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Court Rejects Sierra Club’s Challenge to NWP 12 Wetlands Permit (December 30, 2013)
AGA/Coalition Amicus Brief in Wetlands Permitting Case – Mingo Logan v. EPA (December 13, 2013)
AGA Comments on EPA NPDES Electronic Reporting Rule Proposal (October 28, 2013)
AGA Comments on 2014 State Department Climate Action Plan (October 24, 2013)
AGA Opposes DOE’s Use of a new “Social Cost of Carbon” in Appliance Standards Absent Notice and Opportunity to Comment
AGA Comments to the OMB Interagency Steering Group under Executive Order 13604 – Modernizing Natural Gas Permitting (July 31, 2013)
Vapor Intrusion Guidance - AGA Comments Ask EPA to Delete References to Pipelines
AGA Comments on EPA Proposal to Modify Construction Stormwater Discharge Rules (May 31, 2013)
AGA Letter to CEQ Supports PGE Comments on Streamlining Federal and California Environmental Review Process (April 19, 2013)
USWAG-AGA Comments on EPA Draft Guidance for Sampling Non-Liquid PCBs (March 29, 2013)
AGA Comments on EPA 2013 Draft Inventory of Greenhouse Gas Emissions (March 25, 2013)
AGA-USWAG Letter to EPA on PCBs (Feb. 22, 2013)
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 USWAG-AGA Comments on EPA Draft Guidance for Sampling Non-Liquid PCBs (March 29, 2013) 

AGA joined in comments filed by the Utility Solid Waste Activities Group (USWAG) on EPA’s Draft Guidance describing how ship owners and operators should sample PCBs in non-liquids such as paint, caulk and plastics.  While gas and electric utilities usually do not own or operate ships,  the guidance could have much broader implications.  Notably, this appears to be the first time EPA has developed guidance on how to sample non-liquid PCBs, which can appear in a wide range of industrial and commercial products used in buildings and equipment manufactured before 1979, when the manufacture of PCB products was banned pursuant to the Toxic Substances Control Act (TSCA).   The USWAG-AGA comments note that the guidance conflicts in many respects with EPA’s existing PCB regulations, and that the guidance should be revised to be consistent with the regulations.  In particular, EPA should eliminate any suggestion that a ship owner or operator must assume the presence of PCB contamination other than in an export for disposal context.  In addition, EPA should clearly state that there is no such assumption in the domestic disposal context. 


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