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PG&E’s Management ofOil-Filled Electrical Equipment

(OFEE) and Other Materials Containing

Polychlorinated Biphenyls (PCB)

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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

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POLYCHLORINATED BIPHENYLS

Man-made organic chemicals, domestically manufactured beginning in 1929Used in many commercial applications

Insulating properties Stability Non-flammable

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

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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

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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

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

endocrine systems

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PCB Regulations40 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

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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

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PCB Regulatory Information

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Federal and State LevelsPCB in mineral oil (or in any material) :

Federal level TSCA: >50 ppm State level: 5-49 ppm

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Equipment that contains PCB’s

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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

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PGE Policy’s and Emergency Response

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

23Our 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

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PCB Waste Management Requirements

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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

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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.