1446.12_ss-Attachment-E_Consultations

1446.12_ss-Attachment-E_Consultations.pdf

PCBs: Consolidated Reporting and Recordkeeping Requirements

1446.12_ss-Attachment-E_Consultations

OMB: 2070-0112

⚠️ Notice: This form may be outdated. More recent filings and information on OMB 2070-0112 can be found here:

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Appendix E to the Supporting Statement for
PCBs, Consolidated Reporting and Recordkeeping Requirements
EPA ICR No. 1446.12; OMB Control No. 2070‐0112
Record of 2018 PCB ICR Consultations and Responses

1. Summary of Consultation Outreach, Comments and EPA Response to
Comments
2. EPA request for consultation comments
a. EPA email to Lacey, AGA
b. EPA email to Pennell, RCS
c. EPA email to Wawer, CPMA
d. EPA email to Roewer, USWAG
e. EPA email to Ronning, Xcel
3. Comments received by EPA in response
a. Pennell phone message Memorandum
b. CPMA email to Gimlin, EPA
c. USWAG email to Gimlin, EPA, with attachment

Summary of Consultation Outreach, Comments and EPA Response to Comments
Consultation Outreach
In proposing to renew this ICR, EPA provided a 60‐day public notice and comment period that ended on
October 26, 2018 (83 FR 43675, August 27, 2018). No public comments were submitted to the docket at
regulations.gov in response to this notice.
During the public comment period, EPA conducted a consultative outreach effort, submitting questions
to five potential respondents via e‐mail to solicit their opinion on the PCB recordkeeping and recording
requirements. A copy of EPA’s consultation e‐mails to each of the potential respondents is attached to
this summary. The individuals contacted were:
Jim Roewer, Executive Director
Utility Solid Waste Activities Group
c/o Edison Electric Institute
701 Pennsylvania Avenue, NW
Washington, DC 20004‐2696
Jim.Roewer@USWAG.org
(202) 508‐5645
Pam Lacey
American Gas Association
400 N. Capital St., NW
Washington, DC 20001
placey@aga.org
(202) 824‐7000

Mark Pennell
RCS, INC.
Ozark, MO 65721
RCSINC@aol.com
(417) 886‐4580

David J. Wawer, Executive Director
Color Pigments Manufacturers Association
1850 M Street NW, Suite 730
Washington, DC 20036
cpma@cpma.com
(202) 465‐4901

Tedd Ronning, P.G.
Xcel Energy Environmental Services
414 Nicollett Mall – 02
Minneapolis, MN 55401
Theodore.A.Ronning@xcelenergy.com
(612) 330‐7764
In response to these requests, EPA received three substantive replies. EPA received two sets of
written responses from: (1) the Color Pigments Manufacturers Association, Inc. (CPMA); and (2) the
Utility Solid Waste Activity Group (USWAG). Additionally, EPA also received one verbal response by
telephone from Mark Pennell of RCS, Inc. Copies of these responses are attached to this summary.
CPMA Comments and EPA Response
CPMA commented on the burden associated with maintaining records of monitoring and
analysis, as well as compliance certification, for persons who inadvertently generate PCBs and/or import
products inadvertently containing PCBs, as per §761.185 and .193 (Item # 100 in the Supporting

Statement). CPMA commented that, based on an informal survey of color pigment manufacturing
companies conducted in response to EPA’s solicitation, domestic manufacturers take from 12 up to 24
hours annually to comply with these recordkeeping requirements. In follow‐up correspondence, CPMA
clarified that 4 to 5 domestic manufacturers maintain files, and perhaps 15 distributors import pigments
[some whom presumably also maintain records]. Using this information, EPA has adjusted the time
estimate for individual respondents upward from the previous 4.5 to 8 hours. EPA is using a figure less
than that proposed by CPMA, because it is averaged between domestic manufacturers and importers,
who EPA believes to have appreciably less burden. EPA also used information provided by CPMA to
refine its estimate of the number of respondents.
USWAG Comments and EPA Response
In response to EPA’s inquiry, USWAG commented to confirm that the estimates of the PCB
Large Capacitor inventory that it provided to EPA in 2010 was still fundamentally accurate. In particular,
the 2010 estimation that almost all remaining large PCB capacitors should be retired by 2013. However,
USWAG also noted in its comments that current information from some of its members indicates that
some PCB Large Capacitors still do remain in service. Based on USWAG’s comments, as well as those
from Mark Pennell, and EPA’s disposal data, EPA has significantly lowered its previous estimate of the
remaining PCB Large Capacitor inventory from 100,000 units to 10,000 (of which 10% remain unmarked
and subject to recordkeeping). (Item #78)
USWAG also commented that many members continue to use the storage for reuse provision to
maintain PCB equipment, but did not provide any updated inventory information. EPA has updated its
estimates of PCB equipment in storage for reuse based on the most current estimates provided by
USWAG in 2010. (Item #77)
Pennell Comments and EPA Response
Additionally, EPA received a verbal response from Mark Pennell of RCS, based on informal
feedback from RCS members, some 250‐300 mainly municipal and rural electric utilities. Mr. Pennell
commented that he believes in general that large utilities have already removed and disposed of their
inventories of PCB Large Capacitors. However, they always find ‘stragglers” of residual remaining units.
This comment is consistent with USWAG’s comment noted previously. EPA took Mr Pennell’s
confirmatory comments into account in adjusting its estimate of the inventory of remaining PCB Large
Capacitors significantly downward to reflect a residual inventory.

Gimlin, Peter
From:
Sent:
To:
Cc:
Subject:

To:

Gimlin, Peter
Thursday, October 18, 2018 10:06 AM
'Lacey, Pam'
Swetland-Johnson, Karen; Winchester, Erik; Gimlin, Peter
two pipeline questions and Request for Comments; Renewal of "PCBs, Consolidated Reporting and
Record Keeping Requirements" ICR

Pam Lacey
American Gas Association
400 N. Capital St., NW
Washington, DC 20001
placey@aga.org
(202) 824-7000

Dear Pam,
It has been a long time since we have talked about PCB in pipeline issues, but I am updating the current PCB
ICR for renewal and looking for your input on two particular questions, as well as any other comments you may
have on the regulatory burden.
1) Regarding §761.60(b)(5)(i)(A)(1) -- Include abandoned natural gas pipes that contain PCBs in public service
notification programs. (Item #56 in the ICR Supporting Statement). The ICR currently estimates 50 pipes
annually are subject to this requirement, based on an estimate you provided in 2003 to the contractor, Caroll
Wendell of ERG. Do you think this estimate is still accurate, or is there a better number to use?
2) Regarding §§761.30(i)(1)(iii)(B) and (C) -- Keep records on certain natural gas pipeline systems with ≥50
ppm PCBs and records of actions taken to reduce PCB contamination for three years after PCBs reduced to <50
ppm. (Item #76). The ICR currently estimates 100 companies are subject, that is, still have or recently had
>50ppm PCBs. Do you think this estimate is reasonably accurate, or is there a better number to use?
If you could call or reply this week or next, that would be very helpful; note the comment period closes
officially on October 26, 2018.
Here are details on accessing the ICR supporting statement and general information the Agency seek:
On August 27, 2018, EPA published a Notice in the Federal Register (79 FR 61302) titled “Agency Information
Collection Activities; Proposed Renewal of an Existing Collection (EPA ICR No. 1446.12); Comment
Request.”
(See https://www.regulations.gov/docket?D=EPA-HQ-OPPT-2017-0647)
This Notice refers to EPA's intention to request renewed Office of Management and Budget (OMB) clearance
of an information collection related to reporting and/or recordkeeping requirements for individuals,
establishments or organizations that currently possess PCB items, PCB-contaminated equipment, or other PCB
waste.
In addition to public notice and comment requirement that the above Notice initiates, OMB regulations at 5
CFR 1320.8(d)(1)) require agencies to consult with potential respondents and data users about specific aspects
1

of an information collection request (ICR) before submitting it to OMB for review and approval, regardless, in
the case of ICR renewals, of whether changes have or have not been made to the collection activity.
Please note that if you take this opportunity to provide input, your name, affiliation, e-mail address, phone
number and any information you provide (e.g., copies of e-mails) will be incorporated and attached to the ICR
supporting statement, which will be a public document. In addition, the OMB Desk Examiner for the ICR in
question may contact you to verify the accuracy of any comments EPA identifies in the ICR.
EPA solicits your input on the following questions:


Are the data that EPA seeks under this ICR available from any public source, or already collected by
another EPA office or by another agency? If so, where can the data be found?



Is it clear what is required for data submission? If not, are there any suggestions for clarifying
instructions?



Would you be interested in an electronic/data submission option? What type of alternative would you
be most likely to utilize – web form, USB flash drive, CD-ROM?



For electronic submission, how should signature requirements be handled – Private Key Infrastructure,
PINS and passwords, signed paper cover sheet?
How does TSCA CBI affect your choice or use of an electronic medium? Would you be more inclined
to submit TSCA CBI on CD-ROM or a USB flash drive than on paper and what benefits would you
realize (e.g., burden reduction, greater efficiency in compiling information, etc).



Do you agree with EPA's estimated burden and costs (the ICR addresses only the costs associated with
paperwork)? Are the Bureau of Labor Statistics (BLS) labor rates accurate? If you have any reason to
consider the BLS labor rates as used by EPA inaccurate or inappropriate, explain your rationale.

To access the Federal Register Notice, the ICR supporting document, and any public comments received to
date, go to:
 www.regulations.gov/
 enter EPA-HQ-OPPT-2017-0647 in the Enter Keyword or ID field
 click on "Search"
 click on “Open Docket Folder”
 then click on any of the documents listed within the docket to read the document; you will be most
interested in the Supporting Statement, identified by its title "PCBs, Consolidated Reporting and Record
Keeping Requirements”
Your response will be greatly appreciated. If you have any comments in response to the above questions, or
with respect to any other part of the information collection, please respond by return e-mail by October 26,
2018. EPA will consider those responses, as well as any public comment received in response to the Federal
Register Notice identified above, in preparing a final document for OMB review.
Thanks for your consideration; please call me if any questions, 202-566-0515.
Peter
Peter Gimlin
Environmental Protection Specialist
Fibers and Organics Branch/NPCD/OPPT
2

U.S. Environmental Protection Agency
tel. 202‐566‐0515, email: gimlin.peter@epa.gov

Gimlin, Peter
From:
Sent:
To:
Cc:
Subject:

To:

Gimlin, Peter
Thursday, October 18, 2018 11:10 AM
'RCSINC@aol.com'
Winchester, Erik; Gimlin, Peter
large capacitor question and Request for Comments; Renewal of "PCBs, Consolidated Reporting and
Record Keeping Requirements" ICR

Mark Pennell
RCS, INC.
Ozark, MO 65721
RCSINC@aol.com
(417) 886-4580

Dear Mark,
It has been a long time since we have talked about PCB use issues, but I am updating the current PCB ICR for
renewal and looking for your input on a particular question, as well as any other comments you may have on the
regulatory burden.
In 2010, USWAG submitted comments on the PCB Use Reassessment ANPRM and provided as an attachment
a study by ENVIRON estimating an inventory of PCB equipment. That study concluded that “At the assumed
rate of retirement, almost all of the remaining large PCB capacitors should be retired by 2013.” In updating
our estimate of the number of large PCB capacitors for the current ICR, I am wondering if this
conclusion that all large PCB capacitors would be gone by now is a reasonable conclusion? If you think
an appreciable inventory of large PCB capacitors will remain in the next three years (2019-2022), how
many do you think that might be? If you could call or reply this week that would be very helpful; note the
comment period closes officially on October 26, 2018.
Here are details on accessing the ICR supporting statement and general information the Agency seek:
On August 27, 2018, EPA published a Notice in the Federal Register (79 FR 61302) titled “Agency Information
Collection Activities; Proposed Renewal of an Existing Collection (EPA ICR No. 1446.12); Comment
Request.”
(See https://www.regulations.gov/docket?D=EPA-HQ-OPPT-2017-0647)
This Notice refers to EPA's intention to request renewed Office of Management and Budget (OMB) clearance
of an information collection related to reporting and/or recordkeeping requirements for individuals,
establishments or organizations that currently possess PCB items, PCB-contaminated equipment, or other PCB
waste.
In addition to public notice and comment requirement that the above Notice initiates, OMB regulations at 5
CFR 1320.8(d)(1)) require agencies to consult with potential respondents and data users about specific aspects
of an information collection request (ICR) before submitting it to OMB for review and approval, regardless, in
the case of ICR renewals, of whether changes have or have not been made to the collection activity.
Please note that if you take this opportunity to provide input, your name, affiliation, e-mail address, phone
number and any information you provide (e.g., copies of e-mails) will be incorporated and attached to the ICR
1

supporting statement, which will be a public document. In addition, the OMB Desk Examiner for the ICR in
question may contact you to verify the accuracy of any comments EPA identifies in the ICR.
EPA solicits your input on the following questions:


Are the data that EPA seeks under this ICR available from any public source, or already collected by
another EPA office or by another agency? If so, where can the data be found?



Is it clear what is required for data submission? If not, are there any suggestions for clarifying
instructions?



Would you be interested in an electronic/data submission option? What type of alternative would you
be most likely to utilize – web form, USB flash drive, CD-ROM?



Gimlin, Peter
From:
Sent:
To:
Cc:
Subject:

Gimlin, Peter
Wednesday, October 17, 2018 4:43 PM
'David Wawer'
Gimlin, Peter
PCB Recordkeeping question and Request for Comments; Renewal of "PCBs, Consolidated Reporting
and Record Keeping Requirements" ICR

To: David Wawer, Executive Director
Color Pigments Manufacturers Association, Inc.
1400 Crystal Drive, Suite 630
Arlington,VA 22202
(571) 348-5106

David,
In follow up to my phone message, I am updating the current PCB ICR for renewal and looking for your input
on changes to address some comments you made in response to the last PCB ICR renewal in your letter to
Toiya Goodlow dated November 14, 2014 (attached). In that letter, you noted:
However, the costs of generating the monitoring records described above
are not adequately reflected in the Supporting Statement, Annual
Respondent Hourly Burden and Cost Estimate, which states that only .5
hours of management time and 4.5 hours of technical time are needed
toward each reporting submission. The 5 hours allotted to recordkeeping
for excluded manufacturing processes is too low.

I would like to discuss with you what might be a more accurate figure(s) to capture this recordkeeping
burden. Or let me know your thought in response to this email. Also, your thought on what might be the
number of manufacturers/importers who still retain these records. If you could call or reply this week
that would be very helpful; note the comment period closes officially on October 26, 2018.
Here are details on accessing the ICR supporting statement and general information the Agency seeks:
On August 27, 2018, EPA published a Notice in the Federal Register (79 FR 61302) titled “Agency Information
Collection Activities; Proposed Renewal of an Existing Collection (EPA ICR No. 1446.12); Comment
Request.”
(See https://www.regulations.gov/docket?D=EPA-HQ-OPPT-2017-0647) This Notice refers to EPA's intention
to request renewed Office of Management and Budget (OMB) clearance of an information collection related to
reporting and/or recordkeeping requirements for individuals, establishments or organizations that currently
possess PCB items, PCB-contaminated equipment, or other PCB waste.
In addition to public notice and comment requirement that the above Notice initiates, OMB regulations at 5
CFR 1320.8(d)(1)) require agencies to consult with potential respondents and data users about specific aspects
of an information collection request (ICR) before submitting it to OMB for review and approval, regardless, in
the case of ICR renewals, of whether changes have or have not been made to the collection activity.
1

Please note that if you take this opportunity to provide input, your name, affiliation, e-mail address, phone
number and any information you provide (e.g., copies of e-mails) will be incorporated and attached to the ICR
supporting statement, which will be a public document. In addition, the OMB Desk Examiner for the ICR in
question may contact you to verify the accuracy of any comments EPA identifies in the ICR.
EPA solicits your input on the following questions:


Are the data that EPA seeks under this ICR available from any public source, or already collected by
another EPA office or by another agency? If so, where can the data be found?



Is it clear what is required for data submission? If not, are there any suggestions for clarifying
instructions?



Would you be interested in an electronic/data submission option? What type of alternative would you
be most likely to utilize – web form, USB flash drive, CD-ROM?



Gimlin, Peter
From:
Sent:
To:
Cc:
Subject:

Gimlin, Peter
Wednesday, October 17, 2018 5:21 PM
'Jim.Roewer@USWAG.org'
Gimlin, Peter; Winchester, Erik
Large PCB Capacitor estimate and Request for Comments; Renewal of "PCBs, Consolidated Reporting
and Record Keeping Requirements" ICR
USWAG-ENVIRON inventory 2010.pdf

Attachments:

To:

Jim Roewer, Executive Director
Utility Solid Waste Activities Group
c/o Edison Electric Institute
701 Pennsylvania Avenue, NW
Washington, DC 20004-2696

Dear Mr. Roewer,
It has been a long time since we have talked about PCB use issues, but I am updating the current PCB ICR for
renewal and looking for your input on a particular question, as well as any other comments you may have on the
regulatory burden.
In 2010, USWAG submitted comments on the PCB Use Reassessment ANPRM and provided as an
attachment a study by ENVIRON estimating an inventory of PCB equipment. That study concluded that
“At the assumed rate of retirement, almost all of the remaining large PCB capacitors should be retired by
2013.” (page 13) In updating our estimate of the number of large PCB capacitors for the current ICR, I
am wondering if USWAG believes that to be a reasonable conclusion for the 2019-2022 period, or if an
appreciable inventory of large PCB capacitors remains, what a more accurate estimate might be. If you
could call or reply this week that would be very helpful; note the comment period closes officially on
October 26, 2018.
Here are details on accessing the ICR supporting statement and general information the Agency seek:
On August 27, 2018, EPA published a Notice in the Federal Register (79 FR 61302) titled “Agency Information
Collection Activities; Proposed Renewal of an Existing Collection (EPA ICR No. 1446.12); Comment
Request.”
(See https://www.regulations.gov/docket?D=EPA-HQ-OPPT-2017-0647)
This Notice refers to EPA's intention to request renewed Office of Management and Budget (OMB) clearance
of an information collection related to reporting and/or recordkeeping requirements for individuals,
establishments or organizations that currently possess PCB items, PCB-contaminated equipment, or other PCB
waste.
In addition to public notice and comment requirement that the above Notice initiates, OMB regulations at 5
CFR 1320.8(d)(1)) require agencies to consult with potential respondents and data users about specific aspects
of an information collection request (ICR) before submitting it to OMB for review and approval, regardless, in
the case of ICR renewals, of whether changes have or have not been made to the collection activity.
Please note that if you take this opportunity to provide input, your name, affiliation, e-mail address, phone
number and any information you provide (e.g., copies of e-mails) will be incorporated and attached to the ICR
1

Are the data that EPA seeks under this ICR available from any public source, or already collected by
another EPA office or by another agency? If so, where can the data be found?



Is it clear what is required for data submission? If not, are there any suggestions for clarifying
instructions?



Would you be interested in an electronic/data submission option? What type of alternative would you
be most likely to utilize – web form, USB flash drive, CD-ROM?



Gimlin, Peter
From:
Sent:
To:
Subject:

Gimlin, Peter
Thursday, October 18, 2018 11:34 AM
'Theodore.A.Ronning@xcelenergy.com'
FW: Request for Comments; Renewal of "PCBs, Consolidated Reporting and Record Keeping
Requirements" ICR

From: Gimlin, Peter
Sent: Thursday, October 18, 2018 11:31 AM
To: 'Theodore.A.Ronning@xcelenergy.com'
Cc: Winchester, Erik ; Gimlin, Peter
Subject: Request for Comments; Renewal of "PCBs, Consolidated Reporting and Record Keeping Requirements" ICR

To:

Tedd Ronning, P.G.
Xcel Energy Environmental Services
414 Nicollett Mall – 02
Minneapolis, MN 55401
(612) 330-7764
Theodore.A.Ronning@xcelenergy.com

Dear Mr. Ronning,
I am updating the EPA’s current estimates of the reporting and recordkeeping burden imposed by the PCB
regulations at 40 CFR Part 761, and I am looking for your input on a particular question, as well as any other
comments you may have on the regulatory burden.
On April 12, 2018, you submitted to EPA a PCB Transformer Registration form for 3 transformers.
Currently we estimate that it requires one hour of managerial time to register a newly discovered
transformer with the EPA. Do you think this is a reasonable estimate? If not, what do you believe to be a
more accurate assessment of the time required to prepare and submit the notification to EPA, in terms of
time required for: managers; technical staff, and clerical staff?
If you could call or reply this week or next that would be very helpful; note the comment period closes
officially on October 26, 2018.
Here are details on accessing the ICR supporting statement and general information the Agency seek:
On August 27, 2018, EPA published a Notice in the Federal Register (79 FR 61302) titled “Agency Information
Collection Activities; Proposed Renewal of an Existing Collection (EPA ICR No. 1446.12); Comment
Request.”
(See https://www.regulations.gov/docket?D=EPA-HQ-OPPT-2017-0647)
This Notice refers to EPA's intention to request renewed Office of Management and Budget (OMB) clearance
of an information collection related to reporting and/or recordkeeping requirements for individuals,
1

establishments or organizations that currently possess PCB items, PCB-contaminated equipment, or other PCB
waste.
In addition to public notice and comment requirement that the above Notice initiates, OMB regulations at 5
CFR 1320.8(d)(1)) require agencies to consult with potential respondents and data users about specific aspects
of an information collection request (ICR) before submitting it to OMB for review and approval, regardless, in
the case of ICR renewals, of whether changes have or have not been made to the collection activity.
Please note that if you take this opportunity to provide input, your name, affiliation, e-mail address, phone
number and any information you provide (e.g., copies of e-mails) will be incorporated and attached to the ICR
supporting statement, which will be a public document. In addition, the OMB Desk Examiner for the ICR in
question may contact you to verify the accuracy of any comments EPA identifies in the ICR.
EPA solicits your input on the following questions:


Are the data that EPA seeks under this ICR available from any public source, or already collected by
another EPA office or by another agency? If so, where can the data be found?



Is it clear what is required for data submission? If not, are there any suggestions for clarifying
instructions?



Would you be interested in an electronic/data submission option? What type of alternative would you
be most likely to utilize – web form, USB flash drive, CD-ROM?



Peter Gimlin
Peter Gimlin
Environmental Protection Specialist
Fibers and Organics Branch/NPCD/OPPT
U.S. Environmental Protection Agency
tel. 202‐566‐0515, email: gimlin.peter@epa.gov

Gimlin, Peter
From:
Sent:
To:
Cc:
Subject:

David Wawer
Monday, October 29, 2018 1:28 PM
Gimlin, Peter
Tatiana Letcheva
RE: PCB Recordkeeping question and Request for Comments; Renewal of "PCBs, Consolidated
Reporting and Record Keeping Requirements" ICR

Hello Peter,
Glad you and Eric could join us Friday (electronically) for the Region 10 Administrator meeting in Seattle.
Tatiana has been surveying color pigments manufacturing companies for information related to your recent request. I’ve
summarized company feedback that has been received to date.
1. Does your company still file PCB reporting and recordkeeping at USA manufacturing sites? Yes‐ it had been filed
2. How frequent are reports compiled and submitted? Products are spot tested. No updates to the initial report
has been submitted
3. How many hours does it take annually to comply with this recordkeeping requirement? 1‐2 hours/month ~ 12‐
24 hr/yr
4. Is this reporting requirement management internally, or by outside contractor? Report in prepared
internally; testing is done externally. Testing is expensive ($500/sample) with 3‐4 week turnaround time.
Call me Wednesday or Thursday with any follow‐up questions (tied up balance of today and traveling for business on
Tuesday).
Dave
From: Gimlin, Peter
Sent: Thursday, October 18, 2018 9:32 AM
To: David Wawer
Subject: RE: PCB Recordkeeping question and Request for Comments; Renewal of "PCBs, Consolidated Reporting and
Record Keeping Requirements" ICR
Thanks Dave!

Gimlin, Peter
From:
Sent:
To:
Cc:
Subject:
Attachments:

Foley, Allison D.
Friday, October 26, 2018 9:35 PM
Gimlin, Peter
Winchester, Erik; 'jim.roewer@uswag.org'; Green, Douglas H.
Utility Solid Waste Activities Group (USWAG) Feedback on EPA Renewal of "PCBs, Consolidated
Reporting and Record Keeping Requirements" ICR
USWAG-ENVIRON inventory 2010.pdf

Peter:
Thank you for reaching out to USWAG in connection with the PCB ICR.
In conducting the ICR, it is important that EPA not misinterpret or misapply USWAG’s comments on the 2010 Advanced
Notice of Proposed Rulemaking, including the report prepared by Environ that was submitted therewith (the “Environ
Report”). As explained in USWAG’s 2010 comments, that report was intended to update the numbers provided to EPA
in 1982 estimating the universe of PCB‐containing equipment in use by electric utilities, as well as the costs that would
be incurred by electric utilities in identifying and removing this equipment from service.
The Environ Report looked to several sources of data (including 1981 and 1988 studies performed by Resource Planning
Corporation (“RPC”)) and was based on certain assumptions spelled out in the Environ Report. In light of the limited
timeframe provided for responding to the ANPRM, the analysis of inventories in 2010 necessarily relied on extrapolation
of pre‐existing data, as opposed to the undertaking of a detailed survey of all USWAG members. Environ’s conclusions
regarding the 2010 inventories of PCB‐containing equipment and corresponding projections regarding future inventories
were estimates, not precise calculations or predictions. This extrapolated data and the corresponding projections are
important as they demonstrate clear and striking trends which we believe hold true today, eight years after the Environ
Report was prepared. Of particular relevance in the context of the ICR, the Environ Report demonstrated that the
number of pieces of PCB‐containing equipment in service had, as of 2010, declined significantly since TSCA was enacted;
those inventories are expected to steadily decline through a combination of voluntary PCB phase‐down programs and
normal attrition.
Inventories of PCB Large Capacitors: Based on information from USWAG members, these trends also hold true with
respect to PCB Large Capacitors. Environ based its conclusions in the 2010 ANPRM on the following assumptions: (1) no
new PCB units were added after the 1981 RPC inventory; (2) most PCB Large Capacitors identified in the 1981 RPC
inventory were removed from the electric utility distribution system by 1988; (3) on average, 51,755 units are retired
from non‐distribution systems each year; and (4) the ratio of PCB Large Capacitors to the number of mineral oil
transformers in use by electric utilities has remained flat since the 1981 RPC inventory. Based on these assumptions,
Environ extrapolated information from prior studies to project that approximately 120,000 PCB Large Capacitors
remained in use by electric utilities in 2010 (down 95% from the 1981 figure of approximately 2.8 million), and estimated
that, “[a]t the assumed rate of retirement, almost all of the remaining large PCB capacitors should be retired by 2013.”
Based on information from USWAG members, Environ’s assumptions appear to remain valid in 2018, as does the
approach used to determine future inventory levels. While USWAG has not undertaken an update to the 2010 Environ
study, information from our members indicates that some PCB Large Capacitors do remain in service, but that utility
inventories of PCB Large Capacitors (as with other types of PCB‐containing equipment) continue to diminish at a steady
rate. Nonetheless, given the value of this equipment to ensure consistent and reliable utility operations, it is critical that
the use authorization for the equipment remain in place. As discussed in detail in USWAG’s 2010 ANPRM comments,
EPA has determined that such use represents to unreasonable risk to health or the environment.
1

Storage for Reuse: While USWAG has not undertaken a formal survey of member storage for reuse activities since the
2010 ANPRM, feedback from USWAG members indicates that many members continue to use the storage for reuse
authorization to maintain equipment that can serve a critical role in utility operations, including in storm response
and/or other scenarios to ensure consistent, safe, and reliable electric service for customers. If EPA would like more
information regarding current storage for use practices and inventories, USWAG would be happy to work with its
members to compile more detailed information.
Thank you again for the opportunity to provide feedback as EPA conducts this ICR. Please do not hesitate to reach out
with questions about these comments or any other aspects of the PCB regulations EPA is currently evaluating.
Best,
Allison D. Foley, Esq. | Venable LLP
t 202.344.4416 | f 202.344.8300 | m 845.797.6635
600 Massachusetts Avenue, NW, Washington, DC 20001
ADFoley@Venable.com | www.Venable.com

From: Gimlin, Peter
Sent: Wednesday, October 17, 2018 5:21 PM
To: Roewer, James
Cc: Gimlin, Peter ; Winchester, Erik
Subject: Large PCB Capacitor estimate and Request for Comments; Renewal of "PCBs, Consolidated Reporting and
Record Keeping Requirements" ICR
Your attachments have been security checked by Mimecast Attachment Protection. Files where no threat or malware was detected are
attached.

To:

Jim Roewer, Executive Director
Utility Solid Waste Activities Group
c/o Edison Electric Institute
701 Pennsylvania Avenue, NW
Washington, DC 20004-2696

On August 27, 2018, EPA published a Notice in the Federal Register (79 FR 61302) titled “Agency Information
Collection Activities; Proposed Renewal of an Existing Collection (EPA ICR No. 1446.12); Comment
Request.”
(See https://www.regulations.gov/docket?D=EPA-HQ-OPPT-2017-0647)
This Notice refers to EPA's intention to request renewed Office of Management and Budget (OMB) clearance
of an information collection related to reporting and/or recordkeeping requirements for individuals,
establishments or organizations that currently possess PCB items, PCB-contaminated equipment, or other PCB
waste.
In addition to public notice and comment requirement that the above Notice initiates, OMB regulations at 5
CFR 1320.8(d)(1)) require agencies to consult with potential respondents and data users about specific aspects
of an information collection request (ICR) before submitting it to OMB for review and approval, regardless, in
the case of ICR renewals, of whether changes have or have not been made to the collection activity.
Please note that if you take this opportunity to provide input, your name, affiliation, e-mail address, phone
number and any information you provide (e.g., copies of e-mails) will be incorporated and attached to the ICR
supporting statement, which will be a public document. In addition, the OMB Desk Examiner for the ICR in
question may contact you to verify the accuracy of any comments EPA identifies in the ICR.
EPA solicits your input on the following questions:


Are the data that EPA seeks under this ICR available from any public source, or already collected by
another EPA office or by another agency? If so, where can the data be found?



Is it clear what is required for data submission? If not, are there any suggestions for clarifying
instructions?



Would you be interested in an electronic/data submission option? What type of alternative would you
be most likely to utilize – web form, USB flash drive, CD-ROM?



Your response will be greatly appreciated. If you have any comments in response to the above questions, or
with respect to any other part of the information collection, please respond by return e-mail by October 26,
2018. EPA will consider those responses, as well as any public comment received in response to the Federal
Register Notice identified above, in preparing a final document for OMB review.
Thanks for your consideration; please call me if any questions, 202-566-0515.
Peter
Peter Gimlin
Environmental Protection Specialist
Fibers and Organics Branch/NPCD/OPPT
U.S. Environmental Protection Agency
tel. 202‐566‐0515, email: gimlin.peter@epa.gov

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Comments of the Utility Solid Waste Activities Group
Polychlorinated Biphenyls (PCBs); Reassessment of Use Authorization; ANPRM
Docket ID No. EPA-HQ-OPPT-2009-0757

Attachment 1

Inventory and Cost Estimates for
PCB-Containing Electrical Equipment Owned/Operated by
U.S. Electric Utilities

Prepared on behalf of the
Utility So lid Waste Activities Group

Prepared by
ENVIRON International Corporation
Arlington, Virginia

August 18,2010

CONTENTS
1.0 INTRODUCTION ....................................................................................... ... ........... 1
2.0 PREVIOUS STUDIES AND DATA RESOURCES .............................................. 2
2. 1 Previous Inventory Estimates ................................................................................. 2
2.1.1
RPC Inventory Estimates (1981) ....................................... ......................... 2
2.1.2
EPRI Inventory Estimates (1989) ................ ....................... ...... .... ... ........... 3
Other Inventory Estimates and Related Data Resources ............. ......... ...... 4
2.1.3
2.2 Previous Cost Estimates ................................................. ......................................... 5

3.0 METHODOLOGy .................................................................................. ................. 6
3.1 Estimating the Current Inventory of PCB-Containing Equipment ................ ......... 6
3.1.1
Mineral Oil Transformers ................................. ... ............... ........................ 6
3.1.2
Askarel Transformers ... .. ..................................... ...................................... .. 7
3.1.3
Large PCB Capacitors .. ........ ... .. .............. ......................... .. ... ..................... 8
3.1.4
Other Types of Equipment That May Contain PCBs ........ ......................... 8
3.2 Estimating the Cost to Identify Remaining PCB-Containing Equipment .............. 9

4.0 RESULTS .......................... .... ............ .............. .... ...................... ...... ........ ....... ......... 1 I
4.1 Estimates of the Current Inventory of PCB-Containing Equipment ....................
4. 1.1
Mineral Oil Transformers ................................. ... .. ...................................
4.1 .2
Askarel Transformers .. ....................................................... ..................... ..
4.1.3
Large PCB Capacitors ........................... ...................................................
4.1.4
Other Types of Equipment That May Contain PCBs ........... ......... .... .......
4.2 Estimates of the Cost to Identify Remaining PCB-Containing Equipment. .. .......
5.0 SUMMARY AND CONCLUSIONS ..................................... .... ...... ......................

TABLE
TABLE 1:

Inventory Estimates for PCB-Containing Electrical Equipment
Owned/Operated by U.S. Electric Utilities

FIGURE 1:

Changes in Equipment Inventories Since 1981

11
II
12
13
13
14
15

Inventory and Cost Estimates for
PCB-Containing Electrical Equipment Owned/Operated
by U.S. Electric Utilities

1.0 INTRODUCTION
ENVIRON International Corporation (ENVIRON) was retained by Venable LLP
(Venable) in April 2010 to provide technical support for the Utility Solid Waste
Activities Group (USW AG) in responding to a recent Advanced Notice of Proposed
Rule-Making (ANPRM) published by the U.S. Environmental Protection Agency (EPA).
The ANPRM (published on April 7, 2010 at 75 Fed. Reg. 17645) is titled
"Polychlorinated Biphenyls (PCBs); Reassessment of Use Authorizations." The specific
tasks USW AG asked ENVIRON to address include:

I. Updating earlier estimates of the inventory (number of units) of PCBcontaining equipment in use by electric utilities in the U.S.
2. Updating earlier estimates of the cost of identifYing all PCB-containing
electrical equipment currently in use by electric utilities in the U.S.

This report describes ENVIRON's work on these tasks. Previous studies and data
resources are discussed in Section 2; the methods used in developing the current
estimates are described in Section 3; and the resulting estimates are discussed in Section
4. Section 5 provides a summary of the report and our conclusions.

-1-

2.0 PREVIOUS STUDIES AND DATA RESOURCES
ENVIRON reviewed previous studies related to estimation of the inventory of electrical
equipment in use by U.S. electric utilities and the cost to identify the PCB-containing
portion of this inventory. The phrase "PCB-containing" as used in this report means
having a PCB concentration of 50 parts per million (ppm) PCB or greater. The most
useful and relevant studies are discussed in the following subsections.

2.1 Previous Inventory Estimates
2.1.1

RPC Inventory Estimates (1981)

The most detailed of the previous inventory documents reviewed by ENVIRON was
prepared by Resource Planning Corporation (RPC) for USWAG, the Edison Electric
Institute (EEl), and the National Rural Electric Cooperative Association (NRECA). The
RPC report was submitted to EPA in February 1982.

RPC conducted a survey of the 100 largest electric utilities in the U.S . and received
responses from 98 of the 100 subjects. The results of the survey were projected to the
entire industry; the RPC report indicates that the responding subjects accounted for
approximately 70 percent of the total inventory for all U.S. electric utilities. The
questionnaire used in the survey was developed to collect information on a number of
topics, including the following:

•

A "census count" of various types of PCB and oil-filled equipment

•

The frequency of leaks and releases from such equipment

•

The feasibility of inspection and maintenance programs

•

The feasibility and likely costs of mandatory phase-out programs for transformers
and capacitors

-2-

The RPC report provides separate inventory estimates for the number of units of each of
the following types of equipment owned by U.S. electric utilities in 1981:

•

askarel transformers

•

mineral oil transformers

•

large PCB capacitors

•
•

oil-filled voltage regulators

•

oil-filled reclosers

•

oil-filled switches

•

oil-fill ed/askarel electromagnets

oil-filled circuit breakers

The 1982 RPC report also classifies the total number of units of each type of equipment
by PCB content in three concentration ranges: less than 50 ppm, greater or equal to 50
ppm but less than 500 ppm, and 500 ppm or greater. Under regulations established by
EPA, equipment containing PCBs at greater or equal to 50 ppm but less than 500 ppm is
referred to as "PCB-contaminated" equipment, and equipment containing PCBs at 500
ppm or greater is referred to as "PCB" equipment. The RPC inventory estimates for
1981 are reproduced in Table 1 of this ENVIRON report. One of the reports included in
the reference list (EPRI 1989) states "The data contained in Table I were specifically
cited by EPA, along with other study findings, as the basis for the final 1982 PCB
regulations."

2.1.2

EPRI Inventory Estimates (1989)

The 1981 RPC inventory estimates were updated in 1989 on behalf of the Electric Power
Research Institute (EPRI). The updated inventory estimates were prepared for EPRI by
RPC as a subcontractor to General Electric (GE) and presented in an EPRI report
published in 1989. The updated estimates were derived by adjusting the 1981 RPC
estimates to account for the addition and retirement of the following types of equipment:

-3-

•

askarel transformers

•

mineral oil transformers

•

large PCB capacitors

As in the 1982 RPC report, the 1988 inventory classifies these types of equipment
according to three ranges of PCB content. Unlike the 1982 RPC report, the 1988
inventory includes estimates for just three types of equipment (askarel transformers,
mineral oil transformers, and large PCB capacitors). The 1988 inventory estimates for
the electric utilities industry are used to derive estimates for non-utility US industries in
the 1989 EPRI report.

RPC's 1988 estimates for the electric utility industry were developed using average
annual rates of addition and retirement based on data obtained primarily from forms
submitted annually to the Federal Energy Regulatory Commission (FERC) by 49 large
electric utilities from 1982-1987. The data from the FERC forms suggest that while
transformers were retired from service at an average rate of approximately 2.1 percent
per year, the number of transformers added by the electric utility industry was
approximately four percent per year over this period. These rates suggest that the total
number of transformers used in the electric utility industry increased at an average rate of
1.9% per year from 1982 to 1987.

2.1.3

Other Inventory Estimates and Related Data Resources

Additional information re lated to the inventory of equipment owned by U.S. electric
utilities was found in a number of sources. A 1985 EPRI publication notes and explains
some adjustments to the 1981 RPC estimates. The EPA publications listed as references
in this ENVIRON report provide inventory estimates for some types of equipment in use
in all or selected parts of US industry in 1982, 1988, 1994, and 2007. Additional
information was obtained from EPA's PCB Transformer registration database and PCB
activity database. In addition, recent inventory information for some individual electric
utilities was obtained from USW AG members.

-4-

2.2 Previous Cost Estimates
Previous estimates of the cost of identifying all PCB-containing equipment used by U.S.
electric utilities for purposes of a phase-out were obtained from the 1982 RPC report. As
summarized in Table 7 of that report, RPC's estimate of the cost to identify all mineral
oil transformers with PCB levels of 500 ppm or greater is $6.1 billion, and the cost to
identify all mineral oil equipment with PCB levels greater than 50 ppm is $6.4 billion.
Details provided in Appendix A of the 1982 RPC report indicate that the second estimate
($6.4 billion) includes the first estimate ($6.1 billion), and that these estimates are based
on average costs for inspecting and testing distribution system, substation, and generating
equipment.

-5-

3.0 METHODOLOGY
3.1 Estimating the Current Inventory of PCB-Containing Equipment
The current inventory ofPCB-containi,ng equipment used by electric utilities in the U.S.
was estimated by extrapolating from the earlier studies performed by RPC. The 198 I
RPC inventory took nearly a year to complete and required the commitment of
substantial resources by many utilities and organizations. Preparation of a similar
survey-based inventory in response to the 20 I 0 ANPRM was not feasible given the time
constraints associated with responding to the ANPRM in a timely manner. The methods
used to develop current inventory estimates for various types of PCB-containing
equipment in use by U.S. electric utilities are described below.

3.1.1

Mineral Oil Transformers

To extrapolate from the 198 I and 1988 RPC estimates for mineral oil transformers to the
current time, ENVIRON used the following assumptions:

•

No new PCB-containing units were added to the inventory after 198 I.

•

All pre- I 982 units are retired at a constant annual rate of 424,772 units per year
(this rate is equal to 2. I percent of the 198 I inventory).

•

All pre- 1982 units are retired at the same relative rate regardless of PCB content;
the 1981 inventory estimates indicate that 10.7% ofpre-1982 units are PCBcontaminated (i.e" containing;::: 50 ppm PCBs but < 500 ppm PCBs) and 1.09%
ofpre- 1982 units are PCB (i. e., containing;::: 500 ppm PCBs).

•

The total number of mineral oil transformers in service has grown by 1.9% each
year.

•

The total retirement rate for all units (pre- I 982 and post- 1982 combined) is 2. I %
of inventory each year.

-6-

In addition to estimating the number of mineral oil transformers classified as PCB and
PCB-contaminated, ENVIRON estimated the total number of these units in the U.S.
electric utility industry to provide a basis for estimating the percentages of PCBcontaining mineral oil transformers relative to all mineral oil transformers in service. To
do this, we used the 1.9% average annual growth rate for the total number of mineral oil
transformers suggested by the RPC studies reported in the 1989 EPRI report. This
resulted in an inventory estimate of approximately 34.3 million mineral oil transformers
currently in service in the U.S. electric utility industry. This estimate is believed to be
very conservative given the significant increase in the size of utility transmission and
distribution systems since the 1980s due to accelerated industry growth and greater
emphasis on service reliability.

3.1.2

Askarel Transformers

ENVIRON used the following assumptions for estimating the current inventory of
askarel transformers:

•

No new askarel units were added after the 1981 inventory.

•

The high rate of retirement of askarel units from distribution systems suggested
by figures in the 1989 EPRI report (2,163 units or 9.6% of 1981 inventory per
year on average) continued until all virtually all readily-identified askarel
transformers had been removed from these systems in the 1990s.

•

On average, 357 pre-1982 units are retired from other (non-distribution ') systems
each year (this number is 2.1 % of the askarel units in non-distribution systems
inventory in 1981).

-7-

The 1989 EPRI report indicates that askarel transformers were removed from distribution
systems on an accelerated basis in the 1980s and 1990s, and that some utilities also
removed askarel equipment from other systems on an accelerated basis during this
period . USWAG publications listed in the references section of this ENVIRON report
document efforts by members to reduce the amount of PCB-containing equipment in their
systems.

3.1.3

Large PCB Capacitors

ENVIRON used the following assumptions to estimate the current inventory of large
PCB capacitors from the earlier inventory estimates:

•

No new PCB units were added after the 1981 inventory.

•

Most identified large PCB capacitors were removed from electric utility
distribution systems by 1988.

•

On average, 51 ,755 units (3.3% of the units in the 1981 inventory) are retired
from non-distribution systems each year.

To estimate the total current inventory of large capacitors, ENVIRON assumed that the
ratio ofthe number of large capacitors to the number of mineral oil transformers in use
by electric uti lities has not changed significantly since the 1981 inventory.

3.1.4

Other Types of Equipment That May Contain PCBs

Figures provided in the 1982 RPC report indicate that some oil-filled voltage regulators,
circuit breakers, and switches may contain PCBs at levels

of~

50 ppm. Oil-filled

reclosers and electromagnets are also addressed in the 1982 RPC report but PCBcontaining units were not identified for these types of equipment. According to the 1981
I As used in Appendix A of the 1989 EPRI report, the term "non-distribution" appears to mean _
all equipment used by electric utilities except the distribution system equipment. This would
consist primarily of equipment used in generation and transmission systems.

-8-

inventory, the total number of units of other types of equipment that may contain PCBs is
less than four percent of the total inventory of mineral oil transformers. The 1989 EPRI
report does not provide inventory data or retirement rates for these types of equipment.

ENVIRON estimated the current inventory of PCB-containing oil-filled voltage
regulators, circuit breakers, and switches using the following assumptions:

•

No new PCB-containing units were added after the J 98 J inventory.

•

All pre- J 982 units are retired at a constant annual rate equal to 2. J % of the J 98 J
inventory.

•

All pre- 1982 units are retired at the same relative rate regardless of PCB content.

•

The total number of each type of equipment in service has grown by 1.9% each
year.

•

The total retirement rate for all units (pre- 1982 and post- J 982 combined) is 2. J%
of inventory each year.

The assumed rates of inventory growth and retirement match those used to develop the
current inventory estimate for mineral oil transformers, so current inventory estimates for
voltage regulators, circuit breakers, and switches were derived by applying the ratios
observed in the 198 I inventory to the current estimate for mineral oil transformers.

3.2 Estimating the Cost to Identify Remaining PCB-Containing Equipment
The current cost to identify the remaining PCB-containing equipment in use by U.S.
electric utilities is estimated from data provided by USWAG members. Thirty four
USWAG members provided an estimate of the total cost to identify all PCB-containing
equipment in their respective systems. Collectively, these 34 members account for

-9-

approximately 59% of total retail sales of electricity in the U.S. The sum of the cost
estimates provided by these members was divided by this percentage to obtain a cost
estimate for the entire U.S. utility industry.

-\ 0-

4.0 RESULTS
4.1 Estimates of the Current Inventory of PCB-Containing Equipment
ENVIRON's estimates of the current inventory of PCB-containing equipment in use by
U.S. electric utilities are provided in Table 1 and discussed below. Changes since 1981
in the total inventory of the types of oil-filled equipment addressed in this report and in
the percentages of PCB and PCB-containing equipment in use by the U.S. electric utility
industry are illustrated in Figure 1.

4.1.1

Mineral Oil Transformers

One of ENVIRON's primary tasks was to update the earlier inventories for PCBcontaining equipment. The estimates in Table 1 indicate that the number of mineral oil
transformers with PCB levels of ~ 500 ppm was reduced from approximately 220,000 in
1981 to about 90,000 by 20 I O. The number of mineral oil transformers containing

ppm PCBs but < 500 ppm PCBs was reduced from almost 2.2 million in 1981 to less than
900,000 by 2010. In both cases, the current estimate is only 41 % of the 1981 estimate;
this reflects the retirement of almost 59 percent of the PCB-containing transformers that
were in use in 1981.

All of the current inventory estimates for PCB-containing equipment are based on the
assumption that no PCB-containing transformers were added to service after 1981, so
there should be no PCB-containing mineral oil transformers still in service when the
remaining pre-1982 PCB-containing equipment is retired. At the assumed rate of
retirement, all of the remaining PCB -containing mineral oil transformers should be
retired from service in approximately twenty years, or by 2030.

ENVIRON also estimated the current inventory for the total number of all mineral oil
transformers (both PCB-containing and other) currently in use by the U.S. electric utility

-11-

industry. The estimates in Table 1 indicate that the total number of such transformers has
grown from approximately 20.2 million in 1981 to approximately 34.3 million in 2010.
The annual rates of addition and retirement used in this estimate are based on values
reported in the 1989 EPRI report, including an average net growth rate of 1.9% per year.

Relevant data obtained from other sources were used to evaluate the current estimates in
Table 1. EPA data indicate that the total number of PCB Transformers (i. e., units
containing

500 ppm PCBs) disposed of from 1991 to 2007 is 232,647. This total

includes both askarel and mineral oil PCB Transformers from all U.S. industry (not just
utilities). The current estimates in Table 1 are based on retirement rates that suggest that
approximately 78,500 mineral oil PCB Transformers and 11,400 askarel PCB
Transformers were retired from 1991 to 2007. These figures cannot be compared to the
EPA figure without adjusting for the portion of the total U.S. inventory owned by the
electric utility industry. According to the 1989 EPRI report, electric utilities owned
approximately 72% of mineral oil transformers and approximately 30% of askarel
transformers in the 1980s. Adjusting the assumed electric utility retirement rates for
these percentages results in estimates of approximately 109,000 mineral oil PCB
Transformers and 38,000 askarel PCB Transformers retired by all U.S. industries from
1991 to 2007. The sum of these estimates is approximately 147,000 units, which is only
about 63% of EPA's disposal figures. This comparison suggests that the actual rate of
retirement of PCB Transformers from 1991 to 2007 was substantially higher than the
rates used to generate the current inventory estimates in Table 1. Therefore, the current
inventory estimates in Table 1 for PCB Transformers (both mineral oil and askarel units)
may be substantially greater than the actual numbers of such units still in service.

4.1.2

Askarel Transformers

The estimates in Table 1 indicate that the number of askarel transformers in use by
electric utilities has been reduced from almost 40,000 units in 1981 to about 7,000 units
in 2010. These figures indicate that less than 18 percent of the askarel transformers in

-12-

use in 1981 are still in service. At the rate of retirement assumed for other electric utility
transformers, all of the remaining askarel transformers will be retired by 2030.

4.1.3

Large PCB Capacitors

The 1989 EPRI report indicates that approximately 44% of the large PCB capacitors
owned by electric utilities in 1981 were used in distribution systems, and that the average
service life of these capacitors was 30 years. The estimates in Table 1, which were
derived from these numbers, indicate that the number of large PCB capacitors used by
electric utilities has been reduced by more than 95% (from approximately 2.8 million in
1981 to about 120,000 in 2010). At the assumed rate of retirement, almost all of the
remaining large PCB capacitors should be retired by 201 3. The EPA disposal data
suggest that the actual rate of retirement of these units from 1991 -2007 was substantially
less than suggested by the model used to derive the current estimate in Table 1. This
difference may be due to aggressive industry efforts to remove PCB equipment prior to
the 1991-2007 time period; some util ities that removed all or nearly all large PCB
capacitors from their distribution systems in the 1980s may have also substantially
reduced their use of such units in other systems by 1991 . Aggressive efforts to remove
PCB-containing equipment have been undertaken by a number of large utilities, as
documented by USWAG publications.

4.1.4

Other Types of Equipment That May Contain PCBs

Table 1 includes current inventory estimates for oil-filled voltage regulators, circuit
breakers, and switches because the 1981 RPC inventory indicated that some of these
units contained PCBs at 500 ppm or greater. Estimates are not provided for oil-filled
rec losers or electromagnets because PCB-containing units of these types were not
reported in the earlier inventory. In addition to the types addressed in the 1981 RPC
inventory, some units of other types of equipment may contain PCBs (e.g., bushings, oilfilled cable, potential transformers, current transformers, coupling capacitors and other
types of metering equipment). These types of potential PCB-containing equipment are
not considered in ENVIRON's inventory estimates because we have not found

-13-

information that would allow us to estimate or characterize the inventory of PCBcontaining units of these types.

The current estimates in Table 1 were generated using a constant annual retirement rate
equal to 2.1 % of the 1981 inventory, regard less of PCB level. The resulting estimates
indicate that the inventory of PCB-containing units of each type was reduced by
approximately 59% from 1981 to 2010. At the assumed rate of retirement, nearly all of
the remaining PCB-containing equipment of these types will be retired by 2030.

4.2 Estimates of the Cost to Identify Remaining PCB-Containing Equipment
As explained in Section 3.2 of this report, the cost to identify all remaining PCBcontaining equipment in use by U.S. electric utilities was estimated from data provided
by USWAG members. Each of34 members provided an estimate of the cost to identify
the PCB-containing equipment remaining in their own system. The total cost for these 34
estimates is more than $1 2.3 billion. The 34 members account for almost 59% of tota l
U.S . retail electricity sales. Thus, when the $ 12.3 billion in costs for this 59% is
extrapolated to the entire U.S. electric utility industry, the industry-wide cost for
identifying all remaining PCB-containing equipment in service is nearly $21 billion.

Additional estimates provided by the 34 members indicate that approximately 12.6
million units would be tested in this effort, which suggests that the average cost to
identify a PCB-containing unit by testing is approximately $980. This average can be
compared to the average of $303 per unit reported by RPC in 1982. Over 29 years (from
1981 to 2010), inflation at 3% per year would raise the 1981 estimate from $303 to about
$714. The additional difference between the 1981 average and the 2010 average is likely
due to increases in the cost of service interruptions and more stringent environmental,
health and safety measures .

-14-

5.0 SUMMARY AND CONCLUSIONS
This report provides ENVIRON's estimates of the current inventory of PCB-containing
equipment in use by U.S. electric utilities and explains the methods used to generate
these estimates. Estimation of the cost of identifying the remaining PCB equipment is
also addressed. ENVIRON used information obtained from a number of earlier studies
and other sources to derive the estimates. The current inventory estimates were derived
by extrapolating from earlier estimates developed by RPC for 1981 and 1988. The cost
of identifying the remaining PCB-containing equipment was estimated from 2010 values
provided by 34 USWAG members that account for approximately 59% of retail
electricity sales in the U.S.

The primary findings of this report are as follows:

•

The amount of PCB-containing equipment in use by U.S. electric utilities has
been reduced by approximately 78% since the last comprehensive inventory
estimates were compiled in 1981.

•

The PCB-containing equipment that is still in use constitutes a very small
proportion (less than three percent) of all oil-filled electrical equipment in use by
these utilities.

•

The retirement rates used to derive the current inventory estimates suggest that
virtually all of the remaining PCB-containing equipment will be removed from
service within the next 20 years (by 2030).

•

Identification of the remaining PCB-containing equipment is expected to cost at
least $20 billion.

-15-

REFERENCES
Electric Power Research Institute (EPRI) 1985 . PCB Disposal Manual, CS-4098. Palo
Alto, CA. June.
Electric Power Research Institute (EPRI) 1989. PCB Residues in Transformer
Carcasses, EL-6237. Palo Alto, CA. August.
Electric Power Research Institute (EPRI) 2000. The PCB Information Manual, Volume
2: PCB Releases and Regulatory Issues. Palo Alto, CA. September.
Resource Planning Corporation (RPC) 1982. Comments and Studies on the Use of
Polychlorinated Biphenyls in Response to an Order of the United States Court of
Appealsfor the District of Columbia Circuit, volume III. Washington, DC.
February 12.
U.S. Environmental Protection Agency (EPA) 1976. PCBs in the United States
Industrial Use and Environmental Distribution, EPA 560/6-76-005 . Office of
Toxic Substances, Washington, DC. February 25.
U.S. Environmental Protection Agency (EPA) 1977. Microeconomic Impacts of the
Proposed "PCB Ban Regulation ", EPA 56016-77-035. Office of Pesticide and
Toxic Substances, Washington, DC.
U.S. Environmental Protection Agency (EPA) 1985. Project Summary: Assessment of
PCDDs and PCDFs from PCB Transformer and Capacitor Fires, EPA/600/S2851036. Hazardous Waste Engineering Research Laboratory, Cincinnati, OH.
May.
U.S. Environmental Protection Agency (EPA) 1987. Locating and Estimating Air
Emissions from Sources of Polychlorinated Biphenyls (PCB), EPA-450/4-84007n. Office of Air and Radiation, Research Triangle Park, NC. May.

-16-

U.S. Environmental Protection Agency (EPA) 1998. Draft Paper on PCBs in the United
States, Great Lakes Binational Toxics Strategy Stakeholder Forum. Chicago, IL.
March 23 . http://www.epa.gov/glnpo/bnsdocs/stakeholder98/pcbinus.htm
U.S. Environmental Protection Agency (EPA) 2009. Great Lakes Binational Toxics
Strategy 2008-2009 Biennial Progress Report. December.
U.S. Environmental Protection Agency (EPA) 2010. Polychlorinated Biphenyls (PCBs),'
Reassessment of Use Authorizations, ANPRM. Federal Register (75 Fed. Reg.
17645). April 7.
U.S. Environmental Protection Agency (EPA) undated. PCB Transformer Registration
Database (January 2008) and PCB Activity Reports. Accessed at
http://www.epa.gov/epawaste/hazard/tsd/pcbs/pubs/data.htm
U.S. Environmental Protection Agency (EPA) undated. Compilation of Total Annual
PCB Large Capacitors and Total PCB Transformers Disposed in the United
States From Annual Reports from Commercial PCB Disposal Companies from
1991-2007.
Utility Solid Waste Activities Group (USWAG) 2005. Promoting the Voluntary PhaseDown of PCB-Containing Equipment. Washington, DC. October.
Utility Solid Waste Activities Group (USWAG) 2006. Member Company PCB
Reduction Efforts, 2006 Update. Washington, DC .

-17-

TABLE

TABLE 1
Inventory Estimates for PCB-Containing Electrical Equipment
Owned/Operated by U.S. Electric Utilities
1981-1982
inventory
20,227 ,248
2,166 ,159
219 ,918
10.7%
1.09%

2009-2010
inventory
34,262,098
892,458
90,606
2.6%
0.26%

39 ,640

7,004

2,800,619

119,207

total oil-filled voltage regulators
units with 50-500 ppm PCBs
units with >500 ppm PCBs

145,159
17,854
2,468

245,879
7,357
1,017

total oil-filled circuit breakers
units with 50-500 ppm PCBs
units with >500 ppm PCBs

180,939
3,256
0

306,485
1,341
0

385,768
54,007
0
20 ,266 ,888
2,166,159
259 ,558
10.7%
1.28%

653,436
22,251
0
34 ,269,102
892,458
97 ,610
2.6%
0.28%

23,779 ,373
5,303,921
2,241,276
3,062 ,645
22 .3%
9.43%
12.9%

40,251,391
1,141,241
923,407
217,834
2.8%
2.3%
0.54%

equipment category
total mineral oil-filled transformers
units with 50-500 ppm PCBs
units with >500 ppm PCBs
percentage of total with 50-500 ppm PCBs
percentage of total with >500 ppm PCBs
total askarel transformers (all >500 ppm PCBs)
total large PCB capacitors (all >500 ppm PCBs)

total oil-filled switches
units with 50-500 ppm PCBs
units with >500 ppm PCBs
totals for all transformers (mineral oil and askarel)
units with 50-500 ppm PCBs
units with >500 ppm PCBs
percentage of total with 50-500 ppm PCBs
percentage of total with >500 ppm PCBs
totals for all listed types of equipment*
total units, all types, regardless of PCB content**
total units with >50 ppm PCBs
total units with 50-500 ppm PCBs
total units with >500 ppm PCBs
percentage of total with >50 ppm PCBs
percentage of total with 50-500 p~m PCBs
percentage of total with >500 ppm PCBs

* This table lists only the types of equipment for which PCB-containing units were identified in the 1981 RPC
inventory. The total number of oil-filled units of all types in use by the U.S . electric utility industry is substantially
higher than the total for the equipment types listed in this table.
** The numbers of large capacitors (4,743,853), voltage regulators (245,879) , circuit breakers (306,485), and
switches (653,436) included in the 2009-2010 total units estimate were calculated to maintain a constant ratio for
each type of equipment to the number of mineral oil transformers. The 2009-2010 total also includes 39,640
transformers representing the pre-1982 askarel units still in use and their replacements .

FIGURE

FIGURE 1: CHANGES IN EQUIPMENT INVENTORIES SINCE 1981

._---------'- --- - '------

45,000,000

40,000,000

35 ,000,000

30,000,000

,I--------'--------~---------

~-- -------------------~-------::::::;o;o-~-----~--______j

1 - - - - - - --

--1,

0-- -------=-_ =::...-- --------'-_-___________

§ 25,000,000 I- -__:;;;;;oo-~=-------------

..
CI>

E 20,000,000 1----- - - -- - - - - -- - - --------:::I

15,000,000

---J

I------~

10,000,000

----1

5,000,000

~~~~*~~~~~~~w~~~~~~~~~~~~~~~~~

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
year

File Type	application/pdf
Author	Pgimlin
File Modified	2018-11-05
File Created	2018-11-05