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    Xcel Energy Issues Public Comment on EPA Proposed Rule


    January 25, 2022 - Targeted News Service

     

      WASHINGTON, Jan. 25 -- Jeffrey L. West, senior director for environmental services at Xcel Energy Inc., Minneapolis, Minnesota, has issued a public comment on the Environmental Protection Agency proposed rule entitled "Alternate Polychlorinated Biphenyls Extraction Methods and Polychlorinated Biphenyls Cleanup and Disposal Regulations". The comment was written on Jan. 20, 2022, and posted on Jan. 21, 2022:

      * * *

      Xcel Energy submits these comments in response to the United States Environmental Protection Agency's ("EPA") proposed rulemaking to establish alternative PCB extraction methods and amendments to PCB cleanup and disposal regulations.

      Xcel Energy is a major U.S. energy company serving approximately 3.7 million electric customers and 2.1 million natural gas customers in the eight states of Colorado, Michigan, Minnesota, New Mexico, North Dakota, South Dakota, Texas, and Wisconsin. We are a vertically integrated generation, transmission, and distribution owner. Our generation fleet is capable of producing 20,140 megawatts of power from a mix of energy sources including coal, natural gas, nuclear, wind, solar, hydroelectric and biomass.

      Xcel Energy has taken steps to remove from its electric transmission and distribution system any electrical equipment known to contain PCBs at a concentration of 500 ppm or greater. In addition, we have adopted a general policy not to place into service electrical equipment with a known concentration of 50 to 499 ppm except in rare instances when it is necessary to sustain the operation of our distribution system, retrofill is not an available option and no reasonably obtainable alternative is available.

      Xcel Energy has established regional spill response programs to facilitate the prompt clean up and reporting of spills from electrical equipment. Xcel Energy operates three certified laboratories that provide analytical services including the analysis of liquid and solid samples for the presence of PCBs. Each lab maintains industry accreditations and follows all appropriate sampling and analysis protocols and review. As such, we are familiar with the cleanup and disposal requirements, and the laboratory methods identified in EPA's proposal.

      Xcel Energy incorporates by reference herein the comments filed by the Utility Solid Waste Activities Group ("USWAG"). In addition to those comments provided by USWAG, Xcel Energy offers the comment outlined below.

      1. EPA should not remove Ultrasonic Extraction (including Method 3550C) from the PCB Regulations as proposed: Xcel Energy recommends that rather than removing SW-846 Method 3550 as a permissible lab method, EPA should authorize for ongoing use Method 3550C for wipe samples and other similar applications.

      The proposed rules preamble suggests that there is an increased uncertainty when using ultrasonic extraction for difficult matrices, such as caulk and clay materials ('the level of uncertainty raised by these studies causes concerns, especially for difficult to extract media, such as caulk and clay materials'). While this may be the case for these materials, the ultrasonic extraction remains an effective extraction method when applied to the removal of PCBs from the gauze used in a wipe sample. If individual laboratories are not able to meet QA/QC requirements in the matrices they analyze, those individual laboratories should be responsible for reviewing an alternate approved extraction method that is appropriate for more difficult sample matrices.

      Xcel Energy laboratories regularly utilize Method 3550 ultrasonic extraction for wipe samples and do not have difficulty meeting QA/QC requirements in the wipe matrix. The only extraction method that our laboratory currently utilizes for these samples is Method 3550. These wipe samples are processed internally to facilitate rapid sample turn around to support the waste characterization activities required to ensure for the proper disposal of potentially PCB impacted waste streams. Wipe samples are utilized to confirm whether PCBs are present from oil filled electrical equipment when liquid samples are not available, and to characterize gas pipeline and appurtenances for waste disposal. All other nonliquid samples that Xcel Energy collects are sent out to external laboratories for analysis. If the ultrasonic extraction was no longer permissible, our laboratories would need to either completely change their processes associated with analyzing wipe samples or rely exclusively upon external laboratories which may not be able to match the turnaround times that we can accomplish internally.

      EPA has proposed the use of SW-846 Method 8082A as a determinative method in the PCB regulations found in 40 CFR part 271. Method 8082A specifically references Method 3550 as an appropriate extraction procedure for PCB analysis. All methods proposed for addition in 40 CFR 761 are also listed in 8082A as appropriate extraction procedures. The proposed rule states that the proposal to remove EPA Method 3550B is based on 'previous studies arriving at different conclusions regarding the effectiveness of ultrasonic extraction'. However, EPA Method 3550 has not been removed as an acceptable extraction method listed in the most current Method 8082A. Removing ultrasonic extraction from the PCB regulations while it is referenced as an approved method in Method 8082A would create a conflict between the current laboratory methods and the PCB regulations.

      Method 3550 (ultrasonic extraction method) should not be removed from the PCB regulations. Our recommendation is that EPA should authorize for ongoing use Method 3550C for wipe samples and for other similar applications.

      2. Response to solicitation for comments on pre-cleanup notifications for performance-based disposal options (Sec. 761.61(b)(1)): EPA has solicited comments on whether a pre-notification requirement should be established for Sec. 761.61(b)(1). Xcel Energy relies heavily upon the use of the performance-based disposal option currently identified in Sec. 761.61(b), now Sec. 761.61(b)(2) in the proposed rule. This disposal option is preferred over the self-implementing procedure identified in Sec. 761.61(a) specifically because it does not have a pre-cleanup notification requirement. Our experience is that the current performance based disposal option allows Xcel Energy to respond more expediently to site conditions warranting remedial activation. From our perspective, the addition of a pre-cleanup notification in connection with Sec. 761.61(b)(1) would have the same dampening effect as the current pre-cleanup notification has on the utilization of the self-implementing cleanup option.

      In closing, thank you for the opportunity to provide comments on EPA's proposal to establish alternative PCB extraction methods and amendments to PCB cleanup and disposal regulations. Please feel free to contact me if you have any questions at (303) 571-2762 or jeffrey.l.west@xcelenergy.com.

      Sincerely,

      Jeffrey L. West

      Senior Director, Environmental Services

      Xcel Energy Inc.

      * * *

      The proposed rule can be viewed at: https://www.regulations.gov/document/EPA-HQ-OLEM-2021-0556-0001

      TARGETED NEWS SERVICE (founded 2004) features non-partisan 'edited journalism' news briefs and information for news organizations, public policy groups and individuals; as well as 'gathered' public policy information, including news releases, reports, speeches. For more information contact MYRON STRUCK, editor, editor@targetednews.com, Springfield, Virginia; 703/304-1897; https://targetednews.com

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