i- at-oo · respondent filed ils proposed restructuring plan on oetol)cr 1, 1999. 1 sent my formal...

13
Testimony of Kenneth C. Springirth BEFORE THE I'ENNSYLANIA PUBUC U l LITY COMMISSION I- at-oo n e Slalemenl/M - £ ^ ERIE, PA HEARING January 25, 2000 Docket ti R-00994785 Purpose o f my testimony is to get meaningful changes in the National Fuel Gas Distribution Corporation (Respondent) customer choice plan. On June 22, 1999, the Natural Gas Choice and Competition Acl was signed into law to give Pennsylvania's natural gas customers choice in the provider of their natural gas supply services. The Respondent filed ils proposed restructuring plan on Oetol)cr 1, 1999. 1 sent my formal complaint daled November 15, 1999 requesting that the unbundling of gas service does not result in rales which are above the current bundled rale, and thai the plan be implemented in a manner understandable lo consumers. Under cuslomcr choice customers can purchase their natural gas from a differenl company, and their present natural gas utility company delivers it lo the customer. Customer choice to IK successful must overcome the following: 1. If a custonier anlicipates no bcnelils, there would be no reason to switch. 2. Customers may become so confused that they decide to not change. 3. Onerous rcquircmenis by llie Rcspoudcnl may decrease lhe number of suppliers. The Respondent should not be permitted lo charge cuslomers $104,000 for a system wide cuslomer education plan as noted in Exhibit 2 Schedule 1 pg. 1. Respondent admits on Exhibit #2 Schedule //I pg. I, "Distribution can only raise awareness about supplier choice and how to shop inlclligenlly." A simple one page spread sheet providing specific^ '^fX^ information from suppliers would make il possible for customers lo make an intelligent <9 ^ S\ i ... . . . . I . i i. . . . . . ... . i ...... i.. •... O. A 4? choice. Customers should not need a Icxl book lo understand customer choice. Customers arc more likely to participate in customer choice when they expect lo receive higher net benerus. The spread sheet listing suppliers should eonlain the following questions: 1. Are you a licensed supplier? 2. Your rates including all fees and taxes? 3. Length of agreement? 4. Is the price fixed, or wilt it change peviodieally? 5. Is the conlract renewed aulomalically or is il subject to rcucgocialion? 6. How much notice is needed lo cancel conlract? 7. Is there a penalty for canceling before the lime is up? 8. Is there a penally for switching suppliers? 9. Any incentives or bonuses? 10. Is there 1 bill or 2 separate bills (I from supplier & 1 from Respondent)? 11. How much notice is given for a rale change? 12. Mow much notice is given if supplier discontinues service? V0 4 m o m -<: I TO' 'HZ rn cz CD GO ro T: It is import early termin switch their natural gas supplier. lant that residential customers nol l>c subject to any minimum scrw(ftJ«rin of / £ / / j * ination penalties. No switching fee should be charged to customers ^^^J^^p

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Page 1: I- at-oo · Respondent filed ils proposed restructuring plan on Oetol)cr 1, 1999. 1 sent my formal complaint daled November 15, 1999 requesting that the unbundling of gas service

Testimony of Kenneth C. Springirth BEFORE THE I'ENNSYLANIA PUBUC U l LITY COMMISSION

I- at-oo

n e Slalemenl/M - £ ^

ERIE, PA HEARING January 25, 2000 Docket ti R-00994785

Purpose of my testimony is to get meaningful changes in the National Fuel Gas Distribution Corporation (Respondent) customer choice plan. On June 22, 1999, the Natural Gas Choice and Competition Acl was signed into law to give Pennsylvania's natural gas customers choice in the provider of their natural gas supply services. The Respondent filed ils proposed restructuring plan on Oetol)cr 1, 1999. 1 sent my formal complaint daled November 15, 1999 requesting that the unbundling of gas service does not result in rales which are above the current bundled rale, and thai the plan be implemented in a manner understandable lo consumers.

Under cuslomcr choice customers can purchase their natural gas from a differenl company, and their present natural gas utility company delivers it lo the customer. Customer choice to I K successful must overcome the following: 1. I f a custonier anlicipates no bcnelils, there would be no reason to switch. 2. Customers may become so confused that they decide to not change. 3. Onerous rcquircmenis by llie Rcspoudcnl may decrease lhe number of suppliers.

The Respondent should not be permitted lo charge cuslomers $104,000 for a system wide cuslomer education plan as noted in Exhibit 2 Schedule 1 pg. 1. Respondent admits on Exhibit #2 Schedule / / I pg. I , "Distribution can only raise awareness about supplier choice and how to shop inlclligenlly." A simple one page spread sheet providing specific^ ' ^ f X ^ information from suppliers would make il possible for customers lo make an intelligent <9 ^ S\

i . . . . . . . I . i i. . . . . . ... . i ...... i.. •... O . A

4?

choice. Customers should not need a Icxl book lo understand customer choice. Customers arc more likely to participate in customer choice when they expect lo receive higher net benerus. The spread sheet listing suppliers should eonlain the following questions:

1. Are you a licensed supplier? 2. Your rates including all fees and taxes? 3. Length of agreement? 4. Is the price fixed, or wilt it change peviodieally? 5. Is the conlract renewed aulomalically or is il subject to rcucgocialion? 6. How much notice is needed lo cancel conlract? 7. Is there a penalty for canceling before the lime is up? 8. Is there a penally for switching suppliers? 9. Any incentives or bonuses? 10. Is there 1 bill or 2 separate bills ( I from supplier & 1 from Respondent)? 11. How much notice is given for a rale change? 12. Mow much notice is given if supplier discontinues service?

V0 4

m o m

-<:

I

TO' 'HZ

rn

cz

CD

GO

ro

T:

It is import early termin switch their natural gas supplier.

lant that residential customers nol l>c subject to any minimum scrw(ftJ«rin of / £ / / j * ination penalties. No switching fee should be charged to customers ^ ^ ^ J ^ ^ p

Page 2: I- at-oo · Respondent filed ils proposed restructuring plan on Oetol)cr 1, 1999. 1 sent my formal complaint daled November 15, 1999 requesting that the unbundling of gas service

The PUC needs to develop a number of guidelines to promote a vibrant and competitive natural gas market for all classes of customers.

1. Establish a shopping credit that will encourage shopping and attract competitors to the natural gas marketplace. Only meaningful shopping credits will encourage consumers to shop.

2. Competitors should have access to lhe resources needed to serve the market. Interstate pipeline and storage resources, which are uo longer needed by the Respondent, should l>e offered to their suppliers. However, suppliers should not be forced lo take interstate pipeline and storage resources that are ofTcred by lhe Respondent if they arc able to make other more economic arrangements.

3. There should be no switching fees. Customers who choose a supplier, and (hen later return to the Respondent or pick another supplier should nol have to pay any penalty.

4. Customers should receive clear, easy lo understand infonnation. In order lo shop inlclligenlly, customers must be able to understand the unbundled rate informalion contained on the hill, and must he able to easily ascertain their shopping credit, or price to compare against offers by third party suppliers.

5. Steps should be taken to attract local suppliers and encourage local production, because local gas is cheaper than out of stale gas.

The overall goals should be to:

1. Create viable compeiilive market with lower rales for customers.

2. Establish structure thai encourages broadest possible customer choice.

3. Maintain basic utility service at reasonable rales for all classes of cuslomers.

4. Ensure that all natural gas customers share the benefils of competition.

5. Maintain existing supply reliability anil effective consumer protection.

6. Encourage development of robust marketplace attracting competitors.

There is an urgent need for a successful customer choice program, Ijccausc the Respondent's residential customers have seen a 581% increase in natural gas rates from $.97/Mcf in 1973 to $6.61/Mcf as of January I , 2000 which is alxmt 2 times the increase in the consumer price index for that period. Cuslomcr choice does not guarantee customer savings, but designing a plan to attract suppliers, encouraging the use of lower cost local gas, and achieving meaningful compel il ion should provide opportunities for consumers lo save money.

Page 3: I- at-oo · Respondent filed ils proposed restructuring plan on Oetol)cr 1, 1999. 1 sent my formal complaint daled November 15, 1999 requesting that the unbundling of gas service

SUPPLIER COMPARISON CHART FOR RESIT)EXTLAL CUSTOMERS Suppiier Nrame (These are the list ot" licensed suppliers rrom the PL'C) obtained by calling 1-888-732-3223. GPU Energy number is 1-888-478-2300. At this time PG Energy Power Plus is not taking any new residential customers but call 1-3SS-699-7587 to check their status.

Allegheny Enerev

DTE Edison America Inc.

Green Mountain Energy Resources

Touchstone Energy-American Cooperative Services. Inc.

Exelon Energy Subsidiarv of PECO

People's Plus Pitisbursh

First Energy 1-888-254-9:27 Ptim Power 1-300-964-5568 aiHIiated co. both New Castle

Power Choice Allentown

Price in cents per K.WH (Make sure this includes transmission cost to GPU Service territory and applicable taxes; tor the panicuiar system you have (such as gas heat & gas water heater, gas heat & electric water heater, or all electric). GPU PRICE TO COMPARE 4.52S CENTS/KVVH

4.26 e 3.4 i 5.04 c

ccjaiuan

4.213 t Gas 4.29 c

5.83 c Environblcr.d

4.35 £ Ojslieat

4.23 e Doesn't cover all electric home

4.2 e

7.10 C S'jmrss Cioics

4.508 C.M\ Eleiiric home

4.00 e

Leninh of agreement ! Ocen ended \ Ocen ended | No coimac: j Up ;o 12/31/99 | Lrp-oreb:cot } Up » May 2000 | i year Ocen ended

Is contract be renewed automaticaiiv or is it subject to renegociation? I Not sure No contract i Net sure ! No contract ! Reneacciauon i Ves Ves No contract

Will the price stay the same for entire time"? Till \lav 2000 12 Momhs 1 vear I L'oto 12/31;99 Ves Ves Ves j year suarantee

Kow much notice is needed to cancel contract0 30 davs . No notice No notice aavs 30 davs 30 davs

Is there a oenaltv for cancelimz before time Is UD? No No No ! No No

Is there a cenaitv for switchins suooiiers? No ; No No i No No

I 30 days -Ant I nciicc

Same dav

No [ No i No No No No

Does rate varv on usaue? No No No No No No No No

Does rate varv during the dav? No No No No i No No No I No j Anv restrictions on how much electricitv is used and when it is used'? I No i No No ! No No No i No No

Are there anv other fees such as demand charges, service charges. membershio fees, or termination tees':

SiO.OO/monih charge for secarate bill

5::.oo/-cntii rr.ernbershiD :o--* crSIZO.CO/vr.

No j No No No No S9.99 monthly service charae

Will a soecial meter be needed & if so is there a charge for that meter? j No i No No ! No ! No i No • No ! Ves

No

Will there be estimated bills'1 Ves ! Yes Yes I Yes i Yes Yes ! Yes

Is there I bill or will there be 2 bills (separate bill for generation) I bill 2 bills 2 bills biil I or 2 bills octicn

i I bill i I or 2 bills 2 bills

Anv incentives or bonuses'? i No ; S25 towards l " I month's bill

$25 towards l " month's biil

No No No ! No Lock rate for 3 vears

Company phone number 1-8^-232-4042 [ 1-300-250-2371 l-8S3-2Jo--i7jO i 1-877-567-2667 i-300-301-3:00 I i-300-56 -5380 | '-388-254-9227 j 1-338-285-9153 | j !-SC0-964-<;:63 I

Customer service hours ' M-F Sam^pm i M-F 3a:n-9pm SAT lOarr. cm SAT iOrur. pm

Daily 7am-12 midnight

M-F 8am-5cm M-F Sam- M-F 7am-7cni

hours/day ever/dav

/pm S A l 9am-2cm M-F 830am iom

_ i

How much notice is given for a rate change? 90 davs I Month 2 Months 90 davs 90 days accrox.

I 2 months 90 davs Not sure

How much notice is siven if sucoiier discontinues service? Not Known I Not known | Not known I Not known i Not :<™w"- 1 Not sure 1 90 davs j Not sure

Konneth C. Springirth telephoned each supplier on S/19y99. but dees not aramee or Castomcrs arc rcsconsibie for contacting suppliers fceforc making any decision.

.varrant this informaucn in anv wav and is not iiabie tor any errors it may contain. This iniormaiicn may change at any time without notice.

Page 4: I- at-oo · Respondent filed ils proposed restructuring plan on Oetol)cr 1, 1999. 1 sent my formal complaint daled November 15, 1999 requesting that the unbundling of gas service

2,

3

/. fog TMC IM Soviet- flG?e£iWr W S^^LI. /JGGperG/ir/oM rp/Hnfovxr,*)

<:osr rc^r/nc/jnwH OF 20 for, ITATII TO ^£ a</9P6£D

JELETFER T O VOL. | E x i n t o T " Z . S c M \ > 0 i € A 3 rc. ^ ' JTAA-^rJ T u g

pfFfR To VOL. I fxi^&T ^2. Scnn^u T /6^. * ^ r / ) , L

THE PROTF^TCD cosrs or cusToAtff!. fia.L»wc; Sv«rrt-7>i; C^-r^fP.

c y/Mrtr rsn-PS" win- fet" r/Ovarj To /fMcouP/)6f Sufrugps ro

Page 5: I- at-oo · Respondent filed ils proposed restructuring plan on Oetol)cr 1, 1999. 1 sent my formal complaint daled November 15, 1999 requesting that the unbundling of gas service

R I G H T W A Y S T O G I T TMI M O S T O U T O F Y O U R H E A T I N G S Y S T I M

1 Get a system lune-up done by a qualified technician • usually a worthwhile invesfntent at $50 fo J150 . Heat pumps should be tuned every three y e a n , gas Furnaces and bo i len should be tuned every two yean , and oil units should be tuned every year.

3 Turn off tfie pilot light during the summer on

gas and propane systems. Tfib wi l l save about $2 to $4 a month. Efectronlc ignitions can be retrofitted to replace pilot lights on natural gas units.

3 Vacuum or change the air filter on womvair furnaces and heat pumps. Filters should be vacuumed or changed every month during the heating season. Reusable filters that last a year or two can be bought for about $5.

4 Vacuum out warm air registers and base­board radiators. Also make sure they are not blocked by furniture, carpets, or curtains.

5 Seal and insulate heating ducts. See "Insulation" on page 10 for tips on saving money by sealing air ducts.

6 Insulate supply and return pipes on steam and hot water boilers. Use high temperature foam of fiberglass insulation.

7 Install rgflectors behind hot water radiators. You can make reflectors out of aluminum foil and cardboard or buy them at a building supply jtare.

8 Bleed trapped air From hot water radiators. Trapped air reduces the efficiency of hot-wa­ter radiators. To release the air, buy a valve key at cj hardware store. Slowly open the valve on the side of the radiator until only water runs out.

electronic thermostat, available at hardware stores for S25 to $150, will do this for you au­tomatically.

Gas area heaters In some well-insu­lated homes, high-ef­ficiency propane or natural gas space heaters can satisfy all heating requirements. The most efficient and safest models draw combustion air from the outside and also exhaust to the exte­rior. Look for passive systems that do not require electricity to run fans. Expect to pay about $400 to $500 for models which pro­duce between 4,000 and 10,000 Btu/hour. enough to heat a room or home up to 2.000 square feet. Think about "task" heating— like task lighting— only heat when and where you are!

THS TAfilf SHOWS TVC IELAJ1VE COS15 Of OfElAnNG DtfTEKNT HCAIMG AND COOW4G

SYSTEMS. COSTS AK ESIWAIH) NMKMU. AVEtAGCS. ACTUAL COSES WU WCT VWH flja

PUCES, QJMATE, AND HOUSING CONSmjCDON. F YOU HAVE WEB ACCESS, YOU MAY USE AN

LNTEZACDVE PROGtAM CAUED THE HCMfE ENBK*Y SAVEI TO EST1MAIE tCAIMG, COOUNG. AM) V M B

tCAflNG COSTS FOt HOUSES Of D H B B a CONSTRUCTION IN VAJTflNG REGIONS. TIB CAN t f i f YOU ESnMAIE COST SAHNGS FROM tMROVEMBITS TO tOUt OWN HOME rfTTP-V/EANOEJ&OOV/CSV

C O S T S O f H I A T I N G A N D C O O U N G S Y S T E M S

svsiEMme MSWUnCM ooo aosrmu

and high-flfl A /C. $7,200 $746

Standard gas himoce and ikxidard A/C

$5,775 $901

Advancad ground-lourcs net* pump

$9,250 $682

Advancad air-souro hoot pump

$8,940 $822

Standard air-sourcs heat pump

$ V 1 5 $1,232

Advancod oil Fumoca and high-«fF A/C

$6,515 $1,266

BedricaJ mistancs heat and itandord A/C

$5,515 .

4-$1769

Adapiad bam Ridwrd Hmdm «f <J, 1995, p. 96. Rodty Mountain btdte^,

Buying a new heaiiri" sy.sk rn When buying a new heating system, make sure that your heating contractor carefully explains to you the calculations used to size your system. Weatherization and insulation may allow you to downsize your fumace or boiler.

Tf you have the opportunity to switch to a cheaper heating fuel when buying a new system, look into it. The long-term cost sav­ings may be significant. If the fuel switch also requires that you replace the whole dis­tribution system, make sure to factor thi

0

a n

CO

CO

1 • I

ccr-

cost in when you are making your dectsi if you use electric resistance heating, live a mild climate, and also use air cur.diucm'- j ing, look into switching to an air-source heat pump, ff you have access to natural yas. consider an advanced (condensing-type) furnace.

Page 6: I- at-oo · Respondent filed ils proposed restructuring plan on Oetol)cr 1, 1999. 1 sent my formal complaint daled November 15, 1999 requesting that the unbundling of gas service

of the needed hot water during the summer and less durtng the winter. T>pically ihey pro­vide a year-long average of 60 to 80 percent of the total water heating toad. Simple batch water heaters can be made for a few hundred dollars using an old water heater stripped of its insulation and painted black. When in­stalled outdoors in a sunny location, the batch water heater acts as an integrated col­lecting surface and water storage tank.

Solar hot water systems use different methods to circulate water through the cot-lector. Active solar water heaters use pumps to move water through the solar collector back to a storage tank. Passive systems use a stor­age tank located above the collector surface and natural thermosiphoning to circulate the water. Thermosiphoning takes advantage of the fact that heated water is less dense than cool water. The heated, lowdensity water rises from the collector through pipes to the top of the storage tank where it displaces cool, higher density water. The system will con­tinue to cycle as long as additional heat is available from the sun. Passive systems are usually more reliable than active systems and do not require energy to run a pump. How­ever, a passive system may require mounting the storage tank on the roof to be above the collector, which is not always possible.

Solar water heating systems usually in­clude a backup heating system for use on cloudy days. An existing water heater or an on-demand gas heater can be used for this purpose. During cold spells, water inside the collector must be kept from freezing.The sys­tem can either be drained during freezing weather, or an anti-freeze can be added to the circulating water. In and-freeze systems, the water supply is kept separate from the circulating fluid and is heated using a heat exchanger.

Much has been learned in the last twenty years about making reliable solar water heat­ing systems. Talk to local installers when buy­ing a solar water heating system or making your own so that you will not repeat the same mistakes.

Buying a water healer May away from, electric water heating if at all possible. With conventional systems, heating

HorwAxa

CCtD WATER

with gas costs half as much as heating with electricity. Heating with propane will cost more than natural gas but will still be cheaper than electric heat. If you already have an electric tank heater, conservation and insulation is the way to go. Another al­ternative to an electric tank heater is an elec­tric heat pump water heater. These are simi­lar to the heat pumps discussed in "Heating Systems," except some or all of the heat used for space heating is used to heat water.

fHERMOSW

SOLA* HOT WATER SYSTIM. FLAT PIATC SOLAR COLLECTORS, GRCULAHNG PUMP. SENSOS CIRCUIT. AND HOT WATER STORAGE TANK WTTW A HEAT EXCHANGE LOOP.

AOAfTB) FtOM AN

UUSTMIION IN *OMLVA:(

COSTS FOR WATER HEATING

CCSI

Pourw xiar $3,000 $30 to $80

Cafii^Ajnal gen U 5 0 $140

Sodnc hoot pump $1,200 $140

Proper* system U50 $230

Oil-fired free standing $1,100 $2X

Cortvtftiiooal declnc $450 $390

Auixnai 40 gpd of hot water h r a tomily of Fouc Cott or* appranmate, induda indalafian, and a u i M tfiol u t i% hocdnjp» ara cfraady preart. Paunv M k r water floating cash auomn A d lygtm i i uiod to dilplaca 80% d convanfonal ga> or eWtxi ty Kacrting. Adopted (ram A l u W ry;* ond John Morrill. Consumar Gui'do W Home Energy Sovi'ngj. im ad.. 1995, p. 143.

American Council an Ere-ny-E".;ienl Eeonomv. Waihirigion. 0C

Page 7: I- at-oo · Respondent filed ils proposed restructuring plan on Oetol)cr 1, 1999. 1 sent my formal complaint daled November 15, 1999 requesting that the unbundling of gas service

Cleveland Live News 3 / 7 / 9 9 1:30 PM

mytyMp Officials to meet Mentor residents ~ ™ r affected by leak

Thursday, March 04,1999

By THOMAS OTT PLAIN DEALER REPORTER

MENTOR - The rupturing of a natural gas line and release of carcinogen-tainted oil mist left city officials with a lot to talk about.

They will meet today with Easton Leasing Co., the sewer construction contractor that broke the gas line, to make sure it does not happen agaii* They also will huddle with representatives of East Ohio Gas Co., which drew scorn from the city engineer and police chief for failure to warn about the possibility of pofychlorinated biphenyl, a cancer-causing chemical, in its system.

And at 6:30 tonight, they will meet in City Council chambers with residents of a stretch of Johnnycake Ridge Rd. that was dosed to traffic for two days by the cleanup. Representatives of the Ohio Environmental Protection Agency and of East Ohio Gas will answer questions.

The road, closed from Garfield Rd. west to Plaza Blvd. after the line broke about 9:40 a.m. Monday, was reopened about 2 p.m. yesterday. Tests showed no lingering health threat

"Ifs all clear," said Reginald A. Brown, an emergency response specialist for the Ohio EPA. "We can document that we are below the regulatory limit for PCB contamination."

East Ohio Gas hired Great Lakes Response Inc. of Wil lough by for the cleanup. Gas company spokesman Jeff Zidonts said the cost had not been determined.

The road was washed twice and soil containing three times the level triggering a mandatory cleanup was removed.

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East Ohio paid to wash John and Diane Dixon's house and driveway and will remove additional soil from the lawn because of an oil sheen, but their PCB readings were safe, Brown said. No PCB was detected elsewhere in the area.

East Ohio offered to put up six families at a motel, but most stayed in their homes. Dixon, who accepted the offer, returned uneasily yesterday.

"I do not know that my family is going to be safe in my house,'

h t t p : / / w w w . c l e v e l a n d . c o m / n e w s / p d n e w s / m e t r o / c 3 p c b s 0 4 . s s f Page 1 of 2

Page 8: I- at-oo · Respondent filed ils proposed restructuring plan on Oetol)cr 1, 1999. 1 sent my formal complaint daled November 15, 1999 requesting that the unbundling of gas service

Cleveland Live News saio uix two gran that

<Jwno nas an y-year-oia son at no me, anaf lhsf t i lacnildren, ages 2 and 1. "1 am very concerned at>

3/7/99 1:30 PM ea oy

atxjLrt

Residents of about 20 houses on the closed stretch of Ohio 84 came and went in a minivan rented by Great Lakes Response and manned by firefighters.

"It was a fair amount of traffic" Deputy Fire Chief Thomas C. Talcott said. "Citizens were great They were real cooperative, real understanding."

Retirees William and Margaret Monasky took the inconvenience well.

They went without mail and newspapers for two days, and their garbage sat at the curbside. But their gas stayed on, and parking at Fairfax Manor apartments behind their property allowed freedom of movement.

"We're not the kind of bugs to sit," Margaret Monasky said.

tt has been more than 20 years since Congress banned production and use of PCBs, which served as a lubricant in electrical equipment. But they remain in circulation and may be found in oil that is a byproduct of natural gas. East Ohio said the PCBs in the gas line came from connections with suppliers.

PCBs pose no health risk when pipelines are undisturbed, according to East Ohio. Zidonis said PCBs are rarely in East Ohio's gas supply, but City Engineer John W. Konrad said the city will not take chances when gas lines break in the future.

"If there is oil present, we are going to expect that tests are done to verify whether PCB is there," he said.

01999 THE PLAIN DEALER. Used with permission.

Discuss this topic in Water Cooler | Chat live with others

© 1999 Cleveland Live. All rights reserved. Please read and understand our Online User Agreement and Prjyac.y.

Policy.

h t t p : / / w w w . c l e v e l a n d . c o m / n e w s / p d n e w s / m e t r o / c 3 p c b s 0 4 . s s f

Page 9: I- at-oo · Respondent filed ils proposed restructuring plan on Oetol)cr 1, 1999. 1 sent my formal complaint daled November 15, 1999 requesting that the unbundling of gas service

4. Dioxin Source Revea le^^ 3 /7 /99 8:21 PK

Dioxin Source Revealed To: Gascape Publications

From: Richard F. Sowinski

RE: As per your request

New Evidence Supports Missing Source of Dioxins and Furans

Following is a summary of our recent findings relating to such an undisclosed and undocumented source of PCDD/Fs entering the environment.

The June 1994 issue of Environmental Science and Technology, page 1797:

"Global deposition of Polychlorinated Dibenzo-p-dioxins and Dibenzofurans is roughly four times greater than annual emissions. More data are needed on emission factors and on introduction rates of PCDD/F to the global atmosphere."

1981 San Francisco Chronicle, August 21 Front Page, news reports continue thru November.

Gas Pipe Rupture Spews PCB Oil - Area Evacuated as reported and is the first public disclosure of PCBs contaminating natural gas pipes.

1986 California voters pass The Safe Water and Toxic Enforcement Act of 1986, commonly referred to as Proposition 65, which requires the Governor to publish a list of chemicals "known to the State to cause cancer, birth defect, or reproductive harm. No warning of PCBs in natural gas is mentioned.

1991 California gas utilities under threat of a suit filed by Natural Resource Defense Council start issuing PROP 65 public warning: Natural gas is contaminated by chemicals known to cause cancer, birth defects and reproductive harm.

1991 Southern Indiana Gas & Electric (SIGECO) Sued by EPA for $14 million for delivery of PCBs into customer's homes. Court documents reveal SIGECO routinely monitors for PCB levels within their gas system, as early as the IQGO's.

http: / /www.gascape.org/ index%20/Dfoxin%20Source%20Revealed.htm! Page 1 of i

Page 10: I- at-oo · Respondent filed ils proposed restructuring plan on Oetol)cr 1, 1999. 1 sent my formal complaint daled November 15, 1999 requesting that the unbundling of gas service

'-Dioxin Source R e v e a l e d ^ ^ 3 / 7 / 9 9 8:21 1992 U.S. PatedB,145,494 issued September 8 •

Background Of The Invention

The danger of polychlorinated biphenyls (PCB's) is well documented. PCBs were used as insulating fluids for processing equipment until banned in 1979. Beheved to cause cancer, liver and skin damage, sterility and brain damage, the compound has a surprising longevity and once within a human's body, does not dissipate and builds a significant body burden as a function of frequency and level of exposure. Gas utility companies introduced PCB's in gas pipe networks to clean out particulates such as rust, dust, moisture or other gas-laden impurities. Gas line compressor stations also used PCB contaminated oil until banned by Congress. While the EPA and various State Agencies are aware of the problem of PCB's in gas lines, they do not think the exposure danger is of sufficient levels, do not monitor PCB's concentration adjacent to a customer's home, business or like and moreover, do not know how to expunge PCB's from the gas line network since the PCB-contained oil is scrub resistent In such situation, I find that surprisingly large PCB concentrations sporadically occur. Sources of such a concentration: dampening effects of the compressor-driven network, multiple customer outlet usage, and maintenance practices that add to aperiodic loading of the natural gas stream coupled with surprising longevity of the in situ PCB's. As a result, PCB's can flow to appliances in the customer's home, business or the like at sufficient levels to be a health hazard, and exceed "Federal and/or State health and safety standards. Moreover, since the original source of the PCB's is in the liquid phase, both gas phase and liquid phases (say attached in aerosol form to gas bom particulates) are combinable and form the final end-use contamination levels at the appliance to be used

1995 University of Pennsylvania Research Reported

First manufactured commercially in 1929, due to their unique chemical and thermal stability, Polychlorinated Biphenyls (PCBs) quickly gained widespread use in a number of industries, including gas and electric. Their use continued for more than four decades before their toxic nature was established. Although their production was banned by die U.S. Congress by the Toxic Substance Control Act CTSCA) of 1976, because of their inherent thermal and chemical stability, they persist in the environment. It fos been established that, due to past use of PCB-based oil as lubricants in compressors in thousands of gas compressor stations across the country, PCBs entered the natural gas transmission and distribution systems.

What are PCBs?

PCBs refer to a group of aromatic compounds and there are 209 distinct

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i Dioxin Source Revealed 3 / 7 / 9 9 8:21 PCB congenei Pfepending on the number and po4^n of chlorine atoms on the biphenyl. Another subdivision of PCBs is in terms of their degree of chlorination where each group is referred to as a homologue; there are ten homologues of PCBs. The PCB compounds used are known by the trade name of Aroclor in the U.S. and each of these is a mixture of several homologues. Their characterization is therefore very complex; this and their other physico-chemical characteristics makes migration and transport of PCBs very complicated.

What is the problem?

Thousands of miles of gas pipelines are deemed to be contaminated by PCBs. These components may enter the environment through spills and leaks around gas pipelines and compressor stations. In spite of the cessation of use of this product, PCBs have persisted in the pipeline systems, thus necessitating a remediation plan. This plan must be based on a comprehensive understanding of the mechanisms governing the transport and distribution of PCBs in gas pipeline systems. This should be in the form of a predictive computer simulator, since sampling of the entire pipeline system would be cost prohibitive and impractical.

"What is-tbe solution?

It must be emphasized that in gas pipelines, PCBs are being transported in the presence of gas condensates, a multiphase dynamic environment. This makes their migration characterization very challenging. Under the sponsorship of Gas Research Institute, Adewumi and his students and associates are currently studying the migration characteristics of PCBs in gas pipelines using multiphase hydrodynamic approach. The understanding gained from this effort will help devise remediation and preventive strategies that would ensure that these toxic substances do not end up in homes and factories. Research efforts in this area target the development of a predictive model that the gas industry would use in devising operational as well as remediation strategies that would help to resolve this problem.

Some Current Research Results

The current research efforts on this front consist of two main areas, namely phase behavior and hydrodynamics. The focus of the research so far in 1995 is developing PCB clean-up scenarios for natural gas pipelines. One method of clean-up that has been investigated is injecting a solvent into the pipeline to remove the PCB from the pipeline. Several solvents were selected and tested with the computer models. Some of these results are presented below.

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Dioxin Source Revealed^ 3/7/99 8:21 Pf This graph sho^the phase behavior of a natural system contaminated with 1 ppm PCB and with 100 gal/MMSCF of acetone injected into the system. The quality lines show the concentrations of PCB in the liquid phase. (Since PCB exists predominantly in the liquid phase, we consider only PCB concentration in the liquid phase.) The dashed red box represents the "operating region" for a typical pipeline, or in other words, the temperatures and pressures that might be found in a natural gas transmission pipeline.

We are interested in the relative shift in the quality lines effected by the solvent. If we can achieve a shift to the right in the quality lines by adding solvent, then the PCB becomes more concentrated in the liquid. Hence, if the liquid is removed from, ihe pipeline, then more PCB will be also be removed. As you can see from this graph, the quality lines do not shift signiflcandy with a fairly high quantity of acetone added. Next, we will see the effect of another solvent, terpinolene, on the phase behavior of the PCB-natural gas system.

In this graph, one can clearly see that there is a dramatic shift in the quality lines within die operating region. By running the phase behavior model for various solvent injection scenarios, we can determine which solvents would hold more potential for clean-up purposes. Hence, in this part of the research, the phase behavior model serves as a screening tool. Our findings indicate that terpinolene would be the best solvent to test in an actual pipeline.

The hydrodynamic model was used to determine the effect of solvent injection on PCB concentration within a natural gas transmission pipeline. A 12,000-foot pipeline segment was tested with several injection rates of terpinolene. The following results confirm that terpinolene effectively reduces the PCB concentration in the liquid within the pipeline.

The hydrodynamic model was modified to account for the PCB adsorption/'desorption to the pipe wall. The final step is to run the modified hydrodynamic model in order to determine how long it will take to clean the pipeline. The initial PCB distribution in the pipeline was determined from the previous runs of the hydrodynamic model. The graph shown below indicates that at a terpinolene injection rate of 50 gal/MMSCF, the pipeline is effectively cleaned after 4-1/2 hours. The blue curve shows the initial PCB concentration distribution.

What's Next?

The next step in this research project is to go to the field to conduct some tests. Field testing will allow us to validate and tune the multiphase hydrodynamic model. After the model has been validated and appropriately tuned, clean-up protocols can be recommended. We are

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Dioxin Source Revealed ^ ^ 3/7/99 8:21 PY optimistic that proBftn of PCB-coataminated natural p i pipelines will soon be resolved.

Go to Dr. Adewnmi's Faculty Page. Go to Penn State's PNGE Home Page. Go to Penn State's Home Page.

The questions we find intriguing from the above effort - is the use of a "flushing agent"

Why would one attempt to flush the gas mains - while ignoring the consumers pipes and appliances?

The next question, known to one trained in the art Because PCBs are such a persistant chemical, known to stubbornly adhere to any surface it contacts. To completely remove such persistant PCBs from the gas distribution system - would mean replacing the pipes - not cosmetically flushing them out with another chemical additive.

In our opinion, placing a gas filter between the consumer and the supplier would solve the PCB contaminated gas problem.

1996 A new book:

Our Stolen Future

by Theo Colbom, Dianne Dumanoski and John Peterson Myers Are we threatening our fertility, intelligence and survival? A scientific detective story.

1996 Summary of Findings

The natural gas industry has over 1.5 million miles of underground gas pipes containing undisclosed amounts of PCBs. Our research shows this undocumented resivour of PCBs in the nation's gas pipes has been known to the natural gas industry for years.

PCBs residing in said gas pipes, is transported from the gas pipe system into the consumer's gas appliance. Wherein, said PCBs contaminating the gas, enter the appliance flame.

Consumer gas appliances are not designed to incinerate PCBs or any other hazwaste. Thus incomplete combustion occurs at such low consumer gas appliance temperatures - coupled with short residence times for the PCB toxicant. Where incomplete combustion of any PCBs - produces unbumed hydrocarbons (UBHs) byproducts such as Dioxins and Furans.

Herein we report, an undiscovered source of Dioxins and Furans, to wit: http://www.gascape.org/index%20/Dioxin%20Source%20Revealed.html Page 5 of (