AGA

American Gas Association

Testimony of the American Gas Association on

EPA's Reassessment of PCB Use Authorizations,

Advance Notice of Proposed Rulemaking

75 Fed. Reg. 17645 (April 7, 2010)

Docket 10 EPA-HQ-OPPT-2009-0757

Chicago Public Meeting

May 18, 2010

Good afternoon, the American Gas Association (AGA) appreciates the

opportunity to comment on EPA's reassessment of the PCB use authorizations under

40 C.F.R. Part 761. My name is Pamela Lacey, AGA Senior Managing Counsel,

Environment.

AGA represents 195 local energy companies that deliver clean natural gas

throughout the United States. There are more than 70 million residential, commercial

and industrial natural gas customers in the U.S., of which 91 percent - more than 64

million customers - receive their gas from AGA members. AGA is an advocate for

natural gas utility companies and their customers. Today, natural gas meets almost

one-fourth of the United States' energy needs.

PCBs are a legacy issue for natural gas utilities. In the mid 20th century, PCBs

were added as a fire retardant to the lubricating oil used in some pipeline compressor

engines and turbines. Lubricating oils containing PCBs sometimes leaked from the
compressors and could be carried downstream into natural gas distribution systems by

small amounts of oily liquid hydrocarbons entrained in the natural gas. Some gas

utilities were unlucky and obtained PCB-contaminated gas supplies from their upstream

supplier in the past. Some were lucky and did not. A few had their own compressors

and used PCBs in them several decades ago. No one has added PCBs to lubricating

oil in compressors for many decades. The terminology of the PCB regulations

awkwardly refers to the "use" of PCBs, but that term does not really fit the situation. We

are really dealing with residual contamination left over from the past use of PCBs, and

our challenge is to locate and remove the PCBs in affected systems.

In the Advance Notice of Proposed Rulemaking published on April 7, 2010, EPA

announced that the agency is considering significant changes in the regulations

governing the management of PCBs in natural gas distribution systems.

First, EPA is considering whether to require gas utilities to notify EPA "when

PCBs are found in any pipeline system, regardless of the source of the PCBs or the

owner of the pipeline."

Second, the agency is considering the elimination of all PCBs at greater than or

equal to 50 parts per million (ppm) in all distribution or pipeline systems. 2

I will briefly address each in turn. First, we do not object to providing information

to EPA about PCBs in natural gas distribution systems, but we have serious concerns

I 75 Fed. Reg. at 17653.

2 1d.
about the potential scope of the reporting requirement. Gas utilities that have found

PCBs in their systems have been following the requirements under Part 761 to

characterize where they have found PCBs in their systems. The resulting

characterization plans are quite detailed and are available to EPA for inspection, as

required by Part 761. We suggest that the agency refer to these plans for information

about past testing results, and that any new reporting requirement would be

prospective. In addition, it is important to define and narrow the scope of what would be

reported and when. The goal should be to reach a balance that provides the

information the agency needs, without imposing unnecessary burdens and costs on gas

utilities and their customers.

Second, we have serious concerns about your potential requirement to remove

all PCBs from transmission and distribution pipeline systems by 2020 - either at a 50

ppm or 1 ppm threshold. We do not believe it is physically or economically possible to

achieve this goal, nor is it necessary to protect the public health. The small amount of

PCBs that remain in the distribution system are actively monitored and managed so that

they are contained within the system and actively removed when found. It is not

possible to use robotic "smart pigs" to clean distribution systems, because the pipes are

too small, the gas mains under the urban street grid have too many tight turns, and

there are no traps to recapture the pigs. Certain types of solvent can be used to

decontaminate pipes that have been removed for disposal, but solvent cannot be

injected in live distribution systems withouttaking the mains and service linesout of service

thus disrupting the flow of gas to the customer. In addition, solvents can damage plastic

pipes and cause serious public safety issues.
Over time, PCBs have been and will continue to be removed as our members

remove hydrocarbon liquids from scrubbers, drips and filters. But the only way to

accelerate this process to meet a hard 2020 deadline would be to remove and replace

millions of miles of distribution pipes at astronomical cost and disrupting service to

millions of homes and businesses. And for what purpose? There is no exposure risk to

justify this measure. PCBs do not move within the low pressures and low velocities of

natural gas distribution system unless oil is present, and our member gas utilities

remove the small amounts of oil from the systems. Small amounts of oil in low pressure

and medium pressure systems are undetectable and are only discovered when the line

is taken out of service. To require the lines be cleaned of these traces of PCB by 2020

is impossible unless all lines are replaced. Current practices under the existing

regulations are working to remove the small amounts of oily pipeline condensates and

to protect people from the residual PCBs that remain inside the pipes. AGA strongly

opposes EPA's proposal to require the removal of virtually all trace of PCBs from

pipeline systems by 2020.

AGA plans to file written comments on the Advance Notice. We urge EPA to

extend the comment period by at least an additional 90 days to allow stakeholders to

provide the data EPA will need to make an informed decision, based on science.

Thank you for the opportunity to comment.