately 747,000 customers. Pepco has approximately 3,300 networktransformers in high-density residential areas and approximately 4,000 pad mount transformers located in urban settings. Pepco continues to phase down PCBs by removing PCB-containing equipment, such

as istribution and transmission transformers, oil circuit breakers; bushings, and PCB large capacitors from its substations. Pepco implemented a voluntary program to remove PCB large capacitors from substations and replace them with non-PCB capacitors. Since 1990, Pepco has replaced PCB large capacitors with non-PCB capacitors. There

are less than 600 PCB large capacitors at substations, down from approximately3,600 in 1990. Pepco retrofills and reclassifies PCB and PCB-contaminated Transformers to non-PCB status. Pepco has also installed station service transformers containing Envirotemp FR3 Fluid, a nonhazardous seed-based oil.

In South Carolina, South Carolina Electric 

### &Gas (SCE&G) has an ongoing, voluntary PCB reduction effortto remove PCBs from electrical equipment. SCE&G provides electric service to 620,000 retail and wholesale customers throughout South

6 Carolina. Through the early 1990's all large powertransformers and regulators were retrofilled and reclassified as non-PCB «50 ppm) or replaced with non-PCB transformers. All known PCB distribution transformers**(~500** ppm PCBs) have been removed from service for disposal. In addition, all large PCB capacitors in SCE&G's transmission and distribution system have been replaced with non-PCB capacitors. SCE&G also has a longstanding policy to remove from service for disposal all in-stock distribution transformers (small pole and pad mount units) that are identified through testing as PCB-contaminated**(~50** to 499 ppm PCBs) and replace the equipmentwith units containing no PCBs. 

### Asa resultof SCE&G's commitmentto the phase-down policy, through time, SCE&G's inventoryof

more than 236,822 distribution transformers will contain fewer and fewer "unknown" assumed to be PCB-contaminated units. In the late 1990's SCE&G had over70,000 "unknown" transformers in service or instock. In 2006, fewerthan 53,444 "unknowns" remain in SCE&G's inventory. SCE&G's ongoing efforts to remove PCBs when identified resulted in the disposal of 64 transformers, 54 oil-filled bushings, 60tar-filled bushings, 12 tar-filled potential transformers and 3 oil circuit breakers in 2005. In addition, SCE&G manages all leaking and non-leaking "unknown" small capacitors and lamp ballasts as PCB wastes.

USWAG member

### TXU has, since the early 1990s, aggressively pursued removal of PCBs from its system and, since 1993, has retired 3,457 pieces of PCB equipment (2:,500 ppm). With the exception of a small quantityof specialized equipment, TXU has a policy of retiring all distribution equipment identified for repair or service with PCB concentrations> 1 ppm. During 2005, TXU retired 149 pieces of electrical equipment containing 2:, 500 ppm PCBs, 713 pieces of electrical equipmentthat were PCBcontaminated (50- 499 ppm PCBs), and 3,717pieces of equipmentcontaining 1 to 49 ppm PCBs.

Vectren Corporation (parentof Southern Indiana Gas and Electric Company), which provides electricservice to customers in SW Indiana, has been phasing PCBs out of its system for over two decades. The majority of substation transformers were retrofilled or replaced between the mid-1980's to the early 1990's. As of November 1, 2006, only three pieces of oil filled substation equipment (circuit breakers, regulators, capacitors, ortransformers) are known to be PCB-contaminated and they are scheduled to have the oil replaced in early 2007. On the distribution side, steps were taken in the past five years to remove 42 known submersibletransformers from the system that typically contained oil in the range of 50-500 ppm PCBs. Two units remain in service due to the propertyowner's reluctance to allow for the removal but efforts to gain access are on-going. It is also the company's practice to notattempt repair on any unit that was manufactured prior to 1980. Any unit that is damaged or otherwise taken out of service and is pre7 1980, is tested todetermine the appropriate disposal option.

We Energies, servinq-rnore than 1.1 million electric customers in Wisconsin and Michigan, has conducted a voluntary PCB phase-down program for more than a decade. Due to the successful implementation of this program, the company has just eight known PCB Transformers in service in EPA Region 5, all of which are in service at its nuclear plant. This equipment ismonitored and periodically reviewed for reclassification or replacement. No other known PCB (2:, 500 ppm) equipment is in service in the We Energies system. Since January 1999, We Energies has removed from service more than 1,300transformers, large capacitors and bushings containing 2:, 500 ppm PCBs. It is We Energies' general practice that equipment identified as containing 2:, 50 ppm PCBs is either replaced or is reclassified as non-PCB prior to return to service.

USWAG memberXceJ Energy (Xcel), which serves customers in the northern Midwest, including Michigan, Minnesota, North Dakota, Wisconsin, and South Dakota, also has undertaken voluntary PCB phase-out efforts. During 2006, Xcel removed four known PCBTransformers from service. In addition, Xcel removed 39,008 kg of PCB articles, containers, oil and equipmentcontaining 2:, 500 ppm PCBs and 295,785 kg of equipmentcontaining 50 to 499 ppm of PCBs from service.

### USWAG wasformed in 1978 and is an association primarilydedicated to assisting members in the managementof wastes and the beneficial use of materials associated with the generation, transmlsslcn, and sale of electricityand natural gas. USWAG is comprised of approximately80 individual utilities, energycompanies, and energytrade associations. Together, USWAG members represent morethan 85% ofthe total electric generating capacity ofthe U.S.,and service morethan 95% ofthe nation's consumers of electricityand over93% of the nation's consumers of natural gas.

Formoreinformation on USWAG's PCB reduction efforts, pleasecontactUSWAG Executive DirectorJim Roewerat202/508-5645orjim.roewer@uswag.org.

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