November 14, 2014

National Program Chemicals Division (7404

- T)

Office of Pollution Prevention and Toxics

Environmental Protect ion Agency 1200 Pennsylvania Ave., NW. Washington, DC 20460

- 0001

Re: Renewal of EPA ICR 1446.11, OMB Control No. 2070

- 0112, "PCBs, Consolidated Reporting and Record Keeping Requirements"

Docket ID : EPA

- HQ

- OPPT

- 2014

- 0597

To whom it may concern:

The Utility Solid Waste Activities Group (“USWAG”) 1 appreciates the opportunity to comment on the Environmental protection Agency’s (“EPA”) burden analysis identified for the federal PCB reporting/recordkeeping requirements as part of the Agency’s Information Collection Request (“ICR”) submission to OMB. Importantly, as we began our review of the background document underlying the ICR submission, we identified some significant errors in the document that require correction before an accurate review of the Agency’s burden analysis can be

conducted.

Specifically, the supporting document entitled “Supporting Statement for a Request for OMB Review under the Paperwork Reduction Act,” which reviews the PCB recordkeeping/reporting requirements subject to the ICR, fails to reflect the important changes made to the PCB reporting/recordkeeping requirement s by the Agency’s direct final rule issued on September 6, 2012. That rule aligned the PCB manifest requirements with EPA’s hazardous waste manifest requirements by modifying and/or eliminating certain of the requirements, as well as reorganizing

and renu mbering many of the PCB manifest requirements. See 77 Fed. Reg. 54818. The supporting document must be corrected to reflect these amendments before an accurate review of the PCB recordkeeping/reporting burden analysis can be conducted.

While we have n ot identified every error in the supporting document attributable to this omission, below are some

of the errors that we have identified.

1 USWAG, formed in 1978, is an association of over one hundred energy utilities, utility operating companies, energy companies, and associations including the Edison Electric Institute (“EEI”), the American Gas A ssociation (“AGA”), the American Public Power Association (“APPA”), and the National Rural Electric Cooperative Association (“NRECA”). EEI is the principal national association of investor

- owned electric power and light companies. AGA is the principal na tional association of investor

- owned natural gas utilities. APPA is the national association of publicly

- owned electric utilities. NRECA is the national association of rural electric cooperatives. Together, USWAG members represent more than 73% of the t otal electric generating capacity of the United States, and service more than 95% of the nation’s consumers of electricity and 92% of the nation’s consumers of natural gas.1. On page 13, reference 46 in Table 2

- 1 regarding Exception Reporting incorrectly refers to 40 C.F.R § 208(a)(4) ; this requirement has been removed from the PCB regulations as a result of the September 6,

2012 direct final rule. Additionally, the reference to the requirement in 40 C.F.R. § 761.215(b) has been renumbered to 40 C.F.R. § 761.217(b) under the September 6, 2012 direct final rule.

2. On page 38, reference number 46 regarding “Exception Reports” contains the same errors identified

above.

3. On page 38, reference number 47 discussing “Discrepancy Reporting” incorrectly refers to 40 C.F.R. § 761.210(b ); the discrepancy reporting requirement referenced in this discussion is now contained in 40 C.F.R. § 761.215(c).

4. On page 38, reference numbers 48 and 49 discussing “Unmanifested Waste Reports” incorrectly refer to 40 C.F.R. § 761.211(c); the unm anifested waste reporting requirement referenced in this discussion is now contained in 40 C.F.R. § 761.216(a).

5. O n page 66, reference 46 contains the same errors regarding Exception Reporting identified in number

one above.

6. On page 83, refere nce 46 contains the same errors regarding Exception Reporting identified in number

one above.

In addition to the above, USWAG questions the accuracy of certain language on page 29 describing the PCB Transformer Registration requirement. In describing th is requirement, the document states that “[t]his information is also for use to address requirements of international environmental programs to identify sources and reduce or

eliminate the reliance on PCBs.” It is unclear why this language is included in this discussion. USWAG is not aware of any international environmental treaties that have been ratified by the United States imposing management requirements on PCBs in electrical equipment. USWAG suggests that this statement be deleted from the backgrou nd document.

We hope the above information is helpful to EPA in correcting the errors in the important background document underlying the PCB ICR. Please contact me ( jim.roewer@uswag.org ; 202

- 508

- 5645) with qu estions.

Jim Roewer

Executive Director