# "There areliterally millions of pieces ofoil-filledelectrical equipmentin service alonghundreds ofthousands of miles oftransmission anddistribution networks" ,"

# U~WAG UTll.HY SOt.lD WASTE ACIWITIES liROOI'

in concentrations >50 ppm identified after removal from the field is either disposed of and not returned to service or retrofilled before being returnedto service, Thispracticehelps 

### ensuretheaccelerated retirement fromserviceof a largeclass of potentially PCB-containing equipment 

### (e,g

.. distribution pole-top and padmount transformers) that could otherwise lawfully be placed back into service, USWAG will continue to actively promote these systematic practices ofvoluntarily identifying and retiring PCB-containing equipment from service, To the extent necessary, USWAG will work with members in identifying efficient and practical means for implementing the above procedures, 

# Developing and Sharing Information to Assist In Identifying PCB-Containing Equipment

An important factor in enabling users of PCB-containing equipment to engage in accelerated PCB phase-down programs is developing the means for identifying the locations ofsuch equipment. This task requires determining what particular pieces of equipment out of the millions currently in service contain regulated levels of PCBs (i.e., >50 ppm), In some cases, readily identifiable equipment, such as Large PCB Capacitors in substations and PCB Transformers previously registered with EPA, has already been removed from service.

Thus, the real challenge facing users of PCB-containing equipment is developing the means for accurately identifying the potential locations of the remaining equipment still in service, This challenge cannot be understated, There are literally millions of pieces of oil-filled electrical equipmentin service along hundreds ofthousands of miles oftransmission and distribution networks where there is no certain 

### way- absentconfirmatory testing or physical inspection of each piece of equipment

- to ensure that all of the remaining PCBcontaining equipment is identified, Aside from the practical obstacles, undertaking such a testing program could damage or compromisethe integrity of cover gaskets and/or other equipment components and increase the risk of outages, Compounding this challenge is the fact that the surviving PCB-containing equipmentcomprises an extremelylowpercentageof the total amount of electrical equipment currently in service, And, as noted above, the per-unit cost of identifying and removing this equipment increases dramatically as such equipment continually becomes a smaller portion of the total universe of active electrical equipment.

To assist entities in identifying existing PCB-containing equipment still in service, USWAG is committed to working with its members in shariog information regarding the potential locations of this equipment. 1his goal can be achieved in various ways, such as conducting workshops to share and discuss information concerning sources of PCBs,

or methods of identifying equipment likely to be PCBcontaminated, In addition to sharing this information with its members and other users of PCB-containing equipment in the United States, USWAG will coordinate with EPA and the U.S, Department of State in sharing the information with signatories to the Stockholm Convention to assist other countries in meeting their goals with respect to PCB reductions,



### Page 3

# Assisting Utility Customers with Voluntary Phase-Down Efforts

An important element of a successful nationwide PCB reduction effort is to assist users of PCBcontaining equipment in voluntarily removing such equipment from service. To this end, USWAG is committed to working with its individual utility memhers inpromoting strategies to work with their respective industrial and commercial customers (e.g., "primary metered customers"), who are often owners and operators of PCB-containing equipment. The utilities

can provide technical assistance regarding the appropriate methods for voluntarily removing PCBs from service.



### USWAG was fanned in 1978 and is an association primarily dedicated 10assisting members in the management of wastes and thebeneficial use ofmaterials associated with thegeneration, transmission, 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% ofthe total electric generating capacity ofthe U.S., and service more than 95% of thenation's
consumers ofelectricity and over 93% ofthe nation's consumers ofnatural gas.

October

### 2005 

# Promoting Phase-Down Awareness

USWAG will continue to work with itsmembers to encourage them to communicate the information outlined above to appropriate company personnel so that these objectives

are understood and supported at all relevant levels of the company. 

# Cooperating with Other Industry Groups

USWAG will work with other industry groups that use PCB-containing equipment and encourage these entities to embrace these phase-down efforts, as well.

lfyou have questions regarding USWAG's commitment
to the voluntary phase-down ofPCB-containing equipment, please contact:

Jim Roewer, USWAG's Executive Director jim,roewer@USWAG,orgor 

### (202)508-5645