# AGA American GasAssociation 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 thecompressors 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 pastuse 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 whetherto 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 greaterthan 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 - eitherat a 50 ppm or 1 ppm threshold. We do not believe it is physically or economically possible to achieve this goal, nor is it necessaryto 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 andservice linesout ofservice thusdisrupting the flow of gas to thecustomer. Inaddition, 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 membergas 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 opportunityto comment.