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 PUBLIC MEETING FOR THE

 POLYCHLORINATED BIPHENYLS (PCBs):

 REASSESSMENT OF USE AUTHORIZATIONS

 ADVANCE NOTICE OF PROPOSED RULEMAKING

DATE: July 22, 2010

TIME: 9:00 a.m.

LOCATION: EPA Region 9

 Hawaii/Nevada Room

 First Floor Conference Rooms

 75 Hawthorne Street

 San Francisco, California

REPORTED BY: MEGAN F. ALVAREZ, RPR

 Certified Shorthand Reporter

 License No. 12470
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1 A P P E A R A N C E S

2

3 MS. LYNN VENDINELLO

4 Chief, Fibers and Organics Branch

5 National Program Chemicals Division

6 Office of Pollution Prevention and Toxics

7 U.S. EPA

8

9 MR. DAEMIAN SCHREIBER, QuanTech Inc.

10

11 PUBLIC COMMENTS BY:

12 ERNIE LUXTON

13 JANET O'HARA

14 JIM BENNETT

15 ATHENA HONORE

16 JON KONNAN

17 KELLY MORAN

18 NANCY HUMPHREY

19 PATRICK HAYES

20

21 * * * * *

22

23

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25
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1 I N D E X

2 EXAMINATION BY: PAGE:

3 WELCOME/EPA PRESENTATION

4

 LYNN VENDINELLO 4

5

6 PUBLIC PRESENTATIONS/PUBLIC COMMENT

7 ERNIE LUXTON 13

8 JANET O'HARA 21

9 JIM BENNETT 27

10 ATHENA HONORE 28

11 JON KONNAN 37

12 KELLY MORAN 41

13 NANCY HUMPHREY 48

14 PATRICK HAYES 51

15

16 * * * * *

17

18

19

20

21

22

23

24

25
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1 P R O C E E D I N G S

2 LYNN VENDINELLO: Good morning. I'm Lynn

3 Vendinello. I am chief of the Fibers and Organics

4 Branch, also we call it soap and towels -- I wish I did

5 soap and towels, but I don't -- in the National Program

6 Chemicals Division in EPA's Office of Chemical Safety

7 and Pollution Prevention Headquarters in D.C.

8 And with me from the region is Arlene Kabei,

9 who is the associate director for the waste management

10 division, and who recently just joined us, the Honorable

11 Jeff Scott, who is the director of the waste management

12 division.

13 Here, in the region, the waste management

14 division implements amongst other things the PCB use

15 inspection enforcement permitting and clean up programs.

16 And they just recently began to oversee the PCB use

17 issues, which is really what we're here about today.

18 This is our fifth public meeting to gather

19 comments on the issue of EPAs, reassessment of its

20 current authorizations for PCB use and distribution in

21 commerce.

22 We added -- there's one final public meeting,

23 which is next week in New York, and it's in the evening.

24 There was a particular interest there to allow parents

25 to come because they've had some issues in New York with
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1 PCBs in caulk. So the -- we're doing it at night.

2 The -- we propose the advance notice of

3 proposal rulemaking on April 7th of this year.

4 And, originally, the comment period was going

5 to close in June, and we have now extended that to

6 August 20th of this -- this year. So this summer, the

7 last day for receiving public comments is August 20th.

8 Those -- you -- the easiest way to -- and

9 everything that's spoken today will be included in our

10 docket. We have a docket set up now, and you can find

11 it at www.regulations.gov. Also, all comments can be

12 mailed to EPA as well.

13 So we do suggest, although we have a court

14 reporter here recording what you're saying, that

15 whatever you say today, you also submit it to the

16 docket.

17 And if you have a hard copy of it with you, we

18 can take that as well.

19 The plan for today is, we will go until no

20 later than 1:00 p.m. We'll start off, and I'm going to

21 give a brief background which will probably be very

22 boring for most of you since you already known about

23 PCBs, but just in case, I'll give brief background on

24 how we got to where we are today.

25 And then we will proceed with the public
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1 presentations. I want to stress that this is not a

2 public dialogue or public forum. We're here to listen.

3 There will be an opportunity for you to ask

4 clarifying questions about the ANPRM after I give my

5 presentation, but we will not be entertaining a question

6 and answer period after each presentation, although I'll

7 be around after the presentation if you want to come up

8 to me afterwards or anyone on my staff.

9 Join with me is Robert Corniche, who is also

10 working on the rules, sitting in the back.

11 Important information, the restrooms are

12 straight out those doors, and we will take a break if --

13 at around 11:00 o'clock so that everybody can get up and

14 move around. And that's it for the logistics.

15 So I'm going to go ahead and -- oh, also with

16 me is Daemien Schreiber with Quantech, the organization

17 that's been supporting the -- all the public meetings.

18 Okay.

19 So what I'm going to cover in this 10-minute

20 talk is what are PCBs, what were they used for, what are

21 the health effects, what is -- our authority for this

22 rulemaking that we're undertaking today, and what do we

23 hope to get out of the rulemaking, what information are

24 we looking for during this public comment period, and

25 what is our time table.
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1 Next.

2 PCBs are a group of over 200 different

3 chemical compounds called congeners and they're

4 different -- they're commercially formulated and not

5 naturally occurring. And there's about 50 different

6 congeners depending on how much chlorine, the chlorine

7 tends to be what varies in all the different congeners.

8 They were first produced in 1929 primarily by Monsanto

9 and they produced over 1.4 billion pounds between 1929

10 and 1977.

11 And our estimates that are -- that possibly

12 half were released into the environment as a result of

13 that production.

14 They were very important in industrial

15 applications because they did not decompose over time.

16 They're heat resistant. They provide elasticity to

17 plastics, hence, the use in caulk, and they have low

18 electrical conductivity.

19 MALE SPEAKER: Excuse me, your microphone

20 keeps cutting in and out back here.

21 LYNN VENDINELLO: Oh, I'm sorry. I think I

22 have to keep it really close.

23 All right. And I can talk loud. Is that

24 better? Oh, I'm sorry. Okay.

25 What were PCBs used for? A wide, wide range
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1 of uses, and we keep discovering even today new uses

2 that they were used for.

3 A lot of them was electrical fluids,

4 dielectric fluids, hydraulic fluids, key transfer

5 fluids, carbonless copy paper. Those were some of the

6 authorized uses. And then we found out that there have

7 also been used in cutting oils, lubricants, pump oils,

8 caulks and sealants, paints and coatings, rubber and

9 inks and pigments.

10 And if you noticed, the asterisk means that

11 those were not authorized uses. In the original

12 regulations, we asked folks to tell us what are you

13 using them for. And some people did not come forward

14 and so we did not authorize those uses, and so those are

15 unauthorized uses, and if found, then the TSCA requires

16 that they be cleaned up and disposed of.

17 Next.

18 Some of the health effects, they are those

19 acute and chronic health effects. The most common acute

20 ones are irritation, burning of the eyes, chloracne, and

21 then long term -- the dates of course, liver disorders,

22 reproductive effects, developmental effects and PCBs are

23 a probable human carcinogen.

24 There is a lot more information on the health

25 effects on our website, which is just WWW.EPA.GOV/PCBS.
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1 Next.

2 So what is the authority for the rulemaking

3 that we're undertaking today.

4 In 1976, when the Toxic Substance Control Act

5 was passed by Congress, it established a section 6(e),

6 which was the regulation of PCBs, which they -- and they

7 were primarily banned for manufacture, processing,

8 distribution and commerce, and use starting in 1978.

9 However, the original regulations provided for

10 exemptions or original statutes said that EPA could make

11 some exemptions if we found that there was no

12 unreasonable risk of injury to health or the environment

13 from that use.

14 And most of the exceptions that exist today

15 took the form or take the form of authorizations.

16 And each of those has various conditions such

17 as location restrictions, repair restrictions, and also

18 concentration limits.

19 Okay.

20 So the other key factor about section 6(e) is

21 that we authorize the use of PCBs if -- because they

22 were used in a totally closed manner, and therefore, the

23 activities would not present an unreasonable risk to

24 health or environment. Today, and it's been almost over

25 30 years, EPA has determined that certain non-totally
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1 closed PCB use activities -- well, originally, we

2 decided that the PCB use activities would not present

3 unreasonable risk and we were told to reassess that in

4 five years.

5 And so it's been more than five years. So,

6 basically, we are reassessing that determination that

7 was made that the uses are totally closed and don't --

8 don't support an unreasonable risk today.

9 Now, in order for us to -- next.

10 In order for us to remove the existing use

11 authorizations, we -- the standard is that EPA must be

12 less than arbitrary and capricious. So there's a much

13 stricter standard in order to allow a use authorization

14 and a much less stringent standard in order to remove

15 one.

16 So the burden to remove a use authorization,

17 as I just said, is much less. And this was based on a

18 Circuit Court of Appeals ruling, 5th Circuit.

19 So the objective of the rulemaking is to

20 reassess the current authorizations for certain PCB uses

21 to determine whether they may now pose an unreasonable

22 risk to human health and the environment. And to meet

23 this objective, this Advanced Notice of Proposed

24 Rulemaking solicits information from the public on

25 several topics, in fact, many topics. As you can see,
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1 there's many, many questions asked in the Advance Notice

2 of Proposed Rulemaking.

3 For example, we are interested in knowing

4 about the population, where are the transformers, how

5 many, where are the capacitors. We'd like to know about

6 equipment management practices, equipment failure rates,

7 we do have some date on that, and insurance costs for

8 failure, what does it cost to remove and -- to remove

9 the existing PCBs transformers and replacement cost for

10 equipment, information on the impact of severe spills,

11 weather events and vandalism.

12 We've heard of situations where people are

13 vandalizing the transformers to get the metals out of

14 them, like copper. It's very common in other countries

15 outside the U.S. in particular.

16 We'd like to know about disposal and metal

17 recycling capacity because if we were to phase out the

18 use of PCB transformers, then there would be an increase

19 in the amount going to disposal companies.

20 Environmental impacts of alternatives to PCBs,

21 and the -- we also are very interested in not just about

22 liquid, but also about the types and concentrations of

23 non-liquid PCBs, such as PCBs in caulk, pigment, et

24 cetera.

25 And as I mentioned earlier, the comment period
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1 ends on August 20th. That's where you submit your

2 comments that there's a particular docket number. And

3 what we are -- our time line for the rulemaking is that

4 we will be spending the rest of 2010 analyzing the

5 comments, reviewing the comments, before we go any

6 further in terms of initiating the actual rulemaking.

7 Okay.

8 That is my brief overview, but I'd be happy to

9 entertain any clarifying questions. Sure.

10 MALE SPEAKER: Will that PowerPoint be

11 available somewhere?

12 LYNN VENDINELLO: Yes. It's already on the

13 docket now, so you can get it at the same place, yes.

14 Anyone else? Great.

15 Okay.

16 I was totally clear or totally confusing, but

17 whatever. The way we're going now is, we will take each

18 speaker in turn, and Daemian is going to read off the

19 list.

20 Okay.

21 DAEMIAN SCHREIBER: Yes.

22 Okay.

23 If you would please remember to state your

24 name and organization before you provide your comments,

25 feel free to adjust the microphone however you like.
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1 Our first speaker is Ernie Luxton, Oncor Electric

2 Delivery.

3 ERNIE LUXTON: Good morning. My name is Ernie

4 Luxton. I'm the environmental field service manager for

5 Oncor Electric Delivery. I'd like to begin by thanking

6 EPA for the opportunity to speak with you about this

7 important process, agency's undertaking, to reassess the

8 PCB use authorizations.

9 Oncor appreciates EPA's extension of the

10 comment period. The extra time has proven critical to

11 us as we're gathering inventory cost historical data to

12 help us respond to the ANPRM request for information.

13 Oncor operates the largest electric distribution

14 transmission, such as in Texas with service territory

15 including over 100,000 miles of distribution lines and

16 14,000 miles of transmission lines providing electricity

17 to approximately 3 million points of delivery and

18 serving 7 million customers.

19 At Oncor, we pride ourselves in providing

20 reliable and affordable electric service to our millions

21 of customers. Well, Oncor appreciates EPA's desire to

22 reassess the PCB use authorizations. We are concerned

23 that the measures contemplated in ANPRM will severely

24 compromise both the reliability and affordability of the

25 electric service we're able to provide. The significant
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1 reduction to Oncor is made in our inventory of PCB

2 regulated grievance, as I will discuss in a moment,

3 proved Oncor shares EPA's government promoting the phase

4 down of PCB equipment.

5 Our experiences with others in the utility

6 industry, most notably through our participation in

7 utility solid waste activities group have made clear

8 that utility industry as a whole is working to eliminate

9 PCB-containing electrical equipment in a manner that

10 goes far beyond compliance with the existing

11 regulations. Our efforts and those of our peers in the

12 industry have proven that phase down is ultimately

13 achievable though not in the manner suggested in the

14 ANPRM.

15 With respect to Oncor's own commitment to

16 eliminate PCB-containing equipment, the numbers speak

17 for themselves.

18 Since 1998, Oncor has reduced its inventory of

19 PCB regulated versions in storage for reuse by

20 80 percent. We have spent approximately four and a half

21 million dollars over the last 30 years to dispose of

22 PCB-containing equipment. And this figure does not even

23 include the systemwide program Oncor undertook in the

24 mid to late 1980s, during which we spent several million

25 dollars to replace PCB large capacitors.
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1 We generally utilize the servicing options

2 provided for the regulations only for very specialized

3 equipment that's extremely costly or impossible to

4 replace. Our primary goal is to dispose the PCB

5 regulated equipment.

6 In short, over the past 30 years, Oncor is

7 engaged in identification and removal of the PCB

8 regulated equipment that far exceeds what's been

9 required in the regulations.

10 Even so, we simply do not know what -- with

11 certainty where all the PCB regulated pieces of

12 equipment in our service territory are located.

13 Despite EPA's suggestion in ANPRM, that it

14 would have been prudent for owners to locate this

15 equipment within their service territories, such

16 identification has not been a requirement of the

17 regulatory scheme for the past three decades because as

18 EPA realizes, it would not be cost effective.

19 In fact, at the time of the original use

20 authorizations, EPA considered whether to require

21 testing of middle oil fill transformers and the climate

22 to do so stating that any additional health or

23 environmental benefits derived from such mandatory

24 testing would be extremely small compared to the cost of

25 testing even this subset of electrical equipment.
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1 Thirty years later, the cost associated with

2 testing have not diminished. Meanwhile, the marginal

3 potential benefit of such testing had dramatically

4 decreased as there are far few pieces of PCB regulated

5 equipment exist since today than they were three decades

6 ago.

7 While the ANPRM does not explicitly

8 contemplate requirement to test all equipment, this

9 would nonetheless be a factor requirement calling for

10 both measures concerning the ANPRM. Requirements that

11 utilities mark and/or dispose of all equipment

12 containing PCBs ever involve the certain level will

13 necessitate large scale testing as owners wouldn't have

14 to ensure compliance with those requirements once they

15 have definitive knowledge of the PCB status of every

16 individual a piece of equipment they own or operate.

17 Oncor has determined that cost to identify all

18 pieces of PCB-containing equipment, so we can comply

19 with the suggested requirements would be up towards

20 $40 million.

21 Industrywide, it appears that the cost

22 associated with identification would be tens of billions

23 of dollars. The implication of this kind of large scale

24 testing are not limited to financial burdens on utility

25 companies or increased rates for the customers we serve.
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1 The need to test so many pieces of equipment,

2 including large numbers of inservice and energized

3 units, will require utilities to choose between

4 widespread service disruptions, not to mention unplanned

5 outages and the grave safety risk posed by testing of

6 energized equipment.

7 Testing will also jeopardize the integrity of

8 otherwise intact equipment. Any operator of electrical

9 equipment is well aware that invasive testing increases

10 likelihood of future leaks from the compromised

11 equipment.

12 On the subject of equipment failures leaks, I

13 would like to clarify what it means when aging

14 equipment, such as electrical transformers manufactured

15 before the 1979 PCB ban fails. The ANPRM repeatedly

16 leaves the concept of equipment failure resulting from

17 the age of the equipment to increased risks from PCBs

18 and our experience has shown that that's just simply not

19 the case.

20 Age-related failure simply means that the

21 equipment stops working. At that point, it's removed

22 from service and disposed of whether or not it contains

23 PCBs.

24 Failure of equipment, age-related or

25 otherwise, does not equate to a release. And even when
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1 there is some kind of release, this does not mean

2 there's a release of PCBs. Over the past 10 years of

3 those pre-1979 pieces of equipment that have failed as a

4 result of age less than 14 percent resulted in a release

5 of any kind. Of that subset, only 3 percent of the

6 releases contained PCBs. This means that less than one

7 half of 1 percent of all age-related to pre-1979

8 equipment failures over the past decade posed even the

9 slightest risk of PCB exposure.

10 Bear in mind that even though small numbers

11 represent only a portion of the much greater universe of

12 equipment. Failure incidents that are normal part of

13 the electric utility operations, meaning, that it's an

14 extremely small percentage of all equipment failure

15 incidents, age-related or otherwise, that results in a

16 release of any amount of PCBs.

17 On the subject of equipment failure, it's

18 worth noting that Oncor has seen equipment fail for a

19 number of reasons have nothing to do with age. Some of

20 these causes for equipment failure cannot be foreseen or

21 prevented by Oncor such as extreme weather advance,

22 vehicular accidents. And, in fact, one of the few

23 foreseeable causes of equipment prior to a malfunction

24 is actually the kind of invasive testing that would

25 become implicit, an implicit requirement of the phase
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1 out strategy considered in ANPRM.

2 Years of experience with electrical equipment,

3 regardless of the date of manufacture, have shown us

4 that equipment that is otherwise intact, but has been

5 broken open or pump punctured for sampling is far more

6 likely to malfunction, fail or release liquids following

7 the invasive sampling.

8 I want to share information regarding the

9 level of commitment Oncor has demonstrated towards the

10 PCB phase down, successes that we have achieved as a

11 result of that commitment. To show that phase out is

12 ultimately achievable just not through the approach

13 suggested in the ANPRM. Additionally, I can not stress

14 enough that there's no one-size-fits-all approach to

15 phase out.

16 Oncor appreciates the desire for -- toward

17 clarity and certainty, but the reality is that electric

18 utilities are differently situated with different

19 limitations, challenges and resources.

20 Developing an efficient practical approach to

21 phase out would depend on such variables as number of

22 customers, extended service territory and personnel and

23 training resources.

24 Imposition of a rigid arbitrary phase out time

25 line will not only come at a staggering cost, but will
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1 prove impractical, perhaps even impossible for many

2 utilities.

3 An overly burdensome regulatory scheme will

4 strain the analysis and disposal markets, as well as the

5 budgets in human resources of the utilities. This will

6 lead to the very problem EPA foresaw at the time it

7 promulgated the use authorizations:

8 Unnecessarily stringent regulations and

9 extraordinary costs could lead to an increase in

10 improper disposal, while simultaneously placing an undue

11 regulatory and enforcement burden on the Agency.

12 EPA should not remove or restrict the ability

13 of utilities to use, manage, and dispose of

14 PCB-containing electrical equipment in the manner

15 authorized by the existing regulations.

16 The population of PCB-containing equipment is

17 already dwindling, and the Agency has already determined

18 that the use of this critical equipment in the meantime,

19 in the manner authorized under the regulations, does not

20 pose an unreasonable risk.

21 To further accelerate the elimination of

22 PCB-containing electrical equipment, EPA should work

23 with utilities and other industries to provide

24 incentives for phase-out, through programs like the

25 National Partnership for Environmental Priorities.
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1 Avoid rigid and arbitrary timelines and

2 instead allow for more flexible and adaptable targets,

3 and the utility industry will continue its significant

4 progress towards ultimate phase-out -- all the time --

5 all the while, continuing to provide reliable, safe and

6 affordable electric service to our customers.

7 Thank you again for allowing me to speak to

8 you regarding this rulemaking process.

9 DAEMIAN SCHREIBER: Thanks. Our next speaker

10 is Kelly Moran, TDC Environmental.

11 Ms. Moran?

12 LYNN VENDINELLO: We switched the orders. She

13 is going to be number 6. Sorry.

14 DAEMIAN SCHREIBER: Sorry. Janet O'Hara, San

15 Francisco Bay Regional Water Quality Control Board.

16 Ms. O'Hara?

17 JANET O'HARA: Hi, for the record, I'm Janet

18 O'Hara. Am I on? And you got that I'm with the San

19 Francisco Bay Regional Water Quality Control Board.

20 The state water board is our over arching

21 agency in our nine regions. I'm with San Francisco Bay

22 region. And what I'd like to talk about is, how PCBs

23 are water quality issue here in the Bay Area.

24 And I'm going to talk about caulks and

25 sealants particularly in relation to that issue.
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1 You've been here awhile so you've probably

2 seen the Bay is very beautiful place. We have some --

3 you probably also aware of the health advisories against

4 eating fish in the Bay. Are you hearing me because I'm

5 not hearing that?

6 Okay.

7 So let me just read off what the health

8 advisories are. You can't take more than two meals per

9 month of San Francisco Bay sport fish, including

10 sturgeons, striped bass, croakers, surf perch and

11 shellfishes. Women of child-bearing age, pregnant and

12 nursing mothers and children should not eat more than

13 one meal of fish per month, nor should they, any striped

14 bass over 27 inches, any sharks or any fish that resides

15 in Richmond Harbor.

16 So can you imagine that the San Francisco Bay

17 is on the Clean Water Act 303 deal as impaired water

18 bodies based on the elevated PCB concentration in fish

19 tissues.

20 And my agency spent several years doing the

21 science required to develop the TMDL for PCBs in the

22 Bay. The TMDL is a program for finding out how much

23 impairment, how much of a bad pollutant there is in the

24 water body and a way to get that pollutant reduced.

25 So the TMDL has been approved by your agency.
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1 So from your viewpoint today, the most important finding

2 of that scientific evaluation for the TMDL is that

3 two-thirds of the annual load to PCBs to the Bay. 20

4 kilograms per year is a stormwater run off. Two-thirds

5 of it is from run off. The other third is coming from

6 the Delta from the central valley watershed and we can

7 do nothing to control that source. Industrial and other

8 sources are minor contributors.

9 So stormwater run off is the biggest

10 contributor of PCBs to the Bay. Where are those PCBs

11 coming from. Well, obviously Legacy PCB sites -- where

12 PCB spill sites, and soil containing PCBs can run off

13 from those sites and into the Bay or into creeks and

14 that lead to the Bay.

15 The water board and municipalities are

16 increasing efforts to get these sites into the clean up

17 process, sites that aren't already in the clean up

18 process. We're looking to get them in, and we're

19 working to ensure that water quality and run off are

20 fully considered during the clean up process.

21 Potentially, another site is sealed electrical

22 equipment, the last gentleman spoke of, could be a

23 source of spills occur and they're not handled properly.

24 And also a great source in our mind is uncontained PCBs

25 in building materials.
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1 Based on the information from other urban

2 areas, we expect that hundreds, and maybe even thousands

3 of kilograms, of PCBs are in materials in San Francisco

4 Bay buildings. Materials, like you mentioned, caulk

5 sealants, you gave the list.

6 So the TMDL's waste load allocation for strong

7 water run off, that's how much they can have in order --

8 how much PCBs should be in the run off in order to meet

9 the targets that we want to hit in the Bay to have a

10 healthy day, so that's called the waste load allocation.

11 And for stormwater agencies, they -- the waste

12 load allocation is 2 kilograms per year. That's an

13 order of magnitude reduction that they need to achieve

14 from 20 to 2.

15 Municipalities are already feeling the heavy

16 weight of that requirement.

17 I'm going to talk about their MS4 stormwater

18 runoff permit that was issued in October to 76

19 municipalities. That contains a bunch of activities

20 that the municipalities have to undertake to try to

21 reduce the PCBs that are getting into the runoff and

22 going into their creeks and into the Bay.

23 MALE SPEAKER: Could you speak closer to the

24 microphone?

25 JANET O'HARA: Yes.
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1 MALE SPEAKER: It's cutting in and out. Thank

2 you.

3 JANET O'HARA: So let me just say some of the

4 activities that municipalities are undertaking.

5 They need to abate their own municipal

6 properties where sediments have elevated PCB

7 concentrations. They need to abate properties where --

8 I -- oh, I already said that.

9 They need to enhance stormwater removal

10 practices like street sweeping and inlet cleaning. They

11 need to retrofit stormwater treatment systems into the

12 landscape.

13 And they need to divert dry weather and first

14 flush flows to POTWs. All of those are expensive, pilot

15 projects that they are already beginning to undertake.

16 But what I want to really focus on is the MS4

17 requirement and the TMDL implementation requirement to

18 sample buildings and -- sample building materials for

19 PCBs, to develop BMPs to minimize discharges from those

20 building materials, to develop model ordinances and

21 policies that will put into place those BMPs for the

22 buildings, train the city inspectors to look for PCBs in

23 buildings and to pilot test for BMPs.

24 So this is really the crux of our comments

25 today and you'll be hearing from several of my
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1 colleagues about the details.

2 But to state it as simply as possible, the

3 permittees are trying to conduct this work, but they're

4 being stopped before they can even start because under

5 the current PCB regulations, no one will give permission

6 to sample building materials due to the great potential

7 liabilities they face if PCBs is found.

8 And as I said, I'll leave it to my municipal

9 colleagues to fully illuminate the enormous challenges

10 they are facing in that regard.

11 What we're asking of you is this: Please

12 amend the PCB regulations to minimize the disincentive

13 that now exists for sampling the PCB-containing building

14 materials.

15 Building owner needs a process that has

16 multiple steps including sampling, labeling or similar

17 recordkeeping operation, containment and ultimate

18 removal with proper disposal during an appropriate

19 renovation or demolition time.

20 The current regulations prevent us from taking

21 the steps necessary to protect the waters of the U.S.

22 from impairments due to PCBs.

23 We believe that any regulatory framework

24 requiring immediate removal of PCBs when building

25 occupants are not at risk would do the same.
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1 In summary, building materials are quite

2 likely the biggest ongoing source of PCBs to the Bay

3 which we have not already taken steps to control. To

4 achieve a TMDLs order of magnitude reduction of PCBs in

5 runoff, to meet the MS4 permit requirements, more

6 important, to restore the water quality of the Bay and

7 to maintain the Bay Area residence who favor or subsist

8 on fish caught in the Bay, we must have a regulatory

9 framework that incentivizes building owners to identify

10 and properly manage PCBs in their buildings.

11 Thank you very much for this opportunity, and

12 good luck.

13 DAEMIAN SCHREIBER: Thank you. The next

14 speaker is Jim Bennett from Jaco.

15 JIM BENNETT: Good morning. My name is Jim

16 Bennett. I'm with Jaco. We test energized

17 transformers. We have a drill -- kind of drill

18 procedure that we can obtain the samples with the

19 transformers energized.

20 At the same time, we do an inspection of the

21 pole, the transformer, notify the utility if it's

22 leaking. The plug that we utilize to put back in the

23 transformer to seal it up is guaranteed for the life of

24 the transformer. Jaco has probably done in excess of a

25 million transformers. We've been in business for 22
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1 years.

2 We also have a lab in Ephrata, Washington,

3 that a lot of the samples were sent back for analysis,

4 where they do EPA method 8082.

5 And it's -- along with the inspections with

6 the transformers as well as other benefits to it as far

7 as what we find wrong, broken bushings, we do a complete

8 inventory with it.

9 And as far as the leaking, we haven't had our

10 rivets, what we call our plugs, leak, and, basically, it

11 was -- I'm introducing the company; that we do do this.

12 I have business cards, and I can talk to anybody after

13 the meeting. And thank you.

14 LYNN VENDINELLO: Thank you.

15 DAEMIAN SCHREIBER: Okay.

16 The next speaker is Athena Honore; is that

17 correct?

18 ATHENA HONORE: Yes. Thank you.

19 DAEMIAN SCHREIBER: San Francisco Estuary

20 Partnership Association of the Bay Area.

21 ATHENA HONORE: I'm trying to get close, real

22 close in here.

23 Good morning. My name is Athena Honore. I'm

24 with the San Francisco Estuary Partnership, which is

25 part of the Association of Bay Area Governments. That's
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1 the last word that got left off.

2 Thank you for holding this meeting in San

3 Francisco today. This rulemaking indirectly affects a

4 conflict that I'm working on with many others here in

5 the Bay Area, and several of my colleagues on the

6 project are here today.

7 I'm the project manager for grant funded

8 project which seeks to minimize water quality impacts of

9 PCBs in caulk. San Francisco Estuary Partnership is a

10 national estuary program for San Francisco Bay, and we

11 coordinate priority water quality improvement projects

12 all around the San Francisco Bay region.

13 We call our projects simply the PCBs in caulk

14 project. It was originally funded through California

15 Prop 50 state bonds in 2007.

16 The goal of the project is to implement part

17 of the TMDL for PCBs in San Francisco Bay, which as you

18 heard requires municipalities to reduce PCBs loading to

19 the Bay by 90 percent.

20 I've only been working on this issue for two

21 years, and I remember first learning that I'd be working

22 on this emerging issue. I marveled to myself. I didn't

23 know there were PCBs in caulk. It turned out that not

24 many other people did either. There wasn't much

25 guidance on how to protect water quality from PCBs in
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1 caulk.

2 So how is this a stormwater issue? I asked

3 Dr. Kelly Moran, one of our local experts on the issue,

4 from whom we'll hear in a little bit. She explained to

5 me that when buildings were demolished, chunks of caulk

6 would be left on the ground, where PCBs they contain

7 could leech out into stormwater, and that the PCB levels

8 in the caulk have been found to be up to 30 percent of

9 full 60,000 times higher than EPA's legal limits.

10 This was the weight that needed to be managed

11 with a new set of controls at the regional level. Our

12 project was going to figure out how.

13 Walking on that day, I thought this is going

14 to be a tough sell. It's in every material. It's

15 everywhere. I walked past houses in my neighborhood

16 being painted with paint flakes and caulk everywhere

17 outside the windows. Were they using tarps, I wondered?

18 Do they know about the PCBs that can lurk in the caulk?

19 What would they do if they do know?

20 I thought about the PCB laden caulk as a

21 poison pellet. And that project would be successful if

22 you have to let people know about the poison pellets

23 lining their walls, and work with them to ensure that

24 when it was time to take it out, that it was contained,

25 properly disposed of and kept out of dusts the ground
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1 and run off.

2 Tough sell or no, people here in the Bay Area

3 were aware of this issue early on. And they pushed to

4 get addressed because of this uncontained source of PCBs

5 could be contributing to a known water quality problem.

6 Several years of effort later, San Francisco,

7 PCBs TMDL was adopted and approved by EPA and has

8 implementation planning from several pilot efforts,

9 including developing a management process for PCBs in

10 caulk.

11 New regional stormwater permit from

12 municipalities also contains a requirement to carry out

13 the PCBs in caulk work. We've even received a state

14 grant to develop the management process.

15 Our project contains two phases. One is to

16 analyze local caulk samples, providing first picture of

17 PCB levels in the Bay Area in caulk. Thus, helping to

18 quantify the potential loading to stormwater.

19 The second phase would be to develop best

20 management practices for containment and management of

21 caulk at building demolition or renovation.

22 That said, the BMPs would be integrated into

23 local government demolition and building permit

24 processes with some trial implementation projects.

25 In the future, municipalities may be required
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1 to adopt ordinances requiring caulk to be managed per

2 these pilot projects.

3 It's a good plan to manage poison pellets, and

4 one that makes sense from the perspective reducing water

5 quality impact to PCBs to the Bay.

6 The project got started, but soon screeched to

7 a halt. Once the project team delved deeper into the

8 regulations and found the unauthorized use issue around

9 PCBs in caulk.

10 We found that PCBs in caulk had at levels over

11 an infinitesimal threshold were unauthorized use subject

12 to clean up upon discovery, even if the caulk was in

13 use, structurally sound and, there was no clean up plans

14 current.

15 Now, the poison pellets were becoming poison

16 pills. Our project's logical first step to protect

17 water quality was to find if the PCBs were, in fact,

18 present in some sample buildings, to ask building owners

19 to sample caulk for PCBs.

20 But doing so would mean that if PCBs were

21 found, owners had to jump to a clean up that they may

22 not have planned or budgeted. We tried to find a way to

23 move the project forward.

24 We approached building owners and management

25 to ask them to allow us to sample in their buildings.
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1 And I'd like to relate an example of how those requests

2 have been perceived.

3 I approached a large research facility in the

4 region to ask them about sampling at their buildings.

5 The facility had been working through a PCBs

6 clean up plan unrelated to PCBs in caulk, but since they

7 were already actively removing PCBs from their buildings

8 and their soils, we thought they might work with us. We

9 submitted fact sheets about our project and scheduled a

10 call to discuss.

11 The facility manager was considering our

12 request. However, the meeting was canceled abruptly.

13 After investigating the regulations, the use

14 authorizations and the clean up requirements, the

15 building managers determined that only they would not

16 participate in our project, they would not even respond

17 in writing, for fear of being on the record as being

18 aware of the issue given potential liability concerns.

19 I received the message through an

20 intermediary, like a spy.

21 We worked hard for two years to find a way to

22 move our water quality work forward -- there are Bay

23 Area data to improve loading estimates and to find

24 building willing to try out the management process we're

25 developing.
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1 We tied ourselves in knots trying to work out

2 a municipality that would comply with those use

3 authorizations and keep the commitment reasonable for

4 the municipalities.

5 For example, we're working to further develop

6 a rapid screening method at the text and indicator of

7 PCBs, rather than the PCBs themselves, meaning, that

8 test results might point a building owner towards the

9 need to clean up PCBs, without actually providing clear

10 cut data showing that they were in the unauthorized use

11 zone.

12 They worked to develop line sampling protocols

13 so that cross samples of these buildings could be

14 analyzed, providing some useful data without identifying

15 the building owners and visiting liability upon them.

16 We held a stakeholder meeting just last week

17 to roll the project out to building owners, construction

18 and demolition contractors and municipal permitting

19 departments.

20 We heard from a number of groups, but they

21 knew they had to work to meet new local -- water

22 regulations, but that they were stymied by some key

23 issues. Regulations around PCBs in caulk currently

24 require them to clean up their caulk and surrounding

25 surfaces, and dispose of all these materials as
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1 hazardous waste, if PCBs were found over 50 parts per

2 million.

3 Initial estimates assumed that this would add

4 considerable cost and time to any clean up project. And

5 if the building owners is not already considering a

6 clean up or demolition or renovation, our experience is

7 that there is zero chance that they will consider

8 investigations to find if PCBs are present in caulk and

9 we've lost the chance to manage these PCBs, creating

10 potential risks, not just to water quality, but to human

11 health because of the strong disincentives to accomplish

12 that a building caulk has PCBs.

13 We've also heard about fear of the unknown,

14 how far does the contamination extend if the PCBs can be

15 found not just in the caulk but in surrounding surfaces?

16 Our clean up is required for soil as well.

17 These are the issues that we will need to work

18 to address.

19 So we're thrilled that EPA is reconsidering

20 the regulations covering the PCBs in caulk, the very

21 piece that's been standing so strongly the way of our

22 water quality work.

23 We understand that it's a complex issue and

24 our mission here in the San Francisco Bay Area is only

25 one aspect. And you're about to be considering new
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1 approaches to the unauthorized uses of PCBs.

2 We hope that you're able to keep the water

3 quality project in line and arrive at an approach that

4 removes some of the disincentives for building owners to

5 look for PCBs in caulk and manage them properly if

6 found.

7 I will not leave you with any specific

8 recommendations at this time, but instead note that our

9 project is working as best we can under the current

10 regulatory context to institute some local water quality

11 protection measures and recognizing some real obstacles

12 to getting our work going as things panned out.

13 We'll be very willing to work with you going

14 forward to relay our experiences of how these

15 regulations affect prospects for improving water quality

16 underground.

17 I also want to recognize the work of the EPA

18 Region 9 staff on this issue.

19 The regional PCBs coordinator and team have

20 provided invaluable help to us, and EPA's office of

21 water staff will receive -- national estuary programs

22 have also been tremendously helpful.

23 Thank you for the opportunity to share our

24 experiences with you today.

25 DAEMIAN SCHREIBER: Thank you. Our next
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1 speaker is Arleen Feng. Is Ms. Feng present?

2 JON KONNAN: Arleen is not here. I'm going to

3 fill in. I'm also on your list, Jon Konnan.

4 DAEMIAN SCHREIBER: Okay.

5 Jon, did you want to come up and make comments

6 in her stead?

7 JON KONNAN: Yes. Thank you, Athena, for your

8 stories about poison pellets.

9 LYNN VENDINELLO: I'm sorry. And your

10 orientation?

11 JON KONNAN: Okay.

12 I'm Jon Konnan, and I'm here today to

13 represent what's called BASWMAA, Bay Area stormwater

14 Management Agency Association. It's an organization

15 that represents all of the municipalities all around the

16 Bay that discharge stormwater to the Bay and regulate

17 it.

18 So I was just going to mention, I really liked

19 Athena's story about poison pellets and pellets and

20 spies and so forth.

21 I don't think I need to ask that, but I do

22 have some interesting things to say. So Athena told you

23 about the PCBs in caulk projects that several of us are

24 working on.

25 And what we are trying to do, just to
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1 reiterate, is characterize PCBs and building materials

2 in caulks in particular in the Bay Area, and then we're

3 trying to develop methods to control release of those

4 materials during building renovation and demolition.

5 So Athena told you that they're coming up with

6 some real problems when we try to actually implement

7 this. I've contacted a lot of municipal representatives

8 myself and explained to them what we're doing trying to

9 find a building or buildings where we can do some of the

10 characterization and test the controls, and I always get

11 the same response.

12 They really want to help us and really want to

13 work with us, but they are really very afraid of the

14 potential liability. It's our understanding if they

15 find PCBs in caulk that the level is greater than 50

16 parts per million, then a clean up is required along

17 with the whole nine yards, clean up plan, all of that,

18 which could be very expensive.

19 So municipal staff are really concerned about

20 that. What we want to do is on a relatively small

21 scale. We just want to do a little bit of

22 characterization, and then a pilot scale, test it in a

23 few areas, but we're really stymied by this rule.

24 So I don't know if there's a way to have an

25 extension when you're just trying to do what we're
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1 doing, which is characterization and methods development

2 on a small scale. Like I said, the 50 parts per million

3 rule is really stymying us.

4 Cities have asked can we come up with some

5 information about where are the potential consequences

6 and costs if we do this. One piece of information we've

7 been able to gather so far from one consultant is that

8 disposal of building materials, if PCBs are below 50

9 parts per million, would be in the 50 to $60 per ton

10 range, that would be going to any number of local

11 landfills.

12 If PCBs are greater than 50 parts per million,

13 then the range that we've been told is $150 to $250 a

14 ton for disposal, going to specialized landfill.

15 So that's up to a factor of five, just for

16 disposal alone. And that's just one little piece of the

17 potential increase in cost if they have to deal with

18 this.

19 Another little anecdote of things that we've

20 been told is that several industrial hygiene consulting

21 firms told us verbally that they often inform their

22 clients that there's a potential for PCBs to be in caulk

23 in buildings, and they ask whether they would be

24 interested in testing that, along with other routine

25 tests, like asbestos and lead. And, of course, they
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1 always give the same response, no, we are not interested

2 in doing that testing.

3 I also want to mention something about the

4 PCBs TMDL, which Janet told you about earlier. There is

5 a sediment concentration going, the TMDL that is very

6 low. It's one part per billion, not million, but

7 billion.

8 And that was derived using -- modeling. And

9 the idea is that, if you achieve that goal in sediment,

10 and -- sediments in San Francisco Bay, they would then

11 achieve the fish target, which is the thing that drives

12 the whole clean up in the Bay.

13 So it gives you an idea about how -- there's

14 different pieces of this puzzle. You know, there's a

15 water quality aspect, and because of a bioaccumulation

16 effect, we need very low concentrations of PCBs in

17 sediments in the Bay to achieve what we're trying to

18 achieve with keeping a level low enough in fish but

19 doesn't pose a health threat to people that cash and eat

20 those fish.

21 I guess what this all really amounts to is

22 that when our PCBs in caulk project, the PCBs TMDL in

23 general, we have a state agency that is trying to

24 address a particular water quality problem, the PCBs and

25 fish in the Bay, and part of what they're doing -- and
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1 it makes sense because they're trying to get local

2 agencies to do some things which is -- one of them is to

3 control PCBs in caulk, but we're running up against the

4 fact that PCBs is in other types of media, and that

5 there's a lot of different exposure pathways, and it's a

6 complicated picture.

7 What we really need is a federal agency, like

8 you guys, who have the ability to deal with and regulate

9 PCBs and, you know, a number of different media.

10 And, you know, with your ability to do that,

11 maybe you can help us fit together the pieces of the

12 puzzle and kind of whole stick way because actually it

13 was Kelly Moran that first pointed out to me this need

14 for a federal agency, you can look at all the different

15 media, hold the pathways and put the puzzle together.

16 She'll be talking to you shortly a little more about

17 this.

18 So thank you.

19 DAEMIAN SCHREIBER: Ms. Moran, would you

20 please come to the podium?

21 KELLY MORAN: I'd like to say thank you. I

22 want to also thank you for coming out the west and

23 having this meeting with us, and for all of you for

24 taking your time and energies towards -- towards finding

25 a solution on this problem.
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1 I know that a lot of folks are saying, oh, I'm

2 embarrassed, we didn't deal with it a long time ago.

3 And I'm not looking backwards. I'm looking forward, and

4 saying how can we move forward in the situation we're at

5 today to find practical solutions to the problem.

6 I first ran across this when I was working for

7 the City of Palo Alto back a decade ago and was trying

8 to find sources of PCBs into urban runoff and sewage

9 treatment plant.

10 (Reporter request for clarification.)

11 KELLY MORAN: And that was when I first saw,

12 oh, there were PCBs in caulk. That's pretty weird. And

13 I practically fell out of my chair, when 10 years later,

14 I'm sitting at the gym reading scientific papers in the

15 journal and, sure enough, there's a series of studies.

16 And we see first in Boston, and then from Europe, and I

17 wound up finding things from all over the globe about

18 PCBs in caulk, and the need to identify and manage that.

19 And what I also found were studies that showed

20 that those PCBs were released out into the outdoor

21 environment, so when it rains, that water can carry

22 those little particles of the caulk, of the PCBs, of the

23 PCB contaminated soil near the building and take that

24 into that storm drains which flow untreated in almost

25 all the entire U.S. into our water ways.
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1 And that's how it's getting into San Francisco

2 Bay, into other urban watersheds across the nation. It's

3 also in California, and that's how fish are getting

4 exposed through that bio accumulation in the ecosystem.

5 And although we're talking here about San

6 Francisco bay and we've been using that as a water

7 quality example, because it's a pretty compelling

8 example and we've gotten pretty far along, this is not

9 the only water body that has PCBs problem.

10 And, in fact, right now, there's a meeting

11 going on in the California Stormwater Quality

12 Association where they're talking about this for other

13 places in the state and making some of the same

14 comments. I'm hoping you'll see a comment from there on

15 this I'm going to add.

16 So I didn't say for the record, my name is

17 Dr. Kelly Moran, and my firm is TDC Environmental. I

18 just realized I forgot to do that.

19 As you've heard, there's a real lack of public

20 awareness of PCB in caulk. And because there's no

21 requirement to sample, nobody's sampling. And the

22 disincentives of sampling are really, really high.

23 There's just so many unknowns. To the extent

24 the regulatory framework and other actions by EPA can be

25 used to reduce those disincentives to samples by making
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1 things known, by making a finite, by establishing

2 procedures so that when folks find PCBs, they know what

3 to do. And that there are realistic expectations on the

4 part of the property owners that will --

5 DAEMIAN SCHREIBER: Try to slow down.

6 KELLY MORAN: If there's realistic

7 expectations and a real understanding of what the costs

8 will be to respond, I guess so, we're at -- none of the

9 comments I think you're hearing from this area are

10 suggesting that we don't take care of public health.

11 But that we try to -- that we need your help in finding

12 a path forward that's realistic that's going to work.

13 We want to protect public health.

14 We're not public health experts. We're water

15 quality experts. We have to protect water quality.

16 That's a regular mandate coming out of a US EPA under

17 the Federal Clean Water Act. And we need to find a way

18 to do that, that city's can do because we're owners of

19 buildings, and we need to make sure that we're not

20 writing new development and redevelopment of our areas

21 to a halt, because that's a very big priority for us, in

22 climate change, is to redevelop our existing buildings,

23 and that means buildings in the exacting time period

24 that have the PCBs -- and because of the way that Bay

25 Area was built.
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1 Under the current system, ignorance is bliss.

2 If you don't know there's PCBs, you don't have to do

3 anything about it.

4 And that's the problem.

5 That somehow, we need to flip things around so

6 that ignorance is not bliss.

7 And I -- I've got to also share some

8 experience I've had since I've been aware of this. I am

9 consulting some work with many different clients, and

10 all of those are government.

11 Some are kinds of institutions, and whenever

12 I've been in the right place at the right time to bring

13 up PCBs and testing, I recommend to clients that they do

14 that so they're aware of what they need to do and that

15 they protect the building occupants and so forth, and

16 not one of them has done that.

17 And the most compelling example for me is a

18 hospital system that I worked with. And I shared with

19 them all the information, the health issues, and they

20 did not want to test even buildings that they're

21 proposing for demolition.

22 So I think, you know, somebody -- a real

23 mission for health not doing this shows you exactly how

24 improperly structured the regulations are today.

25 So you've heard from other folks working on
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1 the project that I'm also working on, and I think

2 there's a strong commitment, among all of us and among

3 municipalities in the Bay Area to work with EPA to find

4 a productive path forward.

5 And that we think our little grant resources

6 and our experience forward to help, but we really need

7 your help. So which -- you should hear in this is a

8 plea for help, not just for the regulations, but also to

9 help work with us to help put the system in place.

10 If we're successful in our project, we're

11 working towards a system that would, in one way or the

12 other, end up at least in the Bay Area to try to require

13 testing of building for PCBs, and we think demolition

14 and remodeling because that's the time when the biggest

15 releases occur.

16 So -- and we're not saying all of the PCBs

17 don't matter, but we're just recognizing that that's

18 when most of that would get out into the environment

19 which is our priority.

20 The thing about that is there's several

21 thousand demolitions a year in the San Francisco Bay

22 Area, so even if only a small fraction of those include

23 the buildings in the right age range, do contain PCBs,

24 we could very quickly, just from the San Francisco Bay

25 Area, just overwhelm EPA's resources to oversee these
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1 kinds of clean ups.

2 So we're very aware and sensitive to that and

3 want -- that's another important piece of moving

4 forward, is to try to create systems so that we can be

5 able to work together and move forward to implement

6 measures that actually work.

7 In that regard, we see not only change in the

8 regulatory system as help to that but also the need for

9 procedures and processes. We've been pointing many

10 times to asbestos as a really great example. There's

11 ASTM standard for surveying. There's a standard

12 procedures for doing the clean ups. There's a lot there

13 to build off of for PCBs. And that's something we in

14 the Bay Area don't have the capacity or resources to be

15 looking at to set up those kinds of nationwide systems.

16 That's something we really like to talk with you about

17 and explore further.

18 In terms of a workable path forward, we're --

19 what we're seeing here is that if it were possible to

20 get folks to just sturgeon the system so that PCBs need

21 to be identified. And then here's the question, we --

22 we think that it would work best if the technology is

23 there, and that's something we're not expert on, to

24 contain those PCBs in the buildings, and then to label

25 them.
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1 And that provides the time and the ability to

2 do the clean up when the building is remodeled or

3 demolished when it's going to be most cost effective.

4 So that's a real question for us. We see that

5 as a real workable system, identification, containment,

6 labeling, maintenance until removal.

7 But we've got some questions about the

8 feasibility, the containment piece and, again, that's

9 not something we're going to be able to do within our

10 resources. So we're really looking for your help.

11 And so I think that's really the bottom line.

12 We're here to work with you. We're looking forward to

13 that and we could use your help to facilitate how much

14 complete our requirements, our mission to protect water

15 quality. And thank you very much for your time.

16 DAEMIAN SCHREIBER: Our next speaker is Nancy

17 Humphrey representing the City of Oakland.

18 NANCY HUMPHREY: Loudness has never been my

19 problem.

20 I'm Nancy Humphrey. I'm an environmental

21 compliance specialist with the City of Oakland. And we

22 are one of the municipalities that -- that are

23 colleagues at the agencies have been referring to in

24 terms of what the impact on us, the incentives and

25 disincentives for addressing these issues might be.
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1 The City of Oakland shares the EPA's concern

2 about high levels of PCBs in the environment and

3 supports efforts to further identify and reduce sources

4 of PCBs in water ways.

5 We have participated in several pilot

6 projects, studies and clean up efforts relating to

7 reducing the impact of PCBs in our regional waters.

8 Currently, we are implementing one of five PCB

9 reduction pilot projects under our clean watersheds for

10 clean water grant, which is an EPA funded grant, that's

11 just one of -- we -- we were interested, we're on board,

12 we're doing it when we can do it.

13 However, in the absence of data about the

14 relative contribution of various sources of PCBs to the

15 environmental load and specifically the potential impact

16 on environmental conditions, if controls on the use

17 and/or handling of PCB containing caulks and relating --

18 related building materials, it would be irresponsible

19 for a cash strapped municipal government to spend an as

20 yet unknown and potentially sizeable amount of public

21 money to address an issue for which no quantifiable

22 improvement and conditions can be assured.

23 This relates to what some of the others have

24 been saying and represents the strongest incentives for

25 participation in the studies that would help answer
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1 these very questions.

2 The liabilities associated with investigating

3 a city facility for PCB containing caulk range from the

4 cost of doing the investigation itself to the potential

5 cost for removal and disposal of the caulk associated

6 masonry and contaminated soils hazardous waste, and to

7 the potential cost for claims of health effects in past

8 and present building occupants and neighbors.

9 If funding were provided to address all of

10 these costs, the City of Oakland might be in a position

11 to participate in this effort.

12 If and whether data are available, that enable

13 us to maximize the environmental effects of our

14 expenditures. And if and when disincentives to action

15 are addressed, through provision of funding and/or

16 regulatory relief, the City of Oakland will do its

17 utmost to further the effort to reduce or perhaps

18 reverse the accumulation of the PCBs in our local water

19 ways.

20 But as others have stated, the liability is

21 the cost liabilities, are just too great under the

22 current system for most entities, and certainly

23 municipalities, to take it on at this point.

24 So we need -- we too are asking for relief in

25 the form of regulatory relief or funding.
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1 Thank you.

2 DAEMIAN SCHREIBER: Patrick Hayes, would you

3 like to come to the microphone?

4 PATRICK HAYES: Good morning. I'm Patrick

5 Hayes, also from the City of Oakland. I'm a recycling

6 specialist, and I've been managing and developing our

7 construction demolition --

8 (Reporter request for clarification.)

9 PATRICK HAYES: Thank you.

10 Our construction demolition, waste reduction

11 and recycling program. And a lot of the comments that I

12 have today, you've already heard. Nancy and I should

13 have gotten together probably and spent some for time so

14 that we didn't necessarily repeat each other. Give me

15 one second to turn back.

16 I also really wanted to say thank you for

17 extending the comment period because I only found out

18 about just two weeks ago. I'm another one of those

19 people who I was to share I knew everything, and only to

20 find out that, wow, there are PCBs in construction

21 materials. I knew about electrical equipment, I knew

22 about other kinds of pollution. So this was a real wake

23 up call for me to spend some more time reading

24 professional journals and keeping track of what's going

25 on.
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1 We want to re-emphasize the City of Oakland

2 wants to support any efforts to protect and approve

3 human environmental health, and we see cooperation as a

4 major benefit for our constituents as well as everybody

5 who lives here in the Bay Area.

6 It's not clear though to me how much

7 construction demolition activities are contributing to

8 current pollution levels. The data does seem to be

9 incomplete. Now, that could be that I'm not informed,

10 I'm not looking, I don't know enough, but it's not

11 obvious to me that there is a real strong connection

12 between construction and demolition activities and the

13 current pollution levels that we see in the Bay Area in

14 particular.

15 Urban redevelopment is specially important to

16 us. We're a very big city, we have no open lands. So

17 it means that buildings are going to have to get

18 renovated so that we can continue to have a vibrant

19 city. The current rules, as everybody's repeated

20 several times now, are very prohibited and dissent --

21 they are great dissenters for anybody to do the testing

22 to confirm what's actually going on there. And we're

23 concerned that -- that any new rules may slow down

24 development in our city.

25 We do support pilot studies to better
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1 understand what's going on, how to contain and control

2 sources, with -- with appropriate financial support and

3 other assistance to navigate some of the cross

4 jurisdictional issues that we had. We've talked about

5 cost sharing around the Bay Area to find some pilot

6 projects, but, you know, the question about who's going

7 to pay for this, if we do discover significant levels of

8 PCBs that require a clean up.

9 There's some communities in the Bay Area that

10 when PCBs in caulking and in particular were heavily

11 used, those cities hardly existed. They were mere burbs

12 around the Bay Area where Oakland is an old city, high

13 population for a long time, and the thoughts are, well,

14 if we find a couple of pilot studies, how do we divide

15 the cost up fairly among the jurisdictions. So if we

16 are to look at something, we want some support and some

17 help from the EPA to facilitate moving forward. I share

18 Dr. Moran's point, I don't want to look back what we

19 didn't do. Let's make some progress forward, and this

20 is another plea for support and assistance. I'm not

21 going to say, help, I want an assistance because I want

22 to participate in the solutions.

23 Again, we don't really have any incentive as

24 to the municipalities start tackling this program, this

25 problem on our own. We don't have the money. I'd like
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1 to remind everybody, and maybe you don't even minding

2 the economy, is in a bit of tough spot right now. We've

3 laid off several hundred employees in the City of

4 Oakland, including 80 police officers and associated

5 safety services. It's hard for us to look at immediate

6 safety versus long term safety of our residents.

7 Americans, as all of us know, are very poor

8 long term planners. We can't see the benefit of doing

9 something now that's going to take good care of us in

10 the long run. We want immediate result. It said

11 immediate gratification, and right now in Oakland losing

12 80 police officers off the street is really tough for us

13 to say, well, let's put some money aside to test this

14 building and possibly spend 4 or $5 million to remediate

15 PCBs in building materials.

16 We do support, and I think I said this a

17 minute ago, we do support protection and improvement for

18 human environmental health, but we're asking for a

19 cooperative and progressive solution.

20 One of the things that has struck me is there

21 are a number of federally-owned buildings, properties

22 here in the Bay Area that are either imminently going to

23 be remodeled, redeveloped, demolished or will happen in

24 the very new near future and worry, but I would like to

25 ask for assistance from the EPA to facilitate
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1 conversations with those other agencies to volunteer

2 their buildings for the pilot studies that we need since

3 those agencies, and I'm not going to name names, Coast

4 Guard, seem to be very well-funded and very concerned

5 about minimizing their impact on water quality.

6 So we're asking for some help to get those

7 pilot studies squared away where there is existing

8 funding with entities that are interested in making a

9 positive contribution in order to characterize the

10 possible extent of this program.

11 Thank you very much.

12 DAEMIAN SCHREIBER: That concludes our list of

13 registered speakers. Would anyone else like to come to

14 the microphone and make a comment?

15 (No response.)

16 DAEMIAN SCHREIBER: Okay.

17 Well, on behalf of EPA, I would like to thank

18 you all for attending the meeting, and have a good day.

19 (Whereupon, at 10:17 a.m. the proceedings

20 were concluded.)

21

22 * * * * *

23

24

25
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1 CERTIFICATE OF REPORTER

2

3 I, Megan Alvarez, a Certified Shorthand

4 Reporter, hereby certify that the foregoing proceedings

5 were taken in shorthand by me at the time and place

6 therein stated, and that the said proceedings were

7 thereafter reduced to typewriting, by computer, under my

8 direction and supervision;

9

10 DATED: _______________________

11

12 _______________________

13 MEGAN F. ALVAREZ

14 RPR, CSR 12470

15

16

17

18

19

20

21

22

23

24

25
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$250 38:15

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conflict 28:6

confusing 11:18

congeners 6:5,8,9

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consequences 38:7

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considering 32:13

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constituents 51:6

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34:16

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data 12:13 32:25

33:12,16 48:15
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49:14 51:10

date 0:9 10:9 18:5

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enormous 25:11

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29:25

entertain 11:11

entertaining 5:7

entire 42:2

entities 49:24 54:10
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environment 6:14

8:14 9:1,24 41:23

45:20 48:4

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21:6,11,15,16,20

26:10

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42:5

fit 40:13

five 9:6,7 38:17

48:10

flakes 29:18
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flexible 20:4

flip 44:7

Floor 0:14

flow 42:1

flows 24:16

fluids 7:5,6,7

flush 24:16

focus 24:18

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45:2 46:22

foregoing 55:5

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foreseen 17:22

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27:21

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gather 3:20 38:9

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53:20

Humphrey 1:17

2:13 47:19,20,22

hundred 53:5

hundreds 23:4

hydraulic 7:6
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hygiene 38:22

I

I'd 11:10 12:7

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14:9,18 15:24

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41:3,5,16

42:16,17 45:3

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immediate 26:1

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institutions 44:13

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34:10

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29:4,5 30:5 31:10

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44:9,10,14 50:8

J

Jaco 26:16,18 27:1

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20:16,19 24:2,5

39:6
Capital Reporting Company

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Jeff 3:13

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Jim 1:13 2:9

26:16,17

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joined 3:12

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30:11,16,22 32:1

33:1 36:16

manager 12:6 28:9

32:13

managers 32:17

managing 50:8
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mandate 43:18

mandatory 14:25

manner 8:24

13:11,15

19:16,21

manufacture 8:9

18:5

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16:16

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storm 42:1

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