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Great Lakes Binational Toxics Strategy

Polychlorinated Biphenyls (PCB) Workgroup

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

Stakeholder Meeting – May 16, 2000
PCB Workgroup – Progress Report

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 November 1999 in Chicago, Illinois.

The Challenges

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.

Progress

Quantitative Progress:

Canada

Graph showing 70% reduction in high level PCBs


United States

Graph showing 90% reduction in number of transformers

Canada:

To date, approximately 70% of high level PCB wastes have been destroyed, up from approximately 40% from 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 remaining low-level waste is soil from a contaminated site clean-up, stored in an engineered containment 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 larger quantities have been able to incorporate PCB phase-out and destruction into their multi-year operating plans.

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. Although reductions of PCB transformers have occurred since 1994 and continue to occur, reductions alone may not account for the difference between the 1994 baseline of 200,000 estimated transformers containing high level PCBs and the 1999 database total. The PCB Workgroup will be re-evaluating the 1994 baseline after EPA compiles data on PCB disposal activities between 1995 and 1999.

The Four Step Analytical Process

With completion of Steps 1 and 2, PCB Workgroup activities continue to focus within Step 3, broadening into Step 4, of the Four Step Analytical process. The Workgroup documented progress in the following specific areas:


Information Resources:

PCB Sources and Regulations Report
The PCB Sources and Regulations report (addressing Steps 1 and 2) was updated. Comments on the Draft PCB Sources and Regulations Report were received from the Council of Great Lakes Industries, General Electric, the Utility Solid Waste Activities Group, and Virginia Power. A summary of the comments, and EPA’s response to these comments, was prepared. The final report incorporates many of the comments, as well as new data obtained from the PCB Transformer Registration Database (December 1999) and the 1996 Air Toxic Emissions Inventory for PCBs. An advisory was sent to all PCB subscribers to alert them to the report being posted.

PCBs in Submersible Well Pump Fact Sheet
As recommended at the November 1999 meeting, a sub-group was formed to determine ways to communicate potential dangers associated with PCBs in submersible well pumps. The sub-group held a conference call on February 3, 2000. The group agreed to gather existing information on PCBs in submersible well pumps and develop a Workgroup Fact Sheet based on the information obtained. A draft Fact Sheet has been developed, and once finalized, will be posted on the PCB Workgroup website.

Equipment Photographs
As suggested during the November meeting, the PCB Workgroup began to identify sources that can provide photographs of electrical equipment which may contain PCBs (transformers, capacitors, fluorescent light ballasts, etc.) and initiated communication and coordination with a similar effort under the U.N. It is hoped that collected photographs can be placed in a clearing-house (such as the PCB Workgroup website) to help increase the awareness of the types of equipment that may contain PCBs and what this equipment looks like.

In-use Inventory Survey (Canada)
Environment Canada has undertaken to update its inventory of in-use PCB equipment. A letter and survey were recently mailed to the approximately 500 registered owners of in-use PCB equipment in Ontario, requesting updated information if applicable, as well as a questionnaire requesting information on plans for decommissioning and destruction. To date, approximately 40% have returned the survey and approximately 30% of those surveyed have returned questionnaire information on future PCB management plans. A report on survey results will be completed by July 2000 and reported to the Workgroup.

PCB Transformer Registrations (United States)
The 1999 update to the PCB Transformer Registration Database shows that there are 20,741 transformers (up from 18,714 in 1998) registered and in-use in the U.S., containing a total of 109,626,878 pounds of PCBs (up from 108,625,659 pounds in 1998). While the database provides the best existing and current information on the number of PCB transformers remaining in use, it has not been thoroughly quality controlled.

Cook County (Illinois) PCB and Mercury CleanSweep
Collection of PCB and mercury containing waste continued with another park district in Cook County generating fluorescent bulbs and lamps. Due to the lower than expected participation, the CleanSweep partners extended the collection phase of the program until October 21, 2000, and began a mailing of outreach material on the project targeted at specific small businesses and municipalities. As a result of the mailings, several potential generators called the hotline about the program and may arrange for pick-ups of PCB and/or mercury containing waste.

PCB Reduction Commitments

PCB Phasedown Program
EPA met with representatives of nine of the major utilities serving the Great Lakes Basin to present the final provisions of the PCB Phasedown Program. This program is a pilot project in EPA Region 5 designed to obtain commitments from utilities to remove their remaining PCB transformers, capacitors, and voltage regulators. 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. EPA expects to obtain commitments from the utilities early summer of 2000.

Commitment Letters
PCB reduction commitment letters have been sought from three sectors in Ontario – automotive, iron and steel, and utilities. In the automotive sector initiative, have been received from DaimlerChrysler and Ford. General Motors has verbally responded that their commitment letter will be forthcoming.

Following a presentation to the Canadian Steel Producers Association, commitment letters were mailed to association members. Positive responses were received back from Algoma Steel and Slater Steel. Dofasco and Stelco have verbally responded that their commitment letters are forthcoming.

Most recently, the Municipal Electric Association has partnered to distribute the PCB commitment letter to their approximately 250 member utilities across Ontario. To date, approximately 30 positive responses have been received. Responses came from both large and small utilities. Further responses are expected to follow.

Recognition of Reduction Commitments
The PCB reduction commitments obtained from the major U.S. automobile manufacturers (DaimlerChrysler, Ford, and General Motors) received public recognition in January when EPA issued a press release announcing receipt of these commitments. In March 2000, EPA Region 5’s Regional Administrator presented plaques to representatives of each company at the Southeast Michigan Counsel of Government’s general assembly meeting. The press release was picked up by several media sources, including Occupational Hazards (1/27/00) the Environmental News Service (1/28/00). All three automobile manufacturers committed to go beyond the PCB challenge and achieve 100% removal. 

Engaging Stakeholders in Further Reduction Commitments
Representatives of the Council of Great Lakes Industries (CGLI) and the PCB Workgroup leaders have discussed the following initiatives:

Regulatory Activities

Amendments (Canada)
Canadian Environmental Protection Act (CEPA)

In April 2000, a renewed CEPA was promulgated. The new CEPA contains sweeping amendments to strengthen the Act. In particular, with respect to provisions related to waste management, the Act now gives the federal government the authority to deny application for a proposed transboundary movement on the basis of environmentally sound management. The federal government will commence the process of developing guidelines for environmentally sound management for public consultation.

PCB Regulations Consultation

A 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 future proposed amendments would strengthen the Regulations as follows:

Public consultation on proposed amendments is expected to begin in Summer 2000.

Coordination with LaMPs

The Workgroup leaders reviewed and provided input on the PCB action plans in the LaMPs for Lakes Superior, Michigan, and Erie. Where possible, identified opportunities will be followed up to leverage BTS PCB-related activities to further LaMP activities.

 


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