USWAG Meeting

April 27, 2010 Attendees: Mary Davis

– American Electric Power James Roewer
- USWAG Lynn Vendinello

– EPA/OPPT John Smith

– EPA/OPPT Peter Gimlin

– EPA/OPPT Christine Zachek

– EPA/OPPT
In our comments, we will be requesting an ex tension of the comment period, based on the number of questions in the ANPR, and the fact that it is a complex is sue with complex questions. We need time to gather information, the sooner we know if there will be an extension, the sooner we can triage whic h questions will get answered. We will ask for 90
- day s, and will not ask for another extension. It is easier to plan a response if we know sooner whether an extension request will be granted. If there will not be an extension, EPA should tell the regulated community what is important, so they

can focus their attention, as some questions may or may not apply to them. EPA would like to know how many pieces of PCB

- containing equipment the utilities have out there and the costs of phasing them out. This is a difficult question because there is equipment that contains PCBs that we don’t know about. You have to have some sense of the proportion of PCB

- containing equipment based on the number taken out for service
. EPA cannot equate the number of pieces of PCB
- containing equipment that we are se eing to the costs of going out and finding this equipment
. The Aska re l transformers were made with PCBs and name

- plated by the companies

. We know where those are. We removed 62 in multi
- story buildings at a lot o f cost. Sections 5 and 14 that ask for data on populations, we don’t know if these questions are “answerable.” T he higher concentration material seems to be the most important. For the definitional changes, where are these numbers coming from? The Stockholm C

onvention
. We want to be consistent with Stockholm whether we are a party or not, as government policy.But the Stockholm language is to “endeavor to identify and remove from service
. ” What do we need to demonstrate to you that the voluntary programs are working? T he disposal records are showing downward trends. T he registration database is staying consistent, and that is why we are asking these questions. We need that information and right now there is no deadline to collect it. Utilities are the leaders in collecting this information, and others are far behind, including the federal government. When we use “equipment” in the ANPR, we do not mean utilities specifically. Has the transformer database been corrected? We sent the entire database to Doug Green and we have not gotten any comments yet. We have to keep a record of the facilities, and we have to keep track of the status of the equipment and where everything went. Will there be a mechanism to de
- register units? T he database reflects that when it is updated. W e can get you the data to correct that. F or non - liquid uses, what information would be helpful for obtaining a use authorization? Anecdotal or otherwise. We just want to know what is out there; we didn’t mean to impl y that we were doing use authorizations. It is just a request for information because we don’t know how broad the use of PCBs in caulk has been. What about for excluded PCB products, like used oil? Right now all 2
- 4 9 oil wi ll be regulated and burned in a ccordance with 40 CFR 761.20(e). We would want to know h ow large is this and what would be the impact of changing? We do not sample equipment unless we take it out of service for disposal. We have to ask. In 30 years, a lot of life is gone from this equipment For vintage equipment and failure rates... it is not alway s true that if it fails, it releases PCBs. We cannot count on the fact that if it fails again, it will not release PCBs. I f it fails, it comes out of service.We would think that your members would keep this type of information for insurance

records, and for the purp ose of replacing old equipment. T rying to find out how long this equipment lasts would be helpful. We want to know if equipment fails, does it fail catastrophically? Th ere was much less necessity to keep up records of this in 1978, now there is more reason. We will survey

our members to see if they have insurance and/ or records. Right now, we do not have a need to know where this PCB equipment is. You have thousands of do llars in equipment and you do not know where it is? The field people will know where the new equipment is, based on manufacture dates. It is more likely that the older equipment will have PCBs. Do these have higher failure rates? The repair/shop peo ple tel l us the newer equipment does not last as long. Reclassification does not ty picall y happen on distribution units. Based on Canada’s rule, the Canadian Electrical Association said they cannot go out and identify their PCB
- containing equipment. And they have a smaller universe than we do in the U.S. Would the millions of dollars spent to identify this equipment be worth it to find it? Also, if you sample it, then you destro y it. It will be very costl y in terms of time, labor, safet y precautions, and outages. And Canada is not a third
- world country ; they have the technical capacit y to do it. We will get EPA more information on this in Canada. A few of the terms were unclear in the ANPR. What do y ou mean when you say “regulated” levels? Above 50 pp m. What about “PCB
- contaminated”? 50 to less than 500 ppm “PCB
- containing”? It generally has PCBs in it, no specific concentrations, just used as a catch

- all to mean that PCBs were not purposefully added. For the small
- capacitors and light fixtur es, how would you determine if they contain 1.7 fl oz.? Y ou could use the external dimensions to estimate capacity; you would have to do it by density. We hope to get some information from the manufacturers. Lots of equipment has small capacitors. We don’t know how you’re going to register all those. In section I, number 4 , what does this mean?Is the substitute worse than the PCBs in terms of releases? The release rate of non

-PCBs

compared to PCBs. Does this equipment fail catastrophically more ofte n ? We have to look at alternatives to see if there are any downsides. Do you track substation equipment for insurance purposes? W hat percentage of transformers do you lose to releases? You would track it if it is insured and you would track it because yo u need to replace it. We track spills.