Great Lakes Binational Toxics Strategy

Polychlorinated Biphenyls (PCB) Workgroup

Stakeholder Meeting - November 14, 2001

CANADA - UNITED STATES STRATEGY FOR THE VIRTUAL ELIMINATION OF PERSISTENT TOXIC SUBSTANCES IN THE GREAT LAKES

PCB Workgroup Update

The purpose of this report is to present progress made by the PCB Workgroup in support of the challenges for Canada and the United States under the Great Lakes Binational Toxics Strategy (BTS). In particular, this report addresses those activities undertaken since the last BTS stakeholder meeting held in May 2001. Additional information on PCB Workgroup activities can be found on the BTS PCB website at http://www.epa.gov/glnpo/bns/pcb.

Canada's Challenge

Seek by 2000, a 90 percent reduction of high-level PCBs (>1 percent PCB) that were once, or are currently, in service and accelerate destruction of stored high-level PCB wastes which have the potential to enter the Great Lakes Basin, consistent with the 1994 COA.

United States' Challenge

Seek by 2006, a 90 percent reduction nationally of high-level PCBs (>500 ppm) used in electrical equipment. Ensure that all PCBs retired from use are properly managed and disposed of to prevent accidental releases within or to the Great Lakes Basin.

Quantitative Progress

High Level PCBs and Number of Storage Sites in Ontario, Canada Canada:
As of April 2001, approximately 80% of high level PCB waste has been destroyed, up from approximately 40% in Spring 1998 when work in support of the BTS commenced. Further, approximately 25% of low-level PCB waste has been destroyed (a large portion of the remaining low level waste is soil from a contaminated site clean-up, stored in an engineered contaminated facility). It is expected that strong progress towards the target will be sustained. Awareness among owners continues to increase, options available for destruction have increased over the past 2 years, and owners of large quantities have been able to incorporate PCB phase-out/destruction into multi-year operating plans. See Environment Canada's PCB Owner Outreach Bulletin.

USA - Apparent 90% reduction in number of PCB transformers United States:
EPA still expects that the U.S. challenge for PCB reduction will be met by 2006. The 1999 PCB Transformer Registration Database shows that there are approximately 20,000 PCB transformers currently registered and in use in the U.S. but the actual number remaining in use is likely to be higher due to the number of transformers that have not had their oil tested and are not registered on the database. However, reductions of PCB transformers and capacitors continue to occur. EPA is currently evaluating data on the amount of PCBs destroyed over the past 5 years which will help track progress towards meeting the U.S. challenge.

PCB Reduction Commitments

Canada:
Since the PCB Workgroup's PCB Commitment Letters were mailed out in late 1999, to the automotive and iron and steel sectors, all four steel companies have returned their responses, along with all three automotive industries. In addition, in response to Environment Canada-Municipal Electrical Association mail out of commitment letters in February 2000, 15 of the 20 largest utilities including Toronto Hydro and 21 other utilities have submitted their commitment letters to EC. Due to recent amalgamation of 250 electric utilities into approximately 90, a new mail-out was completed in October 2001. Ontario Power Generation (OPG), a major utility in Ontario (Formerly Ontario Hydro) adopted a corporate policy approved by the board of members to phase out and destroy approx. 81% of OPG's high level PCB by 2005 and 100% by 2015. Environment Canada's proposed new PCB Regulations require PCB phase-out to be complete by 2010.

In addition, PCB phase-out commitment letters have also been sent out to the Council of Great Lakes Industry (CGLI) trade associations such as: Aluminum Association of Canada, Canadian Petroleum Products Institute (CCPI and its members eliminated 90% PCB), Ontario Forest Industries, Hearth Products, Vinyl Council and Canadian Portland Cement Association. In spite of several follow-ups, response from Hearth Association, Canadian Portland Cement Association and Forest Association are tardy to Environment Canada's letter dated November 2000.

DaimlerChrysler Canada has shown leadership in phasing out hazardous materials at its Ontario facilities. The company is planning to dispose of their PCBs in the Windsor and Toronto areas by the end of the year 2002. The company has already removed all the high-level PCBs from transformers and capacitors at its facilities and shipped them to a government-licensed incinerator in Swan Hills, Alberta for destruction.

Algoma Steel Inc.'s Ontario operations have voluntarily committed to eliminate, by the end of December, 2005, a volume equivalent to the estimated 71,103 kilograms (44,400 litres) of PCBs that were held in approved storage as of the end of 1999. The elimination of the firm's existing stored inventory was originally scheduled to begin in 2001. Algoma seized an opportunity in 2000, a year ahead of its own schedule, to proceed with the direct shipment and destruction of approximately 13,300 kilograms (8,300 litres) of PCBs from equipment being taken out of service.

Slater Steel Company, Hamilton, Ontario advised Environment Canada that they had removed all of their PCB materials by the end of 1998.

U.S.:
U.S. EPA, with support from Counsel of Great Lakes Industries, sent letters to five major national trade associations seeking their support and assistance in pursuing voluntary reductions of PCBs by their membership: American Forest and Paper Association, American Petroleum Institute, American Zinc Association, International Copper Association, and the Aluminum Association. Most of the associations contacted their members about the letter and EPA's voluntary PCB reduction efforts, the others plan to.

EPA also identified other individual businesses and trade associations targeted for additional outreach under which voluntary reductions of PCB equipment will be sought.

Information Resources

PCB Reports
Reports entitled Report on Polychlorinated Biphenyls (PCBs): Sources and Regulations and PCB Step Three Report: Options for Reducing PCBs addressing Steps 1, 2 and 3, respectively, are posted on the BTS PCB website (www.epa.gov/glnpo/bns/pcb).

Outreach
The web site for the PCB workgroup was updated and information the workgroup had been working on was finally posted (see www.epa.gov/glnpo/bns/pcb). The new information included photographs of transformers and capacitors, which should help increase the awareness of the types of equipment that may contain PCBs by displaying actual examples of the equipment; a fact sheet on submersible well pumps; and a case study on the removal of PCBs provided by Bethlehem Steel, which is intended to promote the removal of PCBs by companies that have not yet done so by providing examples of beneficial factors considered when companies decide to remove their PCBs. In addition, the workgroup is updating the standard presentation that can be used by members and non-members to help describe the Binational Strategy, the PCB workgroup challenges, actions, and PCB reduction commitments being sought when they meet and associate with other potential stakeholders. All of this information is intended to encourage and facilitate the identification and removal of PCB equipment.

U.S. PCB Phasedown Program

Six of the eleven utilities EPA approached last year seeking their commitments to voluntarily phase down their remaining PCB electrical equipment responded to date. All six committed to continue to remove any PCBs they have or find, two stating they already removed all of their known high concentration PCBs. None of the six took advantage of the programs' self-disclosure policy. The five utilities which have not submitted formal responses requested more time to consider the obligations, policies, and incentives of the program Under the pilot project, if a utility commits to remove its PCB equipment and self-disclose any potential violations of the PCB or TRI regulations, as an incentive, EPA would offer reductions to any penalty that may be assessed, up to 100% in some cases.

PCB Phaseout at Federal Facilities

In an effort to reduce the PCB equipment owned by the U.S. Government, EPA identified which Federal facilities own PCB transformers and then evaluated ways to phaseout the PCBs. The main approach was determined to be a letter from a senior EPA official to counterparts at the other Federal Departments or agencies seeking reductions of their PCBs combined with necessary follow-up. The letter is in draft.

Regulatory Activities

Amendments (Canada)
Environment Canada's regulatory amendment process is underway which proposes strengthening of federal regulations regarding PCB management. The Chlorobiphenyl Regulations and Storage of PCB Material Regulations were promulgated in 1977 and 1992, respectively. Combined, these two regulations presently address management aspects including use, sale, manufacture, release, and storage. Highlights of the proposed amendments would strengthen these regulations as follows:

PCB phase-out from sensitive sites
Limit levels in products to 2 ppm (pigment)
PCB storage time of 2 years
Phase-out of all uses by 2008
Prohibition against storage after 2010 for existing stored material

An extensive public consultation was conducted during the summer and fall of 2000. The amended regulation could be promulgated in the year 2002 in Gazette II.

PCB Waste Export Regulations (SOR/97-108) is being amended and will be published in Gazettte 1 in 2002. Public consultation is planned in December 2001.

A notice with respect to Polychlorinated Biphenyls in Automotive Shreader Residue was published in the Gazette, Part I on 7th July, 2001 for automobile shreaders facilities that generated residue contaminated with PCBs during 1998, 1999 or 2000.

Coordination with the Lakewide Management Program (LaMPs)

Environment Canada has prepared and mailed out a package of information in September 2001 to all small quantity PCB owners (approximately 340 companies) in the Lake Superior and Lake Erie drainage basins. The purpose was to raise awareness of PCB initiatives underway in support of the GLBTS. The package included the PCB Owner Outreach Brochure, BTS-PCB Workgroup Activity Regional Update, a fact sheet of Ontario PCB in-use inventory survey results and PCB location/quantity map of Lake Superior or Lake Erie Basin.

Within EPA, the workgroup leader and the LaMP managers worked together to coordinate the workgroup's PCB reduction efforts with the LaMPS in developing a Great Lakes Commitment Tracking database.

GLBTS Links