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"

t . Canadian Electricity Association .. .. Assoclatio. cenadle••e del'electrici"

www.canelect.ca

Bob LaRocque

Acting Chief, Waste Program

Waste Reduction and Management

Environment Canada

70 Cremazie

Gatineau, Quebec

Canada

K1A OH3

November 23, 2008

Dear Mr. LaRocque

Re: Electricity Sector Concerns with PCB Regulations

On behalf ofCanadian Electricity Sector member companies I would like to thank you for

meeting with us on November 12th to discuss the PCB regulations released in September.

CEA had sent you a letter on Friday November i h seeking clarification in interpreting a

number of areas ofthe regulations. You provided the information requested for a good

number ofthese areas, and committed to consider and further discuss others. One key area of

outstanding concern discussed is the treatment of a set of equipment located at generation,

transmission or distribution facilities with unknown levels of potential PCB contamination.

This letter identifies the equipment and outlines the issues of concern.

The key issue with this group of equipment is that the levels ofPCB contamination, if any,

are unknown. Testing the majority ofthis type of equipment is impractical for the following

reasons:

• Sealed, specialized equipment, which is critical to the safe and reliable operation of

the power system would be destroyed in testing; and

• Prolonged, unplanned outages at major power substations and generating stations

would need to be taken to remove equipment from service. It would be impossible

for the electricity sector to schedule these outages by the end of2009 without placing

the reliability ofthe power system at significant risk.

It is for these reasons that the electricity sector has serious concerns about its ability to

comply with the regulatory requirement that this type of equipment, with contamination

levels greater than 500 mg/kg PCB, must be removed from service by 2009. Although it is

anticipated that the number of units that would contain PCBs in a concentration of greater

than 500 mg/kg would be low, large numbers of equipment would have to be destroyed to

oSparks Street.suite 907. Ottawa. Ontario Canada KIR 7S8

.: 16131230·9263· fax: 1613) 230·9326" info@eaneleeLea

The voice of Canadian Electricity

350 rue Sparks. bureau 907. Ottawa. Ontario Canada Kl A 7

Tsl.: (613) 230·9263 • Telee,: (613) 230·9326 • info@eaneleet.

La voix de I'electricite canadienne
(/{ . Canadian Electricity Association :~' Associatio. canadle... dal'i1actricit8

www.canelect.ca

verify this; placing the electrical system at increased risk due to the number of unplanned

outages.

From the outset ofthe discussions with Environment Canada on the PCB regulations early in

the decade, CEA has been proposing that this group of equipment be treated in a similar

manner to poletop transformers: to have out ofservice requirement dates that would facilitate

planning cycles for maintenance and management practices and reasonable capital stock

turnover. The Canada Gazette I draft ofthe PCB regulations did this in Section 18(c) (A

person may continue to use, until December 31, 2025 ....current transformers, potential

transformers, circuit breakers, reclosers and bushings that are located at an electrical

generation, transmission or distribution facility). Unfortunately this appears to have been

dropped in the final version ofthe regulations published in Canada Gazette II.

CEA is proposing that an end of use date of 2025 be assigned to this equipment through

revisions to the regulations that: reinstates the language from the Canadian Gazette I Section

18(c); adopts alternative language; uses other non-regulatory method.

This is an extremely important issue for the sector and we hope you can accommodate our

request. Other materials, including a redraft ofthe full equipment table for the purpose of

clarifying the interpretation of "pole top transformers and their auxiliary equipment" and the

end of use requirements for other equipment will be forwarded to you under separate cover.

We look forward to discussing this further with you.

Yours Sincerely

CANADIAN ELECTRICITY ASSOCIAnON

Original signed.

Victoria Christie

Senior Advisor, Environmental Affairs

cc CEA PCB Task Group

Eli Turk, Vice President Government Relations, CEA

Carolyne Blain, Director, Waste Reduction and Management, EC

oSparks Street, suite 907, Ottawa, Ontario Canada K1R 7S8

.: 16131230·9263· fax; (6131230·9326·info@canelectca

The voice of Canadian Electricity

350 rue Sparks, bureau 907, Ottawa, Ontario Canada K1 R7S

Ts!.:(613) 230·9263· T~I~c.: 1613) 230·9326 • info@canelect

La voix de I'electricite canadtenne