SUPPLEMENTAL
RESPONSE
TO
COMMENTS
DOCUMENT
ON
THE
PROPOSED
RULE
 
DISPOSAL
OF
POLYCHLORINATED
BIPHENYLS
STORAGE
OF
PCB
ARTICLES
FOR
REUSE
January
2004
Prepared
by
the
Office
of
Pollution
Prevention
and
Toxics
National
Program
Chemicals
Division
Fibers
and
Organics
Branch
Office
of
Prevention,
Pesticides,
and
Toxic
Substances
U.
S.
Environmental
Protection
Agency
Washington,
DC
20460
INTRODUCTION
In
1998,
EPA
promulgated
the
PCB
Disposal
Amendments,
a
major
revision
of
the
rules
governing
use,
manufacture,
processing,
distribution
in
commerce,
and
disposal
of
polychlorinated
biphenyls
(
PCBs)
(
63
FR
35384,
June
29,
1998).
One
of
these
amendments
created
new
requirements
for
storing
PCB
Articles
(
as
defined
at
40
CFR
761.3)
for
reuse
(
40
CFR
761.35).

These
requirements
were
challenged
in
court.
Central
&
South
West
Services,
Inc.
v.
EPA,
220
F.
3d
683
(
5th
Cir.
2000).
While
the
court's
decision
generally
upheld
the
requirements,
the
court
directed
EPA
to
address
comments
submitted
during
the
rulemaking
process
that
requested
a
waiver
from
the
storage
for
reuse
requirements
for
the
electric
utility
industry.
This
supplement
addresses
those
comments.
1
Comment
1:
Electric
utilities
store
equipment
that
is
electrically
sound
and
that
does
not
present
a
risk.
Several
commenters
stated
that
electric
utilities
typically
keep
an
inventory
of
electrically
sound
equipment,
such
as
capacitors,
PCB
Transformers,
PCB­
Contaminated
Transformers,
and
voltage
regulators,
awaiting
reuse
to
replace
units
that
fail.
The
commenters
stated
that
these
units
are
tested
and
maintained
so
that
they
can
be
energized
on
short
notice.

Commenters
also
argued
that
the
larger
quantities
of
PCB­
containing
equipment
accumulated
by
brokers,
junk
yards,
and
service
shops
pose
a
greater
environmental
risk
than
the
inventories
maintained
by
owners
or
users
of
such
equipment
(
like
electric
utilities).
Also,
brokers,
junk
yards,
and
service
shops
are
less
likely
to
have
business­
related
justifications
for
keeping
the
equipment.
Commenters
urged
EPA
to
take
enforcement
action
against
known
abusers
instead
of
regulating
others
on
the
basis
of
suspected
abuse,
or
to
exempt
from
regulation
equipment
held
by
a
company
for
reuse
in
its
own
system.

Source:
(
C1­
027,
C1­
038,
C1­
122,
C1­
161,
C1­
199,
C1­
210,
C1­
217,
C1­
226)

Response
1:
EPA
imposed
the
new
storage
for
reuse
requirements
to
prevent
the
potentially
serious
environmental
damage
that
can
result
from
long­
term
unprotected
storage
of
equipment
containing
PCBs.
EPA
acknowledges
that
the
risks
are
greater
where
large
quantities
of
such
equipment
are
stored
by
facilities
that
have
no
intention
of
reusing
the
equipment
themselves
and
therefore
may
not
be
concerned
with
its
state
of
repair
(
see
the
preamble
to
the
proposed
PCB
Disposal
Amendments,
59
FR
62788,
December
6,
1994,
p.
62822).
While
risks
may
be
greater
at
these
facilities,
unregulated
storage
of
PCB
Articles
by
electric
utilities
can
also
present
an
unreasonable
risk
to
health
and
the
environment.

For
example,
EPA
inspected
a
facility
owned
by
Texas
Electric
Cooperatives,
Inc.,
that
provided
transformer
repair
and
re­
manufacturing
support
for
member
cooperatives
(
Complaint
and
Notice
of
Opportunity
for
Hearing,
TSCA
Docket
No.
VI­
533C,
September
27,
1991).
The
inspection
revealed
that
the
company
maintained
an
area
where
it
stored
transformers
for
repair
and
future
reuse.
This
area
contained
a
PCB­
Contaminated
transformer
that
had
leaked
or
spilled
2
PCBs
in
concentrations

50
ppm
to
the
ground,
constituting
an
improper
disposal
of
PCBs
under
§
761.60(
a).
The
company
consented
to
the
assessment
of
a
civil
penalty
for
violations
of
the
PCB
storage
and
disposal
regulations
(
Consent
Agreement
and
Consent
Order,
TSCA
Docket
No.
VI­

533C,
June
11,
1992).

An
EPA
inspector
visiting
a
transformer
storage
site
operated
by
the
City
of
Timpson
Electric
Utility
observed
about
50
transformers
stored
in
the
open,
either
directly
on
the
ground
or
on
wooden
pallets
(
Complaint
and
Notice
of
Opportunity
for
Hearing,
TSCA
Docket
No.
VI­

676C(
P),
December
31,
1996).
The
utility's
representative
stated
that
some
of
these
transformers
had
possible
future
reuse
and
others
would
not
be
reused.
The
inspector
observed
stains
on
the
exterior
surfaces
of
many
of
these
transformers.
The
transformers
showing
stains
either
did
not
have
nameplates,
or
the
information
on
the
nameplates
did
not
indicate
the
type
of
dielectric
fluid
the
transformers
contained.
The
transformers
had
not
been
tested
to
determine
their
PCB
concentration,
so
were
required
under
existing
regulations
to
be
assumed
to
be
PCB
Transformers
(
containing
PCBs

500
ppm).
The
utility's
representative
stated
that
the
utility
did
not
keep
records
on
the
use
or
disposal
of
PCBs.
City
of
Timpson
Electric
Utility
consented
to
the
assessment
of
a
civil
penalty
for
violations
of
the
PCB
storage
and
disposal
regulations,
and
agreed
to
dispose
of
56
transformers
containing
PCBs
and
otherwise
to
come
into
compliance
with
the
PCB
regulations
(
Consent
Agreement
and
Consent
Order,
TSCA
Docket
No.
VI­

676C(
P),
June
30,
1997).

EPA
does
not
dispute
the
comments
from
electric
utilities
stating
that
they
maintain
as
much
electrically
sound
equipment
as
is
needed
to
ensure
the
functioning
of
their
electrical
systems.
However,
these
EPA
inspections
show
that
electrical
equipment
that
a
company
claims
is
stored
for
reuse
can
present
a
risk
to
health
or
the
environment
from
spills,
leaks,
or
other
unauthorized
disposal.

Moreover,
the
commenters
did
not
supply
any
data
showing
that
the
equipment
stored
for
reuse
at
their
facilities
is
maintained
in
such
a
way
that
it
remains
intact
and
non­
leaking
and
3
therefore
does
not
present
a
risk
to
health
or
the
environment.
There
is
no
supporting
evidence
as
to
how
often
equipment
is
tested
after
being
placed
into
storage
or
how
it
is
maintained.
As
to
PCB
Transformers
and
voltage
regulators
containing
PCBs

500
ppm,
inspection
and
maintenance
data
should
be
readily
available.
The
PCB
rules
have
required
since
1982
that
this
equipment,
when
stored
for
reuse,
be
inspected
periodically
for
leaks
(
40
CFR
761.30(
a)(
1)(
ix)

and
(
xiii))
(
47
FR
37342,
August
25,
1982).
If
the
equipment
is
found
to
have
a
leak,
the
equipment
must
be
repaired
or
replaced
to
eliminate
the
source
of
the
leak,
and
released
PCBs
must
be
cleaned
up
and
properly
disposed
of.
Until
appropriate
action
is
completed,
any
active
leak
of
PCBs
must
be
contained
to
prevent
exposure
of
humans
or
the
environment
and
inspected
daily
to
verify
containment
of
the
leak
(
40
CFR
761.30(
a)(
1)(
x)).
The
owner
of
the
equipment
must
keep
records
of
these
inspection
and
maintenance
activities
for
a
least
three
years
after
disposing
of
the
equipment.
The
records
must
include
the
location
of
the
equipment;
the
date
of
each
visual
inspection
and,
if
a
leak
was
discovered,
the
date
that
it
was
discovered
(
if
different
from
the
inspection
date);
the
estimated
amount
of
fluid
that
leaked;
the
date
of
any
cleanup,

containment,
repair
or
replacement;
a
description
of
any
cleanup,
containment,
repair,
or
replacement;
and
the
results
of
any
containment
and
daily
inspection
required
for
uncorrected
active
leaks
(
40
CFR
761.30(
a)(
1)(
xii)).
In
establishing
the
inspection
and
maintenance
requirements,
EPA
stated
(
47
FR
37342,
August
25,
1982,
p.
37345):

EPA
is
concerned
about
releases
of
PCBs
from
all
transformers
because
of
the
potential
to
expose
humans
and
the
environment
to
PCBs.
In
general,
PCB
Transformers
pose
greater
exposure
risks
due
to
the
use
of
higher
concentration
and
larger
quantities
of
PCBs
than
mineral
oil­
filled
transformers.
A
release
of
PCBs
into
the
environment
has
the
potential
to
reach
aquatic
systems,
build
up
in
the
food
chain
and
ultimately
expose
humans
through
ingestion
of
PCBs.
.
.
.
[
The
inspection
and
maintenance
program]
will
reduce
the
actual
amount
of
PCBs
released
from
PCB
Transformers
by
correcting
otherwise
undetected
leaks
of
dielectric
fluid
and
reducing
the
number
of
transformer
failures
due
to
improper
maintenance.
Additional
benefits
of
this
program
include
containment
of
active
leaks
which
are
discovered
and
cleanup
and
disposal
of
leaked
material.
All
of
these
benefits
4
will
result
in
reduced
exposure
to
PCBs.

The
commenters
did
not
submit
records
of
these
inspection
and
maintenance
activities
to
support
their
position
that
EPA's
concerns
about
leaks
from
this
equipment
are
unfounded.

Commenters
also
stated
that,
because
of
the
value
of
the
equipment,
it
is
stored
in
a
restricted
area
to
which
only
authorized
personnel
have
access.
Equipment
is
typically
stored
on
concrete
pads
in
proximity
to
the
energized
equipment
that
it
would
replace
or
in
storage
yards
where
the
utility
maintains
an
inventory
to
replace
failed
units.
The
term
"
restricted
access
area"

generally
refers
to
an
electrical
substation
or
other
area
to
which
access
is
restricted
by
man­
made
barriers
such
as
fences
or
by
natural
barriers
such
as
mountains,
cliffs,
or
rough
terrain.
These
areas
generally
include
industrial
facilities
and
extremely
remote
rural
locations
(
see
40
CFR
761.123).
A
"
restricted
access
area"
is
not
necessarily
designed
with
environmental
protection
in
mind.
Spills
of
regulated
levels
of
PCBs
in
a
restricted
access
area
can
pose
a
risk
to
those
outside
the
area
by
escaping
from
the
area
or
by
leaching
to
groundwater.
In
contrast,
facilities
designed
for
the
long­
term
storage
of
PCBs
and
hazardous
waste
are
designed
primarily
to
contain
and
control
releases
from
the
equipment
to
prevent
PCBs
from
being
released
to
the
environment
outside
the
storage
area.
The
final
rule
therefore
allows
storage
of
PCB
Articles
for
reuse
in
such
an
area
indefinitely.

In
short,
commenters
arguing
that
current
storage
for
reuse
practices
are
environmentally
protective
did
not
support
their
position
with
data,
only
general
statements,
impressions,
or
beliefs.
This
is
illustrated
by
the
following
comments
(
emphasis
added).
The
CMA/
USWAG/
NEMA
comments
state,
"
To
the
best
of
our
knowledge,
there
have
been
few,
if
any,
incidents
of
leaks
or
releases
from
the
electrical
equipment
being
stored
for
reuse
and
therefore
no
risk
of
injury
to
human
health
or
the
environment"
(
C1­
161).
The
Department
of
Energy
"
does
not
believe
that
storage
for
reuse
presents
a
threat
to
human
health
or
the
environment
in
as
much
as
electrical
equipment
is
designed
to
be
installed
and
used
in
extreme
weather
conditions,
under
load,
outside
and
unprotected
from
the
elements"
(
C1­
147).
5
Connecticut
Department
of
Environmental
Protection
proposed
a
less
restrictive
regulatory
alternative
for
electric
utilities,
noting,
"
The
risk
associated
with
this
change
seems
low,
since
electric
utilities
are
generally
more
aware
and
knowledgeable
about
maintenance
of
such
items
than
others"
(
C1­
249).
Pacific
Gas
&
Electric
"
believes
that
existing
storage
flexibility
provided
by
40
CFR
Part
761
is
sufficient
and
protective
of
the
environment
given
utilities'
mandate
to
provide
safe
and
efficient
service"
(
C1­
210).
Montana­
Dakota
Utilities
Co.
opined
that
"
most
utilities
have
made
efforts
to
reclassify
or
dispose
of
surplus
PCB
articles,
since
the
liabilities
attached
are
so
great"
(
C1­
038).
Commonwealth
Edison
confessed
that
it,
"
like
all
large
electric
utilities,
has
been
very
much
impacted
by
TSCA
regulations
and
are
already
well
aware
of
the
importance
of
proper
storage
methods,
disposal
requirements,
etc.
hence
abuses
are
not
likely
and
certainly
not
intentional"
(
C1­
114).
Northeast
Utilities
System
"
knows
of
few
incidents
of
leaks
or
releases
from
electrical
equipment
stored
for
reuse.
.
.
.
Based
on
their
larger
storage
quantities,
[
brokers,
junk
yards,
and
service
shops]
may
present
a
greater
environmental
risk"

(
C1­
217).
Iowa­
Illinois
Gas
and
Electric
Co.
argues
that
"
the
continued
and
indefinite
storage
of
this
equipment
for
use
poses
no
particular
environmental
threat
since
it
must
be
intact
and
nonleaking
but
acknowledged
that
"
any
damaged
equipment
that
is
discovered
[
i.
e.,
after
the
intact
and
non­
leaking
stored
equipment
has
started
to
leak]
is
either
repaired
or
decommissioned
in
accordance
with
U.
S.
EPA's
requirements
for
disposal"
(
C1­
257).

EPA
concludes
that
comments
do
not
demonstrate
that
storage
for
reuse
practices
in
the
electric
utility
industry
are
so
environmentally
protective
that
the
industry
should
receive
a
waiver
from
the
requirements
of
§
761.35.
Electric
utilities
provided
only
their
subjective
belief
that
conditions
at
their
sites
are
sufficiently
protective
against
unreasonable
risks
to
health
and
the
environment.
The
commenters
did
not
support
their
belief
with
data
adequate
to
support
a
finding
that
current
practices
across
the
industry
do
not
present
an
unreasonable
risk.

Comment
2:
Stored
equipment
is
vital
to
maintaining
a
reliable
power
system.
Many
commenters
believed
the
storage
for
reuse
requirements
would
restrict
their
ability
to
maintain
back­
up
equipment
or
spare
parts
necessary
to
keep
their
power
systems
operating,
or
to
repair
6
equipment
that
was
otherwise
usable.
Other
commenters
stated
that
capacity
in
§
761.65(
b)

storage
facilities
is
insufficient,
and
utilities
would
have
to
incur
the
costs
of
building
new
storage
areas.
Others
stated
that
utilities
would
have
to
reclassify
their
equipment
to
avoid
the
new
requirements,
generating
unnecessary
waste
and
unnecessary
disposal
costs,
without
additional
protection
to
health
or
the
environment.
One
commenter
noted
that
some
equipment
known
or
assumed
to
be

50
ppm
cannot
be
reclassified
because
it
is
sealed.

Source:
(
C1­
029,
C1­
046,
C1­
081,
C1­
122,
C1­
136,
C1­
144,
C1­
147,
C1­
161,
C1­

179,
C1­
199,
C1­
210,
C1­
217,
C1­
249,
C1­
257)

Response
2:
EPA
recognizes
the
importance
of
spare
equipment
and
parts
to
a
utility's
ability
to
provide
uninterrupted
electrical
service,
and
acknowledges
that
in
many
cases
extended
storage
for
reuse
of
spares
is
warranted
(
see
the
preamble
to
the
proposed
PCB
Disposal
Amendments,
59
FR
62821­
22).
Nonetheless,
this
equipment
must
be
stored
in
a
manner
that
does
not
pose
an
unreasonable
risk.
The
final
rule
addressed
these
comments
by
allowing
storage
for
reuse
outside
a
§
761.65(
b)
storage
area
for
five
years,
as
opposed
to
the
proposed
limit
of
three
years.
In
addition,
based
on
comments,
the
final
rule
allows
PCB
Articles
to
be
stored
in
excess
of
five
years
outside
a
§
761.65(
b)
storage
area
if
the
owner
or
operator
has
received
the
approval
of
the
EPA
Regional
Administrator.
Finally,
the
rule
allows
indefinite
storage
for
reuse
of
PCB
Articles
placed
in
a
storage
area
permitted
under
RCRA
section
3004
or
3006.
These
modifications
allow
utilities
to
maximize
their
use
of
existing
storage
arrangements
and
reduce
the
need
for
constructing
new
storage
areas.

EPA
disagrees
with
the
comment
that
reclassifying
PCB
equipment
generates
unnecessary
waste
and
creates
unnecessary
disposal
costs,
without
additional
protection
to
health
or
the
environment.
Reclassification
does
produce
environmental
benefits.
The
process
of
retrofilling
electrical
equipment
during
reclassification
removes
substantially
all
the
original
fluid,
and
because
this
fluid
is
subject
to
the
disposal
requirements
of
40
CFR
part
761,
subpart
D,
it
is
not
released
to
the
environment.
The
reclassified
equipment
remains
in
use,
but
the
lower­
concentration
fluid
7
poses
a
reduced
risk
to
health
and
the
environment
from
spills
or
other
exposures.
In
addition,

disposal
of
the
equipment
at
the
end
of
its
useful
life
and
the
fluid
it
contains
are
regulated
to
protect
health
and
the
environment.
The
commenter
is
correct
that
there
are
costs
to
reclassification,
just
as
there
are
costs
associated
with
many
aspects
of
managing
PCBs
to
protect
health
and
the
environment.
However,
reclassification
is
a
voluntary
process.
The
owner
or
operator
of
equipment
stored
for
reuse
should
weigh
the
costs
of
continued
storage
of
the
equipment
as
a
PCB
Article
under
§
761.35
against
the
costs
of
reclassifying
the
equipment
to
an
unregulated,
non­
PCB
status.

EPA
concludes
that
these
comments
do
not
demonstrate
that
the
electric
utility
industry
needs
an
exemption
from
§
761.35
to
allow
it
to
store
the
equipment
necessary
to
make
sure
their
systems
can
operate
and
their
customers
can
be
served.
The
modifications
to
§
761.35
made
in
response
to
comments
allow
the
use
of
storage
areas
that
would
not
have
been
allowed
under
the
proposal,
and
increase
the
time
equipment
can
be
kept
in
storage
for
reuse
to
allow
efficient
operation
of
electric
utility
systems.

Comment
3:
Recordkeeping
requirements
would
be
costly
and
difficult
to
implement.

Some
commenters
asserted
that,
in
general,
additional
requirements
for
record­
keeping
and
approvals
would
be
time­
consuming
and
would
add
to
administrative
costs,
without
additional
protection
to
health
or
the
environment.
Another
commenter
stated
that
it
already
maintains
all
the
information
required
by
the
proposed
rule
(
date
of
removal
from
use,
projected
location
and
future
use,
date
the
article
will
be
repaired
or
serviced)
in
a
computer
database.
A
commenter
objected
to
the
requirement
to
maintain
records
of
the
projected
location
and
future
use
of
a
PCB
Article
that
is
stored
for
reuse
(
see
§
761.35(
a)(
2)(
ii)).
The
commenter
stated
that
it
would
be
difficult
to
determine
in
all
cases
where
this
equipment
would
be
used
on
the
power
system.

Another
commenter
thought
this
requirement
would
not
be
overly
burdensome,
as
long
as
general
answers
were
allowed.
Commenters
also
stated
that
the
proposed
requirement
to
label
equipment
stored
for
reuse
was
burdensome
and
unnecessary
because
information
EPA
proposed
to
require
on
the
label
was
already
maintained
in
the
annual
document
log
(
see
the
preamble
to
the
final
PCB
8
Disposal
Amendments,
63
FR
35399).

Source:
(
C1­
046,
C1­
081,
C1­
122,
C1­
147,
C1­
199,
C1­
217)

Response
3:
As
was
explained
in
the
preamble
to
the
final
rule,
EPA
concluded
that
the
requirement
to
maintain
records
of
the
projected
location
and
future
use
of
a
PCB
Article
that
is
stored
for
reuse
is
necessary
to
distinguish
an
article
in
storage
for
reuse
from
one
in
storage
for
disposal
(
63
FR
35400).
A
generic
statement
saying
that
a
piece
of
equipment
is
of
a
size
and
voltage
that
could
be
used
in
numerous
locations
throughout
a
distribution
system
would
fulfill
this
requirement;
it
would
not
be
necessary
to
identify
a
specific
piece
of
equipment
that
the
article
could
replace.
EPA
also
agreed
with
the
commenters
that
the
proposed
labeling
requirement
should
not
be
finalized,
noting
that
PCB
Articles
stored
for
disposal
are
required
to
be
labeled,
and
that
adding
a
labeling
requirement
for
PCB
Articles
stored
for
reuse
could
therefore
be
confusing
(
63
FR
35399).

EPA
retained
the
other
proposed
recordkeeping
requirements
for
PCB
Articles
being
stored
for
reuse,
since
much
of
this
information
is
normally
maintained
in
the
facility's
annual
document
log.
The
Agency
believes
that
owners
or
operators
with
PCB
Articles
being
kept
for
reuse
already
maintain
records
indicating
when
articles
are
removed
for
servicing
or
repair
for
scheduling
and
budgeting
purposes
(
see
the
preamble
to
the
final
PCB
Disposal
Amendments,
63
FR
35400).
The
Office
of
Management
and
Budget
approved
the
recordkeeping
requirements
in
§
761.35
under
the
Paperwork
Reduction
Act
as
part
of
EPA
Information
Collection
Request
1729.02
(
63
FR
57123,
October
26,
1998,
p.
57124).

These
comments
from
the
electric
utility
industry
do
not
demonstrate
that
compliance
with
the
recordkeeping
requirements
of
§
761.35
would
be
so
costly
and
burdensome
as
to
justify
a
waiver
for
that
industry,
or
that
the
requirements
are
unnecessary
to
protect
against
risk
and
to
ensure
compliance
with
the
storage
for
reuse
requirements
in
that
industry.
9
Comment
4:
Revise
the
rule
to
exempt
individual
electric
utilities
with
comprehensive
PCB
programs.
A
commenter
suggested
EPA
revise
§
761.35
to
say,
"
The
three­
year
time
limit
on
storage
for
re­
use
.
.
.
shall
be
disregarded
if
the
storer
of
PCB
contaminated
or
PCB
electrical
equipment
has
tested
the
entire
storage
facility
for
PCB
content
by
gas
chromatograph
testing,
the
stored
electrical
equipment
is
repaired
and
is
available
for
immediate
use
and
is
intact
and
nonleaking
Other
commenters
suggested
EPA
waive
the
requirements
for
utilities
storing
intact
and
sealed
electrical
equipment
for
replacement.

Source:
(
C1­
122,
C1­
136,
C1­
144)

Response
4:
These
comments
envision
an
alternative
regulatory
approach,
whereby
EPA
would
determine
on
a
case­
by­
case
basis
which
utilities
have
a
comprehensive
program
that
adequately
protects
against
the
potential
risks
of
long­
term
storage
of
electrical
equipment.

However,
the
commenters'
suggestions
did
not
include
details
such
as
how
a
utility
would
ensure
that
its
equipment
was
intact
and
non­
leaking,
how
frequently
equipment
would
be
inspected
for
leaks,
and
what
records
would
have
to
be
kept.
EPA
therefore
did
not
see
these
suggestions
as
viable
regulatory
alternatives
to
the
proposed
rule.
It
is
worth
noting,
however,
that
§
761.35(
b)

provides
a
mechanism
for
the
Regional
Administrator
to
approve
storage
for
reuse
outside
an
approved
storage
area
for
a
period
in
excess
of
five
years.
Utilities
that
believe
their
practices
adequately
protect
against
the
potential
risks
of
long­
term
storage
could
request
an
extension
of
the
storage
period
based
on
that
justification.
10
LIST
OF
COMMENTERS
C1­
027
The
Association
of
Texas
Electric
Cooperatives,
Inc.

C1­
029
American
Electric
Power
Service
Corp.

C1­
038
Montana­
Dakota
Utilities
Company
C1­
046
Public
Utility
District
#
1
of
Clallam
County
C1­
081
Nebraska
Public
Power
District
C1­
114
Commonwealth
Edison
C1­
122
Northwest
Public
Power
Association
C1­
136
Northern
States
Power
Company
C1­
144
Cooperative
Power
Association
C1­
147
U.
S.
Department
of
Energy
C1­
161
Chemical
Manufacturers
Association
(
CMA)

C1­
179
Consumers
Power
Company
C1­
199
City
of
Los
Angeles,
Department
of
Water
&
Power
C1­
210
Pacific
Gas
&
Electric
Company
C1­
217
Northeast
Utilities
System
C1­
226
Brazos
Electric
Cooperative
C1­
249
State
of
Connecticut
Department
of
Environmental
Protection
C1­
257
Iowa­
Illinois
Gas
&
Electric
Company
