Document 5YYJn0rnKdERgdbOY57ROv8D

Montana-Dakota Utilities A Division of MDU Resources Group, Inc. Bismarck, North Dakota Technical Work Plan of the PCB Management Program ENSR Consulting and Engineering January 28,1991 Document Number 3496-004 PCB-ARCH-EXT0371888 3496-004 TECHNICAL WORK PLAN OF THE PCB MANAGEMENT PROGRAM Prepared for MONTANA-DAKOTA UTILITIES A DIVISION OF MDU RESOURCES GROUP, INC. Bismarck, North Dakota Prepared by ENSR CONSULTING AND ENGINEERING Fort Collins, Colorado January 28, 1991 PCB-ARCH-EXT0371889 CONTENTS Page 1.0 INTRODUCTION ......... ............................................................................ ......................1-1 1.1 Purpose ....................................................................................................................... 1-2 1.2 Goal...................................................................................................................... 1-2 1.3 Current Status ......................................... 1-2 1.3.1 Health and Environment................................................................. 1-2 1.3.2 Regulatory Evaluation ............................................................... 1-3 1.3.3 PCS Sampling Program ........................................................ 1-3 1.3.4 Condensate Collection and Handling Program............................... 1-4 1.3.5 Equipment Remediation ............................................................. 1-4 1.3.6 Quality Assurance Project Plan ....................................................................1-4 2.0 SUMMARY OF AVAILABLE DATA ......................................................... .. 2-1 2.1 Sample and Source Characteristics............................................................... 2-1 2.2 Analytical Results by Sample Type ............................................................. 2-1 2.2.1 Grease Gun Analytical Results........................................... ................. .. . 2-1 2.2.2 In-Service Valve Grease Analytical Results........................................ .. . 2-3 2.2.3 Condensate Analytical Results.................................................................... 2-3 2.2.4 Gas Analytical Results........................................................................ 2-3 2.3 Analytical Results by Operating Division.................................................... 2-3 2.3.1 Grease Gun Distribution ........................................................ 2-6 2.3.2 In-Service Valve Grease Distribution........................... 2-7 2.3.3 Condensate Sample Distribution ......................... 2-8 2.3.4 Gas Sample Distribution............................................................. 2-8 2.4 Analytical QA/QC Summary ........................... 2-8 2.4.1 Sampling QA/QC................................................................. 2-9 2.4.2 Analytical QA/QC ......................... .2-9 2.5 Discussion of Analytical Results........................................ 2-10 3.0 CONDENSATE HANDLING PROGRAM .................................................... .............. 3-1 3.1 Condensate Collection Program ............................................................................. 3-1 3.1.1 Compliance Monitoring ......................................... 3-2 3.1.2 Recordkeeping .................................................................... 3-3 4.0 EQUIPMENT MANAGEMENT .................... 4-1 4.1 Equipment Handling and Storage Plan .................................................................. 4-1 3496-004 jj January 1991 PCB-ARCH-EXT0371890 CONTENTS (Cont'd) Page 4.2 Equipment Classification........................................................ .4-2 4.2.1 Valves .................................. 4-2 4.2.1.1 Used Lubricated Plug Valves .................................................. 4-2 4.2.1.2 New Lubricated Plug Valves.................................................. .. 4-2 4.2.2 Meters and Regulators ......... .......................................................... 4-3 4.2.3 Hydraulic Grease Guns.............................................................................4-3 4.2.4 Pipe Classification .................. ................. ...............................................4-3 4.2.4.1 Removed Pipe in Existing Stockpiles......................... .............4-3 4.2.4.2 Pipe to be Removed or Abandoned in Place . ....................... 4-4 4.3 Equipment Cleaning Program .................................................................................. 4-6 4.4 Equipment Disposal Program ........................ 4-6 5.0 DISTRIBUTION SYSTEMS EVALUATION....................................................................5-1 5.1 Work Plan Development........ .............. 5-1 6.0 REFERENCES..................................................................................... ........................ .6-1 APPENDIX A - HEALTH AND ENVIRONMENT........................................................ .. A-1 APPENDIX B - MDU PCB ANALYTICAL DATABASE ................ .. ..................................... B-1 APPENDIX C - DIVISION MAP ........................................................................... ............... .. . C-1 3496-004 jjj January 1991 PCB-ARCH-EXT0371891 LIST OF TABLES Page 2-1 MDU Results for All Sample Types Analyzed for PCBs ............. .. 2-2 2-2 Analytical Results for All Sample Types by Operating Division................................. 2-4 3496-004 j\/ January 1991 PCB-ARCH-EXT0371892 LIST OF FIGURES Page 4-1 Pipe Handling Procedure ............................................................................................. 4-5 3496-004 \j January 1991 PCB-ARCH-EXT0371893 1.0 INTRODUCTION Montana-Dakota Utilities Co. (MDU), a Division of MDU Resources Group Inc., is a local distribution company which provides retail natural gas and electric service to 251 communities in Montana, North Dakota, South Dakota and Wyoming. The company's numerous gas distribution systems serve 175,000 customers with a peak natural gas load of approximately 304,488 Mcf per day. MDU's natural gas supplies are either purchased from or transported through Williston Basin Interstate Pipeline Company (WBI), a wholly-owned subsidiary of MDU Resources Group Inc. As a result of national attention regarding existing or potential PCB problems within the gas industry, WBI developed an ongoing PCB testing program to insure that its systems were continuing to operate free of PCBs. This routine monitoring program indicated the presence of PCB concentrations, predominantly Arochlor 1268, above 50 parts per million in liquids collected from one segment of the WBI pipeline facilities. Because WBI and MDU are part of the same corporate family and were not segregated into different operating entities until 1985, MDU was notified. Since notification, MDU and WBI have undertaken an extensive sampling program to further define the nature and extent of the PCB presence. MDU and WBI determined that certain valves purchased from Rockwell International, were likely delivered from the factory containing a sealant which contained PCBs as Arochlor 1268. The use and presence of Arochlor 1268 is relatively uncommon as compared to species used in the paper and electrical industries. After further investigation, it was also determined that some of the maintenance sealant purchased from Rockwell was of the same formulation. The sealant is a semi-solid petroleum based lubricant. Lubrication is essential for proper operation of Rockwell plug valves, and sealant must be replaced when depleted from valve surfaces due to conditions of temperature, pressure and frequency of operation. Rockwell sealants designated as Lubricant 860 and 991 contain high levels of Arochlor 1268. Under normal distribution system operating conditions, PCBs will not migrate from the sealant to areas beyond the valves. However, when a valve is exposed to natural gas condensates, the dissolution of the sealant may occur allowing the PCBs to migrate with the condensate. MDU has determined that discrete portions of some of its systems exhibit the presence of PCBs as a result of this process. 3498-004 1-1 January 1991 PCB-ARCH-EXT0371894 MDU has initiated a program to assess the extent of PCBs in its distribution systems for the purpose of preparing and implementing a remediation program. This technical work plan outlines MDU's approach to management of the PCBs. 1.1 Purpose The purpose of this work plan is to provide a description of the methods and procedures to be followed in conducting PCB management activities for the MDU facilities. This work plan includes: a summary of available data; a description of the condensate handling program; a description of the equipment handling program; and an approach to evaluate distribution systems. This work plan also delineates the necessary supporting documents to assure the quality of information to be obtained, along with the health and safety requirements of those implementing this work plan. 1.2 Goal It is the goal of MDU to contain, reduce or eliminate PCBs from all MDU distribution systems in a technically sound and cost effective manner while complying with applicable laws and regulations. 1.3 Current Status MDU has established a program to assure the orderly progress to meet the above goal, and activities are currently underway to prevent PCB exposure to workers, the public and the environment. 1.3.1 Health and Environment The safety of the public and the distribution systems employees is important to MDU. MDU has evaluated the potential risks of PCB exposure to the public, the distribution systems employees, and the environment. The evaluation included internal operational and sampling information, as well as data from a U.S. Environmental Protection Agency (EPA) study of pipeline contamination in the northeastern United States (EPA 1984). Based on this evaluation, a risk assessment is not necessary. This evaluation is attached in Appendix A. 3496-004 1-2 January 1991 PCB-ARCH-EXT0371895 MDU has had an active PCB management program for its electric operations since the 1970's. This program has provided for the systematic removal of PCBs from electric system equipment, and includes worker training, proper storage procedures, inspections, and reporting. Because of this program, MDU has considerable experience regarding the appropriate handling and disposal of PCBs. After the discovery of PCBs in the gas distribution systems, information on handling PCBs in gas line liquids was added to the company's Hazard Communication Program. MDU has conducted worker safety training programs for gas personnel who may be exposed to PCBs in handling condensate, meters, removed pipe, or valve grease. This program is designed to ensure that personal protective equipment is utilized when potential PCB exposure exists. Additionally, MDU has provided specific written guidance to employees on the procedures to be followed in situations where PCB exposure is possible. This guidance provides basic information on the nature and characteristics of PCBs along with procedures for controlling potential migration routes from distribution system facilities. 1.3.2 Regulatory Evaluation MDU has conducted an evaluation of all relevant regulatory requirements related to the use and handling of PCB containing fluid, equipment, and materials. This work plan complies with pertinent requirements for: cleaning, disposal, labeling, transportation, and storage. 1.3.3 PCB Sampling Program In establishing a database for work plan development, MDU has collected and analyzed samples of materials for PCBs. This database includes samples of condensate and grease from ail natural gas distribution operating divisions. Natural gas samples were collected from one division where PCBs had been identified in condensate. A summary of this information is provided in Section 2.0. 3496-004 1-3 January 1991 PCB-ARCH-EXT0371896 1.3.4 Condensate Collection and Handling Program Since PCBs are generally only mobile when contained in natural gas condensates, MDU has instituted a program to ensure the proper collection, handling, and/or disposal of such condensates. 1.3.5 Equipment Remediation As an alternative to disposal, MDU is investigating a program to remove PCBs from affected distribution systems equipment taken out of service. MDU is currently evaluating the most efficient and cost effective techniques for the removal of PCBs from valves, meters, pipes, and fittings. This approach will assure that reuse of such equipment will not reintroduce PCBs into distribution system facilities. 1.3.6 Quality Assurance Project Plan The QAPP will be applied throughout the entire sampling and analysis program and will include the following QA/QC procedures: 1) sample collection, handling, and preservation; 2) laboratory analyses; 3) data validation, management, and interpretation. Specific activities will include: data quality objectives, glassware preparation, sampling equipment preparation, surface soil, valve grease sampling, condensate sampling, field documentation, PCB analytical procedures, and applicable QA/QC procedures (i.e., surrogate compounds, precision, accuracy, completeness and documentation). Standard operating procedures (SOPs) are currently in place for many of the sampling and analysis procedures used by MDU and WBI. Procedures and methods not having a specific SOP will be identified, and SOPs will be prepared accordingly. 3496-004 1-4 January 1991 PCB-ARCH-EXT0371897 2.0 SUMMARY OF AVAILABLE DATA MDU has analyzed samples for the presence of PCBs from various locations throughout the MDU distribution systems. The following subsections provide a description of the sample and source characteristics, the analytical results, analytical methods, and data evaluation. 2.1 Sample and Source Characteristics The samples have been categorized into three sample types. A description of the sample types and respective sources is provided below: Grease. This is a semi-solid petroleum lubricant/sealant used in lubricated plug valves in the natural gas distribution systems. Samples of grease have been collected from two primary sources: 1) grease from in-service valves located at regulator stations, meter settings, and various points in the distribution systems; and 2) grease guns used to service the valves. Condensate. This is the hydrocarbon liquid product which separates from natural gas as a result of temperature and pressure changes within the distribution pipelines. This may also include oily liquids, water, glycol, and alcohol in varying amounts. Condensate samples have been collected from meters, gas/condensate separation equipment (e.g., drips, scrubbers, knockouts), and from condensate storage equipment. Gas. This is the natural gas transported as product throughout the MDU systems. Natural gas consists primarily of methane with minor amounts of ethane, propane, butane, and higher hydrocarbons. Gas samples were collected from utilization points. 2.2 Analytical Results by Sample Type A summary of the analytical results are presented by sample type in Table 2-1. A complete printout of the analytical database is presented in Appendix B. The analytical results of each sample type are discussed below. 2.2.1 Grease Gun Analytical Results A total of 41 samples of grease were collected from hydraulic grease guns and analyzed for the presence of PCBs. Of these, 30 grease samples contained less than 2 ppm PCBs. An 3496-004 2-1 January 1991 PCB-ARCH-EXT0371898 TABLE 2-1 MDU Results for All Sample Types Analyzed for PCBs Sample Type Grease Grease Guns In-Service Valves Condensate Gas (Orbo Tube) Number of Samples Total Number of Samples Samples <DL Analyzed (ppm)(1> *DL and <50 (ppm) 50-499 (ppm) *500 (ppm) 41 30 5 3 3 87 54 22 5 6 25 12 8 5 0 2 2 0 0 0 TOTAL (1)DL - Detection Limit. 98 35 13 9 2-2 PCB-ARCH-EXT0371899 additional five grease samples contained between 2 and 50 ppm PCBs. Three grease gun samples contained concentrations between 50 and 499 ppm PCBs, and three samples contained concentrations greater than 500 ppm PCBs. The predominant species of PCBs has been identified as Arochlor 1268. Minor amounts of Arochlors 1242,1254, and 1260 are also present. 2.2.2 In-Service Valve Grease Analytical Results A total of 87 samples of grease were collected from in-service valves and analyzed for the presence of PCBs. Fifty-four of these samples contained concentrations of less than 2 ppm PCBs, and an additional 22 valve samples contained concentrations between 2 and 50 ppm. Five samples contained PCB concentrations between 50 and 499 ppm, and six samples contained concentrations above 500 ppm. The predominant species of PCBs has been identified as Arochlor 1268. Minor amounts of Arochlor 1242, 1254, and 1260 are also present. 2.2.3 Condensate Analytical Results A total of 25 samples of natural gas condensate were collected and analyzed for the presence of PCBs. Twelve of these 25 samples contained concentrations of PCBs less than 2 ppm PCBs. Eight samples contained between 2 and 50 ppm PCBs, and five samples contained con centrations between 50 and 499 ppm. No condensate samples contained concentrations above 500 ppm PCBs. Again, the predominant species of PCBs has been identified as Arochlor 1268. Minor amounts of Arochlor 1242, 1254, and 1260 are also present. 2.2.4 Gas Analytical Results A total of two gas samples were collected and analyzed for the presence of PCBs. Neither of these samples contained quantifiable amounts of PCBs. Gas samples are identified as "OrboTube" in the analytical database. 2.3 Analytical Results by Operating Division The MDU gas distribution systems are divided into seven operating divisions. These divisions include the Billings, Black Hills (Rapid City), Glendive, Williston, Minot, Dickinson, and Bismarck divisions and are depicted on the division map provided in Appendix C. An eighth division, Mobridge, is also shown on the map. This division is excluded from the following discussion because operations are limited to electrical utilities. A summary of analytical results by operating division is provided in Table 2-2. The following subsections provide details for samples that have been analyzed. 3496-004 2-3 January 1991 PCB-ARCH-EXT0371900 TABLE 2-2 Analytical Results for All Sample Types by Operating Division Division Total Number of Samples Analyzed <DL (ppm)(1) Number of Samples *DL and <50 50-499 (ppm) (Ppm) *500 (ppm) Grease Guns Billings Bismarck Black Hills Dickinson Glendive Minot Williston Total 4 4 5 1 16 14 4 2 2 1 4 3 6 5 41 30 0 0 0 0 2 2 2 0 0 1 1 0 1(2) 0 0 1(2) 0 0 0 0 1 5 3 Valve Grease Billings Bismarck 14 8 4 18 13 3(2) Black Hills 6 4 1 Dickinson 11 8 2 Glendive 12 8 1 Minot 17 9 7 Williston 9 5 3 Total WSSKMiSmiiiiiiiiiii 21 0 2 1 1 1 0 0 1 2 1 0 1 1 0 5 6 2-4 PCB-ARCH-EXT0371901 Division TABLE 2-2 (CONTINUED) Total Number of Samples Analyzed ? 3 0A : Number of Samples *DLand <50 50-499 (ppm) (ppm) *500 (ppm) Condensate Billings 2 2 Bismarck 10 4 Black Hills 4 3 Dickinson 3 1 Glendive 2 1 Minot 4 1 Total lllll:" ; 25 12 0 0 0 3 3 0 1 0 0 1 1 0 0 1 0 3 0 0 8 5 0 Gas Bismarck Total 2 2 0 0 0 2 2 . , V.y 0 ..... 0 0 (1)DL = Detection Limit (2)Samples exhibited <2 ppm PCBs. 2-5 PCB-ARCH-EXT0371902 2.3.1 Grease Gun Distribution Grease guns sampled as part of this program consisted of guns located at the time of sampling in each of MDU's seven operating divisions. A total of 41 grease samples collected and analyzed from grease guns are included in this Work Plan. Duplicate samples were collected from each grease gun and only the highest value for each is included in the database. All of MDU's grease guns have been sampled. Analytical results of grease samples taken from four grease guns in the Billings division indicated RGB concentrations of less than 2 ppm. A total of five grease guns were sampled from the Bismarck division. Two of these samples contained PGBs in excess of 500 ppm. Two other samples contained PCBs in concentrations between 50 and 499 ppm. The remaining sample contained less than 2 ppm PCBs. Analytical results of grease samples taken from 16 grease guns in the Black Hills division indicate that all of the samples contained PCBs below 50 ppm. Fourteen of these samples contained less than 2 ppm PCBs. One of the four grease samples collected from grease guns in the Dickinson division contained PCBs between 50 and 499 ppm. One sample contained 11 ppm PCBs, while the remaining two samples contained less than 2 ppm PCBs. Two grease guns were sampled in the Glendive division. Both samples contained less than 2 ppm PCBs. Grease samples from four grease guns in the Minot division were collected and analyzed for the presence of PCBs. All four samples contained less than 2 ppm PCBs. A total of six grease guns from the Williston division were sampled and analyzed for the presence of PCBs. Analytical results indicate the PCB concentration of one sample was in excess of 500 ppm. The remaining five samples contained less than 2 ppm PCBs. 3496-004 2-6 January 1991 PCB-ARCH-EXT0371903 2.3.2 In-Service Valve Grease Distribution Valve grease was analyzed from 87 in-service valves located at various points throughout the distribution systems. Samples were collected from each of the seven operating divisions. Of the 14 valve grease samples taken from the Billings division, two samples contained PCBs in concentrations above 500 ppm. Twelve samples exhibited PCB levels less than 50 ppm, with eight of these samples containing less than 2 ppm PCBs. A total of 18 grease samples were collected from in-service valves in the Bismarck division. One sample exhibited PCBs in excess of 500 ppm, and one other sample exhibited PCBs between 50 and 499 ppm. The remaining sixteen samples contained less than 50 ppm, with 13 samples containing less than 2 ppm PCBs. Six samples were collected from the Black Hills division. One of these samples contained between 50 and 499 ppm PCBs, and one other sample contained 9.9 ppm. The remaining four samples contained less than 2 ppm PCBs. Analytical results of grease samples taken from 11 in-service valves in the Dickinson division indicate that one of the samples contained PCBs in excess of 500 ppm. The remaining 10 samples contained less than 50 ppm PCBs, with eight of these containing less than 2 ppm PCBs. One of the 12 grease samples collected from in-service valves in the Glendive division contained PCBs in excess of 500 ppm. Two of these 12 samples contained between 50 and 499 ppm PCBs, while the remaining nine samples contained less than 50 ppm, with eight of these containing less than 2 ppm. Grease samples from 17 in-service valves were collected from the Minot division. One sample contained a PCB concentration greater than 500 ppm. The remaining 16 samples contained PCBs in concentrations less than 50 ppm, with nine of these samples containing less than 2 ppm. A total of nine in-service grease samples were collected from the Williston division. One sample exhibited a PCB concentration between 50 and 499 ppm. The remaining eight samples contained less than 50 ppm PCBs, with five of these samples containing less than 2 ppm. 3496-004 2-7 January 1991 PCB-ARCH-EXT0371904 2.3.3 Condensate Sample Distribution A total of 25 natural gas condensate samples were collected and analyzed for the presence of PCBs. Condensate samples were collected from all natural gas operating divisions with the exception of the Williston division where condensate was not available for sampling. Two condensate samples were collected in the Billings division. Both samples contained less than 2 ppm PCBs. A total of 10 samples were collected from the Bismarck division. Analytical results indicate that three samples contained between 50 and 499 ppm PCBs. The remaining seven samples contained less than 50 ppm, with four of these samples containing less than 2 ppm. Four condensate samples were collected from the Black Hills division. One sample contained 19 ppm PCBs, while the remaining three samples contained less than 2 ppm PCBs. One of the three condensate samples collected from the Dickinson division contained PCBs between 50 and 499 ppm. One sample contained 24 ppm PCBs and the other sample contained less than 2 ppm. Two condensate samples were obtained from the Glendive division. One sample exhibited PCBs between 50 and 499 ppm, and the other sample contained less than 2 ppm PCBs. Analytical results of the four condensate samples taken from the Minot division indicated PCB concentrations below 30 ppm, with one of these samples containing less than 2 ppm. 2.3.4 Gas Sample Distribution The two natural gas samples analyzed for the presence of PCBs were collected from delivery points within the Bismarck division. PCBs were not identified in either of the gas samples. 2.4 Analytical QA/QC Summary The majority of analytical work has been performed in WBI's laboratory. In order to ensure the proper performance of all analytical work and the development of representative data, a QA/QC program was implemented. The major aspects of this program are discussed below. 3496-004 2-8 January 1991 PCB-ARCH-EXT0371905 2.4.1 Sampling QA/QC Sampling QA/QC includes the preparation of written SOPs for use by field personnel in the collection of samples from the various media. It also includes chain of custody (COC) procedures and the use of a field data sheet. The quality and integrity of each sample has been further assured through the use of field sampling kits which are prepared by WBI's analytical laboratory located in Glendive, Montana. Each kit contains a 40-50 ml wide mouth bottle with a foil lined cap, latex gloves, sample labels, COC forms, ziploc bags, field data forms, and a copy of the sampling SOP. Collected samples are packaged to prevent breakage and sent to the WBI laboratory. Copies of the COC's and field data sheets are maintained. 2.4.2 Analytical QA/QC Analytical QA/QC includes the use of written SOPs for the extraction and analysis of the samples of various matrices by gas chromatography (GC). The SOP for analysis by GC follows ASTM standard procedures D3304-83 and D4059-86. The GC instrument is a Hewlett-Packard Model 5713A. Sample information is controlled both by a manual entry laboratory log book and a computerized system. Results of PCB concentrations and curves for each PCB Arochlor are computer generated. The concentration data are recorded in the master log book and entered into the computer. The computer generates a spreadsheet which includes sample number, location, collector, and collection date. The GC instrument is calibrated using three different standards and a blank. Working standards are prepared from primary standards supplied by EPA. A calibration curve is generated for each batch of samples (typically there are 20 to 40 samples per batch). Duplicate samples are analyzed at a rate of 10 percent or one per batch of less than 10 samples. Other QA/QC activities include the calibration and maintenance of the analytical balance (Mettler Model HL52), use of high grade solvent (iso-octane etc.), routine maintenance of the GC, and use of EPA approved glassware cleaning procedures. Original data reports are filed in the analytical laboratory. 3496-004 2-9 January 1991 PCB-ARCH-EXT0371906 2.5 Discussion of Analytical Results A total of four Arochlor species were detected in samples collected from the MDU systems. Of these four species, three (Arochlors 1242, 1254, and 1260) were found at relatively low concentrations in a limited number of samples. The predominant species of PCBs detected in the various grease samples has been identified as Arochlor 1268. Based on WBI analytical results obtained to date, the source of this contaminant is believed to be certain sealants manufactured by Rockwell International. WBI samples of Rockwell 860 and Rockwell 991 sealants exhibited Arochlor 1268 concentrations in excess of 50 ppm. A limited number of grease samples collected from MDU grease guns and in-service valves also exhibited Arochlor 1242, 1254, and 1260 levels above 50 ppm. The presence of Arochlors 1242,1254, and 1260 at low levels in a small number of samples may indicate: limited transport of PCBs from other sources at interconnect locations, aging of Arochlors from 1268 to less saturated species, or masking of GC fingerprints by the presence of carboxylicacids in a grease matrix. Gas samples have been collected from the Bismarck division. The analysis of the gas samples indicates that PCBs are not present in the gas transported in the MDU distribution systems. For this reason, the transport of PCBs in the gas stream appears to be highly unlikely. This finding is consistent with other studies relating to PCBs in natural gas (EPA 1984). PCBs have not been identified above 500 ppm in natural gas condensates in any of MDU's operating divisions. PCBs have been detected between 50 and 499 ppm in natural gas condensate from three operating divisions, specifically, the Bismarck, Dickinson, and Glendive divisions. 3496-004 2-10 January 1991 PCB-ARCH-EXT0371907 3.0 CONDENSATE HANDLING PROGRAM 3.1 Condensate Collection Program As discussed in Section 1.0 the primary route for the potential migration of PCBs from the grease matrix to workers, the public, and the environment is the dissolution of the grease by distribution system condensates. Therefore, MDU has supplemented their existing condensate management program to provide an even more aggressive and comprehensive approach to ensure the appropriate containment and disposal of condensates. This program is designed to provide assurance that condensate which occurs in the distribution systems is collected, contained, and disposed in an environmentally sound manner. MDU collects condensate where it occurs in the distribution systems, however, very little condensate is present in MDU distribution systems. A collection program has been in place since condensates interfere with the efficient distribution of natural gas. MDU has provided training for field personnel on the proper handling of liquids which have the potential to contain PCBs. At those locations of the distribution systems where detectable levels of PCBs have been identified in pipeline liquids, MDU personnel will collect and store all liquids in accordance with requirements of 40 CFR 761. At those locations where PCBs have not been identified, the condensate collected will not be handled as PCBs until they arrive at a storage facility. However, in order to protect employees and the environment, all condensate and oily liquids will be collected, stored, and disposed as per the requirements of 40 CFR 761. MDU will utilize existing storage facilities or construct new facilities as necessary to provide proper storage of all condensate potentially containing PCBs. MDU has seven PCB storage areas that meet the requirements of 40 CFR Part 761.65. MDU currently has in place a PCB Spill Prevention Control and Countermeasure (SPCC) Plan for all storage areas. Specific steps to be followed by MDU personnel are as follows: 1. All condensate from areas tested where regulated levels of PCBs have been found, are considered to be PCB containing and may be mixed for storage and disposal, based on the requirements for the highest level of PCBs assumed to be present prior to mixing fluids. 2. When several condensate collection points are located at one site, all condensate will be accumulated in one container and one sample collected. 3496-004 3"1 January 1991 PCB-ARCH-EXT0371908 3. Condensate from untested locations within individual MDU distribution systems may be mixed in a common container, but the resultant mixture will be handled as if it contains a concentration of 50 ppm PCBs. 4. If any condensate with a PCB content of 500 ppm or greater is added to a bulk container, the contents of the entire container must be considered to have a content of 500 ppm or greater PCBs. 5. Condensate from tested locations will be assumed to be of the concentration of the initial test, unless and until MDU resamples the location, or has reason to believe the nature of the liquid has changed. 6. Condensate from areas tested and found to contain less than regulated levels of PCBs will be retested at intervals to verify that they remain unregulated. 7. Condensate will be collected in appropriate drums, until full, and then transported to the nearest PCB storage facility. If temporary storage is necessary, the storage area will have a SPCC plan developed prior to any storage of PCB containing materials. The material will be removed to a permanent storage area within 30 days. Condensate from gas operations will be segregated from electric operations PCB wastes until such time as they are characterized and proper disposal procedures are selected. Any spilled condensate suspected of containing PCBs will be handled in accordance with the spill cleanup requirements of 40 CFR Part 761.120. 3.1.1 Compliance Monitoring MDU will implement a condensate collection compliance monitoring program to periodically inspect all distribution system facilities which store or collect condensate and all system locations where liquids may potentially exit the distribution systems. The monitoring program will provide the information necessary to ensure all collection procedures are effective and are properly implemented by MDU field personnel. The program will be conducted by MDU division supervisors under the coordination of the MDU environmental staff. MDU has sampled condensate where it occurs throughout the distribution systems (see Section 2.0). One additional sample will be collected in areas where no regulated level of PCBs has been identified in condensate. If the additional test confirms there are no PCBs present above regulated levels, monitoring will be discontinued for those systems. Condensate from 3496-004 3-2 January 1991 PCB-ARCH-EXT0371909 areas initially found to contain regulated levels of PCBs will be managed as containing PCBs at the level of the most recent test, until and unless MDU determines that the area contains PCBs below regulated levels. 3.1.2 Recordkeeping MDU will prepare records of the condensate volumes collected at each collection point. These volume records will be used to monitor condensate quantities within the MDU systems. MDU will maintain all records for the storage of PCBs as required by 40 CFR Part 761.65. 3496-004 3-3 January 1991 PCB-ARCH-EXT0371910 4.0 EQUIPMENT MANAGEMENT The equipment management program provides the procedures and controls to safely handle, store, remove, transport, clean, and return to sen/ice or dispose of distribution systems equipment which may contain PCBs. The following subsections discuss these procedures. 4.1 Equipment Handling and Storage Plan The equipment handling and storage plan addresses two categories of equipment: equipment currently stored in MDU warehouses; and equipment currently in service. Distribution equipment currently in service will remain in service until removed as part of MDU's routine maintenance or replacement programs. Equipment removed from service will be drained of all free liquids, which will be collected and stored in accordance with procedures described in Section 3.0. The equipment will then be handled as potentially PCB-containing equipment and tested for PCBs. Based on results of the testing, the equipment will be returned to service, cleaned or disposed of in accordance with 40 CFR Part 761. All valves potentially lubricated with PCB-containing Rockwell sealant currently stored in MDU warehouses will either be disposed in accordance with 40 CFR Part 761 or sampled according to section 4.2 to determine the level of PCB content. MDU will use existing PCB storage facilities or construct a new structure(s), if necessary. The PCB storage facilities will meet the following criteria: adequate roof and walls to eliminate rain water; impervious floor with continuous curbing having a containment volume at least two times the internal volume of the largest PCB container or 25 percent of the total volume of ail PCB containers, whichever is greater; no drain valves, floor drains, expansion joints, sewer lines, or other openings within the curbed area; and site location above the 100-year flood water elevation. 3496-004 4-1 January 1991 PCB-ARCH-EXT0371911 4.2 Equipment Classification 4.2.1 Valves 4.2.1.1 Used Lubricated Plug Valves All lubricated plug valves suspected of containing PCBs will be classified as salvageable or not salvageable. Equipment which MDU intends to reuse will be sampled either individually, or by combining equal amounts of sealant from up to five valves. If the results of the composite samples indicate that any one of the sampled valves contain PCB concentrations above 50 ppm, all the sampled valves will be classified as PCB equipment. For example, if five valves are sampled, and the composite sealant contains above 10 ppm PCBs, all five valves will be classified as PCB equipment. Where the salvage value of a valve is less than the cost of sampling, MDU may elect to classify certain valve groups as PCB equipment without any analysis. This PCB equipment will be properly disposed according to 40 CFR Part 761. 4.2.1.2 New Lubricated Plug Valves MDU presently has lubricated valves in stock as inventory. Some of these valves were purchased new and have not yet been placed in service. Other in-stock valves have been retired from previous service and have been reclaimed for reuse. Except for those valves which were recently purchased and placed in stock it is difficult to determine the exact vintage of each inventoried valve in stock. Therefore it is not possible to determine by vintage which valves may have been lubricated with a sealant containing PCBs except for those recently purchased. In the absence of simply testing actual sealant samples taken from every lubricated valve that MDU has in inventory (except for those unused valves which can be verified by records as being purchased after January 1,1990) it is impossible to know with certainty which in-stock valves are not free of PCBs. It is expected, however, that the vast majority of MDU's on-the-shelf valves are free of PCBs. Until proven otherwise, MDU is taking the position that all inventoried valves which were purchased prior to January 1, 1990 are assumed to contain PCBs. New valves in stock which were purchased after January 1, 1990 will be considered to contain less than 50 ppm PCBs in the valve lubricant, and will be used as necessary in the distribution systems. Valves in stock purchased prior to January 1,1990, will be sampled on the same basis as used valves and treated accordingly, depending on analysis of the valve grease or lubricant. 3496-004 4-2 January 1991 PCB-ARCH-EXT0371912 Lubricated valves containing PCB concentrations greater than 50 ppm may be cleaned or disposed as PCB articles, depending on economic factors. 4.2.2 Meters and Regulators Dry meters and regulators removed from sen/ice under normal maintenance schedules will be handled as PCB free and will be returned to service. When meters or regulators removed from service in the course of normal maintenance are found to contain liquids, the equipment will be contained and transported to the maintenance area for draining and sampling. The equipment and liquids will be handled as if they contained PCBs, pending analytical results. Liquids from meters and regulators will be handled according to the procedures outlined in Section 3.0. Depending on the replacement cost of the meters, and the PCB concentration levels, if detected, one of the following options will be selected: clean in accordance with 40 CFR Part 761.79, dispose in accordance with 40 CFR Part 761.60, remediate according to an alternative approved technology, or return to service. 4.2.3 Hydraulic Grease Guns MDU conducted a sampling program to evaluate PCB levels in all 41 hydraulic grease guns used to maintain valves in the distribution systems. Only six of these grease guns were found to contain PCB concentrations of greater than 50 ppm. MDU has handled all six guns in accordance with 40 CFR 761. They are currently being stored for cleaning and reuse in the distribution systems. 4.2.4 Pipe Classification 4.2.4.1 Removed Pipe in Existing Stockpiles Presently, MDU has less than 3,000 feet of stockpiled pipe in six division pipe yards. This pipe is completely dry of any liquid, and will either be sold as scrap metal, or cut up and used by MDU for meter barriers and/or protective fences. 3496-004 4-3 January 1991 PCB-ARCH-EXT0371913 4.2.4.2 Pipe to be Removed or Abandoned in Place It is the general practice in MDU's replacement projects to abandon distribution mains and services in place in the ground, after capping the pipe ends. Exceptions to this practice occur occasionally when the abandoned pipe interferes with the new gas distribution mains or with other utility or street grading projects. Economics and public inconvenience often supports leaving the abandoned pipe in place since, in most cases, replacement pipe is installed in a different location. In many replacement projects, new pipe is installed in alleys, whereas in the past, pipe was installed in streets. For pipe which is to be abandoned in place the following procedures will be implemented: Open pipe ends, at tie-in points for replacement pipe, will be inspected for evidence of condensate or liquids. Where such tie-in points are more than one city block apart, an inspection will be made at intervals not to exceed one city block to determine the presence, if any, of condensate or liquids. If no condensate or liquids are found at pipe ends, or at one block interval inspection points, the pipe ends will be capped and sealed. If liquids are found at the open pipe ends or at the other inspection locations, the liquid will be drained and placed in approved containers. Prior to capping the ends of the pipe, an absorbent swab will be pulled through the pipe and any residual liquids collected. A sample of the liquids will be analyzed for PCBs. If analysis indicates that liquids contain PCB concentrations greater than 500 ppm, MDU will follow the requirements specified in 40 CFR 761.60 (b)(5) for disposal of the pipe. An approved alternative method of disposal, or cleaning may be considered. If the liquids contain less than 500 ppm PCBs, the pipe will be disposed in place. For pipe which is to be removed from the ground (i.e., not abandoned in place), the following procedures will be implemented (see Figure 4-1): Pipe sections in which no liquids are found will be available for salvage or reuse. If liquids are found they will be drained prior to the removal of the pipe. The liquids will be placed in approved containers for disposition. A sample from each location where liquids are recovered will be analyzed for PCBs. If the liquids contain PCBs in excess of 50 ppm, they will be handled as outlined in Section 3.0. 3496-004 4-4 January 1991 PCB-ARCH-EXT0371914 Figure 4-1. Pipe Handling Procedure 4-5 PCB-ARCH-EXT0371915  Pipe sections from which liquids have been drained will be cut into joints approximately 40 feet in length. The open pipe ends will be temporarily capped and the pipe will be transported to the division pipe yard and stored to await analysis of the liquids. If analysis of the liquid removed from the pipe indicates PCB concentrations at levels less than 50 ppm, the pipe will be handled and transported for salvage or reuse. If the analysis indicates PCB concentrations in excess of 50 ppm, the following procedures will be completed before disposing of or re-using the pipe: - Disposal will be in accordance with 40 CFR 761.60(b)(5)(i) or (ii), or pipes will be cleaned using a permitted process. - The capping method will be determined by the project supervisor to ensure that the pipe interior is not exposed during handling, transportation, and storage. - Each pipe end will be capped with a welded metal plate, insert, compression fitting or polyethylene plastic covering. 4.3 Equipment Cleaning Program All equipment classified as PCB equipment and salvageable by MDU will be cleaned if feasible. Those items of equipment which have been in contact with PCB containing grease or condensate will be cleaned using effective procedures. The cleaning process for equipment which has been in contact with condensate containing PCBs will be a triple solvent rinse, as described in 40 CFR Part 761.79, or an alternative approved technology. 4.4 Equipment Disposal Program All equipment classified as non-salvageable and potentially containing PCBs will be properly stored prior to disposal. This equipment will be transported with a manifest to a licensed disposal facility within one year of placement in storage. 3496-004 4-6 January 1991 PCB-ARCH-EXT0371916 5.0 DISTRIBUTION SYSTEMS EVALUATION MDU has initiated a condensate sampling program in all of its distribution systems where condensate collection facilities exist to collect the liquids and where condensate has historically been found. In addition, meters removed from service are checked for the presence of liquids which if found, are analyzed for PCBs. The location on the distribution systems from which the meter was removed is recorded. All MDU grease guns used to lubricate plug valves have been evaluated and tested for the presence of PCBs and those guns exhibiting PCB concentrations in excess of 50 ppm have been removed from service. The location of PCB containing guns is being studied to determine the extent of past possible use by operating division and town. This data, when analysis is complete, will be used to evaluate individual distribution system contamination potential and possible migration of condensate from any exit points. 5.1 Work Plan Development Based on evaluation of the data, MDU will prepare a Soil Sampling Plan, if warranted, to assess potential PCB exposure of the soil in the immediate area of distribution facilities where condensate has been collected and removed from the systems. The Plan will detail the soil sampling activities and provide an implementation schedule. 3496-004 5-1 January 1991 PCB-ARCH-EXT0371917 6.0 REFERENCES U.S. Environmental Protection Agency. 1984. Final Report: Exposure Assessment for Incidentally Produced Polychlorinated Biphenyls. 3496-004 6-1 January 1991 PCB-ARCH-EXT0371918 HEALTH AND ENVIRONMENT Introduction Although PCB contamination was found in gas pipeline systems in the early 1980's, the primary source for PCBs has been oils used in compressor stations. Recently, however, polychlorinated biphenyls (PCBs) have been found in valve grease used in some areas of the WBI and MDU systems. This grease is a potential "source1' of contamination. The grease is not transported by natural gas, but may be partially dissolved and transported by hydrocarbon liquids sometimes found in a gas pipeline. Thus a secondary source has been identified as the contaminated condensate liquids found at various points in the systems. Potential pathways for PCB exposure include the natural gas traveling through the pipeline, and any solid or liquid materials which can become contaminated, either inside or outside the pipeline. Potential receptors include the pipeline employees, the public, and the environment. Risk To The Public A public risk assessment need not be completed because a credible pathway for PCB exposure cannot be identified. For the public to be exposed through the air pathway, three conditions are required: 1) PCBs must be present; 2) they must be volatilized from condensate or grease; and 3) for contaminated gas to contaminate the actual breathing air, PCBs (if present in the gas) must survive combustion in a flame. Only small flames, such as pilots or stove burners are applicable in this case since gas furnaces provide heat through heat-exchangers and they provide no direct exposure to the combusted gas. The first condition for the air pathway model is met because PCBs have been identified in the grease and condensate of some line segments. However, the second condition, volatilization, has not occurred. Sampling by MDU and WB! has identified no significant levels of PCBs in the gas stream. This outcome is expected since volatilization of PCBs requires a high temperature, or a liquid solvent to carry PCB's in the gas stream. PCBs have a very low volatility, especially at pipeline temperatures (summer: 60F, winter 28F). This fact combined with the low exposure cross section of grease to the gas stream, makes volatilization extremely unlikely. Presently, there is no evidence that contaminated distribution systems can serve as a pathway to public receptors under normal circumstances. In fact, a study by the United States Environmental Protection Agency (EPA) in Long Island, New York found no public exposure through the gas distribution system containing PCBs (EPA 1984). Solvent action is the most likely transport mechanism for the limited amount of PCBs found in pipeline condensate. Liquid-phase hydrocarbons in the gas stream may dissolve PCBs and transport them to points of collection in the line. However, an objective of all natural gas systems is to remove liquid hydrocarbons from the line to provide more efficient operation. A-1 PCB-ARCH-EXT0371919 Thus, high concentrations of liquid hydrocarbons are not generally a constituent of the gas stream. Solvent action is therefore an intermittent or uncommon event. The third link in the air pathway is that of the combusted gas-air interface. As mentioned above, small burners and pilots are the most likely interface. To summarize, based upon MDU and WBI testing, EPA studies, and an evaluation of potential pathways, there is no rationale for performing a risk assessment for the public. The mere presence of RGBs in condensate or grease does not indicate exposure. Risk to Employees Historically, workers have handled PCBs for 60 years. Risks to employees working with PCBs are well characterized and documented, with worker exposure seldom proving to be of concern. Workplace procedures and protective equipment, together with limited airborne exposure, appear to offer adequate protective barriers for employees working with PCBs. The difficulty of reaching hazardous levels in workplace air makes the PCB air pathway exposure model highly unlikely under normal circumstances. Again, the low volatility of PCBs at normal temperatures mitigates against airborne exposure. Intense heating, agitation or pressurization would be required to vaporize or aerosolize enough of the material to reach the exposure limit. In these cases, respiratory protection is available. The other modes of potential exposure, dermal and oral, are easily controlled through the use of proper protective clothing including impervious gloves, aprons, and boots; and through proper workplace hygiene. Based upon the adequate historical information available regarding workplace PCB exposures, a risk assessment for pipeline employees is unnecessary. Risk To The Environment The only significant potential pathway to the environment is contaminated condensate liquids. These liquids have routinely been collected at various points. Conceivable pathways to environmental receptors include water run-off and contaminated soil. To date, these events have not been shown to have occurred in this case. Unless soil or water contamination is shown to exist, there is no need to perform an environmental or ecological risk assessment. Summary Based upon the above evaluation, the following can be concluded: 1. A thorough evaluation of risk to the public has been performed by EPA for contaminated pipeline systems in the northeast United States. These risks were found to be very low, with the gas-pathway identified as an ineffective transport mechanism for PCBs. Risk to the public is not of concern because break-down A-2 PCB-ARCH-EXT0371920 products from PCBs in a flame did not occur in the EPA New York study. Dibenzofurans and dioxins are not formed in the high temperatures of natural gas flames (EPA 1984). 2. The workers, are protected from well identified risks by protective work procedures, exposure limits, and equipment. With adequate historical information available, it is unnecessary to re-assess the risk to employees handling PCBs. 3. Regarding the environment, a risk assessment is also unnecessary. No significant releases to the environment have been identified, and no other valid pathway to the environment has been established. A-3 PCB-ARCH-EXT0371921 APPENDIX B MDU PCB ANALYTICAL DATABASE PCB-ARCH-EXT0371922 MDUPCB ANALYSIS Lab No. 1557 1557 17194 17195 17196 17381 17382 17383 17386 17387 17389 17394 17395 17397 17399 17401 17402 17403 17408 17407 03 17408 -* 17413 17414 17416 17418 17420 17423 17424 17427 17428 17430 17431 17434 17436 17438 17440 17441 17444 17445 17448 17450 17456 17457 17460 No.1 No.2 13 13 13 14 13 15 12 8 12 9 12 14 12 12 12 20 12 10 24 1 24 3 20 5 24 10 24 13 20 3 24 6 20 2 20 7 24 8 12 22 15 1 15 3 15 5 13 28 13 31 13 32 13 35 13 36 13 38 13 39 13 42 13 44 13 46 13 48 13 49 13 52 13 53 13 56 13 58 16 1 16 6 16 4 Location BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. Detail Loc. BISMARCK SWEETHEART BAKERY BISMARCK SWEETHEART BAKERY BELLEFOURCHE METER 9686 LEAD METER 12226 AM COLLOID WEST COLONY STAGE STOP BISMARCK REGULATOR STATION BISMARCK 12-3 TIP BISMARCK 12-2 END JAMESTOWN PLUNGER BISMARCK 12-1 END WOLFPOINT TGUN PLUNGER,VALVTEX WOLFPOINT GREEN TIP MINOT 20-3 D.C. RESERVOIR WILLISTON T PLUNGER MINOT 20-1 RESERVOIR MINOT 20-2 TIP TIOGA TIP MINOT 20-1 HOSE MINOT 20-4 END WOLFPOINT RED PLUNGER,GLASGOW LADDISH BORDER DICKINSON 15-1 HOSE END DICKINSON 15-2 HOSE END DICKINSON 15-3 HOSE END RC 13-1 SPARE HOSE RC 13-2 SPARE HOSE END RC 13-3 HOSE END RC 13-4 HOSE END RAPID CITY GREASE GUN 13-5 RAPID CITY GREASE GUN 13-6 RC 13-7 HOSE END RC 13-8 CYLINDER RC13-9 HOSE END RC 13-10 HOSE END RC 13-11 CYLINDER RC 13-12 CYLINDER RC 13-13 CYLINDER RC 13-14 CYLINDER RC 13-15 CYLINDER RC 13-16 CYLINDER GLENDIVE,TIP MILES CITY,TIP GLENDIVE,JACK'S OIL Article CONDENSATE CONDENSATE CONDENSATE CONDENSATE CONDENSATE CONDENSATE CONDENSATE GREASE GREASE GREASE GREASE GREASE GREASE GREASE GREASE GREASE GREASE GREASE GREASE GREASE GREASE CONDENSATE GREASE GREASE GREASE GREASE GREASE GREASE GREASE GREASE GREASE GREASE GREASE GREASE GREASE GREASE GREASF GREASE GREASE GREASE GREASE GREASE GREASE OIL Sampler LEO LENO LEO LENO A. STOMBERG A. STOMBERG A. STOMBERG A. STOMBERG A. STOMBERG A. STOMBERG A. STOMBERG A. STOMBERG A. STOMBERG A. STOMBERG A. STOMBERG A. STOMBERG A. STOMBERG A. STOMBERG A. STOMBERG A. STOMBERG A. STOMBERG A. STOMBERG A. STOMBERG A. STOMBERG D. CONNELLY D. CONNELLY D. CONNELLY D. CONNELLY D. CONNELLY D. CONNELLY D. CONNELLY D. CONNELLY D. CONNELLY D. CONNELLY D. CONNELLY D. CONNELLY D. CONNELLY D. CONNELLY D. CONNELLY D. CONNELLY D. CONNELLY D. CONNELLY D. CONNELLY A. STOMBERG A. STOMBERG A. STOMBERG Sample Date 10-Aug-82 10-Aug-82 18-Aug-90 16-Aug-90 16-Aug-90 23-Aug-90 23-Aug-90 10-Oct-90 10-Oct-90 10-Oct-90 10-Oct-90 15-Oct-90 15-Oct-90 10-Oct-90 10-Oct-90 10-Oct-90 10-Oct-90 15-Oct-90 10-Oct-90 10-Oct-90 10-Oct-90 08-Oct-90 1B-Oct-90 16-Oct-90 22-Oct-90 18-0ct-90 18-Oct-90 18-Oct-90 1B-Oct-90 18-Oct-90 18-Oct-90 1B-Oct-90 18-Oct-90 18 -Oct-90 1B-Oct-90 18-Oct-90 1B-Oct-90 1B-Oct-90 1B-Oct-90 1B-Oct-90 18-Oct-90 25-Oct-90 25-Oct-90 25-Oct-90 Analyze Date 22-Oct-82 22-Oct-82 22-Aug-90 22-Aug-90 22-Aug-90 01 -Oct-90 02-Oct-90 24-Oct-90 24-Oct-90 24-Oct-90 24-Oct-90 24-Oct-90 24-Oct-90 24-Oct-90 24-Oct-90 24-Oct-90 24-Oct-90 23-Oct-90 23-Oct-90 23-Oct-90 23-Oct-90 25-Oct-90 29-Oct-90 31 -Oct-90 31 -Oct-90 01-Nov-90 31-Oct-90 31 -Oct-90 31-Oct-90 31 -Oct-90 31-Oct-90 31 -Oct-90 31 -Oct-90 31 -Oct--90 31 -Oct-90 31 -Oct-90 31 -Oct-90 01-Nov-90 01 -Nov-90 01-Nov-90 01-Nov-90 01 -Nov-90 01-Nov-90 01-Nov-90 Pcb ppm Arochlor 187.3 36 <1 <1 19.0 1268 14.1 1268 20.9 1268 232.2 1268 16125.1 1268 <1 464.2 1268 378.5 1268 <1 <1 <1 <1 <1 <1 1.6 1268 <1 <1 <1 381.2 1268 10.9 1254,1268 <1 <1 7.5 1254 <1 2.5 1254 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 1.9 1268 <1 PAGE1 PCB-ARCH-EXT0371923 MDUPCB ANALYSIS PAGE 2 Lab No. 17472 17474 17476 17479 17481 17482 17504 17507 17609 17610 17611 17612 17613 17614 17615 17616 17617 17618 17619 17624 17625 17626 17643 17644 17645 17646 17648 17688 17687 17688 17689 17690 17691 17692 17693 17694 17695 17696 17697 17698 17706 17707 17708 17709 No.1 11 11 11 11 11 11 12 20 12 15 15 15 15 12 20 20 20 12 12 12 12 13 24 24 24 24 24 16 16 16 16 16 16 16 16 16 16 16 16 16 15 15 15 15 No.2 2 4 6 8 11 10 25 9 31 8 9 10 7 29 16 17 18 53 54 55 56 27 IB 19 20 21 23 7 8 9 10 11 12 13 14 15 16 17 18 19 .11 12 13 14 Location BISMARCK G O. BISMARCK G O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. Detail Loc. BILLINGS SHOP GUN PLUNGER.11-2 POWELL T-GUN TIP.11-4 SHERIDAN TIP. 11 -6 BILLINGS KURTS PLUNGER,11-9 BNGSLOCKW05OLD HARDIN RD.11-11 CONOCO & S.ELK BSN 30585 VALLEY CITY GUN TIP,12-25 SOUTH 3RD STREET,20-2 ND STATE HOSP JAMESTOWN,645272 DICKINSON DI3T STAT #4,15-8 DICKINSON DIST. STAT #21,15-9 DICKINSON GUN PARKS,15-10 SENTINEL BUTTE N SIDE RETIREMENT SHEYENNE CARE CTER 314531,12 - 29 DEVIL'S LAKE 6TH AVN & BTH ST DEVIL S LAKE 7TH AVN & 8TH ST DEVIL'S LAKE 12TH ST & 2ND AVN NEW SALEM LP STA #1,12-524-1 NEW SALEM LP STA #2,12-524-2 1304 E BROADWAY,12-1 BIS. REG & METER 218347,12-2 METER 762208,13-17 ARNEGARD LIBRARY VALVE,24-18 WATFORD CITY VALVE.24-19 TIOGA VALVE STANLEY HOSPITAL VALVE WILLISTON DISTRIBUTION VALVE GLEND. SHOP, WOLF PNT 663692,16-7 SECTION ALIZING VLV #7,GLEND,16-8 SECTIONALIZING VLV #6,BAKER,16-9 2' VLV @ OLD BOR.ISMAY MT,16-10 DIST. STATION #1,WIBAUX,16-11 DIST. REG STA #2,SIDNEY,16-12 SECT.VLV # 1 .FAIRVIEW, 16-13 DIST REG STATION #1,RICHEY,16-14 DIST.REG STATION #2,SAVAGE,16-15 SECT. VALVE #8,FORSYTH,16-16 DIST REG #2,TERRY,16-17 2" NORD. VLV,ROSEBUD H.S.,16-18 SECT. VLV #11,MILES CITY.16-19 DICKINSON,VALVE 96B.15-11 TAYLOR,VALVE #2,15-12 RICHARDTON H.S., 15-13 MOTT VALVE M15.15-14 Article GREASE GREASE GREASE GREASE CONDENSATE CONDENSATE GREASE CONDENSATE CONDENSATE CONDENSATE CONDENSATE GREASE CONDENSATE CONDENSATE CONDENSATE CONDENSATE CONDENSATE GREASE GREASE OIL OIL OIL GREASE GREASE GREASE GREASE GREASE CONDENSATE GREASE GREASE GREASE GREASE GREASE GREASE GREASE GREASE GREASE GREASE GREASE GREASE GREASE GREASE GREASE GREASE Sampler A. STOMBERG A. STOMBERG A. STOMBERG A. STOMBERG A. STOMBERG A. STOMBERG A. STOMBERG A. STOMBERG VERN HERMAN L. KUDRNA L. KUDRNA A. STOMBERG L. CALLAHAN VERN HERMAN R. ZAAHER R. ZAAHER R. ZAAHER D. HILLMAN D. HILLMAN NICK CAIN NICK CAIN BOB BRAND R. NEHRING R. NEHRING R. NEHRING R. NEHRING R. NEHRING A. STOMBERG A. STOMBERG A. STOMBERG S. STOMBERG A. STOMBERG A. STOMBERG A. STOMBERG A. STOMBERG A. STOMBERG A. STOMBERG A. STOMBERG A. STOMBERG A. STOMBERG ALAN STIEG A. STIEG A. STIEG A. STIEG W 1 oO T COo Sample Date 30-0ct-90 31 -Oct-90 30-Oct-90 25-Oct-90 25-Oct-90 09-NOV-90 07-Nov-90 08-Nov-90 0B-NOV-90 14-Nov-BO 15-Nov-90 07-Nov-90 14-NOV-90 19-Nov-90 19-NOV-90 19-NOV-90 21-Nov-90 21-Nov-90 13-NOV-90 14-NOV-90 01-Nov-90 23-NOV-90 23-NOV-90 26-NOV-90 28-Nov-90 26-NOV-90 27 -Nov-90 27 -NOV-90 28-NOV-90 28-Nov-90 28-NOV-90 29-NOV-90 29-NOV-90 29 --Nov-90 29-NOV-90 29-Nov-90 29-NOV-90 29-NOV-90 29 -Nov-90 28-NOV-90 28-NOV-90 28 -Nov-90 28 -NOV-90 Analyze Date 02-Dec-90 02-D6C-90 02-Dec-90 02-Dec-90 02-Dec-90 01-Dec-90 03-Dec-90 01-Dec-90 01 -Dec-90 04-Dec-90 03-Dec-90 03-Dec-90 01-Dec-90 01-Dec-90 01-Dec-90 01 -Dec-90 02-Dec-90 03-D8C-90 03-Dec-90 02-Dec-90 04-Dec-90 02-Dec-90 03-Dec-90 03-Dec-90 03-Dec-90 03-Dec-90 03-Dec-90 20-Dec-90 04-Jan-91 31-Dec-90 04-Jan-91 02-Jan-91 31-Dec-90 31 -Dec-90 31-Dec-90 31-Dec-90 31 -Dec-90 01 -Jan-91 03-Jan~91 01 -Jan-91 01 -Jan-91 03-Jan-9l 04-Jan-91 01 -Jan-91 Pcb ppm Arochlor <1 <1 <1 <1 <1 <1 39115.7 1268 <1 <1 302.2 1254,126B 23.9 1254 <1 <1 <1 30.1 1268 24.1 1268 21.7 1268 <1 5.3 1260 89.1 1254,1268 94.1 1254,1268 <1 13.1 1254 11.5 1242 <1 152.2 1254 <1 53.1 157.5 1242 <1 6858.5 1242,1254,1268 201.6 1242 <1 <1 <1 <1 <1 <1 5.8 1242 <1 <1 8.0 1268 6447.3 1242,1268 <1 PCB-ARCH-EXT0371924 MDUPCB ANALYSIS Lab No. 17710 17711 17712 17713 17714 17715 17718 17717 17718 17719 17720 17721 17722 17723 17724 17725 17726 17727 17728 17729 17730 17731 17732 17733 17734 17735 17736 17737 17738 17739 17740 17741 17742 17743 17744 17745 17746 17747 17748 17749 17750 17751 17752 17753 No.1 15 15 15 15 15 15 11 11 11 11 11 11 11 11 11 11 11 11 11 11 12 13 13 13 13 13 13 12 12 12 12 12 12 12 12 24 24 24 24 20 20 20 20 20 No.2 15 16 17 18 19 20 13 14 15 16 17 18 19 20 21 22 23 24 25 26 57 60 61 62 63 64 65 32 33 34 35 37 38 39 40 27 26 25 24 19 20 21 22 23 Location BISMARCK G.O. BISMARCK G O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. BISMARCK G.O. Detail Loc. NEW ENGLAND,VLV NE9,15-15 SOUTH HEART SCHOOL.15-16 BELFIELD H.S. RISER.15-17 DIST STATION #2 VLV #2,15-18 GLADSTONE VALVE #1,15-19 HEBRON BRICK INLET,15-20 KAYCEE SCHOOL,11-13 BUFFALO HESSE STATION,11-14 SHERIDAN STATION #4,11-15 CROW AGENCY HOSPITAL, 11 -16 HARDIN DIST. STATION.11 -17 BILLINGS VLV 5TH & MONTANA,11 -18 LAUREL DUTCH TOWN,11 -19 PARK CITY DIST. STATIONS 1-20 EDGAR DIST. STATION,11-21 FROMBERG SCHOOL,11 -22 BRIDGER SCHOOL,11 -23 BELFRY SCHOOL,11 -24 POWELL L.P. STA.,11 - 25 LOVELL DIST. STA.,11-26 BISMARCK SERVICE CENTER BELLEFOURCHE DIST. STA #5,13-60 SPEARFISH DISTRICT STA. #2,13-61 DEADWOOD DISTRICT STA.,13-62 LEAD DISTRICT STA. #9,13-63 STURGIS DISTRICT STA. #2,13-64 RAPID CITY DIST.STA. #19,13-65 STEEL SCHOOL,12-32 DAWSON BORDER, 12-33 TAPPEN BORDER,12-34 GLEN ULLIN MP #3 HAY CREEK STATION.12-37 WILTON H.S.,12-38 WASHBURN H.S.,12-39 WASHBURN VALVE W. OF BORDER POPLAR DIST. #2,VALVE# 1,24-27 WOLFPOINT DIST.STA #2VLV#1,24-26 GLASGOW EMERGENCY VLV,24-25 MALTA STATION #3,VLV #9 MINOT STA #10,20-16 BERTHOLD RISER VLV @SCHOOL,20-17 DESLACS OUTLET VLV,20 -18 BURLINGTON DIST. STA,20-19 TURTLE LAKE HOSPITAL VLV,20-20 Article GREASE GREASE GREASE GREASE GREASE GREASE GREASE GREASE GREASE GREASE GREASE GREASE GREASE GREASE GREASE GREASE GREASE GREASE GREASE GREASE ORBOTUBE GREASE GREASE GREASE GREASE GREASE GREASE GREASE GREASE GREASE GREASE CONDENSATE GREASE GREASE GREASE GREASE GREASE GREASE GREASE GREASE GREASE GREASE GREASE GREASE Sampler A. STIEG A.STIEG A. STIEG A. STIEG A. STIEG A. STIEG H. MEYER H. MEYERS H. MEYERS H. MEYERS H. MEYERS H. MEYERS H. MEYERS H. MEYERS H.MEYERS H.MEYERS H.MEYERS H.MEYERS H. MEYERS H.MEYERS G. ANFINSON G. HIGLIN G. HIGLIN G. HIGLIN G. HIGLIN G. HIGLIN G. HIGLIN G. OLSON G. OLSON G. OLSON D. HILLMAN D. HILLMAN H.A. JOB H.A. JOB H.A. JOB T. WILKINSON T. WILKINSON G. BOYEFF G. BOYEFF VERN REITER VERN REITER VERN REITER VERN REITER VERN REITER Sample Oate 28-NOV-90 29-Nov-90 29-NOV-90 29-Nov-90 29-Nov-90 30-NOV-90 29-Nov-90 29-Nov-90 29-NOV-90 29 -Nov-90 29-Nov-90 28-NOV-90 30-NOV-90 30-NOV-90 30-NOV-90 30-NOV-90 30-NOV-90 30-NOV-90 30-NOV-90 SO-Nov-90 06-Dec-90 28-Nov-90 28-NOV-90 28-Nov-90 28-NOV-90 28-NOV-90 28-Nov-90 27-NOV-90 27-NOV-9Q 27-NOV-90 28-NOV-90 30-Nov-90 29-NOV-90 29-Nov-OO 29-NOV-90 27-Nov-90 26-NOV-90 28-Nov-90 2B-NOV-90 28-NOV-90 29-NOV-9Q 29-Nov-90 29-NOV-90 29-NOV-90 Analyze Date 01 -Jan-91 01-Jan-91 01 -Jan-91 01-Jan-91 02-Jan-91 02-Jan-91 02-Jan-9l 04-Jan-91 02-Jan-91 02-Jan-91 04-Jan-91 02-Jan-91 02-Jan-91 02-Jan-91 02-Jan-91 02-Jan-91 02-Jan-91 02-Jan-91 02-Jan-91 03-Jan-91 11 -Dec-90 03-Jan-91 03-Jan-91 03-Jan-91 03-Jan-91 03-Jan-91 03-Jan-91 03-Jan-91 03-Jan-91 03-Jan-91 03-Jan-91 11-Dec-90 03 -Jan-91 22-Dec-90 04-Jan-91 03-Jan-91 03-Jan-91 03-Jan-91 03-Jan-91 03-Jan-91 03-Jan-91 03-Jan-91 04-Jan-91 03-Jan-91 Pcbppm Arochlor <1 <1 <1 <1 <1 10.8 1254 <1 837.9 1260,1254 <1 <1 121326 1268 25.0 1268 <1 <1 8.6 1242 <1 9.0 1242 <1 12.8 1242 <1 <1 9.9 1242 <1 <1 <1 <1 52.2 1254 <1 1.5 1268 <1 <1 <1 11.4 1268 172.2 1268 148089 1268 2.9 1254 <1 <1 <1 <1 11.0 1268 10.8 1242,1254 1195.5 1268 3.2 1254 PAGES PCB-ARCH-EXT0371925 MDUPCB ANALYSIS PAGE 4 10.2 Location Detail Loc. Article 24 BISMARCK 0.0. UNDERWOOD VLV @ NURSE.HOME,20-21 GREASE 25 BISMARCK 0.0. RIVERDALE SCHOOL VLE.20-22 GREASE 26 BISMARCK 0.0. GARRISON HOSPITAL VLV.20-23 GREASE 27 BISMARCK 0.0. MAX SCHOOL VLV,20 -24 2B BISMARCK 0.0. SURREY DIST STA #14 VLV A,20-25 GREASE GREASE 29 BISMARCK 0.0. GRAFTON REQ STA B,20-29 GREASE 30 BISMARCK G.O. WALHALLA SCHOOL.20-30 GREASE 31 BISMARCK 0.0. LANODON HOSPITAL.20-31 GREASE 32 BISMARCK 0.0. CAVALIER SCHOOL.20-32 GREASE 33 BISMARCK 0.0. PARK RIVER SCHOOL,20-33 GREASE 34 BISMARCK 0.0. SIOUX MFQ. CO.,20-34 GREASE 35 BISMARCK 0.0. DEVILS LAKE REQ STA A.20-35 GREASE 21 BISMARCK 0.0. BOWMAN VALVE #112,15-21 GREASE 42 BISMARCK G.O. MEDINA CN 706966,12-42 GREASE 43 BISMARCK 0.0. VALLEY CITY VLV NAT.GUARD,12-43 GREASE 44 BISMARCK G.O. CLEVELAND CN 216167,12-44 GREASE 45 BISMARCK G.O. SHEYENNE SCHOOL CN 643372,12-45 GREASE 46 BISMARCK 0.0. VALLEY CITY ISO S 194,12-46 GREASE 47 BISMARCK 0.0. FOSTER CITY CN 643367,12 - 47 GREASE 48 BISMARCK 0.0. NEW ROCKFORD CN 643501,12-48 GREASE 49 BISMARCK G.O. JAMESTOWN WLAMART,12-49 GREASE 50 BISMARCK 0.0. NE DIST STA JAMESTOWN,12-50 GREASE 58 BISMARCK G.O. BISMARCK SERVICE CENTER,12-58 ORBOTUBE Sampler VERN REITER VERN REITER VERN REITEH VERN REITER VERN REITER R. BEZARSON R. BEZARSON R. BEZARSON R. BEZARSON R. BEZARSON R. BEZARSON R. BEZARSON M. BAGLEY V. HERMAN V. HERMAN VERN HERMAN VERN HERMAN VERN HERMAN VERN HERMAN VERN HERMAN VERN HERMAN VERN HERMAN A. STOMBERG Sample Date 29-Nov-90 29-NOV-90 29-Nov-90 29-NOV-90 2B-NOV-90 03-Dec-90 03-Dec-90 03-Dec-90 03-DOC-90 04-Dec-90 04-Dec-90 04-Dec-90 29-NOV-90 30-NOV-90 30-NOV-90 30-NOV-90 28-Nov-90 30-Nov--90 2B-NOV-90 28-NOV-90 27-NOV-90 27-NOV-90 11-Dec-90 Analyze Date 03-Jan-91 03-Jan-91 03-Jan-91 03-Jan-91 03-Jan-91 03-Jan-91 03-Jan-91 03-Jan-91 03-Jan-91 03-Jan-91 03-Jan-91 03-Jan-91 04-Jan-91 03-Jan-91 04-Jan-91 04-Jan-91 04-Jan-91 04-Jan-91 04-Jan-91 04-Jan-91 04-Jan-91 04-Jan-91 17-Dec-90 Pcb ppm Arochlor 41.4 1254 <1 6.3 1254 <1 <1 5.2 1242 2.9 1268 <1 <1 <1 <1 3.6 1268 1781.4 1242,1254,1268 <1 <1 <1 <1 <1 <1 <1 2.8 1268 <1 <1 PCB-ARCH-EXT0371926 APPENDIX C DIVISION MAP PCB-ARCH-EXT0371927 NORTHERN BOROER PIPELINE VALLEY INDUSTRIAL iSGOW WOLF/gOlNT ,FRAZER WHITE TAIL FLAXVJLLE antelope] ,TIE TO BASIN ELECTRIC POWER COOPERATIVE COTEAU itolley pagNMARE Lkenastqn Richey >am TIOGA GAS FIELO TEMPLE- / MISSOURI t R 'OGE , field x \ IILLISTONj I ILLE WENTONj SJRENTJ STONY CREEK FIELD IOhlE PASS vJAS FIELO %Ki< BR0RS0N FIELO SIDNE- Y HILL WELD FORT BUFORO *8. TIE-IN CS^alEXANOER- CITY knife RIVER COAL MINING CO. \ EARTH BEAVER LODGE GAS FIELO TERR' GLENDIVE INTAKE WIBAUX GOLVA SENTINEL. | BUTTE rG0LDEN VALLEY HESKETT STATION tNDAft \aSMARCI (ALLEY CITY BIG COULEE FIELD F0RSY1 MILES CIT NORTH LAKE BASIN FIELD BILLINGS JOUETi r*EOGAR PRYOR' (FROMBER Z |DGER INDIAN AGENCY PUMPKIN CREEK FIELD LISCOM CREEK v FIELD ELK BASIN------------m GAS STORAGE FIELD s\ CIB TIE-IN " SOUTH ELK BASIN GAS FIELD GARU r-POLE CAT/ / FIELD r- GARLANO/GAS \ TREATING PLANT GEORGIA-PACIFIC FIELD FIELD GREYBULL RANCHESTER 0AYTON BIO HORN( STORY UTE FIELD CIB TIE-IN RECLUSE FIELD LITTLE GRASS CREEK FIELD WORLAND GAS FIELD, WORLAND. ^ & ENOS CREEK FIELO GRASS CREEK field __ GOLOEF EAGLE A FIELD TMERMOPOLI! MANDERSON UNIT MANDERSON WORLANO COMPRESSOR ANO DESULPHURIZATION PLANT SLICK CREEK GAS FIELD IFFALO BILLY (WEEK, ,,GAS STbRAGi FIELD iayCEE MUDDY RIDGE AND PAVILLION GAS FIELD HOWARD BOYSEN FIELD RANCH FIELO BONNEVILLE \ UNIT MADDEN DEEP UNIT RIVERTON DOME FIELD '% POISON CREEK FIELD RIVERTON EAST FIELD ^POWELL U UNIT ' GAS FIELD ISMAY PLEWA1 BAKE! CEDAR CREEK OIL 8 GAS FIELD HJFFALO .PRINGS COYOTE CfjEEK FIELO HTft AMERICAN COLLOID COMPANY PLANT ST ONCE ruRGiS TCRRaivillC 1 PLUMA LEAO TT. MEADE PlCOMONTI Black hawk# S O STATE CEMENT PLANT y ELLSwRRTM AIR FORCE AIR Ba\e MOUSING BOX ELC*R RAPID CITY / NEW .EIPZIG MORRISTOWN. SELFRiOGE |FULLERT( 'LLENDAL1 (SWICH WOVEN TOLSTOY] .SENECA BIG STONE CITY DIVISION DISTRICT OFFICE TOWNS WITH EMPLOYEES SYSTEM MAP MDU RESOURCES GROUP. INC --= NATURAL GAS PIPELINES A GAS COMPRESSOR PLANTS NATURAL GAS FIELDS TOWNS SERVEO WITH NATURAL GAS @ TOWNS SERVED WITH ELECTRICITY B NATURAL GAS -- PROPOSED NATURAL GAS PIPELINES ---------OTHER COMPANIES PIPELINES PCB-ARCH-EXT0371928