1. AGA PCB Management Guidelines and EPA Regulatory Update
John P. Woodyard, PE
AGA Consultant
.com
Presented at the
AGA Operations Conference
Grapevine, TX
May 22, 2015

2. Topics 2010 Advance Notice of Proposed Rulemaking (ANPRM) Status and
Subsequent EPA Communications
Continuing EPA Region 5 LDC and Transmission PCB Investigations
MPCA PCB Fact Sheet for Natural Gas Systems
AGA “Voluntary Guidelines”
Non-Liquid PCB Management and Standards
Dioxin-Like PCB Congener Developments

3. 2010 PCB ANPRM: Purpose and Background
“It’s been 15 years since the regulations were amended”
Reassess current use authorizations for certain PCB uses to determine whether they may not present an unreasonable risk
Investigate whether some authorized used of PCBs should be eliminated or phased out
Determine if more stringent use and servicing restrictions would be appropriate
Reexamining the geographical and numerical extent of PCBs and PCB items, both electric and gas-related
(Does not address spill cleanup, remediation, or disposal, at least directly)

4. Draft proposed rule to OMB by November 2015
2010 PCB ANPRM: Status
Draft proposed rule to OMB by November 2015
Proposed rule publication in March 2016
Changes will focus almost exclusively on electric and natural gas industries
Delays due to:
HQ staffing issues, retirements
Inadvertent PCB manufacture (PCB 11)
PCB caulk in schools

5. EPA’s Stated Concerns about Natural Gas & PCBs
EPA expresses concern to natural gas industry ( ) that:
PCBs should have been eliminated by now (“The 10 years…should have allowed owners sufficient time to purge PCBs from their systems”),
EPA has no recent data
PCBs are being found too close to customer,
PCB health risk is greater than they thought, and
Greater PCB control is necessary
ANPRM informs gas industry of EPA’s intent to amend regulations mandating an eventual phase-out

6. Original Changes Proposed by EPA That Concerned the Natural Gas Industry
Notification to EPA when PCBs are Found in any Pipeline System, Regardless of Source or the Owner of the Pipeline
BY 2020, Elimination of the PCB Use Authorization for pipeline systems
By 2025, Elimination of any PCB-Contaminated Equipment ( ppm) Use
Immediately, Elimination of Authorization for Storage of PCB Equipment for Reuse
Possible Reduction of Use Authorization Limit to 1 ppm PCB

7. Natural Gas Industry Comments on PCB ANPRM
EPA’s own risk assessments showed PCB presence in gas systems is safe
PCBs cannot be phased out, since there is often no way to find and remove them
Current management practices are working
If liquids are the concern, then there is no need to regulate dry systems
Reporting to EPA every time PCBs are found is an unnecessary burden on EPA and the industry
Industry has some suggestions for regulatory streamlining and clarification

8. What is the Likely Outcome of the Rulemaking for the Natural Gas Industry?*
Total ban on the use of PCBs in natural gas pipelines “unrealistic” except where practicable
Recordkeeping and possible notification requirements when PCBs ≥50 ppm are found in customer meters
Reconsidering “source” focus and may focus instead on “trouble spot control” and liquid collection points
Pre-TSCA compressor oil sampling (one time)
Broader use of wipe sampling for system characterization
*Comments from EPA during meetings with AGA, most recently 4/22/15

9. Continued Use of Concrete Containing PCBs
Provisions allowing cleaning and coating contaminated porous surfaces enacted in 1998 under 40 CFR (p)
Widely used by transmission and distribution companies to address concrete and paint in locations where substrate removal is impractical
EPA data indicates that this option can still result in airborne exposure to PCBs
EPA considering possible deed recording and some form of notification/recordkeeping* rather than banning practice
* Comments from EPA during meetings with AGA, most recently 4/22/15

10. Other Potential Regulatory Developments
Fluorescent Light Ballasts
Phase-out planned (3-5 years)
PCB Caulk
“Not realistic to make towns bulldoze schools”
Updating web site (policy)
Looking at regulatory options, not planning rulemaking
Inadvertently Generated PCBs
No rulemaking planned

11. Continuing EPA Regional PCB Investigations
Region 5 is the lead region for natural gas issues in the current rulemaking process
After 2010 ANPRM, EPA’s Region 5 Enforcement Division began revisiting LDCs and others that had previously been queried in 2007
In 2012 EPA data and sampling inquiries were made to 24 other LDCs and transmission companies around the US; no feedback based on response
Region 5 facility inspections and sampling has been cited by members ( ), more are possible (although fact finding activities have slowed; nothing in 2015)

12. MPCA Fact Sheet for Natural Gas Systems
In June 2012, the Minnesota Pollution Control Agency published a PCB “Fact Sheet” addressing PCBs in natural gas systems (T&D) operating in Minnesota
The “Fact Sheet” contains numerous deviations from EPA requirements affecting natural gas systems, including:
Assuming all systems could contain PCB despite historical sampling results
Test liquids and pipe for PCBs forever, even if no PCB history
Fuzzy distinction between potential sources and small liquid collection points
Marking any location where PCBs >50 ppm were found
Storage of untested pipe as hazardous waste
No developments since industry complaints
Important in light of Federal preemption precluding states from regulating PCB use; TSCA amendments or replacements pending in Congress

13. AGA Voluntary Guidelines: Background
Dating back to 2003 (the ill-fated “Fix-It” Rule), AGA and its members have been prepared to offer EPA suggestions on how to improve/clarify the PCB regulations affecting natural gas systems
Since it appears that the EPA’s rulemaking trend is less ambitious than previously announced, many of those earlier improvements/clarifications are still timely
Companies are still battling EPA on enforcement issues centered around regulatory interpretation
AGA and members began (2012) to develop consensus guidelines explaining how the industry interprets the regulations.

14. AGA Voluntary Guidelines: Scope
Determining the regulatory status of a natural gas distribution or transmission system containing PCBs in pipeline liquids
Management of PCB-containing pipeline liquids from natural gas transmission or distribution systems
Management of PCB liquid-impacted gas meters and other equipment
Recordkeeping requirements for PCB-impacted natural gas distribution or transmission systems
Encapsulation of PCB-impacted porous surfaces
Communications planning for PCBs in pipeline liquids

15. AGA Voluntary Guidelines: Key Issues
De minimis quantities of liquid for system characterization
Characterization of systems that are dry or have bi-directional flow
The importance of “sources”
The relevance of one-off liquid findings during repair/maintenance, not existing collection points
Limiting regulation and management to hot spots
Response to PCB findings in customer meters
Minimum requirements versus Best Practices

16. Non-Liquid PCB Management and Standards
NLPCB management (caulk, paint in particular) was addressed as part of 2010 ANPRM
EPA once considered (1998) allowing some uses >50 ppm PCB if data demonstrates no unreasonable risk
EPA studied coating or treating in-place NLPCB ( ) as temporary remedy for schools, others
Current EPA thinking is to modify web site “best practices” rather than proposing regulations
Important to industry since it keeps PCBs in the news

17. Dioxin-Like PCB Congener Developments
EPA originally proposed to essentially regulate PCBs as the “toxic equivalents” of dioxins
NSF study dismissed findings, but increasing use of congeners by EPA continues (largely as total PCBs, not dioxin equivalents)
GE research recently concluded that PCB126 (the “most potent” congener) is in fact 30 times less potent than thought
GE findings accepted for publication*, coauthored by Martin van den Berg of WHO
Results, likely to be accepted in the next WHO-TEF Update, would render the TEF approach to PCB risk assessment irrelevant
*Chem. Res. Toxicol., February 2015 acceptance

18. johnwoodyardpe@gmail .com
Questions?
John P. Woodyard, PE
AGA Consultant
Libertyville, IL
.com