Oil-Filled Electrical Equipment (OFEE) and Other Materials Containing PG&E’s Management of Oil-Filled Electrical Equipment (OFEE) and Other Materials Containing Polychlorinated Biphenyls (PCB) Good morning. I’m Tony Jacob. First of, thank you much for inviting us to your workshop. I’m with Env Ops supporting PG&E’s environmental compliance in central and eastern contra costa county since 1997. Prior to this assignment I was with Power Generation as Power Plant Chemist . A year after joining PG&E in 1977, the company started its aggressive PCB program: a system-wide inventory of ‘PCB-equipment’ was prepared, procedures were written and personnel training were conducted. The first priority of the program were replacement of ‘PCB-equipment’ in urban centers, near schools, hospitals, food manufacturing or processing facilities, on agricultural areas or grazing lands, areas near waterways and, places where a release could result in health issues and major damage to the environment. There’s so much information about PG&E’s PCB program so this presentation is intended only to give you a basic understanding of how we manage OFEE and materials containing PCB. The process for handling undamaged OFEE containing PCB is the same as those that had been damaged: they are identified, transported securely and disposed of in State approved facilities.

PCB’s in Oil Filled Electrical Equipment Mineral Oil : to insulate, suppress corona and arcing and, as coolant PCB: as dielectric* fluid *electric insulating by polarization as opposed to electrical obstruction PCB’s ‘desirable ’ properties in electric equipment and in other industrial application such as plasticizer in rubber, paint or plastics, was synthesized in 1881 but commercial production in the US started in 1929. Then 50 years later the health hazards of it – as carcinogen – was identified: it was permanently banned in the US on July 1, 1979. Worldwide in 2001. So what exactly is PCB? It’s an additive to the mineral oil to increase its protective properties and extend its life. PCB is an odorless, tasteless, clear to yellow viscous liquid. Has high dielectric constant, very high thermal conductivity, high flash point, fairly chemically inert, resistant to oxidation, reduction, addition and other chemical reactions but 100% soluble in mineral. In addition to mineral oil, PCB is also present in pastes as in ballasts or in paper insulators as in cables. On the other hand, it is a nasty substances primarily because of its persistency in the environment and if burned, will generate toxins. The other very serious health problem with PCB is its persistency: it’s very stable and do not decompose readily. It has a half life of 8 - 15 years. Remember DDT?

POLYCHLORINATED BIPHENYLS Man-made organic chemicals, domestically manufactured beginning in 1929 Used in many commercial applications Insulating properties Stability Non-flammable

Common Types of PCBs Mineral Oil Dielectric Fluids: Mineral oil-filled electrical equipment may be contaminated from its origin of manufacture through servicing and/or rebuilding activities Must be assumed to contain 50-499 ppm while in use or in storage for reuse if: Manufactured prior to July 2, 1979 PCB level is unknown

Common Types of PCBs Tar/Compound Dielectrics & Potting Agents: Non-liquid type of substance contaminated with PCBs (sometimes at very high levels) that may be found in electrical equipment Bushings, old light ballasts, PTs, CTs are examples that may be tar-filled

Emerging PCB Issues: PCB in Schools (New York, Oregon, Massachusetts) suspected at any location with pre-1979 light ballasts Leaking light ballasts Caulking material Glazing material Paint

Potential Health Effects: Probable Human Carcinogen Causes cancer Animals Non-cancer effects to the immune, reproductive, endocrine systems

PCB Regulations 40 CFR Part 761 = The PCB Mega Rule Subpart A §761.2 – PCB concentration assumptions for use Subpart B §761.2 – Prohibitions & Exceptions §761.3 – Use Authorizations §761.35 – Storage for reuse Subpart C §761.4 – Marking requirements

PCB Prohibitions and Exceptions No persons may use any PCB, or PCB Item regardless of concentration, in any manner other than in a totally enclosed manner within the United States unless authorized under §761.30

PCB Regulatory Information Oil-Filled Electrical Equipment Polychlorinated Biphynels Federal and State Definition Identification Operating Procedures Emergency Response Level of Clean-up Regulatory Reporting This presentation will cover only these three topics: OFEE – I’ll show you photos of oil filled electrical equipment where PCB ‘could’ be present PCB – why is it in OFEE? what is Federal and State definition of PCB? how is it identified in OFEE? Procedures – essentially the core of this presentation : what are the processes we use to make sure PCB-equipment are handled properly to protect public and PG&E’s personnel health and safely, the environment and, public and private property?

Federal and State Levels PCB in mineral oil (or in any material) : Federal level TSCA: >50 ppm State level: 5-49 ppm PCB are known commercially by many names. The most common is Aroclor by Monsanto. In 1981 California mandated that any equipment or material – solid or liquid - containing >5 ppm PCB is ‘PCB-contaminated’. This is the level we follow to determine ‘PCB-cleanliness’. How do we determine PCB content? (next slide)

Equipment that contains PCB’s

Approximate number of PCB containing equipment System Wide PGE has over 1,000,000 pieces of OFEE Of those 1,000,000 Pieces approximately 33% are pre-1979 Of those Pieces approximately 3% contain PCB’s > 5 ppm As I mentioned earlier PG&E’s PCB program started in 1978 , It is still as active as it was 30 years or so ago. Even more intense now because of tighter regulatory requirements that had been enforced the last 10 years. As I said I’ve covered central and eastern contra costa for the last 16 years and based on records I only get 0 to 2 ‘PCB-related’ release - out of 5-20 – every year. To give you an idea – or a birds’ eye view – of where PG&E’s PCB program is at right now, here’s a chart of the ‘PCB-equipment” processed at ERF. This chart is an indication that PG&E has managed to removed significant amount of PCB-equipment in the system since its PCB program started in 1978 . So what exactly is OFEE and PCB? (next slide)

The following photos are the most common OFEE you see all the time: pole mounted transformers and pad mounted transformers. Many sizes. Often bundles in poles in 2’s or 3’s or for pad mount, one very large or in 2’s or 3’s small in one pad.

recloser and capacitors

switches in vaults

More transformers: they’re called potential transformers

substation insulators substation insulators. Not shown here are PCBs in some natural gas distribution pipes, meters, and other facilities or equipment

One of the three ways to determine presence of PCB is by label like these.

The equipment tag is also a source of PCB level: some will clearly show that the equipment has no PCB at time of manufacture. In cases where this statement is not present, we use the equipment nameplate: manufacturer, serial number and date of manufacture, to ‘determine’ the level of PCB by cross-referencing the info on a table. In general, those manufactured prior to July 1, 1979 will most likely be >50 ppm and those manufactured after that date will most likely be 5-49 ppm. This PCB level is the basis of the cleaning procedure we used (that I’ll discuss later). At one point we were using a field test kit to determine the PCB content but there were so many false positive so we discontinued it. This was also the time where we found many chem labs who could run the analytical test 24/7 and get the result within 2-3 hours. Nowadays, we even test those equipment showing non-PCB just to make sure.

PGE Policy’s and Emergency Response

PG&E Policy and Procedures Our internal policy are reviewed on a regular basis to ensure that they meet the TSCA requirements. These two sets of procedures: those involving substation equipment and those for distribution equipment are almost identical except in the degree of response: in substation the entire facility is a hazardous area and the quantity involved are much larger than distribution. Most of the ‘incidents’ you’d encounter will be distribution equipment. In the early years PCB-contaminated equipment and materials were just a part of the Hazardous Waste Management Program. The PCB ‘procedure’ became a stand alone procedure in 1983 but only as bulletin or directives to transmission and distribution operations. The PCB procedure were revised as the regulations became tighter. Currently, both procedures consists of 45-55 pages covering every aspect of PCB management.

Our policies contain information on the following topics: PCB Procedures: Spill categories Degree of response / Emergency Guides Notification requirements Cleaning requirements / Safety Equipment Transportation and equipment re-use Documentation and certification requirements Personnel training 24-hour hotline to reach Environmental Professional There are so many variables in managing PCB spills that it is impossible for me to tell you specifically the actions we would take. In any case, the three basic elements in our response – regardless of amount spilled – are: personnel and public safety (‘don’t do anything to put yourself and others in harms’ way’ or ‘isolate or barricade the area from the public’), report the incident to electric operations, contain the spill (‘prevent it from making it worse than it is such as by diking or application of absorbents’) Read some lines from the book for each category Spill categories: 5, from stain to spill >1 gallon Degree of response in conjunction with spill category: State level – 5 to 49 ppm – from immediate clean-up to next business day. Federal – 50 to 499 ppm – immediate clean-up until it is ‘clean’. Federal >500 ppm, get all resources now to clean the spill. Notification requirement: internal (PG&E): immediately, and external (agencies): as soon as possible (in some cases within a couple of hours of incident). One of the required notifications is the local Env Field Specialist. Our dept- Env Opers – has a 24/7 helpline that any PG&E employee can call for assistance on any environmental issue. Mineral oil spills – whether they contain PCB or not - is the hot issue we in Env Ops deal with everyday. Cleaning requirements / Safety Equipment: from simple wiping to excavation of large area of soil or cleaning all storm drains. Disposable personal safety equipment are required on all personnel responding to clean-up Transportation and equipment re-use: only DOT approved containers and State certified haz waste hauler, some equipment can be re-use but only up to a certain time. Documentation and certification requirements: all PCB spill >50 ppm must be certified by a supervisor for its cleanliness. In addition to spill documentation, we prepare a system wide annual document listing all PCB-equipment and PCB-contaminated materials (>50 ppm) processed within that year. Personnel training: once every two years all personnel who might be assigned to spill clean-up are mandated to attend a refresher PCB course

PCB Waste Management Requirements

Federal Requirements: TSCA – Class 1 TSCA permitted landfill – Waste Management Kettleman Hills – Not Accepting RCRA Not regulated by RCRA California 5ppm STLC, 50ppm TTLC Soluble Threshold Limit Concentration (STLC) and Total Threshold Limit Concentration (TTLC) Regulatory Limits Class 2 only if contaminating material is less than 50 ppm Transformer Oil – if less than 50 ppm oil is recycled >50 oil is incinerated

Summary PG&E started addressing the issue of PCB in 1977 PCB procedures are based on Federal and State regulations and they are reviewed or updated every year. Personnel training conducted every two- years to all PG&E employees who might be assigned to handle PCB.