In response to an EPA proposal to ban all detectible trace of PCBs in all natural gas systems, AGA filed extensive comments demonstrating there is no need to change current practices, which work well to protect people and the environment. There is no justification for EPA’s contemplated phase out and elimination of the PCB use authorizations for natural gas systems. Further, it would be physically impossible to completely eliminate all trace of PCBs from natural gas systems. Any attempt to do so would cost hundreds of billions of dollars, cause severe disruptions in natural gas service to homes, businesses, hospitals, schools, industry and government, and increase rather than decrease risks to human health, safety and the environment. AGA strongly opposes the proposal to phase out and eliminate the PCB use authorizations for natural gas systems.
Instead, we recommend that EPA work with stakeholders to revise Part 761 to focus the rule on what we believe is EPA’s main concern – to manage and reduce the occurrence of oily liquid condensates in distribution systems to keep them from moving PCBs beyond the customer meter. This would allow both EPA and the regulated community to focus scarce resources on measures that have been shown to be effective.