USWAG Meeting 

April 27, 2010

Attendees: 

Mary Davis – American Electric Power 

James Roewer	- USWAG  

Lynn Vendinello – EPA/OPPT 

John Smith – EPA/OPPT 

Peter Gimlin – EPA/OPPT 

Christine Zachek – EPA/OPPT 

In our comments, we will be requesting an extension of the comment
period, based on the number of questions in the ANPR, and the fact that
it is a complex issue with complex questions. We need time to gather
information, the sooner we know if there will be an extension, the
sooner we can triage which questions will get answered. We will ask for
90-days, and will not ask for another extension. It is easier to plan a
response if we know sooner whether an extension request will be granted.
If there will not be an extension, EPA should tell the regulated
community what is important, so they can focus their attention, as some
questions may or may not apply to them. 

EPA would like to know how many pieces of PCB-containing equipment the
utilities have out there and the costs of phasing them out. 

This is a difficult question because there is equipment that contains
PCBs that we don’t know about. 

You have to have some sense of the proportion of PCB-containing
equipment based on the number taken out for service. 

EPA cannot equate the number of pieces of PCB-containing equipment that
we are seeing to the costs of going out and finding this equipment. 

The Askarel transformers were made with PCBs and name-plated by the
companies. 	

We know where those are. We removed 62 in multi-story buildings at a lot
of cost. 

Sections 5 and 14 that ask for data on populations, we don’t know if
these questions are “answerable.” 

	The higher concentration material seems to be the most important. 

For the definitional changes, where are these numbers coming from?

	

The Stockholm Convention. We want to be consistent with Stockholm
whether we are a party or not, as government policy.

But the Stockholm language is to “endeavor to identify and remove from
service.” 

What do we need to demonstrate to you that the voluntary programs are
working? The disposal records are showing downward trends. 

The registration database is staying consistent, and that is why we are
asking these questions. We need that information and right now there is
no deadline to collect it. Utilities are the leaders in collecting this
information, and others are far behind, including the federal
government. When we use “equipment” in the ANPR, we do not mean
utilities specifically. 

Has the transformer database been corrected? 

We sent the entire database to Doug Green and we have not gotten any
comments yet. We have to keep a record of the facilities, and we have to
keep track of the status of the equipment and where everything went. 

Will there be a mechanism to de-register units? 

	

The database reflects that when it is updated. 

We can get you the data to correct that. 

For non-liquid uses, what information would be helpful for obtaining a
use authorization? 

Anecdotal or otherwise. We just want to know what is out there; we
didn’t mean to imply that we were doing use authorizations. It is just
a request for information because we don’t know how broad the use of
PCBs in caulk has been. 

What about for excluded PCB products, like used oil? Right now all 2-49
oil will be regulated and burned in accordance with 40 CFR 761.20(e). 

	We would want to know how large is this and what would be the impact of
changing? 

We do not sample equipment unless we take it out of service for
disposal. 

	We have to ask. In 30 years, a lot of life is gone from this equipment 

For vintage equipment and failure rates… it is not always true that if
it fails, it releases PCBs. 

	We cannot count on the fact that if it fails again, it will not release
PCBs. 

If it fails, it comes out of service. 

We would think that your members would keep this type of information for
insurance records, and for the purpose of replacing old equipment.
Trying to find out how long this equipment lasts would be helpful. We
want to know if equipment fails, does it fail catastrophically? There
was much less necessity to keep up records of this in 1978, now there is
more reason. 

We will survey our members to see if they have insurance and/or records.
Right now, we do not have a need to know where this PCB equipment is. 

You have thousands of dollars in equipment and you do not know where it
is? The field people will know where the new equipment is, based on
manufacture dates. It is more likely that the older equipment will have
PCBs. Do these have higher failure rates? 

The repair/shop people tell us the newer equipment does not last as
long. Reclassification does not typically happen on distribution units. 

Based on Canada’s rule, the Canadian Electrical Association said they
cannot go out and identify their PCB-containing equipment. And they have
a smaller universe than we do in the U.S. Would the millions of dollars
spent to identify this equipment be worth it to find it?  Also, if you
sample it, then you destroy it. It will be very costly in terms of time,
labor, safety precautions, and outages. And Canada is not a third-world
country; they have the technical capacity to do it. We will get EPA more
information on this in Canada. 

A few of the terms were unclear in the ANPR. What do you mean when you
say “regulated” levels? 

	Above 50 ppm. 

What about “PCB-contaminated”?

 

50 to less than 500 ppm 

“PCB-containing”?

	

It generally has PCBs in it, no specific concentrations, just used as a
catch-all to mean that PCBs were not purposefully added. 

For the small-capacitors and light fixtures, how would you determine if
they contain 1.7 fl oz.? 

	

You could use the external dimensions to estimate capacity; you would
have to do it by density. 

We hope to get some information from the manufacturers. Lots of
equipment has small capacitors. We don’t know how you’re going to
register all those. 

In section I, number 4, what does this mean?

Is the substitute worse than the PCBs in terms of releases? The release
rate of non-PCBs compared to PCBs. Does this equipment fail
catastrophically more often? We have to look at alternatives to see if
there are any downsides. 

Do you track substation equipment for insurance purposes? What
percentage of transformers do you lose to releases? You would track it
if it is insured and you would track it because you need to replace it. 

We track spills. 

