1 PGEs Management of OilFilled Electrical Equipment OFEE

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1 PG&E’s Management of Oil-Filled Electrical Equipment (OFEE) and Other Materials Containing Polychlorinated Biphenyls

1 PG&E’s Management of Oil-Filled Electrical Equipment (OFEE) and Other Materials Containing Polychlorinated Biphenyls (PCB)

2 PCB’s in Oil Filled Electrical Equipment • Mineral Oil : to insulate, suppress

2 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

3 POLYCHLORINATED BIPHENYLS Man-made organic chemicals, domestically manufactured beginning in 1929 Used in many

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

4 Common Types of PCBs Mineral Oil Dielectric Fluids: §Mineral oil-filled electrical equipment may

4 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

5 Common Types of PCBs Tar/Compound Dielectrics & Potting Agents: • Non-liquid type of

5 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

6 Emerging PCB Issues: § PCB in Schools (New York, Oregon, Massachusetts) suspected at

6 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

7 Potential Health Effects: § Probable Human Carcinogen § Causes cancer Animals § Non-cancer

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

8 PCB Regulations 40 CFR Part 761 = The PCB Mega Rule Subpart A

8 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

9 PCB Prohibitions and Exceptions No persons may use any PCB, or PCB Item

9 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

10 PCB Regulatory Information Oil-Filled Electrical Equipment Polychlorinated Biphynels § Federal and State Definition

10 PCB Regulatory Information Oil-Filled Electrical Equipment Polychlorinated Biphynels § Federal and State Definition § Identification Operating Procedures § § § Emergency Response Level of Clean-up Regulatory Reporting

11 Federal and State Levels PCB in mineral oil (or in any material) :

11 Federal and State Levels PCB in mineral oil (or in any material) : § Federal level TSCA: >50 ppm § State level: 5 -49 ppm

12 Equipment that contains PCB’s

12 Equipment that contains PCB’s

13 Approximate number of PCB containing equipment System Wide PGE has over 1, 000

13 Approximate number of PCB containing equipment System Wide PGE has over 1, 000 pieces of OFEE Of those 1, 000 Pieces approximately 33% are pre-1979 Of those Pieces approximately 3% contain PCB’s > 5 ppm

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21 PGE Policy’s and Emergency Response

21 PGE Policy’s and Emergency Response

22 PG&E Policy and Procedures Our internal policy are reviewed on a regular basis

22 PG&E Policy and Procedures Our internal policy are reviewed on a regular basis to ensure that they meet the TSCA requirements.

Our policies contain information on the following topics: PCB Procedures: § Spill categories §

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 23

24 PCB Waste Management Requirements

24 PCB Waste Management Requirements

25 Federal Requirements: § TSCA – Class 1 TSCA permitted landfill – Waste Management

25 Federal Requirements: § TSCA – Class 1 TSCA permitted landfill – Waste Management Kettleman Hills – Not Accepting § RCRA § Not regulated by RCRA § California § 5 ppm STLC, 50 ppm 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

26 Summary § PG&E started addressing the issue of PCB in 1977 § PCB

26 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 twoyears to all PG&E employees who might be assigned to handle PCB.