Utility Solid Waste

Activities Group

Member Company

PCB Reduction

Efforts

2006 Update

Since the last update in 2004, electric and

gas utility member companies 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 because they help demonstrate

that the United States is fulfilling its

obligations under the Stockholm Convention

on Persistent Organic Pollutants to "make

determined efforts" to identify and remove

PCB equipment (.;:: 500 ppm PCBs) from

use by 2025, and to "endeavor to" 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 identify and remove

PCB-containing equipment from 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, network transformers 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-storage for

reuse has been reclassified to below 49

ppm PCBs. Large spare bushings have

been tested for PCB content, if possible.

The majority of the spare bushings with a
PCB content over 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

manufacturer certified 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

calendar years 2005-2006, AEP removed

from its service territories 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 items containing ::::: 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 of transmission and

distribution lines throughout Arizona. 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) equipment from service, resulting

in the disposal of 425,336 kg. of PCB

material. During2Q05 and 2006 APS has

removed an additional 6,615 pieces of PCBcontaining equipment from our transmission

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 PCB Transformers

(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 Lakes

Basin. For example, in 2005, New Yorkbased Consolidated Edison (ConEd), as

part of ongoing maintenance and repair,

removed 10,556 lb. of equipment containing

2: 500 ppm PCBs and 217,054 lb. of

equipment containing 50 to 499 ppm PCBs.

Through the third quarter of 2006, ConEd

completed its 5-year phase-down project for

rectifiers in Manhattan that formerly

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 equipment containing 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

approximately 347,000 gallons of PCB oil,

including approximately 30,900 gallons in

2005. Consumers Energy achieved

additional phase-out successes in 2005,

including removing 89 distribution

transformers, approximately 2,000 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 equipment from

distribution and/or generation 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 activities through

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

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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

equipment containing 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 equipment or retrofills

the equipment to 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 any transformers

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 Transformers from 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 from service 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 equipment when possible. Based

on analyses of PCB electrical equipment

managed for repair or recycle in 2004,
approximately 99% of this equipment was

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's Transmission 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's Transmission and

Distribution system has replaced or taken

out of service 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 equipment containing 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 equipment containing PCBs,

instituted more than a decade ago, has

moved the company from among the largest

users of such equipment to 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 equipment from its

system. In addition, EED is undergoing a

voluntary multi-million dollar project to retire

a substation containing PCB equipment.

The project was initiated to remove 10

askarel-filled transformers and regulators in

the City of Chicago. This equipment

contains approximately 4,350 gallons of

askarel. Through these voluntary efforts,

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EED has removed or replaced almost all

PCB and PCB-contaminated sources,

including all known PCB Transformers in

commercial buildings, all known PCB

distribution equipment outside 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

PCB Transformers 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

percent of its testable in-service equipment.

As of 2005, most of the known PCB and

PCB-contaminated equipment in the
Minnesota 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 continues with its ongoing

efforts to reduce the number of PCB articles

in its service territories in Massachusetts,

New York, Rhode Island, and New

Hampshire. As a result of these efforts,

National Grid, whose service territory in

New York includes portions of the Great

Lakes Basin, has retrofilled or removed from

service all known PCB (:;:: 500 ppm PCBs)

Transformers. Additionally, during calendar

year 2005, National Grid systematically

retired or decommissioned approximately

750 pieces of PCB-contaminated or PCB

electrical equipment (:;:: 500 ppm) for a PCB

reduction totaling over 162,556 kg.

National Grid also removed and disposed of

approximately 315,088 kg. of bulk PCBcontaminated transformer oil.

Northern Indiana Public Service

Company (NIPSCO), a subsidiary of

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NiSource, serves 400,000 customers in

Indiana. NIPSCO has continued to

implement a voluntary PCB phase-down

program that began in1.994. Since the

program's inception, NIPSCO has removed

over 4,579 pieces of equipment that were

suspected to contain PCBs, including 56

distribution transformers since 2004.

Additionally, NIPSCO has removed from

service over 99.9% of the PCB quantity

present in its electrical system. NIPSCO

continues to address the small number of

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 our service

territory of EPA Region 6 through its

subsidiaries Public Service Company of

New Mexico and Texas/New Mexico Power

has implemented a voluntary PCB phasedown program since. the early 1990s. Since

2000, PNMR has removed the following .

items from 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); and an additional 1530 nonregulated PCB-containing equipment (> 2

and < 50 ppm PCBs).

In particular, during 2004, PNMR removed

four PCB Transformers (:;:: 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 (> 2
and< 50 ppm PCBs). During 2006, PNMR

removed five PCB Transformers 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 electricity to approximately

747,000 customers. Pepco has

approximately 3,300 network transformers

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 approximately 3,600

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 effort to remove PCBs from

electrical equipment. SCE&G provides

electric service to 620,000 retail and

wholesale customers throughout South

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Carolina. Through the early 1990's all large

power transformers 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 equipment with units

containing no PCBs. As a result of

SCE&G's commitment to the phase-down

policy, through time, SCE&G's inventory of

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 over 70,000

"unknown" transformers in service or instock. In 2006, fewer than 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, 60
tar-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

quantity of 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 equipment that were PCBcontaminated (50- 499 ppm PCBs), and

3,717 pieces of equipment containing 1 to

49 ppm PCBs.

Vectren Corporation (parent of Southern

Indiana Gas and Electric Company), which

provides electric service 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, or transformers) 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

submersible transformers from the system

that typically contained oil in the range of

50-500 ppm PCBs. Two units remain in

service due to the property owner's

reluctance to allow for the removal but

efforts to gain access are on-going. It is

also the company's practice to not attempt

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 to determine 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 is monitored 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 1,300 transformers, 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 member XceJ 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 PCB Transformers

from service. In addition, Xcel removed

39,008 kg of PCB articles, containers, oil

and equipment containing 2:, 500 ppm PCBs

and 295,785 kg of equipment containing 50

to 499 ppm of PCBs from service.
USWAG was formed in 1978 and is an association primarily dedicated to assisting

members in the management of wastes and the beneficial use of materials associated

with the generation, transmlsslcn, and sale of electricity and natural gas. USWAG is

comprised of approximately 80 individual utilities, energy companies, and energy trade

associations. Together, USWAG members represent more than 85% of the total electric

generating capacity of the U.S., and service more than 95% of the nation's consumers of

electricity and over 93% of the nation's consumers of natural gas.

For more information on USWAG's PCB reduction efforts, please contact USWAG

Executive Director Jim Roewer at 202/508-5645 or jim.roewer@uswag.org.

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