VIA ELECTRONIC FILING ://...Docket No. EPA-HQ-OPPT-2009-0757 August 20, 2010 Page 6 of 30 current,...

VIA ELECTRONIC FILING http://www.regulations.gov August 20, 2010 U.S. Environmental Protection Agency (EPA) EPA Docket Center (EPA/DC) Attention: Docket ID No. EPA-HQ-OPPT-2009-0757 1200 Pennsylvania Avenue, NW Washington, D.C. 20460 RE: EPA Advance Notice of Proposed Rulemaking, Polychlorinated Biphenyls (PCBs)

Reassessment of Use Authorizations, 75 Fed. Reg. 17,645 (April 7, 2010) Ladies and Gentlemen:

The American Gas Association (AGA) appreciates the opportunity to comment on EPA’s

Advance Notice of Proposed Rulemaking regarding the Reassessment of the Polychlorinated

Biphenyls (“PCB”) Use Authorizations1 (the “Advance Notice”).

The American Gas Association, founded in 1918, represents 195 local energy companies that

deliver clean natural gas throughout the United States. There are more than 70 million

residential, commercial and industrial natural gas customers in the U.S., of which 91 percent —

more than 64 million customers — receive their gas from AGA members. AGA is an advocate

for natural gas utility companies and their customers. Today, natural gas meets almost one-

fourth of the United States' energy needs.

1 75 Fed. Reg. 17,645 (April 7, 2010).

http://www.regulations.gov/

AGA Comments on ANPRM Reassessment of PCB Use Authorization Docket No. EPA-HQ-OPPT-2009-0757 August 20, 2010 Page 2 of 30

Introduction In the Advance Notice, EPA announces that it is considering phasing out the use authorization

for PCBs in natural gas pipeline and distribution systems, culminating in a ban on the presence

of PCBs above 1 part per million (ppm) by 2020 “or an earlier date.”2 We say “presence” rather

than “use” because natural gas system operators do not “use” PCBs in the ordinary meaning of

the word. Instead, PCBs are a legacy issue for our industry – a residual contamination derived

from the past use of PCBs in the mid 20th century in some pipelines and some distribution

systems, primarily: (1) as a fire retardant in the liquid hydraulic fluid or lubricating oil in pipeline

compressors; (2) in valve grease; or (3) as a fogging agent in local distribution mains. The

actual purchase and use of these legacy PCBs ceased well over 30 years ago.

Currently, EPA’s regulations under 40 C.F.R. Part 761 authorize the presence of these residual

PCBs in natural gas systems (1) at concentrations less than 50 parts per million (ppm)

essentially without condition, and (2) at concentrations above that threshold provided the

operator follows the applicable management practices described in Section 761.30(i) and the

associated characterization and disposal practices described in Section 761.60(b)(5).

EPA asserts that the use authorizations for PCBs and the 50 ppm regulatory threshold in Part

761 were not based on risk assessments but were only based on cost considerations.3 In fact,

EPA established this use authorization in the amendments to Part 761 adopted in 1998 (the

“Mega Rule”)4 based on extensive sampling programs and a risk assessment5 that determined

the presence of PCBs at these levels in buried, largely closed natural gas systems did not pose

an unreasonable risk to human health and the environment.6

2 75 Fed. Reg. at 17657 (middle column). 3 75 Fed. Reg. at 17658 (middle column, section X) states: “The level of 50 ppm has been used in PCB use regulations since 1979. Based on regulatory history, this number is based almost entirely on economic considerations. There are no traditional exposure and risk assessment calculations (Refs 3 and 8).” 4 63 Fed. Reg. 35384 (June 29, 1998) (“Mega Rule”). 5 See EPA Exposure Assessment for Polychlorinated Biphenyls (PCBs): Incidental Production, Recycling, and Selected Authorized Uses, 1984 (“Exposure Assessment”), Exhibit A. 6 See 1984 Regulatory Impact Analysis (“1984 RIA”) and Response to Comments on the Proposed Uncontrolled PCBs Rule, June 1984 (“1984 Response to Comments”) , pp. 84-87. Exhibit A.


EPA asserts in the Advance Notice that it may apply a different, lesser legal standard to

eliminate a use authorization than to establish a new one. Comments filed by the Utility Solid

Waste Activities Group (USWAG) in this docket clearly refute that assertion. As USWAG

demonstrates, any rule that would alter the existing PCB use authorizations, including any

decision to reverse EPA’s no unreasonable risk finding that provides the basis for these

authorizations, must be supported by substantial evidence in the rulemaking record.7 Further,

for reasons discussed in USWAG’s comments and in AGA’s comments, we believe the agency

would not be able to compile a record meeting this evidentiary burden. AGA supports and

incorporates by reference the comments filed by USWAG on the Advance Notice.

In addition to the exposure and risk assessment, EPA’s use authorization for natural gas

pipeline and distribution systems in the Mega Rule was based on a determination that the cost

of attempting to remove all trace of PCBs from natural gas pipelines, distribution systems and

appurtenant equipment would exceed $30 billion in 1984 dollars.8 Specifically, EPA’s June 1984

Response to Comments stated that based on the 1984 Regulatory Impact Analysis,

“EPA believes that it would be difficult, if not impossible to eliminate PCBs from these

systems without replacing the compressors and pipelines. The Regulatory Impact

Analysis (RIA) for this authorization estimates the cost for the replacement of the 28

contaminated compressors at $227 million, and the pipelines at $30 billion.9

It should be noted that this 1984 RIA estimated the cost of implementing the ban only with

respect to interstate pipelines; it did not estimate the cost of trying to eliminate PCBs from

affected natural gas distribution systems. Even for the interstate pipelines, EPA’s 1984 estimate

grossly understated the true cost as demonstrated in comments filed by the Interstate Natural

Gas Association of America (INGAA). In fact, a recent analysis demonstrates that the cost of

7 See USWAG Comments on the Advance Notice, pp. 10-11. 8 See 1984 Response to Comments, at page 85, Exhibit A. 9 Id.


attempting to achieve a complete phase out of PCBs in natural gas interstate transmission

systems would exceed hundreds of billions of dollars.10

AGA’s recent member survey indicates that the cost of attempting to locate and eliminate all

trace of PCBs in natural gas distribution systems would include the cost of excavating, purging,

and sampling pipe and equipment at regular intervals throughout many miles of potentially

affected systems, and removing and replacing significant portions of these systems. It is difficult

to estimate the total cost of such a mammoth and unprecedented project. Further study will be

required to develop a defensible range of these costs, but preliminary information provided in

the 2010 AGA Survey indicate the total cost of eliminating the use authorization for natural gas

distribution systems above 1 ppm PCBs could also exceed hundreds of billions of dollars

Excavating, purging and replacing a significant portion of the 2.1 million miles of distribution

mains and service lines in the United States11and associated valves and other appurtenant

equipment would disrupt service to customers on a massive scale ( involving protracted periods

with no natural gas for furnaces, water heaters, ranges, clothes dryers and other gas

appliances), require excavating millions of miles of streets and roads, millions of acres of

farmland and lawns, and millions of citizens’ property in major metropolitan communities and

small towns across the country. It would also cause significant construction-related traffic

congestion, an increase in the risk of traffic accidents, and an increase in the risk for public and

worker safety. As INGAA notes, EPA’s proposal to eliminate the use authorization for PCBs in

natural gas transmission and distribution systems, air compressor systems and porous systems

would have the unintended consequence of creating genuine risks to health and the

environment, where none currently exist.12 AGA supports and incorporates by reference the

comments filed by INGAA on the Advance Notice.

10 INGAA Comments, section VI. A. 2., and white paper cited therein, Analysis Group, Economic Impacts of EPA’s Advance Notice of Proposed Rulemaking on the PCB Use Authorization for Interstate Natural Gas Pipelines 55, 60 (Aug. 2010). 11 There are 1,206,000 miles of distribution mains and 866,500 miles of service lines, for a total of 2,072,500 miles of distribution pipes in the United States, based on annual data reported to the Department of Transportation (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA). This data is available on the PHMSA web site and is summarized in Gas Facts, an annual AGA publication. See http://www.techstreet.com/standards/AGA/F1012009?product_id=1663646 12 INGAA Comments, sections I and VI.B.

http://www.techstreet.com/standards/AGA/F1012009?product_id=1663646


EPA implies in the Advance Notice that PCBs may have greater toxicity than it originally

assumed when it developed the Mega Rule.13 As shown in USWAG’s comments, EPA is

relying on outdated data and evidence that is anecdotal, unreliable and in many instances

irrelevant. Further, new studies actually show that PCBs are less toxic than originally assumed

for both cancer and non-cancer risks.14 The Advance Notice points to studies that support

what appears to be EPA’s pre-conceived conclusion, while ignoring other significant studies,

including one of EPA’s own making,15 that refute EPA’s assertion on greater PCB toxicity.

Since “EPA seeks information on the environmental effects of PCBs that became available after

2000,” AGA is disappointed that EPA did not grant sufficient time in the comment period to allow

for the extensive analysis of health effects studies and scientific data that GE is undertaking.

On July 20, 2010, AGA, GE and others filed a multi-party request for an additional 45-day

extension of the comment period until October 4, 2010. EPA responded that the agency will not

grant a formal deadline extension, but it will nevertheless accept comments in the rulemaking

docket after August 20, 2010. We appreciate the agency’s commitment in this regard, and

expect that the agency will in fact accept and consider GE’s comments when filed as well as

any supplemental information and comments that AGA and other parties can provide after

August 20, 2010. Given that the agency is not under any statutory or court-ordered deadline

and has announced that it does not plan to issue a proposed rule until May 2012, EPA should

easily be able to consider additional comments and information submitted within the next 45

days, if not longer.

The legal burden is on EPA to provide substantial evidence on the record to support a decision

to overturn its original determination of no unreasonable risk.16 However, EPA has provided no

new risk assessment or other credible basis for altering its original determination that the

presence of PCBs at 50 ppm or greater in natural gas systems poses no unreasonable risk to

human health or the environment.17 The Advance Notice concedes that “EPA does not have a

13 See, 75 Fed. Reg. at 17649,-1. 14 USWAG Comments, section III.A. 15 EPA Exposure Assessment for Polychlorinated Biphenyls (PCBs): Incidental Production, Recycling, and Selected Authorized Uses, 1984 (“Exposure Assessment”), Exhibit A. 16 USWAG comments, pp. 10-11. 17 75 Fed. Reg. at 17651.

AGA Comments on ANPRM Reassessment of PCB Use Authorization Docket No. EPA-HQ-OPPT-2009-0757 August 20, 2010 Page 6 of 30 current, thorough national assessment of the risks to human health and the environment from

PCB releases.” Yet EPA proposes to require the operators of natural gas pipelines and

distribution systems to remove all PCBs from their buried pipe and equipment below 1 ppm –

which is below the reliable detection level of existing technology for PCBs in natural gas

condensates.

It is physically and economically impossible to eliminate PCBs from all natural gas system

locations below 50 ppm, let alone 1 ppm. Member companies subject to the PCB regulations

have removed a significant amount of the original mass of PCBs from their systems since

1981.The management practices these companies invested in developing and applying since

the 1998 PCB Disposal Amendments have been refined over the many years since.

In 2009, AGA conducted a member survey to collect information EPA requested about PCBs

and oily liquid condensates (“hydrocarbon liquids”) that potentially can mobilize PCBs in

distribution systems. Our detailed November 2009 response to EPA is attached and

incorporated in these comments as Exhibit B. As summarized in our cover letter, we found that

the volume of hydrocarbon liquids is generally declining in member natural gas distribution

systems, and many systems are now dry. Many of our members have never found PCBs in their

systems at detectable levels or >50 ppm. Those that have found PCBs above 50 ppm have

procedures for PCB detection and control. Perhaps more importantly, only 9 companies out of

the 67 respondents had ever detected PCBs >50 ppm beyond industrial, commercial or

residential customer meters out of the 67 responding companies. Of those, only 7 residential

meters in the past decade have had PCBs >50 ppm go beyond the meter -- out of the 46 million

residential meters served by the companies responding to the survey -- many of which you are

aware of from the 2007 experience in Region 5. That is equivalent to an incidence of one in 6.6

million meters.

Further, there were only 53 meters in the past decade – or about 5 per year on average out of

46 million meters—that were found to have PCBs above 50 ppm inside but not beyond the

meter. In all cases, the meters were removed and PCBs in hydrocarbon liquids were disposed

of in accordance with Part 761.

AGA Comments on ANPRM Reassessment of PCB Use Authorization Docket No. EPA-HQ-OPPT-2009-0757 August 20, 2010 Page 7 of 30 In July 2010, AGA conducted an additional member survey to update the 2009 survey data and

to gather other information to help us respond to EPA’s Advance Notice. The 2010 AGA survey

confirmed the general trend of declining hydrocarbon liquids, and demonstrated that current

practices are working to reduce the amount of PCBs in natural gas systems over time. Natural

gas distribution and transmission systems have been systematically removing PCBs in

hydrocarbon liquids every year for the past 12 years. Our 2010 survey indicates that the

responding utility members have removed over 58,000 gallons of hydrocarbon liquids containing

>50 ppm PCBs from natural gas distribution and intra-state transmission systems over the last

12 years. However, this is a conservative number, considering that some members were

unable to provide the estimated total gallons removed since 1998, because they do not retain

this type of record over such a long period. Thus, the total amount of condensate removed

since 1998 is likely to be much greater. Given the ban on manufacture and sale of PCBs, no

new PCBs have been introduced in these systems during that period. Obviously, the total mass

of PCBs has declined, because no new PCBs have been introduced, and 58,000 gallons of

hydrocarbon liquids containing PCBs have been removed. As time goes on, the systems have

become drier. Most companies are finding less hydrocarbon liquids in their systems each year

– with or without PCBs. This further reduces the risk of PCBs being mobilized by hydrocarbon

liquids to or beyond the customer meter. Not surprisingly, the recent survey also showed that

out of 41 responding distribution companies or systems, no PCBs reached beyond any

residential or commercial meter.

It is important for EPA to recognize that even in the absence of PCBs, gas transmission

companies aggressively remove liquids ahead of compressors to avoid catastrophic equipment

failure, and gas distribution companies prevent fluids from entering into their systems to prevent

valves and meters from malfunctioning. Fluids must be kept out of meters to prevent the meters

from recording inaccurate information and shutting off gas service to customers.

In short, current practices work well to protect people and the environment. There is no

justification for EPA’s contemplated phase out and elimination of the PCB use authorization for

natural gas systems. AGA strongly opposes the proposal to phase out and eliminate the PCB

use authorization for natural gas systems.

AGA Comments on ANPRM Reassessment of PCB Use Authorization Docket No. EPA-HQ-OPPT-2009-0757 August 20, 2010 Page 8 of 30 Instead, we recommend that EPA work with stakeholders to revise Part 761 to focus the rule on

what we believe is EPA’s main concern – to manage and reduce the occurrence of oily liquid

condensates in distribution systems to keep them from moving PCBs beyond the customer

meter. This would allow both EPA and the regulated community to focus scarce resources on

measures that have been shown to be effective.

AGA and its members have been anticipating for some time that EPA would want to revisit the

regulations governing PCBs in natural gas systems, hopefully to fine-tune the requirements after

years of implementation experience. We have been developing practical approaches to

complying with the intent of the regulations that we believe are equally protective of human

health to what EPA is considering, and are offering some of these refinements here.

Detailed Comments

I. It Is Physically and Economically Impossible to Completely Remove PCBs from Natural Gas Systems

A. Experience under the Mega Rule Shows that the Mass of PCBs Can Be

Reduced Over Time, But Cannot Be Entirely Eliminated

AGA members that have residual PCBs in their systems have been diligently following the

applicable requirements of the Mega Rule for the past 12 years and PCBs are being eliminated

from these systems. In some instances, our members have voluntarily gone beyond the

requirements of the rule in an effort to eliminate PCBs from their systems. This effort has

primarily focused on monitoring drips, separators and scrubbers for the presence of oily liquids

in areas where PCBs have been detected in the past, and removing the oily liquids when found.

The focus has been on oily liquids, because PCBs are not water soluble. PCBs also do not

migrate in a “vapor phase” at the low pressures and low velocities found in natural gas

distribution systems.18 PCBs adhering to a pipe in a dry residue do not move from that location

unless oily hydrocarbon liquids are present. As oily hydrocarbon liquids move through

distribution systems, mobilize PCB residues, and then are removed, this action has necessarily

reduced the overall mass of PCBs remaining in the affected natural gas transmission and

distribution piping. No PCBs have been added since EPA banned the manufacture and sale of

18 See AGA 2009 Presentation to EPA. (Exhibit C)


PCBs in 1978, and PCBs have been removed in oily condensates and impacted equipment and

pipe every year for decades. As noted above, obviously the mass of PCBs remaining in these

systems is going down.

While not a liquid, PCB-containing valve grease is still a legacy contaminant in certain older

valves. Since the grease can enter the pipe through the valve and be dissolved in pipeline

liquid, valves in affected areas of a pipeline system are managed under the use authorization in

the same compliant manner as pipelines with PCB contamination from other sources.

Specifically, Rockwell 860 and 991 valve greases containing PCBs were used in some small

cold-weather gas valves in the mid 20th century as a lubricant. Rockwell manufactured these

formulations from 1962 through 1973. Rockwell did not notify the gas industry that these

formulations contained PCBs until 1991. Years later, it is very difficult to determine which

valves may contain this lubricant, and usually it cannot be determined until the valve is taken out

of service. It would be impossible to identify and remove all such valves by a certain date

without excavating and testing all valves in the system - which would obviously result in massive

costs and disruptions to service. There is no need for this. When valves are identified that

potentially contain the Rockwell grease, the valve assembly is excavated and isolated from the

pipeline to determine the presence of PCBs. Companies that own these valves have practices

in place to test removed valves and properly dispose of them, which over time will ultimately

result in the removal of all valves containing Rockwell grease. EPA has provided no justification

for accelerating this process to remove all such valves by 2020.

Natural gas transmission and distribution systems are generally becoming drier. Therefore,

there is a lower risk of exposure, because PCBs do not move in dry natural gas distribution

systems. They stay in the buried pipe, which are cathodically protected to minimize corrosion,

away from people and the environment.

There is no way to determine, model or predict where the potential residues of PCBs may be or

where oily liquid pipeline condensates may move within a natural gas system, due to its

complexity.19 So it is not possible to target only certain limited portions of the underground

19 See AGA 2009 Presentation to EPA, Exhibit C.


network of pipes for replacement. Instead, large portions of the pipelines, mains, valves, and

other appurtenant equipment in affected systems would have to be excavated and replaced if

EPA eliminates the use authorization in 2020. Even spread across more than the next ten

years, this massive project would result in unprecedented costs and disruption in natural gas

service to homes, businesses, hospitals, schools, and factories across the country. Aside from

the cost and disruption of such an undertaking, there are not enough DOT-qualified personnel20

and material to accomplish this massive rebuilding by 2020.

B. Eliminating the Use Authorization Would Require Excavating, Testing and Replacing Significant Portions of Natural Gas Transportation Infrastructure at Enormous Cost to Ratepayers and the Economy

There are 2.1 million miles of distribution mains and service lines (“distribution pipe”) in the

United States.21 AGA member gas utilities operate 78% of that total, or 1,616,550 miles of

distribution pipe. Of course, much of this pipe is located in systems that are not affected by

PCBs. However, would EPA require all this pipe to be tested, just to determine which sections

are or are not contaminated at concentrations of 1 ppm or above for purposes of complying with

the proposed ban? If so, how could this be accomplished in systems or portions of systems that

are relatively dry and do not have enough oily liquid condensates to collect and test? In the

Advance Notice, EPA states that condensate samples are required to demonstrate PCBs in a

natural gas system are below the regulatory threshold when contamination is discovered. This

creates a dilemma for dry systems because there currently is no process in the Mega Rule to

demonstrate compliance with regulatory level (whether 50 ppm or 1 ppm level) in dry systems.

Would they never be able to demonstrate they are below the proposed 1 ppm level?22 If wipe

sampling is permitted for characterization, then consideration must be given to reporting limits.

Currently, it is common for laboratories to report wipe sample analyses at 1 µg/100 cm2. With

the proposed use authorization reduced to 1 mg/kg, then laboratories would have to report wipe

20 See Pipeline Operator Qualification Rule, 49 C.F.R. Part 192, Subpart N, Qualification of Pipeline Personnel, §§192.801 et seq.. 21 Specifically, there are 1,206,000 miles of distribution mains and 866,500 miles of service lines, for a total of 2,072,500 miles of distribution pipes in the United States, based on annual data reported to the Department of Transportation (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA). This data is available on the PHMSA web site and is summarized in Gas Facts, an annual AGA publication. See http://www.techstreet.com/standards/AGA/F1012009?product_id=1663646 22 75 Fed. Reg. at 17657.

http://www.techstreet.com/standards/AGA/F1012009?product_id=1663646


samples at 0.2 µg/100 cm2. While possible, this will increase the analytical costs per wipe by 50

to 100 percent. When an anomaly of condensate or oil is discovered in the low elevation point

of a distribution system, there is no means to demonstrate the remainder of the system is below

the regulatory threshold. AGA suggests a better approach would be to focus on liquids, as we

discuss in Section IV.C.

At the very least, EPA should require characterization only at existing liquid collection points,

and should allow continued use of dry pipe and equipment without further sampling. It is

important for EPA to understand the economic, safety and environmental impacts of attempting

to do otherwise. As our 2009 and 2010 surveys showed, most natural gas distribution systems

are now quite dry. If EPA were to require sampling to confirm whether any residual PCBs in

dry, live pipe and equipment are below the contemplated 1 ppm level (or wipe sample

equivalent), the costs would be staggering. AGA strongly urges EPA to clarify that it has no

such intention. For dry systems, such an absurd requirement would mean operators would

presumably have to excavate, purge the gas from the system, stop service to customers or

install a bypass, and cut the pipe to wipe sample the pipe at regular intervals – perhaps every

40 feet based on one possible measure referenced in Part 761, or perhaps every half mile if

using another possible measure.23 After each sampling, the utility would have to gain access to

each home or business to re-light appliances and equipment, which often can result in delays in

obtaining access and delays in restoring service. This can increase safety risks to utility field

personnel as well as customers and the public. In addition, there would be significant economic

impacts due to interrupting natural gas service to commercial and industrial customers. Other

potential impacts include disrupting fragile ecosystems, wildlife and cultural resources.

Based on our survey results regarding the estimated miles of pipe that may be in PCB-affected

systems, a ban on PCBs down to 1 ppm in natural gas systems would require our members to

excavate a significant portion of the more than 1.6 million miles of distribution pipe as well as

several hundred thousand miles of intrastate transmission lines in order to test the lines for PCB

23 40 CFR 761.247(b)(1) addresses sampling pipe segments to be removed for disposal, and refers to <40 foot long pipe “segments.” 40 CFR 761.250(b)(3) addresses selecting sample locations for a pipeline “section” (>40 ft) to be abandoned in place. It uses increments of kilometers (about 0.6 miles or roughly half a mile) for selecting sample locations.


concentrations using wipe samples. (This assumes of course that EPA would provide an

approved live pipe wipe sampling protocol and for equating wipe sample results to a 1 ppm or

50 ppm PCB concentration in liquids.) Our survey results indicate the cost per mile of

excavating, purging live pipe and sampling pipe conservatively would be about $50,000 per cut

or $100,000 per mile if sampling every half mile. This amount multiplied by 2.1 million miles of

distribution main in the U.S. would equal $210 billion. Assuming that roughly 30% of the

distribution pipe in the country would have to be tested in this manner, if EPA were to require

testing dry, live pipe, the cost would still be a crippling $63 billion.

Such a testing requirement would also increase greenhouse gas emissions. Service to

customers along the miles of pipe to be tested would have to be shut off during the related

excavation. Lines would be purged of natural gas as a safety precaution before cutting into the

pipe. To the extent possible, the purged methane would be recaptured for later reinjection in

the line; but if not possible, the methane would have to be vented to the atmosphere, increasing

related greenhouse gas emissions and wasting a commodity currently valued at about $5 per

thousand cubic feet (tsf).24

EPA has suggested that pipe found to contain PCBs over the 1 ppm threshold would have to be

decontaminated with a triple rinse of solvent – if this is feasible – and then reconnected before

resuming gas service to customers. Since this is a multi-step process occurring over time, there

is a chance that contamination could occur from other areas not yet addressed, in a system that

contains some hydrocarbon liquids. In that case, EPA’s suggestion could result in having to take

the entire distribution or transmission system offline until all areas are decontaminated, which is

obviously impossible. The amount of waste solvent generated (and which would present a spill

risk) would vastly exceed the amount of any PCBs recovered. In the alternative, and more

likely, the pipe would have to be abandoned in place or removed from the ground and

transported elsewhere for recycling (after decontamination by the recycler) or disposal in a

TSCA landfill pursuant to the applicable disposal rules in 40 C.F.R. §761.60. Natural gas

service to the affected customers would have to be restored by replacing the existing, perfectly

good pipe, with new pipe. We do not know how many miles of pipe might be found to contain

24 See AGA Natural Gas Market Indicators (Aug. 13, 2010), http://www.aga.org/Research/ngmi/.

http://www.aga.org/Research/ngmi/

AGA Comments on ANPRM Reassessment of PCB Use Authorization Docket No. EPA-HQ-OPPT-2009-0757 August 20, 2010 Page 13 of 30 residues of PCBs above 1 ppm. Assuming for present purposes that 20 percent could be found

to exceed this threshold (which as we discuss later is actually below current detection levels), of

which about 10 percent would be disposed in TSCA landfills, this would equal about 42,000

miles of cast iron, steel, and plastic pipe being disposed of. This would overwhelm existing PCB

waste disposal facilities, which are already strained. In the 1991 ANPRM for the PCB disposal

rules, EPA expressed concern about the prospect of overwhelming existing disposal facilities

and filling up chemical landfill space with natural gas pipe.25 That concern remains valid today.

Current demand on TSCA landfill space is already causing some utilizes to transport TSCA

waste 350 miles for disposal. EPA’s contemplated action would create a tremendous increase

in this demand, requiring transportation over longer distances and/or the construction of

additional disposal facilities. Ironically, this EPA action would cause a commensurate increase

in transportation and construction-related greenhouse gas emissions as well as other adverse

environmental impacts.

C. Eliminating the Use Authorization Would Increase Rather Than Decrease the Risk of Exposure and Would Create an Unreasonable Risk to Human Health and the Environment

Perhaps this enormous effort and cost could be justified if it would significantly improve the

protection of human health and the environment, but it would not. In fact, it would increase

environmental impacts, increase the risk of exposure to PCBs and increase the risk of

construction and traffic accident injuries.

II. Why a Ban is Not Needed – Setting the Record Straight on Exposure Risk

In the Advance Notice, EPA asserts that the use authorizations for PCBs and the 50 ppm

regulatory threshold in Part 761 were not based on risk assessments but were only based on

25 56 Fed. Reg. 26738 (June 10, 1991), section II.B. The EPA notice explained that “[l]arge volume PCB Items are those items whose comparatively large surface areas are contaminated with comparatively small quantities of PCBs.” The EPA notice states that disposing of large volume PCB Items such as natural gas pipe “ is not the best use of limited chemical waste landfill space given the degree of hazard that these large items present and the amount of the PCB Items that would have to be disposed.”


cost considerations.26 In fact, EPA established the use authorization for natural gas systems

based on extensive sampling programs for transmission and distribution systems and its own

risk assessment27 that determined the presence of PCBs at these levels in buried, largely

closed natural gas systems does not pose an unreasonable risk to human health and the

environment. EPA performed the original sampling and risk assessment for PCBs in distribution

and transmission systems in conjunction with the 1984 rulemaking. As described in the 1984

Response to Comments,

“The exposure to PCBs in the compressors and the liquid of natural gas pipelines is considered in the document ‘Exposure Assessment for Polychlorinated Biphenyls (PCBs): Incidental Production, Recycling, and Selected Authorized Uses.’ … Based on this information, the Agency has concluded that PCBs in concentrations of less than 50 ppm in the compressors and the liquid of natural gas pipelines would not present an unreasonable risk of injury to human health or the environment and has authorized this use of PCBs.”28

In a related comment response, the same document stated:

“EPA has also considered the exposure to PCBs from the continued use in compressors and the liquid of natural gas pipelines. EPA has examined monitoring data for indoor air concentrations of PCBs in homes using natural gas and found no evidence that PCBs in the compressors or the liquid of natural gas pipelines are entering these customers’ homes. EPA has also found that occupational exposure is limited by several factors, including (1) natural gas pipelines are necessarily closed systems; (2) the pipeline liquid is collected from enclosed fixtures at specific collection points; and (3) many companies require that employees wear protective clothing when handling the liquid.”

EPA also appropriately relied on its own Exposure Assessment when it amended the Section

761.30(i) use authorization in 1998. Reference to that Exposure Assessment is omitted in the

Advance Notice, but the Exposure Assessment provides key data and analysis. The Advance

Notice suggests that PCBs in pipeline condensates are a new issue that bears research, yet the

Exposure Assessment recognized that the following was well known prior to promulgation of the

Mega Rule:

26 75 Fed. Reg. at 17658 (middle column, section X): “The level of 50 ppm has been used in PCB use regulations since 1979. Based on regulatory history, this number is based almost entirely on economic considerations. There are no traditional exposure and risk assessment calculations (Refs 3 and 8)” 27 Exposure Assessment, Exhibit D. 28 1984 Response to Comments, pp. 85-86, Exhibit A.


“PCBs were first identified in gas pipelines in January 1981 when a PCB-containing, oil condensate was found in the gas meters of some residential customers of a Long Island, New York, distribution company”29

The Exposure Assessment involved developing ten consumer scenarios to consider possible

exposures to PCBs in most general types of products that could conceivably be contaminated

with PCBs, including consumer exposure to PCBs in natural gas.

Regarding consumer exposure to PCBs in natural gas, the Exposure Assessment specifically

considered the consumer inhalation exposure pathway. A maximum hypothetical exposure

scenario was developed to assess consumer inhalation exposures to PCBs potentially present

in natural gas based on the following worst case assumptions: maximum potential gas usage of

4,780 cubic meters per year; all natural gas contains the highest mean concentration measured

in residential service lines to date of 8 micrograms per cubic meter; an individual spends 73

percent of his or her time at home over a 70 year lifetime; and none of the combusted natural

gas is vented outside (an impossible assumption because acute carbon monoxide exposure

would be fatal long before PCB exposure would become measurable).30

Based on these worst case assumptions, the estimated lifetime average individual exposure

was calculated at 3.8 x 10-6 milligrams/kilogram/day. However, the Exposure Assessment

further emphasized that the maximum calculated exposure conditions are likely much higher

than actual exposure conditions for several reasons:31

• Liquid PCBs in gas pipelines move around, and concentrations in natural gas change

with time. Thus it is unlikely that any individual could be exposed to these high

concentrations for a 70-year lifetime.

• Transmission and distribution companies are removing PCBs from their pipelines.

The concentration of 8 micrograms per cubic meter used in this assessment came

from a study of air inside residences where PCB-laden condensate was found in gas

29 Exposure Assessment at p. 204, Exhibit D. 30 Exposure Assessment at pp. 215-16, Exhibit D. 31 Exposure Assessment at p. 223, Exhibit D.


meters. This condensate contained PCBs at very high levels (1,000 to 10,000

mg/kg) . . . If PCBs in condensate are reduced to less than 50 kg/mg, concentrations

in the natural gas and consumer exposure should be greatly reduced.

• There is no evidence that PCBs at the levels estimated are escaping into residences.

The PCB indoor air levels in homes that use natural gas supplied by pipelines

containing PCBs are about the same as levels in homes that do not use natural gas.”

The Exposure Assessment actually included the results of an indoor air monitoring survey in

which PCB concentrations in homes of natural gas users were compared to those in homes

where there was no use of natural gas. The indoor air monitoring survey showed that PCB

concentrations were negligible in both survey groups, and that PCB concentrations in homes

where there was no use of natural gas were actually higher than in those using natural gas.32

The Exposure Assessment concluded that “There is no evidence that natural gas contributes to

the PCB level in residential indoor air.”33

In response to EPA’s 2009 request to AGA for information about PCBs in natural gas

distribution systems, AGA surveyed its members and provided a summary of the resulting data.

A copy of AGA’s November 2009 response to EPA is attached and incorporated in these

comments as Exhibit B. EPA was particularly interested in learning the extent to which PCBs in

oily condensates reach or go beyond customer meters. As AGA reported in our November

2009 Response, it is extremely rare for condensates with PCBs >50 ppm (the current regulatory

threshold) to go beyond a customer meter.34 Also, if condensates reach a customer’s meter or

go beyond it, they do not go unnoticed. Indeed, condensates in a customer’s meter or

appliance typically cause a low or no gas pressure situation, prompting an immediate customer

call to and response by the utility, thereby eliminating any potential exposure to PCBs.

32 Exposure Assessment at Table Z-3, Exhibit D. 33 Exposure Assessment at p. 215, Exhibit D. 34 AGA 2009 Survey Response Summary, Exhibit B.

AGA Comments on ANPRM Reassessment of PCB Use Authorization Docket No. EPA-HQ-OPPT-2009-0757 August 20, 2010 Page 17 of 30 EPA’s recent interest in PCBs in natural gas systems appears to stem from an anomalous

experience in Region V in 2007, when oily liquids with PCBs entered some customer meters

and in only four instances went beyond the meter. Even in those rare instances, no PCBs

reached the burner tip and there was no exposure to PCBs from the condensate. At the

insistence of EPA Region V, air sampling was conducted at customer locations to evaluate

potential exposure to PCBs from the pipeline condensate (which in this case contained Aroclor

1260). The air sampling measured the presence of PCBs at very low levels, but not the same

PCBs contained in pipeline condensate. The Aroclor found in the air sampling (1254) is more

commonly associated with PCB-containing building materials.

A similarly rare incident in 1981 launched EPA’s original rulemaking for PCBs in natural gas

systems.35 Although PCBs in condensates were found in some meters and in some cases

beyond the meter at levels from 100 ppm up to 10,000 ppm, EPA’s air sampling in the homes

found no PCBs above extremely low background levels.36 It bears repeating -- the 1984

Response to Comments stated:

“EPA has examined monitoring data for indoor air concentrations of PCBs in homes using natural gas and found no evidence that PCBs in the compressors or the liquid of natural gas pipelines are entering these customers’ homes.”37

Now, 26 years later, after the bulk of PCBs have been removed from natural gas systems and

properly managed, EPA has not provided any quantitative information to demonstrate that the

situation has changed for the worse.

While PCBs were detected in air sampling in some Region V locations in 2007, it was clear

those PCBs did not come from the condensate in the gas system. Instead, they came from

other sources, namely building materials. EPA’s own data show that the PCBs in the air came

from PCBs in grout and paint. There are no data and no unreasonable risk of PCB exposure

from natural gas systems that could possibly justify a decision to require natural gas utilities and

pipelines to excavate and replace millions of miles of pipe, and expend hundreds of billions of

dollars. .

35 See Description of Long Island incident in 1981 and related sampling program, Exhibit E. 36 Id. 37 1984 Response to Comments, p. 85, Exhibit A.


III. Current Practices for Managing PCBs and Reducing Condensates in Pipeline and Distribution Systems are Working to Protect Human Health & the Environment

In Section L of the Advance Notice, EPA poses several questions about “current management

practices.”38 AGA collected information last year regarding current practices and equipment for

managing condensates and PCBs. The 2009 AGA Survey Results, summarized in Exhibit B,

showed that it is extremely rare for PCBs in condensates to get beyond the meter. As stated

earlier, this was confirmed by AGA’s updated 2010 survey, in which members reported finding

no PCBs beyond any residential meter in the past year. Current practices are working.

While there is no one set of cookie-cutter “best” management practices (“BMPs”) applicable to

all natural gas distribution systems, gas utilities that are impacted by PCBs commonly use a

variety of effective practices to manage PCB liquids. Each company and each system require

unique approaches that are specifically designed to meet those needs. Put another way, one

size does not fit all systems and, therefore, prescriptive regulations should not be promulgated

when they may not be useful or relevant for all companies and all systems.

Rather than eliminating the use authorization, the regulations could provide that if natural gas

condensate with PCB concentrations greater than 50 ppm is present in a natural gas system,

then a company would implement effective management practices (“EMPs”) that work to

prevent migration of these liquids including migration into customer meters and migration

beyond a customer’s meter.

Each gas system has unique characteristics that must be considered when developing effective

management practices. Among these characteristics are transmission piping, distribution

piping, line pressure, presence of liquids, presence of PCBs, presence of drips, and

climate/system location. With these considerations, companies could develop EMPs that fit

their system.

EMPs could include maintaining a written plan, properly training personnel regarding the

potential presence of PCB-liquids and the need to document the presence of PCB-liquids.

Aspects of a natural gas system that may call for EMPs include line drip maintenance, main

38 75 Fed. Reg. at 17662.

AGA Comments on ANPRM Reassessment of PCB Use Authorization Docket No. EPA-HQ-OPPT-2009-0757 August 20, 2010 Page 19 of 30 drip monitoring, service-tee drips, meter riser drips, responding to customer reports of

inadequate gas pressure or no-gas in areas where liquids have been found in the gas lines.

Should liquids go beyond a customer’s meter, then checking drip legs within a customer’s

residence/business could also be a part of an EMP.

IV. AGA Recommendations to Make Part 761 Work Better for Distribution Systems

A. Current Part 761 Rules Are Based on Faulty Assumptions About How Natural Gas Transmission and Distribution Systems Operate

The PCB use authorizations were originally designed for electrical utility equipment, and when

EPA first contemplated applying the rules to compressor stations and interstate transmission

lines in the early 1980s, operators found that the rules were a poor fit. EPA and the operators

often had to resort to convoluted interpretations to apply them to the natural gas industry. A

similar problem has arisen under the 1998 Mega Rule. In 1998, EPA largely relied on its

experience with the pipeline Compliance Management Plan (CMP) to design a specific Section

761.30(i) use authorization for natural gas pipelines and distribution systems. It has become

obvious through system operators’ efforts to comply with it that the Mega Rule is largely

premised on an assumption that gas pipelines and distribution lines are entirely long, straight

and flat across many miles. This is not true for interstate transmission lines that must follow hilly

or even mountainous terrain. It is especially untrue for local distribution systems that follow the

terrain as well as the grid pattern of city and suburban streets, where gas does not always flow

in the same direction and is subject to frequent pressure changes. This premise renders certain

provisions of the Mega Rule difficult to follow to the letter in practice.

B. AGA Suggests Revisions to the Existing Natural Gas Use Authorization

Provisions The Mega Rule provisions governing PCB use in natural gas systems have been in place for 12

years. During that time, AGA members have developed management plans and work practices

to comply with these provisions, but in doing so have encountered difficulties with

implementation of some provisions.

About six years ago, EPA personnel indicated that the agency might soon engage in what some

described as a “PCB Fix-it Rule,” and that EPA would entertain ideas for improving the use

AGA Comments on ANPRM Reassessment of PCB Use Authorization Docket No. EPA-HQ-OPPT-2009-0757 August 20, 2010 Page 20 of 30 authorization to make it both more effective at achieving EPA’s objectives and more workable

for operators to implement. To this end, AGA members developed a list of recommended

improvements to the Mega Rule.

AGA encourages EPA to maintain the natural gas use authorization. If the current use

authorization approach is maintained, AGA encourages EPA to improve the rule by, among

other things, making the following changes:

1. Clarify or eliminate the “upstream / downstream” concept for local distribution systems;

2. Eliminate the PCB “source” concept;

3. Authorize a wipe sample protocol and the use of wipe sample data for system characterization

purposes as well as the liquid condensate sampling presently authorized to characterize natural

gas systems;

4. Provide a protocol for operators to demonstrate that a system or distinct portion(s) thereof are

“PCB Free” (below 50 ppm) or “PCB Contaminated” (between 50-500 ppm) including areas

where only piping 4” diameter and smaller exist. For areas demonstrated to be “PCB Free,”

EPA would acknowledge to the operator that their system or distinct portion(s) thereof are no

longer subject to the requirements of the Mega Rule;

5. Authorize a wipe sample testing protocol to determine the PCB levels in small diameter (4 inch

and less) pipe and small equipment such as meters; and

6. Allow the use of the condensate collected at the bottom of an orifice plate39 housing for

characterizing adjacent piping.

Implicit in the Mega Rule is the misconception that there is always an “upstream” and a

“downstream” in a natural gas system, but in fact, the flow direction can frequently change in

any given section of distribution main and intra-state transmission lines, depending on seasonal

and short term changes in demand for natural gas. When an isolated occurrence of oily

condensate exhibiting > 50 ppm is encountered in a predominantly dry local distribution system,

39 An Orifice plate is a natural location for liquids to drip out. These liquids collect in the bottom of the orifice plate housing. Where purchase points either do not have drips, or they have drips that are dry, operators can instead use orifice meters to collect liquids for measurement and sampling.

AGA Comments on ANPRM Reassessment of PCB Use Authorization Docket No. EPA-HQ-OPPT-2009-0757 August 20, 2010 Page 21 of 30 there are usually no clear “upstream” and “downstream” points to check for the extent of PCB

contamination. Rather, the typical “next best thing” is to locate the nearest drip collection points

on mains radiating away in all directions from the original “hit,” and to check these for the

presence of oily condensate to sample. If all of these are found “dry,” there is no further

recourse, nor is it feasible to declare points “downstream” of the original hit to be > 50 ppm

because the direction of gas flow varies season to season and hour to hour. However, it is

possible in some systems to use standard gas engineering modeling tools to estimate the

portion of a gas system that is served from a particular gas supply point at any given time.

These models cannot predict liquid flow, but might provide a more appropriate means of

identifying the boundaries of a PCB-impacted system.

The Mega Rule also creates the artificial concept of “source” of PCBs, which include

compressors, scrubbers, valves, and interconnects. There are several problems with this

concept. The main problem is that EPA assumes (perhaps based on experience with PCBs in

electrical transformers) that the PCBs present in the pipes come from PCBs currently located in

the listed types of “source” equipment, and that once the PCBs are removed from the listed

“source” equipment, there will be no more PCBs in the pipes. However, even after

decontamination, the equipment and/or pipes can be re-contaminated if oily liquids mobilize a

dry residue of PCBs from one point in the system and move it to another.

Another problem with the source concept is the use of the artificial concept of “interconnects.”

There are different configurations of metering and regulating equipment at city gates and other

locations where the custody over the natural gas commodity is transferred from an interstate

pipeline company to a local distribution company. In some cases, the pipeline company owns

and operates this custody transfer metering and regulating equipment, in others the distribution

company owns and operates the equipment, and sometimes they split the responsibility. This

can make it difficult to determine whether a gas distribution system contains “an interconnect”

as a “source” for purposes of Section 761.30(i). We would contend that this is a waste of effort.

It would be more productive to eliminate this “source” concept and focus gas utility efforts simply

on reducing and capturing oily condensates to prevent the remobilization of dry residues of

PCBs.


C. Suggested Changes to the Natural Gas Use Authorization Approach During these same 12 years since the natural gas use authorization provisions were enacted,

both EPA and AGA members have come to better understand how PCBs behave in natural gas

systems. Armed with this understanding, AGA encourages EPA to step back, reconsider, and

revise the approach being taken to regulating PCBs in natural gas systems.

PCBs have not been added to natural gas systems since before 1978, so any impacts are the

result of:

o PCBs already present and still residing in the systems dissolved in pipeline

liquids, and/or

o Legacy PCBs in liquids that have been removed, but contact with pipe and

equipment resulted in surface contamination, and/or

Based on several conversations with USEPA, the principal concerns about PCBs remaining in

natural gas systems seem to be:

o The potential for PCB-containing oily liquids to enter customer premises beyond

the meter, resulting in direct human exposure, and

o The proper management of PCB-impacted pipe, equipment, and liquids when

removed from service.

To address these concerns, AGA believes that regulation of PCBs in natural gas systems could

focus simply on (a) managing, controlling, and/or monitoring the location of liquids and removing

them when found, and (b) managing pipe/equipment contamination from legacy PCB contact in

the same/similar manner as other regulated PCB items, based on the recent concentration of

PCB s in liquids in a defined portion of the system. Starting with these two guiding objectives,

we believe that a more practical yet protective set of regulations could be developed.

This “common sense” approach to regulating PCBs in natural gas systems would be founded on

the following premises:

• Systems containing liquid would be the primary focus of the regulation, and regulated

differently than dry systems.


• Historically contaminated but currently dry systems would eventually (perhaps after 3

years) be “delisted” from the use authorization and subject only to applicable

abandonment and disposal provisions.

• Systems or portions thereof containing liquid (not just equipment) would be classified as

non-PCB, PCB-contaminated, or PCB, based on the most recent liquid PCB

measurements. Pipe and equipment removed from these systems would be similarly

classified and managed accordingly (wipe sampling of any size pipe would no longer be

required, but could be used for disposal profiling at the discretion of the owner)

• The extent of impact of a PCB finding in a liquid sample would be determined using

system knowledge (such as route preference) or (where feasible) use of gas flow

estimation methods specific to distribution systems, rather than the current

upstream/downstream concept, for reasons mentioned earlier.

• PCB liquid findings would trigger a liquid control/management strategy, based on route

preference; protocols would be established to protect customers from liquids containing

PCB, in particular legacy collection/accumulation points that can be controlled

• Elimination of the concept of “sources”. Companies use system knowledge and

established engineering tools to track the locations of significant liquid deposits, the

likelihood that such deposits could potentially spread to other portions of the system, and

the best technical approach to liquid collection and control.

• Definition of what constitutes a “significant” liquid finding. There would be a de minimis

liquid volume threshold established before a control strategy is required (most liquid

findings generate barely enough liquid for a laboratory sample)

There are of course more details to be evaluated with this approach. AGA and its members

have devoted significant time to working through many of the implementation details, and AGA

would welcome the opportunity to engage in a dialog with EPA to explore these and possibly

other recommendations further.


V. Reporting Every Wipe Sample and Liquid Test Would Overwhelm EPA and Stakeholders Needlessly – Instead, Restrict Reporting to Beyond Meter Incidents

In one portion of the Advance Notice, EPA suggests requiring operators (presumably) to report

or notify the Regional Administrator whenever “PCBs are found in any pipeline system,

regardless of the source of PCBs or the owner of the pipeline.”40 In section VII. G., EPA states

that it is considering requiring natural gas system owners to sample and analyze individual

condensate samples:

“when any person finds PCBs in any pipeline system at concentrations > 1 ppm” and “to analyze condensate from surrounding areas to confirm that regulated PCBs were not present in the system. Regardless of the original or current source of the PCBs, owners would report results of >50 ppm findings to EPA.”

There is no need to burden EPA or stakeholders with such a sweeping reporting requirement.

The data are currently available to EPA upon request pursuant to the Mega Rule. Section

761.30(i) requires natural gas pipeline and distribution systems that have a potential PCB

“source” in their system to characterize the system for PCBs, and to re-test condensates (if any)

annually at locations where liquid samples have been found to contain >50 ppm – until an

individual location has two successive liquid samples below 50 ppm. Further, Section 761.30(i)

requires the system operator to retain records of the system characterization and liquid sample

data and to make these records available to EPA upon request. Many companies also retain

wipe sample data in an effort to better define the boundaries of areas with and without PCBs.

Instead of flooding EPA Regional Offices with individual liquid or wipe sampling results, EPA

should either request records as allowed under the existing rule, or at the very least, should

narrow the reporting requirement to provide more meaningful data with less paperwork burdens.

This could include perhaps providing reports on the issue that seems most important to EPA –

those very rare incidents where service calls reveal oily liquids with PCBs have reached beyond

the meter. In conjunction with such a reporting requirement, EPA should provide clear guidance

regarding what industry can expect EPA to require after making the report.

40 75 Fed. Reg. at 17653, middle column and 17657 ANPRM section VII. G.


VI. EPA Should Allow Continued Use of Coated Concrete and Other Porous Surfaces

The cleaning and coating use authorization for porous surfaces under 40 CFR 761.30(p)

(“30(p)”) was promulgated in 1998 specifically for former spill locations where removal of the

affected media is “impractical”. Examples are given for application including electrical

transformer vaults and underground vault equipment, but the determination of impracticality is

left to the user.

Natural gas transmission and distribution companies have found this provision to be extremely

useful. Member companies have used 30(p) at literally hundreds of locations in a variety of

settings, typically in locations where heavy rotating equipment is located and removal of paint or

concrete is impractical due to: (a) possible compromise of the structural integrity of the building

and/or sophisticated equipment pedestals; and/or (b) sensitivity of precision equipment to silica

dust from concrete removal.

EPA has proposed eliminating or significantly limiting the use of this provision in the future, due

to information allegedly indicating that the coating process may not be effective at eliminating

PCBs from escaping and entering the indoor air.41 We are not aware of any such problems, and

EPA does not provide a citation supporting this allegation. Member companies are diligent in

marking and inspecting their 30(p) locations, and there is no scientific basis for active diffusion

of PCBs through a properly applied and intact two-layer coating. The preamble to the 1998

Mega Rule states “EPA believes that the use conditions specified in 761.30 (p) will effectively

prevent exposure to any residual PCBs in the contaminated porous material and therefore

continued use of this material will not present an unreasonable risk.”42 EPA has provided no

data to suggest why this determination should be changed.

41 75 Fed. Reg. at 17657 (VII. F. ). Also see related questions in section XIV. R., 75 Fed. Reg. at 17663. 42 63 Fed. Reg. at 35398.


VII. EPA Should Authorize and Regulate the Use of Non-Liquid PCB Containing Products

AGA members occasionally encounter PCB-containing paint, caulk and other building materials

at compressor buildings and other pipeline, storage and distribution facilities. These facilities are

generally in commercial and industrial settings not accessible to children or the public; therefore

exposure risks are much lower than in public buildings. Additionally, different types of pipe wrap

or coatings have been used to prevent corrosion on steel pipe, not only in the natural gas

industry but other utilities as well. Some of these pipe wrap materials have been found to

contain PCB, but testing has shown that the PCBs are tightly bound in the coal tar matrix of the

multi-layer wrap and do not leach,43 irrespective of the total concentration detected. This wrap

is also on buried pipe, sequestered from the environment and inaccessible to the public. We

urge EPA to increase thresholds based on scientific risk-based levels.

VIII. EPA Should Continue to Authorize the Use of PCBs >50 ppm in Compressed Air Systems

Natural gas transmission and distribution companies use compressed air for several purposes:

to help start natural gas compressors, to mix with propane as supplemental gas during peak

demand periods, to supply air to air powered tools at company maintenance facilities, and other

non-gas related activities in support of company activities. PCB-containing lubricants were

previously used in many of the associated air compressors. Companies reduced the PCB

concentration in the lubricant years ago, as required by EPA.

Companies also found that some lubricant had contaminated the air piping and air receiver

tanks associated with the compressors. In the 1980’s, EPA granted Alternate Disposal Permits

(ADPs) to several contractors for the expressed purpose of decontaminating compressed air

systems, which companies then widely used. EPA later included a self-implementing

43 See Exhibit G, Northeast Gas Association (NGA) Letter Petition to New York DEP to exclude PCB Coal Tar Wrap from being classified as hazardous waste (March 2, 2007), and Data on Gas Mains and Electric Feeder Pipe - Showing PCBs Tightly Bound in Coal Tar Matrix and Do Not Leach under TCLP Test.

AGA Comments on ANPRM Reassessment of PCB Use Authorization Docket No. EPA-HQ-OPPT-2009-0757 August 20, 2010 Page 27 of 30 compressed air system decontamination procedure in the 1998 PCB Disposal Amendments that

could be used by any company or contractor.

The air system decontamination procedures are and were performance based, that is,

successful completion of the decontamination process was based on following a prescribed

series of steps that had been proven to work in several ADP demonstrations. Successful

completion was not based on measuring the residual PCB contamination in the air systems

EPA has proposed eliminating the use authorization for <50 ppm PCB in compressed air

systems, based on having little information on the need to continue it. EPA states that “The 10

years that these authorizations have been in place should have allowed owners sufficient time

the purge the PCBs from their systems.

AGA disagrees with eliminating this use authorization. Companies have in fact purged their

systems as required by EPA, to either the measurement-based levels required in the regulations

or by using the decontamination procedures approved by EPA and incorporated in the

regulations. Companies removed and replaced air compressor lubricants years ago until the

PCB concentrations were <50 ppm PCB and they decontaminated air systems based on

performance-based procedures approved by EPA. As noted in INGAA’s comments, EPA

clearly anticipated that residual PCBs would remain in air compressor systems after this

performance-based procedure, and the agency deemed this to be safe.44 There is no

justification for further reducing the lubricant concentration to <1 ppm, and there is no data

available from the compressed air systems because it was never required by EPA.

IX. EPA Should Continue to Allow Storage for Reuse

The reuse of PCB-contaminated pipe and appurtenances is authorized in the regulations. AGA

members rely on the storage for reuse authorization for equipment removed from areas with

known PCB contamination. They also rely on the storage for reuse authorization to store

equipment that they eventually plan to decontaminate prior to reuse, but that they cannot

necessarily decontaminate within 30 days after removing the equipment from the system for

44 INGAA comments, section VIII. A.

AGA Comments on ANPRM Reassessment of PCB Use Authorization Docket No. EPA-HQ-OPPT-2009-0757 August 20, 2010 Page 28 of 30 storage. EPA has said it is considering eliminating storage for reuse in general, even for items

that are allowed to be reused.45

In many cases, equipment such as meters is assumed contaminated because it came from a

portion of natural gas systems that itself has been tested and found to contain PCBs. The

disposal provisions in 761.60 (particularly wipe sampling or assuming pipe and equipment is

regulated for abandonment or removal) are triggered by an “upstream” hit of PCBs >50 ppm. In

those distribution systems where a large portion of the system is assumed to be regulated at

>50 ppm, all “downstream” equipment including meters is assumed to be contaminated.46

Meters found to contain liquids during testing are usually disposed of, so the remaining meters

in storage for reuse are dry.

The Advance Notice indicates under a list of “options for initial phase-out regulations” on page

17653, that EPA might require testing of equipment stored for reuse and which is assumed to

contain PCBs >50 ppm, and require that equipment be reclassified – i.e. decontaminated –

below 50 ppm within 30 days of receiving the test results or be designated for disposal. While

EPA was obviously discussing electrical equipment, nevertheless, this proposal could impact

natural gas equipment as well. Such a requirement could eliminate reuse of contaminated

natural gas system equipment, including the option of decontamination for reuse. These articles

are typically stored inside buildings due to their value while waiting for reassignment, and may

be decontaminated prior to reuse but not within 30 days of entering storage, as EPA has

proposed. Furthermore, sampling of diaphragm meters is destructive and renders them

unusable. Customer meters are the gas utility’s “cash register.” Under state public utility

commission rules, these customer meters must be removed periodically, taken to a service

center and calibrated to ensure the meters are accurately measuring the volume of natural gas

being delivered to customers. If it is assumed that a meter is contaminated unless proven

45 See Advance Notice in section VIII, 75 Fed. Reg. at 17657 (third column) – 17658; see also section XIV. T., 75 Fed. Reg. at page 17664 46 It is impractical to wipe sample the inside of meters, since there is usually insufficient surface area to wipe, and because testing would destroy the meter or render it unusable pursuant to state utility commission rules. Some AGA member companies have obtained EPA approval to statistically sample meters, but only in large lots prior to disposal; those same companies reinstall proved meters without testing.

AGA Comments on ANPRM Reassessment of PCB Use Authorization Docket No. EPA-HQ-OPPT-2009-0757 August 20, 2010 Page 29 of 30 otherwise, and sampling will destroy the meter, then in effect the utility will have to discard

millions of perfectly clean meters. As a practical matter, this would reduce the useful life of a

meter from 30 years to five years or less, depending on the calibration frequency required by

the state commission. While individual diaphragm meters commonly used in residential and

small commercial applications are not particularly expensive, costing around $50, when

multiplied by millions of meters each year, the cost will be significant. Moreover, large volume

commercial and industrial meter sets cost many thousands of dollars each to fabricate and

install.

Current practice is to remove meters to the meter shop, where they are stored, proved, stored

again, and then installed at a customer location. Therefore, there are two time periods when

regulated meters are stored for reuse, both of which could potentially be eliminated as options if

the storage for reuse provision is removed, i.e. meters removed from a contaminated system

would need to be disposed of immediately, and new meter installations would be limited to a

single use. If gas utility equipment is not allowed to be stored for reuse during their normal life

expectancy, perfectly good equipment would have to be discarded and our members’ customers

would have to bear the cost of this early retirement.

EPA should permit the long-term storage of these articles for reuse.

X. PCB Quantifiable Level/ Level of Detection EPA is considering re-defining the level of detection to as low as 0.5 ppm or lower – rather than

the 2 ppm presently established in 40 C.F.R. §761.3.47 Unlike PCB analysis of transformer oil,

PCBs in oily liquid condensate cannot typically be detected at concentrations <2 ppm due to the

cross contamination and interference of sulfur, mercaptan and sulfide compounds and non-PCB

hydrocarbons. EPA explained this concept in its 1981 natural gas condensate sampling

protocol, and reconfirmed it in a study prepared for the Gas Technology Institute (GTI) in

1993.48 The lowest level that can be reliably detected in oily liquid condensate is 2 ppm.

47 See ANPRM section XI Definitional Changes, D. at page 17658. Also see questions at XIV.W, 75 Fed. Reg. at 17664. 48 Roy Weston Interim Report, Evaluation of Methods for Determination of Polychlorinated Biphenyls in Soil and Condensate, Exhibit F.

AGA Comments on ANPRM Reassessment of PCB Use Authorization Docket No. EPA-HQ-OPPT-2009-0757 August 20, 2010 Page 30 of 30 Conclusion As AGA, USWAG and INGAA have demonstrated, current practices work well to protect people

and the environment. There is no justification for EPA’s contemplated phase out and elimination

of the PCB use authorizations for natural gas systems. Further, it would be physically

impossible to completely eliminate all trace of PCBs from natural gas systems. Any attempt to

do so would cost hundreds of billions of dollars, cause severe disruptions in natural gas service

to homes, businesses, hospitals, schools, industry and government, and increase rather than

decrease risks to human health, safety and the environment. AGA strongly opposes the

proposal to phase out and eliminate the PCB use authorizations for natural gas systems.

Instead, we recommend that EPA work with stakeholders to revise Part 761 to focus the rule on

what we believe is EPA’s main concern – to manage and reduce the occurrence of oily liquid

condensates in distribution systems to keep them from moving PCBs beyond the customer

meter. This would allow both EPA and the regulated community to focus scarce resources on

measures that have been shown to be effective. AGA appreciates the opportunity to comment

on the Advance Notice.

Respectfully submitted, American Gas Association

By: ____________________________ Pamela A. Lacey Senior Managing Counsel, Environment American Gas Association 400 North Capitol Street N.W. Washington, D.C. 20001 [email protected] (202) 824-7340

mailto:[email protected]

AGA Comments on EPA ANPRM, PCBs Reassessment of Use Authorizations

Docket EPA-HQ-OPPT-2009-0757 August 20, 2010

LIST OF EXHIBITS

Exhibit A EPA June 1984 Response to Comments on the Proposed Uncontrolled PCBs

Rule, pages 84-87, Summarizing EPA Exposure Assessment and Regulatory Impact Analysis

Exhibit B AGA 2009 Survey Response Summary and Cover Letter:

1. AGA Cover Letter to EPA (Nov. 18, 2009) 2. AGA 2009 PCB Survey Response Summary (Nov. 18, 2009)

Exhibit C AGA 2009 Technical Presentation to EPA Region V on

PCB Behavior in Natural Gas Systems, Prof. Michael Adewumi, Penn State and John Woodyard, Vice President, Weston Solutions

Exhibit D Final Report, Vols. I and II, Exposure Assessment for Polychlorinated Biphenyls

(PCBs); Incidental Production, Recycling, and Selected Authorized Uses, Prepared by Versar Inc, for EPA (May 2, 1984), excerpted pages (EPA 1984 PCB Exposure Assessment)

Exhibit E Air Sampling:

1. EPA Description of 1981 Long Island Incident and Related Sampling Program, EPA Talking Points

2. An Assessment of the Possible Impact of Natural Gas Use on PCB Levels in Indoor Air, April 1982 Study

Exhibit F Roy Weston Interim Report, Evaluation of Methods for Determination of

Polychlorinated Biphenyls in Soil and Condensate

Exhibit G Northeast Gas Association (NGA) 2007 Data Showing PCBs in Coal Tar Wrap Do Not Leach:

1. NGA Letter Petition to New York DEP to exclude PCB Coal Tar Wrap from

being classified as hazardous waste (March 2, 2007); 2. Data on Gas Mains and Electric Feeder Pipe - Showing PCBs Stay Tightly

Bound in Coal Tar Matrix and Do Not Leach under TCLP Test

AGA Comments on

EPA ANPRM, PCBs Reassessment of Use Authorizations

Docket EPA-HQ-OPPT-2009-0757

August 20, 2010

EXHIBIT A

1. EPA June 1984 Response to Comments on the Proposed Uncontrolled PCBs Rule, pages 84-87

AGA Comments on



August 20, 2010

EXHIBIT B

1. AGA Cover Letter to EPA (Nov. 18, 2009)

2. AGA 2009 PCB Survey Response Summary (Nov. 18, 2009)

November 18, 2009 Maria J. Doa, Ph.D Director National Program Chemicals Division U.S. EPA Office of Prevention, Pesticides and Toxic Substances Washington, D.C. 20460 Re: Summary of Results from AGA PCB Survey Responding to EPA Information Request Dear Dr. Doa, In response to your request for information regarding the management of polychlorinated biphenyls (PCBs) in natural gas distribution systems, the American Gas Association (AGA) conducted a survey of its members in September 2009. We had planned to provide our response to you in October, but based on a review of our initial survey results, we determined that a short supplemental survey was required to provide a more complete response. We had a good response rate. Forty-nine companies responded to the original, detailed summary, and 67 companies responded to our supplemental survey. Those 67 companies serve about 46 million residential customers, which is 78% of the 59 million residential customers served by our membership as a whole. In your letter dated August 28, 2009, you indicated that you are particularly interested in obtaining information regarding:

(1) Management practices currently being used for PCB detection and control;

(2) Data that would help you understand the extent of contamination within pipeline systems;

(3) Information related to PCB detection and control at storage areas;

(4) Various liquid collection and separator systems, liquid management practices;

(5) Attempts to clean the gas stream; and

(6) Federal Energy Regulatory Commission (FERC) tariffs or other government policies relating to PCBs.

AGA PCB Survey Response Letter Nov. 18, 2009 Page 2 of 2 Similar letters were sent to both INGAA and AGA, so I understand that some of these topics are more germane to interstate pipelines than to distribution systems. AGA’s survey focused on the experience of our member natural gas utility distribution companies.

We found that the volume of hydrocarbon liquids is generally declining in member natural gas distribution systems, and many systems are now dry. Many of our members have never found PCBs in their systems at detectable levels or >50 ppm. Those that have found PCBs above 50 ppm have procedures for PCB detection and control, as described in the attached summary of survey responses. Perhaps more importantly, only 9 companies have ever detected PCBs >50 ppm beyond industrial, commercial or residential customer meters out of the 67 responding companies. Of those, only 7 residential meters in the past decade have had PCBs >50 ppm go beyond the meter -- out of the 46 million residential meters served by the companies responding to the survey -- many of which you are aware of from the 2007 experience in Region 5. That is equivalent to an incidence of one in 6.6 million meters.

Further, there were only 53 meters in the past decade – or about 5 per year on average out of 46 million meters—that were found to have PCBs above 50 ppm inside but not beyond the meter. In all cases, the meters were removed and PCBs in hydrocarbon liquids were disposed of in accordance with Part 761.

Attached you will find a detailed summary of the responses we received in answer to your information request. If you have any questions, please do not hesitate to contact me. Sincerely yours,

Pamela A. Lacey Senior Managing Counsel American Gas Association 400 North Capitol Street N.W. Washington, D.C. 20001 [email protected] (202) 824-7340 Enclosures Copy w/ Enclosures:

Margaret M. Guerriero, EPA Region 5 Tony Martig, EPA Region 5,

Response to EPA Information Request

AGA PCB Survey Results Summary

Nov. 18, 2009 The American Gas Association (AGA) conducted a detailed survey of its member natural gas utility companies in September 2009 to collect data to respond to a letter dated August 28, 2009 from Maria J. Doa, PhD, Director, U.S. EPA National Program Chemicals Division. AGA conducted a supplemental survey in October 2009 to collect additional information to respond to EPA’s request for information. Forty-nine companies responded to the detailed survey, and 69 companies responded to the shorter supplemental survey. The 69 companies serve about 46 million residential customers, compared to the 59 million residential customers served by our members as a whole. That represents a response rate of about 78%. The following provides a summary of the information we collected in response to EPA’s request.

1. Management Practices for Detection and Control

a. Current policies for sampling hydrocarbon liquids for PCBs The survey asked for a description of current policies for sampling hydrocarbon liquids in distribution systems – beyond the regulatory requirement in 40 C.F.R. Part 761 to sample annually at locations where polychlorinated biphenyls (PCBs) have been encountered in the past. Here are the typical responses:

Under Certain Circumstances, Some Companies Always Sample Hydrocarbon Liquids for PCBs:

Some companies routinely sample hydrocarbon liquids for PCBs whenever they are discovered. They sample for varied reasons, including for pipeline integrity purposes, during maintenance operations, prior to disposal of the hydrocarbon liquids, and upon discovery in the pipeline. Some of these companies are documenting that their pipeline still does not contain PCBs, while others are sampling to identify and isolate areas of PCB contamination.

Some Companies Test for PCBs in Hydrocarbon Liquids under Certain Circumstances or in Certain Areas:

Some companies sample in areas where PCBs could potentially be present or where they do not have adequate sampling data in order to better characterize PCB-containing hydrocarbons in their gas distribution systems. Some companies sample on a scheduled frequency. They may not sample liquids from areas found to be PCB-free based on prior system characterization. They may also sample when needed for disposal purposes.

AGA Response to EPA PCB Information Request November 18, 2009

2

Some Companies Have No Recent Sampling Data (Companies with no PCBs or <50 ppm): Some Companies have not conducted recent sampling because they have not found PCBs in their system in the past ,or have only found PCBs at levels below 50 ppm.

b. Methods for Tracking Hydrocarbon Liquid Test Results for PCBs

We asked how companies track their PCB sampling results. Most companies use or are in the process of migrating data to a GIS and data base. Companies that have never detected PCBs at all or at levels <50 ppm often do not track their test results. As one company responded, “we could put a note on our GIS database, but it is not necessary due to test results.” Companies that have detected PCBs at levels >50 ppm in liquid samples, typically maintain their wipe samples as well as liquid samples in a spreadsheet or GIS database. Many responding companies see little or no hydrocarbon liquids anymore, and noted that most of their PCB sampling data is from wipe samples.

c. Response Procedures IF Hydrocarbon Liquids Found Inside or Beyond Meters

Companies were asked to describe their response procedures in the event they find hydrocarbon liquids inside or beyond a customer meter – and procedures in the event that PCBs >50 ppm are present. The responses indicate our gas utility members that have encountered hydrocarbon liquids in meters, and that have PCBs in their systems, have procedures for inspection, testing and cleanup. Procedures Where Hydrocarbon Liquids Found Inside Meters: Companies responded that they test the liquids for PCBs and base final disposition of the meter and the hydrocarbons on the lab results. Meters and regulators are handled very carefully to prevent spills, and hydrocarbon liquids are labeled, packaged and disposed properly, according to analytical results. Additional Procedures – Hydrocarbon Liquids Beyond Meters: Infrequently, liquid hydrocarbons get past the meter. In all but a handful of cases in the last decade, no PCBs have been detected in liquid hydrocarbons in or past the meter. Companies have procedures that may include opening interior appliance drip legs to check for the presence of hydrocarbon liquids, and sample collection / analysis when appropriate. Companies vary in how they plan to clean and replace gas valves and/or appliances in the very unlikely event of finding PCBs greater than 50 ppm.

d. Mitigation of Past PCB Contamination in Compressors, Scrubbers or Gas Filters

The survey asked whether companies have natural gas compressors, scrubbers or filters (other than paper-like filters) in their distribution systems. Out of 49 respondents, 24 answered yes. They were next asked what steps they have taken to mitigate any past or present PCB contamination in their compressors, scrubbers, or filters (such as liquid removal and manufacturer-recommended O&M as provided in EPA’s Sept. 2001 Q&A Guidance at pages 23-24). The responses indicate that most companies that have such equipment have followed the Q&A Guidance approach. A few have removed or decontaminated equipment.


3

Sample Responses from companies taking the following approaches:

No Action if No Liquids or No PCBs

• “Sampling results from these facilities were generally non-detect, and all were well below the regulatory action threshold, therefore, no decontamination measures were required.”

• “N/A – No PCB contamination discovered in sources during characterization and regular sampling.”

• “To date, we have not encountered PCBs in any samples that have been tested.”

Remove Liquids and Follow Manufacturer-Recommended O&M

• “Annual check of non-paper-like filters at regulator stations in conjunction with annual

station inspection. When a filter is found to contain enough liquids to pump, they are removed.”

• “Hold suppliers to contract specifications and require them to take custody of any liquids we receive.”

• “As a result of an oil problem in [a particular area of our system], we installed separators along the southern part of [that area].”

• “PCBs were never introduced by our company. We do normal O&M cleaning of all oily surfaces.”

• “Removal of oil and periodic monitoring.”

Decontaminate or Remove Equipment

• “In 1999, we performed decontamination of an air compressor facility. Clean-up of the

air compressor was approved by USEPA in 2000.”

• “Removed separator from service.”

2. Extent of PCBs in Distribution Systems

a. Volumes of Hydrocarbon Liquids and Levels of PCBs PCBs are not water soluble, and they do not migrate in the low pressures and low velocities found in natural gas local distribution systems unless oily hydrocarbon liquids are present. So we asked our members first whether they had encountered hydrocarbon liquids, and if so, at what volumes. Then we then asked whether they had sampled the liquid hydrocarbons, whether they discovered PCBs, and if so, at what concentrations.


4

For purposes of this survey, our focus was on the type of oily liquid that could carry PCBs. We defined “Hydrocarbon Liquids” to mean:

“the oily, liquid hydrocarbons such as propane or butane that are sometimes found in natural gas systems, and are also sometimes called oily condensates. The term does not refer to water. The term also excludes cutting oils used during pipe fitting and clear meter oils that may collect within the meter and that do not derive from pipeline condensates. Hydrocarbon liquids are typically smelly, dark, dirty condensates and can be discerned from a more clear, runny, meter oil.”

The survey indicates that virtually all natural gas distribution companies that have encountered hydrocarbon liquids also have sampled and tested for PCB presence. The table below shows sampling results for companies that collected very low (<5 gallons) to substantial (100-10000 gallons) of hydrocarbons each year (2004-2009).

Companies with:

Sample for PCBs When HC Liquids Discovered?

No PCBs Detected

PCB Concentration <50ppm

PCB Concentrations Range from 50-500 ppm

PCB Concentration >500 ppm

<5 Gallons of Hydrocarbon Liquids in Gas System/Year

6 of 6 Respondents

2

0

4

5-100 Gallons of Hydrocarbon Liquids in Gas System / Year

12 of 12 Respondents

2

3

4

3

100 – 10,000 Gallons of Hydrocarbon Liquids in Gas System / Year

14 of 14

Respondents

1

4

2

8*

Unkown volumes

5 of 5 Respondents

0 1 2 2

*One company assumed their liquids were greater than 500 ppm, rather than sample.


5

Trend: Hydrocarbon Liquid Volumes Declining

Of the companies with larger quantities of hydrocarbon liquids in the table above (5-100 Gallons and 100-10000 Gallons), it appeared that there may be a downward trend in volume from 1998 – 2009. Thirteen companies reported a decline in hydrocarbon liquid volumes, but four companies also reported increases in volumes.

b. Company Responses - Hydrocarbon Liquids Within or Beyond Meters

Most companies Had No Hydrocarbon Liquids (with or without PCBs) in Residential Meters: In our supplemental survey, we asked whether respondents had ever encountered Hydrocarbon Liquids (with or without PCBs) inside residential customer gas meters, and if so at what frequency per 100,000 residential customer meters. Out of the 67 respondents to the supplemental survey, 35 reported they had zero such events in the five year period 1999-2004, and 36 had zero events in the period 2005-2009. Number of Companies with Hydrocarbon Liquids within residential meters per 100,000 meters. No. of Respondents: 67 5-Yr. Period 0 events per

100,000 meters 1-2 events per 100,000 meters

3-10 events per 100,000 meter

10+ Events per 100,000 meters

1999-2004 35 14 9 1 2005-2009 36 15 8 4 *Only one company reported more than 10 events per 100,000 meters in the earlier period. In the later period, four companies reported at that level. As indicated above, it is unusual for hydrocarbon liquids to appear in a residential customer meter. When they do, this will typically reduce natural gas pressures and cause the customer to call the utility company to restore service. This gives the utility a ‘heads up’ opportunity to check the meter. See attached chart displaying “Frequency of Hydrocarbon Liquids.” It should be noted that low pressure calls can be caused by many things other than liquids in the meter; most low pressure calls are due to other causes. Liquids in meters represent a small subset of the overall number of low pressure calls.

c. Very Rarely Were PCBs Found In or Beyond the Meter 58 out of 67 (87%) Companies Have Never Encountered PCBs >50 ppm Inside Industrial, Commercial or Residential Customer Meters: The supplemental survey asked whether companies had encountered PCBs >50 ppm in hydrocarbon liquids (where there was enough to sample and test) inside residential, commercial or industrial customer meters. Of the 67 companies responding, 9 (13%) answered yes, and 58 (87%) answered no.


6

Only 7 Meters Out of 46 Million Residential Meters in the Past Decade Have Been Found to Have PCBs >50 ppm Beyond the Meter, Many of which EPA is Aware of from the Region 5 Investigation in 2007: We asked on the supplemental survey whether companies had encountered PCBs >50 ppm in hydrocarbon liquids beyond the residential, commercial, or industrial customer meter – inside customer piping or equipment. PCBs Present Beyond Residential, Commercial or Industrial Meter at > 50 ppm. No. of Respondents: 67 Yes No No. of Companies: 9 58

Where PCBS are present at > 50 ppm beyond the meter, the total number of meters that are affected by number of companies:

Period No. of

Companies Total Number of Meters Affected

Residential Meters

1999-2004 2 2 2004-2009 3 5

Commercial Meters

1999-2004 2 2 2004-2009 2 2

Industrial Meters

1999-2004 1 2 2004-2009 2 3

Only 7 Meters out of 46 Million Residential Meters had PCBs>50 ppm Beyond the Meter in the past Ten Years: AGA member companies serve over 65 million customers across the United States, of which about 59 million are residential. The 67 companies responding to the supplemental survey serve a total of about 46 million residential meters. Of the 67 companies responding to the supplemental survey, only 5 companies encountered PCBs >50 ppm beyond only 7 residential meters in the past 10 years. Compared to the 46 million residential meters the responding companies serve, 7 meters out of 46 million is equal to an incidence of one in 6.6 million. There were only 53 meters in the past decade – or about 5 per year on average out of 46 million meters—that were found to have PCBs above 50 ppm inside the meter and not beyond the meter. In all cases, the meters were removed and PCBs in hydrocarbon liquids were disposed of in accordance with Part 761.


7

3. Underground Storage Detection and Control

Out of 49 companies responding to the original survey, 16 responded that they operate one or more underground storage facilities. We asked whether they had sampled and tested hydrocarbon liquids at these facilities for PCBs. Six companies responded yes, the rest responded no. In follow up, the companies responding no indicated that they have not found condensate in storage facilities. All five companies that found and tested hydrocarbon liquids at their underground storage facilities reported that they have never detected PCBs >50 ppm. Four of them did not detect PCBs at all, and the remaining two detected PCBs at levels below 50 ppm.

4. Liquid Collection and Separator Technologies In the original survey this September, we asked what types of liquid collection and separator technologies distribution companies are currently using. Some of our transmission members also responded, as indicated in the responses below.

a. Have you installed a separator or other equipment to remove or otherwise to prevent Hydrocarbon Liquids contaminated with PCBs from entering your:

Yes No No Response/ N/A

underground storage facility (out of 16) 4 12 33

utility-operated intrastate transmission system (if any)

15 20 14

distribution system 18 20 11

b. If so, what did you install? Where? And did it perform as designed?

Technology Installed Number of Companies

Installation Locations

Technology Performed to Design Specification?

Drips 2 Low points and areas where liquids

collect

Yes

Coalescing Filters/Strainer 2 Upstream from major customers

Yes

Separators 8 Gates stations; inlet to storage system;

in-line

Yes


8

Drips and Coalescing Filters

4 (see above) Yes

Drips and Separators 7 (see above) Yes Not applicable 6 N/A

What was the approximate cost, stated in a range of rounded dollar amounts, of installing the separator, drip or other equipment, per project and how many customer meters did the measure affect?

Residential Meters:

Equipment Installed Residential – Approximate

Installed Cost ($) Excluding O&M

Residential - Customer Meters Affected

Drips $5,000 - $25,000 (per drip) Drips throughout system No answer No answer Separators & filters at City Gates & customer meters No answer No answer

Filter Separators at City Gates Serving Contaminated Areas

$250,000 - $300,000 400,000

Sparators at 2 City Gates & Drips $4,000 6

Riser Drips (installed if liquids could continue to come to a meter)

$500-700 1 (per meter)

In-line separator >$10,000 per separator <$1,000 per log/drip No answer

Coalescing Filters sized according to gas flow $15,000 2

Drip – upstream of meter $5,000 2 Filters & Drips on service lines & mains where liquids recur

No answer No answer

Drips and separators at meters where liquids have been found

$3,000 to install drip 1


9

Commercial Meters:

Equipment Installed Commercial - Approximate Installed Cost ($) Excluding O&M

Commercial - Customer meters affected

Drips, Surge Tank, Filter Separator $7,000 - $20,000 Per meter

Coalescing Filters $3,000 - $40,000 15 Separators at 2 City Gates and drips $4,000 6

Separator on service line $5,000 1 Coalescing Filters sized according to gas flow $20,000 1

Trash Sump (low pont collection sump) large commercial

$50 each 100

Drips and Separators at meters where liquids have been found

$3,000 each 1

Industrial Meters:

Equipment Installed Industrial - Approximate Installed Cost ($) Excluding O&M

Industrial - Customer Meters Affected

$10,000 1 N/A N/A $500 All new business. Drips, Surge Tanks, Filter Separator $20,000-40,000 Per meter

Coalescing Filter $150,000- 500,000 9 Separator on Service Line (all new business) $500 each Around 100-150 per year

Coalescing Filters sized according to gas flow $75,000 1

Drips and Filter Separators at select industrial meters $5,000 per installation 20

Drip Pot & Calescing Filter (after incident; customer agreement)

$4,000 1

Separators at meter where liquids found $15,000 1


10

c. What procedures do you use to retrieve, collect, or otherwise minimize the amount of Hydrocarbon Liquids within your distribution system? (e.g. pumping or blowing of drips?)

Procedure No. of Companies Utilizing

Procedure

Blowing/pumping drips 14 Filter separator collection tank draining

4

Blowing/draining service line 2 Pigging 2 Filter change-out 2 Meter replacement 1 Removal of screens, drain liquid 1 Install scrubbers and filters 1

d. Are you aware of any additional measures/technologies that may be reasonably/economically deployed to prevent Hydrocarbon Liquids from entering the gas distribution system or to capture Hydrocarbon Liquids that are already being encountered within the distribution system or to remove PCBs from the system? Please explain Sixteen companies responded that they were not aware of any additional measures or technologies that could be either economically or reasonably deployed to prevent hydrocarbon liquids from entering the gas distribution system. One company indicated that the source hydrocarbon liquids could be controlled through the gas purchased.

e. Are you aware of any additional measures/technologies that may be reasonably/economically deployed to prevent Hydrocarbon Liquids from entering customer gas meters, fuel runs or appliances? Please explain: Sixteen companies responded that they were not aware of any additional measures/technologies which could be deployed to prevent hydrocarbon liquids from entering the meter and beyond the meter, aside from those described above. There were only a few specific comments, and they all suggested some variation of the techniques already described above, including diligent pumping of drips in “problem areas” where hydrocarbon liquids seem to habitually accumulate.


11

f. Have you found any particular type and/or configuration of filter/separator to be

particularly effective at intercepting Hydrocarbon Liquids? Please explain.

Type and/or Configuration No. of Companies None/ Drip Pots sufficient 8 Not applicable 8 Cyclone separator with filters 1 Horizontal filter separator 3 Portable and installed drip tank at meter set 3 Coalescing filter separator 3 Mechanical/gravity knockout device 1 In-line filter unit 1 Vertical separator with mesh-type mist eliminators 1 Paper filters 1

g. Do your procedures include routine checking and evacuation of "drips" or other system components that have historically exhibited Hydrocarbon Liquids? (Beyond what is required by Part 761) Yes: 29 No or N/A: 16 Note: Virtually all companies answering “no” had zero or less than 5 gallons of hydrocarbon liquids and/or had sampled and found no detectable PCBs in their systems.

5. Attempts to Clean the Gas Stream We provided an extensive, half-day technical briefing for EPA Region 5 and Headquarters personnel last year regarding the state of research on attempts to clean the gas stream in natural gas transmission systems using solvents. We also explained why it is not possible to use solvent to decontaminate live lines in a distribution system, because among other things, the lines are typically not piggable, it is not possible to ensure recapture of the solvent, solvents would damage modern plastic distribution pipes, and there would be safety concerns given the difficulty of ensuring the recapture of the solvent before delivery of the gas to customers. A copy of the Power Point presentation is attached.

6. Tariff Provisions Addressing PCBs You also expressed interest in whether natural gas utilities have tariff provisions with their suppliers that could prevent the supplier from providing natural gas containing PCBs. We asked our members: Do you have any tariff provisions (e.g. gas quality specs) in place with your gas supplier(s) that address PCBs? Nineteen companies answered that they had some type of tariff (i.e. gas sales contract) provision addressing hydrocarbon liquids and/or PCBs. Gas contracts contain a standard provision stating that “the gas shall not contain substances in an amount sufficient to be injurious to Company facilities or which shall cause the gas to be unmarketable.” Beyond that basic provision, some companies have a tariff provision that requires delivery of clean, dry gas, free of impurities. Some companies have a more extensive tariff provision requiring that (1) the gas must be free of hydrocarbons in liquid form, (2) the gas shall not


12

contain any hydrocarbons which might condense to free liquids under normal pipeline conditions; (3) the LDC reserves the right to sample the gas at the receipt point, and (4) if PCBs are detected in the gas, the LDC has the right to cease receipt of such gas. In addition, some tariffs with this more extensive provision also state that if PCBs are found, the increased operational cost is to be absorbed by the seller. Some companies also reported that their transmission suppliers had certified that their natural gas supply is “PCB free.”

********************************************************************************************

AGA Comments on



August 20, 2010

EXHIBIT C

1. AGA 2009 Technical Presentation to EPA Region V on PCB Behavior in Natural Gas Systems, Prof. Michael Adewumi, Penn State and John Woodyard, Vice President, Weston Solutions

PCB Behaviorin Natural Gas Systems

October 17, 2008

Introductions

• Pam Lacey, American Gas Association

• Michael Adewumi, Ph.D., Penn State

• John Woodyard, Weston Solutions, Inc.

• Marc Himmelstein, National Environmental Strategies

Focus• Modeling PCB movement in natural gas systems • Predicting PCB presence and concentrations in

various phases• Predicting conditions in transmission and

distribution lines• Using solvents to enhance PCB elimination from gas

systems• Determining impacts of solvents on gas system

operation• Updating and field experience for the GRI research

findings

Natural Gas Composition

• Methane

• Other heavier hydrocarbons

• Wet versus Dry Gas

Dry and Wet Gas

Composition

Liquid Formation and Phase Behavior Concepts in Natural Gas

• Retrograde condensation

• Flow regimes

• Low liquid loading

• Vapor/liquid equilibrium

• Vapor/liquid/liquid equilibrium

• Liquid holdup/topography effects

Dew Point Curve (no PCBs)Sample #1

Flow Regimes

Liquid Holdup vs. Pipeline Elevation

Liquid Holdup vs. Gas Pressure

• Pressure recovery is possible as downhill pipeline sections• Pressure gradients increase with decreasing flow rates at downhill sections

Liquid Holdup vs. Gas Throughput

• Liquid distribution depends on operational parameters• Maximum liquid holdup may not occur at the lowest point

Importance of Liquid Removal from Natural Gas

• Compressor protection

• Customer service

• Commercial value

Knowledge About PCB Behavior in Natural Gas Systems Comes From

• Scientific principals (known physical/chemical properties)

• Literature reviews

• Focused research (GRI, Gasunie)

• Field experience, confirmed by the above

PCB Behavior in Gas Systems is Controlled by:

• Known PCB physical/chemical properties

• System temperature, pressure

• Temperature and pressure changes

• Formation, behavior, and volume of pipeline liquids

PCB Physical and Chemical Properties Affecting Removal

• Solid/liquid phase

• PCB solubility in pipeline liquid, other solvents

• Pipeline liquid solubility in other solvents

Search for a PCB Solution

The Gas Research Institute PCB Research Program (1989-1998)

• PCB Physical/Chemical Properties (NIST)• PCB Behavior in Various Solvents (Rice

University)• Liquid Behavior in Natural Gas Systems

(Tulsa University)• Modeling and Prediction of PCB Behavior in

Natural Gas Systems (Penn State)• Removal techniques for PCBs in natural Gas

Systems (All, Geer)

PCB Physical Behavior

• Solubility in various organic liquids

• Physical form at various temperatures and pressures

• Vapor pressure (congeners vs. Aroclors)

• Condensation/crystallization on pipe walls

PCB Behavior in Various Solvents

• Theoretical solubility

• Comparison of theory with available solvents

• Results of theoretical and laboratory testing

• Value of solubility results

• Sharing solubility results with EPA prior to PCB Disposal Amendments

Ideal Solvent Selection for PCB Removal

• High PCB solubility

• Good solubility/miscibility with other pipeline liquids

• Low vapor pressure

• Low toxicity

• Combustible

Relative PCBSolubility in

Solvents

Validation of Liquid Behavior in Natural Gas Systems

• Route preference (“Phase Splitting”) research

• GRI 1991 modeling “competition”

• Tulsa University Fluid Flow Project (TUFFP)

Modeling and Prediction PCB Behavior in Gas Systems

• Model inputs

• PCB and pipeline liquid phase behavior

• Low liquid loading hydrodynamics

• Vapor/liquid/liquid equilibrium

“Why a Model?”

Penn State Research Strategy

PCB Phase Behavior Research Inputs

VLE Problem

Effects of PCB on Phase Behavior

• Condensate formation at higher temperatures

• Early condensate concentrated in PCB

• PCB condensation well before achieving distribution temperatures and pressures

Dew Point Curves

Phase Envelope Shift Due to PCBs

• Impact of Individual PCBs on Phase Envelope

• Impact of PCB mixtures on Phase Envelope

• Impact of Aroclor 1242 on Phase Envelope

• Impact of PCBs on the Phase Distribution of NG

Effect of Aroclor 1242 on Phase Envelope Shift

Quality Lines: PPM of PCB

PCB Concentration

Sample #1 with Different Aroclor Concentrations

Liquid Holdup, PCB Removal and Decline Profile

Liquid Holdup, PCB Removal and Decline Profile (continued)

Weight Percentage of PCBs Resident in Liquid for an Intermediate Gas System

Relative Solvent Effectiveness Over Time

Relative Solvent Effectiveness Over Time (continued)

Phase Splitting and Route Preference

Phase Splitting Parameters Considered Include Flow, Pipe Size,

Pressure and Temperature

Liquid Splitting vs. Gas Demand

PCB Concentration vs. Gas Demand

Impact of T-junction on Phase Envelope

Complex Network Handling Strategy

Conclusions from Penn State Modeling Research

• PCBs cause a radical shift in the phase envelope• Most PCBs are present as liquids at gas transmission

temperatures and pressures• Virtually all PCBs are present as liquids at distribution

temperatures and pressures• Wet PCBs move with pipeline liquid • Dry PCBs condense on pipe walls with organic materials• PCB concentration in collected liquid will vary based on how

much non-PCB pipeline liquid is condensed and present• Route preference modeling has merit, but too complex for gas

distribution systems with variable local flow conditions

Value of the Penn State Modeling Research

• Can be used as a cleanup guideline to design an effective PCB removal process

• For transmission, allows alteration of phase behavior of the original gas mixture, forcing PCBs into the liquid phase

• Cleanup options concentrate on liquid movement for control in low-pressure gas distribution systems

• In high-pressure gas transmission systems, cleanup focuses on– liquid creation/control– pipe wall cleaning

• In low-pressure gas distribution systems, flow conditions and system design limit model application

Conceptual Plan for PCB Removal from Gas Transmission Systems

using Solvent Injection

• Solvent selection, injection, and control/removal

• Real-time sampling and analysis

• Model validation/tuning

Remediation Tool

The Cleanup Scenario

Pipeline Segment Description

PCB Removal with Terpinolene

PCB Cleanup Summary

Research Accomplishments

Industry Evaluation of Solvent Injection Technology

• Theoretical evaluation of solvent injection is promising• Technology has not been tested in the field• Transmission companies with pigging capabilities and liquid

collection systems have expressed interest• Concern over downstream consequences of certain solvents

on materials of construction or lubricants– DOT pipeline integrity requirements– customer gas quality

• Cannot be used on typical distribution systems – lack of adequate liquid control or pigging capability

Conclusions: What the GRI and Other Research Tells Us

• PCBs in gas distribution systems exist almost entirely as liquids

• PCB concentration in liquids is a function of pipeline liquid behavior/condensation

• PCB control in gas transmission systems needs to focus on liquid collection and film removal

• Gas flow velocity and route preference control liquid movement

• Liquid collection in gas distribution systems is more difficult– highly variable flow rates– reliance (generally) upon monitoring route preference to strategically

install liquid traps

• Removing liquid and film from gas system components is possible in some cases with proper solvent selection

AGA Comments on



August 20, 2010

EXHIBIT D

1. Final Report, Vols. I and II, EPA Exposure Assessment for Polychlorinated Biphenyls (PCBs): Incidental Production, Recycling, and Selected Authorized Uses, Prepared by Versar Inc. for EPA (May 2, 1984), excerpted pages (EPA 1984 Exposure Assessment)

AGA Comments on



August 20, 2010

EXHIBIT E

1. Description of 1981 Long Island Incident and

Related Sampling Program

2. An Assessment of the Possible Impact of Natural Gas Use on PCB Levels in Indoor Air, April 1982 Study

AGA Comments on



August 20, 2010

EXHIBIT F

1. Roy Weston Interim Report, Evaluation of Methods for Determination of Polychlorinated Biphenyls in Soil and Condensate

AGA Comments on



August 20, 2010

EXHIBIT G

1. Northeast Gas Association (NGA) Letter Petition to New York DEP to exclude PCB Coal Tar Wrap from being classified as BOO7 NYS hazardous waste (March 2, 2007)

2. Data on Gas Mains and Electric Feeder Pipe - Showing PCBs Tightly Bound in Coal Tar Matrix and Do Not Leach under TCLP Test

75 Second Ave., Ste. 510, Needham, MA 02494-2824 • 1515 Broadway, 43rd floor, New York, NY 10036-5701 781.455.6800, FAX 781.455.6828 212.354.4790, FAX 212.764.7014

www.northeastgas.org

March 2, 2007 Mr. Carl Johnson Deputy Commissioner New York State Department of Environmental Conservation 625 Broadway Albany, NY 12233 Dear Deputy Commissioner Johnson: The Northeast Gas Association (NGA) respectfully submits this petition, on behalf of it’s New York State Members which include Bath Electric Gas & Water Systems, Central Hudson Gas & Electric Corp., Consolidated Edison Company of NY Inc., Corning Natural Gas Corp., KeySpan Energy Delivery NY & LI, Iroquois Gas Transmission System, National Fuel Gas Distribution Co., National Grid, New York State Electric & Gas Corp., Orange & Rockland Utilities Inc., Rochester Gas & Electric Corp., St. Lawrence Gas Company, Inc., Tennessee Gas Pipeline Co., under 6 NYCRR 370.3(c) for your agency’s consideration and approval, recommending excluding coal tar coating from being classified a B007 NYS hazardous waste. NGA is a regional trade association that focuses on education and training, technology research and development, operations, planning, and increasing public awareness of natural gas in the Northeast U.S. NGA represents the Natural Gas Transmission and Distribution Companies serving the region. Its membership includes the local gas distribution companies (LDCs) operating in New York State, who provide natural gas to 4.5 million customers statewide. NGA often works with federal and state agencies in concert with our membership to address issues common to each of the member companies and thereby minimize duplicate efforts and communications for all parties. Through regular maintenance activities and subsequent testing, some NY gas operators have identified the presence of Polychlorinated Biphenyls (PCBs) in some of the corrosion protection coatings of some natural gas pipelines. Specifically, PCBs have occasionally been found in solid coal tar that is removed during repair and/or maintenance activities on buried gas pipelines as well as electric feeder pipes and steam mains. Coal tar is the liquid by-product of the distillation of coal to make coke. It has long been used as a base for coatings and wraps used to protect pipelines from corrosion, and, though not as common as it was 50 years ago, it is still applied on some pipelines. Though the source has not been identified, it is believed that PCBs were introduced to some of the factory applied coatings prior to PCB regulations.

75 Second Ave., Ste. 510, Needham, MA 02494-2824 • 1515 Broadway, 43rd floor, New York, NY 10036-5701 781.455.6800, FAX 781.455.6828 212.354.4790, FAX 212.764.7014

www.northeastgas.org

Waste listed as PCB Solid Hazardous Waste (B007) is currently disposed of as required by state regulations 6 NYCRR Part 371.4(e). However, TCLP/PCB testing of coal tar coatings has been conducted by companies including Consolidated Edison Company of NY Inc., KeySpan Energy Delivery NY, and Rochester Gas & Electric Corp to show that while PCBs are present, they leach less than 10 ug/l PCBs which the EPA currently classifies as PCB Bulk Product Waste under USEPA regulations 40CFR 761.62 (see Attachment A). These federal regulations allow disposal of PCB Bulk Product Waste in non-hazardous landfills with prior notification to and acceptance by the landfills. New York regulations currently classify waste containing 50 parts-per-million or more PCBs as hazardous waste. The attached current testing and historical data for coal tar (Attachment B) show PCB is bound in the solid matrix material and is not released to the environment. It therefore qualifies as TSCA PCB Bulk Product Waste, and may be managed under the existing USEPA regulations referenced above. Thus, NGA respectfully submits this petition under 6 NYCRR 370.3(c) to exclude coal tar coating from being classified a B007 NYS hazardous waste. We suggest the following regulatory change:

6NYCRR 371.1(e)(2) proposed xiv coal tar coating corrosion protection intact or removed from piping and appurtenances, that contain PCBs, is excluded from being a B007 waste and shall be disposed of as required by USEPA 40 CFR 761.62.

In such time as it may take to consider and possibly modify the regulations, NGA asks that the DEC consider providing waivers for gas and other utilities to allow them to manage this waste as PCB Bulk Product Waste per the USEPA regulations. Should you have any questions regarding the technical nature of this request, please contact David Roche, Consolidated Edison Company of NY at (212) 460-2100. All responses to this letter may be directed to Robert Geib of NGA at (212) 354-4790 x 216. We welcome your consideration and response. Sincerely, Thomas M. Kiley President and CEO Northeast Gas Association Attachments:

A - 40CFR 761.62 B - Coal Tar PCB Testing Data

CC: Mr. Steven Hammond Mr. Paul Counterman Ms. Deborah Aldrich

NGA

# Sample ID SAMPLE DATE (mg/kg) PCB TYPE Detected Above 50ppm TCLP/PCB (ug/l) SIZE Pressure Pipe Vintage

1 G2482, F9920 1/2/98 - 12/29/97 Not Detected - HIGH 1952-19542 F9928 1/21/1998 Not Detected -3 F9925 1/8/1998 2.17 1254 x4 F9924 1/5/1998 11.4 1254 x 6" HIGH 19665 F9923 12/31/1997 15.9 1254 x 4" HIGH 19636 F9921 12/3/1997 Not Detected -7 G3532 12/12/1997 55.6 1254 x x Not Done 20" HIGH 19758 F6237 1/15/1998 21.6 1254 x9 F6237 1/15/1998 Not Detected -

10 F6237 1/20/1998 19.8 1254 x 4" LOW 195711 6237 1/20/1998 Not Detected - 8" LOW 195912 F5194 1/13/1998 Not Detected -13 F5194 1/13/1998 19.3 1254 x14 F5194 1/13/1998 88.3 1254 x x Not Done 6" 197115 F4897 1/13/1998 Not Detected -16 F4897 1/13/1998 Not Detected -17 F4897 1/13/1998 Not Detected -18 F4897 1/13/1998 Not Detected -19 F3485 1/20/1998 Not Detected - 6" LOW 195320 G3221, G3853 1/23 AND 1/30/98 Not Detected - 4" MEDIUM 197621 E7597 1/22/1998 Not Detected -22 G3851 1/29/1998 Not Detected - 1" LOW 195423 G3851 1/29/1998 Not Detected - 4" MEDIUM 195824 G3851 1/29/1998 Not Detected - LOW 194825 G3852 1/30/1998 Not Detected -26 G3852 1/30/1998 Not Detected -27 G3854 2/2/1998 Not Detected - 1" HIGH 195328 G3873 2/2/1998 Not Detected - 4" HIGH 195429 G3873 2/2/1998 Not Detected - 4" HIGH 195430 G3873 2/2/1998 Not Detected - 4" HIGH 195431 G3874 2/3/1998 Not Detected - 1 1/2" LOW 195732 G3875 2/4/1998 Not Detected - 4" MEDIUM 1958

ND = Not detected at the specified limit

COAL TAR WRAP - GAS MAINS AND ELECTRIC FEEDER PIPE

Pipeline DataSample Data PCB Test Data

Page 1

NGA

# Sample ID SAMPLE DATE (mg/kg) PCB TYPE Detected Above 50ppm TCLP/PCB (ug/l) SIZE Pressure Pipe VintageND = Not detected at the specified limit



33 98-00279 1/8/1998 Not Detected - 12" HIGH 194934 97-14588 12/19/1997 16 1254 x35 97-14434 Not Detected - 24"36 G1790 2/6/1998 575 1254 x x ND < 3.1 ppb 14" Electric Feeder37 G1791 2/6/1998 869 1254 x x ND < 3.1 ppb 14" Electric Feeder38 G3882 2/10/1998 Not Detected -39 G3877 2/9/1998 Not Detected - 2" HIGH 195940 G3878, G3879 2/9/1998 Not Detected -41 G3880 2/9/1998 Not Detected -42 G2711 2/11/1998 189 1254 x x ND <0.48 ppb 14" Electric Feeder43 G6008 2/13/1998 259 1254 x x ND <0.48 ppb 14" Electric Feeder44 G6011 2/13/1998 1150 1254 x x ND <0.48 ppb 14" Electric Feeder45 G6012 2/13/1998 869 1254 x x ND <0.48 ppb 14" Electric Feeder46 G3886 2/18/1998 Not Detected -47 G3886 2/18/1998 Not Detected - 1 1/2" 196048 G3886 2/19/1998 Not Detected -49 G6014 2/17/1998 81 1254 x x ND <0.27 ppb 16" 196350 G5132 2/26/1998 131 1254 x x ND <1.6 ppb 6" MEDIUM 197351 G3887 2/18/1998 292 1254 x x Not Done 6" LOW 196852 G3887 2/18/1998 45 1254 x53 G3887 2/18/1998 Not Detected - 2" LOW 190454 G3890 2/20/1998 Not Detected - 6" LOW 196655 G3892 2/23/1998 Not Detected -56 G3892 2/23/1998 Not Detected - 1 1/2" LOW 196157 G3884 2/12/1998 Not Detected - 1 1/2" 195358 G3881, G3883 2/10/1998 Not Detected - 4" MEDIUM 195459 G3881, G3883 2/12/1998 Not Detected - 4" MEDIUM 195660 G3881, G3883 2/12/1998 Not Detected - 4" MEDIUM 195661 G3881, G3883 2/12/1998 Not Detected - 4" MEDIUM 195662 G3881, G3883 2/12/1998 Not Detected - 4" MEDIUM 195663 G3889 2/20/1998 131 1254 x x Not Done 8" LOW 192864 G3894 2/25/1998 Not Detected - 2" MEDIUM 1949

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NGA




65 G23884 2/25/1998 Not Detected - 6" MEDIUM66 G3895 2/26/1998 Not Detected - 1 1/2" LOW 195867 G3895 2/26/1998 14.3 1254 x 6" MEDIUM 197468 G3895 2/26/1998 184 1254 x x Not Done 12" MEDIUM 192969 G3896 2/26/1998 Not Detected - 4"70 G3896 2/26/1998 Not Detected - 1"71 G3897 3/2/1998 72 1254 x x Not Done 6" MEDIUM 196672 G3897 3/2/1998 Not Detected -73 G3897 3/2/1998 Not Detected - 4" HIGH 194874 G3897 3/2/1998 Not Detected - 1" HIGH 196075 G3898 3/3/1998 Not Detected - 1" MEDIUM 195176 G3898 3/3/1998 Not Detected - 2"77 G3899 3/3/1998 Not Detected -78 G3899 3/3/1998 194 1254 x x Not Done 6" LOW 196879 G3899 3/3/1998 Not Detected - 1" MEDIUM 195880 G3899 3/3/1998 Not Detected - 1" HIGH 195581 G3900 3/5/1998 Not Detected - 1" HIGH 195582 G3222 3/6/1998 Not Detected - 1"83 G4435 3/6/1998 185 1254 x x ND <0.27 ppb 8" 197584 G3223 3/10/1998 Not Detected -85 G3223 3/10/1998 Not Detected - 2" MEDIUM 195686 G3224 3/11/1998 76.8 1254 x x Not Done 4" HIGH 196187 G3225 3/12/1998 Not Detected - 1 1/4" LOW88 G3226 3/13/1998 Not Detected - 1" HIGH 195589 G3227 3/17/1998 Not Detected - 1 1/2" LOW90 G3229 3/20/1998 Not Detected - 2" 196891 G3229 3/20/1998 Not Detected -92 G3229 3/20/1998 Not Detected - 1" 194893 G3228 3/20/1998 191 1254 x x Not Done 6" LOW 196694 G3228 3/20/1998 Not Detected -95 G3228 3/20/1998 Not Detected -96 G3229 3/20/1998 Not Detected - 2" 1958

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NGA




97 G3229 3/20/1998 Not Detected -98 G3229 3/20/1998 Not Detected - 1" 194899 G3230 3/23/1998 Not Detected - 1955100 G3230 3/24/1998 Not Detected - 2" 1947101 G3231 3/25/1998 2.3 1254 x 2" LOW 1959102 G3231 3/26/1998 Not Detected - 2" HIGH 1955103 G3231 3/26/1998 Not Detected - 2" HIGH 1955104 G3231 3/26/1998 Not Detected - 1 1/2" LOW 1954105 G3231 3/26/1998 Not Detected -106 G3235 3/26/1998 15 1254 x 1" MEDIUM 1958107 G3235 3/26/1998 Not Detected - 1" MEDIUM 1954108 G3235 3/26/1998 Not Detected - 1" MEDIUM 1950109 98-02380 3/4/1998 338 1254 x x Not Done 20" HIGH 1972110 98-02993 3/18/1998 Not Detected -111 G3236 3/31/1998 Not Detected - 2" MEDIUM112 G3236 3/31/1998 Not Detected -113 G3236 4/1/1998 Not Detected - 4" MEDIUM 1951114 G3236 4/1/1998 Not Detected - 2" HIGH 1956115 G3237 4/4/1998 16 1254 x 1 1/2" LOW 1957116 G3239 4/2/1998 Not Detected - 4" MEDIUM 1960/61117 G3239 4/2/1998 Not Detected - 1" HIGH 1950118 G3239 4/2/1998 Not Detected -119 G3239 4/2/1998 Not Detected - 1" HIGH 1952120 G3242 4/6/1998 9.3 1254 x121 G3243 4/8/1998 Not Detected - 1-4" 1957-58

122 G3243 4/10/1998 Not Detected - 1" HIGH 1949123 G3243 4/10/1998 Not Detected -124 G3244 4/10/1998 Not Detected - 2" LOW 1950125 G3244 4/10/1998 Not Detected - 1" HIGH 1955126 G3220 4/15/1998 Not Detected - 6" HIGH 1949127 G7301 4/16/1998 Not Detected -128 G7301 4/15/1998 Not Detected - 1" MEDIUM 1950

Page 4

NGA




129 G7301 4/17/1998 Not Detected -130 G7301 4/20/1998 Not Detected - 1" HIGH 1948131 G7302 4/21/1998 24.5 1254 x 6" LOW 1966132 G7302 4/23/1998 Not Detected - 1" MEDIUM 1956133 G7302 4/22/1998 Not Detected -134 G7302 4/22/1998 Not Detected - 135 G7302 4/22/1998 91.5 1254 x x Not Done 6" MED 1967136 G7302 4/22/1998 Not Detected - 4" HIGH 1949137 G7303 4/24/1998 20.5 1254 x 1 1/2" LOW 1960138 BL0607048-01 6/27/2006 Undetected n/a139 BL0606292-01 6/23/2006 85.8 1254 x x ND <0.045 ppb140 BL0606313-01 6/26/2006 Undetected n/a141 BL0606328-01 6/24/2006 Undetected n/a142 BL0606350-01 6/29/2006 Undetected n/a143 BL0606264-01 6/5/2006 149 1254 x x ND <0.04 ppb144 BL0602111-01 2/10/2006 Undetected n/a145 BL0602111-02 2/10/2006 111.4 1254 x x ND <0.04 ppb146 BL0602111-03 2/10/2006 37.8 1254 x ND <0.04 ppb147 BL0602111-04 2/10/2006 Undetected n/a148 BL0602111-05 2/10/2006 27.1 1254 x ND <0.04 ppb149 BL0602111-06 2/10/2006 Undetected n/a150 BL0602111-07 2/10/2006 131.4 1254 x x ND <0.04 ppb151 BL0602111-08 2/10/2006 58.9 1254 x x ND <0.04 ppb152 BL0602111-09 2/10/2006 81.4 1254 x x ND <0.04 ppb153 BL0602111-10 2/10/2006 Undetected n/a154 BL0602111-11 2/10/2006 Undetected n/a155 BL0602111-12 2/10/2006 56.5 1242 x x ND <0.11 ppb156 BL0606123-01 6/9/2006 31.4 1254 x ND <0.04 ppb157 BL0606123-02 6/9/2006 1.14 1254 x ND <0.04 ppb158 BL0606125-01 6/8/2006 30.8 1254 x ND <0.04 ppb159 BL0606173-01 6/15/2006 Undetected n/a160 BL0606174-01 6/15/2006 Undetected n/a

Page 5

NGA




161 BL0606265-01 6/15/2006 Undetected n/a162 BL0606119-01 5/30/2006 Undetected n/a163 EE05814 8/16/2006 187 1254 X X ND <0.08 ppb 6"164 FF01061 10/4/2006 220 1254 X X ND < 0.2 ppb 8"165 EE02639 9/8/2006 109 1254 X X ND < 0.1 ppb166 EE02639-2 9/8/2006 182 1254 X X ND < 0.1 ppb

Electric feederElectric feeder

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