PG&E's Management of Oil-Filled Electrical Equipment and PCBs

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 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 commercial applications • Insulating properties • Stability • Non-flammable

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 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 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 effects to the immune, reproductive, endocrine systems

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 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 • Identification • Operating Procedures • Emergency Response • Level of Clean-up • Regulatory Reporting

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

13. 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

21. PGE Policy’s and Emergency Response

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

23. 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

24. PCB Waste Management Requirements

25. 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

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 two- years to all PG&E employees who might be assigned to handle PCB.