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 extension of the comment period, based on the 

number of questions in the ANPR, and the fact that it is a complex issue with complex questions. 

We need time to gather information, the sooner we know if there will be an extension, the sooner 

we can triage which questions will get answered. We will ask for 90-days, 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 seeing to the 

costs of going out and finding this equipment. 

The Askarel 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 of cost. 

Sections 5 and 14 that ask for data on populations, we don’t know if these questions are 

“answerable.” 

The higher concentration material seems to be the most important. 

For the definitional changes, where are these numbers coming from?

The Stockholm Convention. 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? The disposal 

records are showing downward trends. 

The 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? 

The database reflects that when it is updated. 

We can get you the data to correct that. 

For 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 imply 

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 2-49 oil will be regulated 

and burned in accordance with 40 CFR 761.20(e).

We would want to know how 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 always true that if it fails, it releases PCBs. 

We cannot count on the fact that if it fails again, it will not release PCBs. 

If 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 purpose of replacing old equipment. Trying to find out how long this 

equipment lasts would be helpful. We want to know if equipment fails, does it fail 

catastrophically? There 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 dollars 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 people tell us the newer equipment does not last as long. Reclassification does

not typically 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 destroy it. It will be very costly in terms of time, labor, safety precautions, and

outages. And Canada is not a third-world country; they have the technical capacity 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 you mean when you say “regulated” 

levels? 

Above 50 ppm. 

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 fixtures, how would you determine if they contain 1.7 fl oz.? 

You 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 often? We have to 

look at alternatives to see if there are any downsides. 

Do you track substation equipment for insurance purposes? What percentage of 

transformers do you lose to releases? You would track it if it is insured and you would 

track it because you need to replace it. 

We track spills.