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Great Lakes Binational Toxics Strategy
Implementation Meeting
Stakeholders Minutes - March 23,
1998
Chicago, Illinois
POLYCHLORINATED BIPHENYLS (PCB) Meeting Minutes
Workgroup Leaders:
Environment Canada: Hamish St. Rose
U.S. EPA: Tony Martig
Facilitator:
Abra Bennett, Ross & Associates
Discussion of goals and work plan for workgroup:
The meeting got underway at approximately 11:00 a.m. and the
workgroup members identified their goals for the PCB workgroup. A list of the goals was
recorded and is attached on the Record of Flip Charts. The goals varied, but the following
summary attempts to capture and consolidate the goals discussed during the meeting.
- Reduce release and input of PCBs to and from the Great Lakes
Basin.
- Focus on the specific (PCB use) reduction challenge in the
Binational Toxics Strategy (Strategy).
- Share experiences, perspectives and technical data.
- Increase awareness of the Strategy.
- Investigate cleanup and disposal options, with PCB Challenges
in mind.
- Address presence and levels of PCBs in sediments and other
media.
- Coordinate with other activities (LaMPs, RAPs).
- Have a consistent goal and definition (of high-level of PCBs)
and ensure the goal is met.
Step 1 - Discussion of status of chemical (i.e.,
inventory, emissions sources, etc.):
Environment Canada (presented by Larry Talbot, EC contractor)
The Canadian challenge is to decommission 90% of the
high-level PCBs (>1%) in-service and to accelerate destruction of stored high level
waste by the year 2000. Information gathered in support of the challenge comes from:
- 1991 IJC- Program to Restore and Protect the Lake Superior
Basin,
- 1994 Canada-Ontario Agreement (COA),
- Toxic Substances Management Policy, and
- Commission for Environmental Cooperation (CEC).
Under the 1994 Canada - Ontario Agreement (COA), achievements
to the end of 1996 are:
- 46% of the 1994 baseline has been decommissioned, and
- 30% of the baseline waste has been destroyed.
Under COA 2.2, achievements to the end of 1996 are:
- 85% of Ontario's federal PCBs were destroyed, and
- all of Transport Canada=s stored PCBs were destroyed.
EC maintains a database to track both PCBs in-use (federal
and non-federal) and PCBs in-storage (federal) as waste. The Ontario Ministry of the
Environment maintains an inventory of non-federal PCBs in-storage as waste. Information
regarding PCBs in-use is collected for the database on a voluntary basis, while
information regarding PCBs in-storage must be reported per EC regulations. EC is working
with the Ontario Ministry of the Environment to increase the databases' capacity.
Under a Canada-Ontario Agreement Initiative, information on
PCB storage has been mailed to almost 1,750 members of the regulated community.
Information is being collected and shared under the following efforts:
- Commission for Environmental Cooperation (CEC), and the
- PCB North American Regional Action Plan (NARAP).
As part of the Small Quantity Owner Outreach Program, EC held
8 workshops in the Province of Ontario to educate and exchange information with PCB
owners. More workshops are scheduled in Ontario for Spring, 1998.
United States (presented by Tony Martig, U.S. EPA)
The U.S. challenge is to seek a 90% reduction nationally of
high level PCBs (>500 ppm) used in electrical equipment and ensure that all PCBs
retired are properly managed and disposed. The baseline information came from 1994
estimates of PCB electrical equipment still in use. Information used to track the
reductions of PCBs in electrical equipment and environmental media will come from various
programs, including:
- U.S. EPA [Toxic Substances Control Act (TSCA), Great Lakes
National Program Office (GLNPO) and Water programs]
- State Water programs
- Environment Canada
- Non-governmental organizations
After these presentations, several issues were raised as
noted below:
- The Canadian and U.S. challenges should use the same
definition of high-level PCBs and should use the same units (e.g., pieces of equipment or
weight).
- Sources which discharge PCBs into the Great Lakes should be a
focus of this workgroup.
- Compiling a list or inventory of PCB publications, guidance
and training material, would be useful.
- How much government owned PCBs in Canada have been destroyed?
- An inventory of the in-service equipment should be the
workgroup's priority.
- The workgroup should not spend too much time on information
gathering, but should focus on the reduction challenge instead.
- One workgroup member estimated that much of the PCB equipment
is about 40 years old and will probably be removed by 2015 - however, 10% may remain in
use beyond 2015 because owners may not be aware they have such equipment.
- A geographic information system (GIS) map showing present PCB
in-service and in-storage locations and concentrations would be a valuable resource.
Action items to the above issues include:
- U.S. EPA will make available the spill reporting data it
researched for the PCB Phasedown Program.
- The workgroup needs to follow-up with the LaMP efforts in
developing the inventory of PCB information.
- EC will report how much government owned PCBs have been
destroyed.
- EC and U.S. EPA will make available their PCB outreach
material.
Step 2 - Discussion of current and upcoming
regulatory status:
Environment Canada (presented by Larry Talbot, EC contractor)
PCBs are regulated in Canada under various federal and
provincial acts, including the Canadian Environmental Protection Act (CEPA), the Ontario
Environmental Protection Act (OEPA), the Transportation of Dangerous Goods Act (TDGA) and
the Fisheries Act.
The federal regulations promulgated under these acts ban the
manufacture, sale and import of PCBs, control releases, and stipulate storage, treatment
and disposal requirements. They also regulate the transportation and export of PCBs. The
renewal of CEPA will focus on pollution prevention and getting PCBs out of the
environment.
The Ontario Provincial Regulations, promulgated under OEPA,
regulate the transportation, storage and mobile destruction of PCBs and are under revision
to encourage consolidation/treatment/destruction of PCB waste.
United States (presented by Tony Martig, U.S. EPA)
In the United States, PCBs are regulated under the Toxic Substances Control Act (TSCA),
the Clean Water Act (CWA), the Safe Drinking Water Act (SDWA), the Comprehensive
Environmental Resources and Compensation Liability Act (CERCLA) and the Clean Air Act
(CAA). PCBs are also regulated under state environmental agencies, and other federal and
state agencies such as the Occupational Safety and Health Administration (OSHA) and the
Department of Transportation (DOT).
The Federal PCB regulations, promulgated under TSCA and found at Title 40, Part 761 of the
Code of Federal Regulations, ban the manufacture of PCBs, prohibit or regulate their use,
include requirements for storage and disposal of PCB waste, and also include requirements
for spill cleanup, decontamination, waste tracking and record keeping. These regulations
specifically authorize the continued use of high-level PCBs in electrical equipment.
Amendments to the federal PCB regulations are forthcoming and
may help achieve the PCB challenge by streamlining disposal options and requiring owners
of PCB transformers to register their PCB transformers with EPA. The amendments will also
recognize additional methods to dispose of PCB waste and will authorize additional
procedures to reclassify transformers from a high level (>500 ppm).
Step 3 - Discussion of cost effective options for
reduction:
In addition to regulatory support by federal, state and provincial governments,
non-regulatory efforts are being carried out to achieve PCB reductions. These efforts
include, Lake-wide Management Plans (LaMPs), Commission for Environmental Cooperation
(CEC), Regional Action Plans (RAPs), U.S. EPA=s Persistent Bioaccumulative & Toxics
Initiative ( PBTI), the PCB Phasedown Program and PCB Clean Sweeps.
After these presentations, several issues were raised as
noted below:
- Adequate resources must be applied to achieve the Strategy's
PCB challenge.
- This workgroup should focus on results - actual reductions and
effective reduction strategies.
- Federal use of progressive enforcement tools (multi-media
SEPs, discretion) should be used when applicable.
- Utilities should be encouraged to work with customers and
non-governmental organizations.
- Peer to peer recruitment will be critical to PCB workgroup
success - workgroup members have a responsibility to spread the workgroup's information
and increase its efforts/membership.
- Incentives (awards or plaques, similar to 33/50 program,
property assessments) for removing/disposing PCB material are essential and need to be
developed.
- Abandoned sites and electrical equipment need to be addressed.
- Information and workgroup success needs to be public
information - the workgroup should prepare information in support of education/outreach.
Step 4 - Recommendations and Implementation of Actions
Based on the discussion of effective options, the action
items noted below were identified for the workgroup. Until the electronic discussion forum
for the Strategy is completely functional, information for a respective action items
should be submitted to the person who volunteered to lead the effort for the action item.
- Refer also to action items already noted under Step 1
- Establish a functional conversion for the comparison of U.S.
and Canadian PCB units to measure reduction achievements (Tony Martig and Hamish St.
Rose) Due: 6/15/98
- Identify gaps in available governmental, non-governmental and
industrial data resources to determine if collecting and compiling additional information
is beneficial. Compile existing data resources (all workgroup members - lead: Tony
Martig) Due: 6/15/98 - ongoing
- Identify PCB reduction incentives (all workgroup members -
lead: Hamish St. Rose) Due: 6/15/98 - ongoing
- Produce APCB Reduction Success Stories (all workgroup
members - lead: Tony Martig) Due: 6/15/98
- Collect relevant use, discharge and inventory information (all
workgroup members - lead: Hamish St. Rose) Due: 6/15/98
- Develop a list of training materials and public
education/outreach materials (all workgroup members - lead: Kaushal Khanna , Due:
6/15/98
- Contact Edison Electric and USWAG regarding PCB workgroup (lead:
Kathy Clancy) Due: 6/15/98
- Draft a memo on sediment for Integration Group consideration (leads:
Greg Hill and Emily Green) Due: 6/15/98
- Develop a peer-to-peer partnership plan (lead: Tracy
Meehan) Due: 6/15/98
- Draft an issue paper on government-owned PCBs (Tony Martig
and Hamish St. Rose) Due: 6/15/98
- Submit technical information to the workgroup on land filling
of PCBs (lead: Mitch Hahn) Due: 6/15/98
Discussion of the need to identify and recruit additional
members:
The session was attended by representatives of industry, both users of PCB equipment and
waste handlers, several trade associations and non-governmental organizations, and federal
and state government representatives. A roster of participants is attached.
It was suggested that the workgroup needs to be more diversified, balanced by
representatives from different sectors and include more owners of PCBs. Specifically,
attempts will be made to recruit representatives of:
- various trade associations,
- additional non-governmental and environmental organizations,
- additional utilities since they account for 70 to 80% of PCB
generators,
- manufacturers of PCBs and electrical equipment (Monsanto, GE,
Westinghouse, etc.), and
- demolition industries.
The National Oil Recyclers Association (NORA) has started
distributing BNS information to their members and will continue these efforts. U.S. EPA
will attempt to recruit representatives of the U.S. manufacturers of PCBs and electrical
equipment. A letter inviting participation from Canadian PCB stakeholders will be mailed
by EC. Due 5/15/98
Issues identified for referral to Integration Group:
- A paper on lake sediments as ultimate dischargers to
atmosphere/sediments relevance.
There were differing views on how the workgroup should
address PCBs in sediment. Some objected to having the workgroup address sediments because
PCBs in sediment were not part of the specific PCB challenge, addressing sediments may be
beyond the scope of the workgroup and may involve additional workgroups, sediment are a
separate challenge under the Strategy, and because there already are ongoing efforts to
address PCBs in sediments. Some supported having the workgroup address sediments because
PCBs could be "released" from sediments into the lakes and because it was more
of a risk than PCBs in electrical equipment.
Discussion of any upcoming events or activities pertaining
to the workgroup (i.e, next conference call, meeting, with specific dates if any):
- No meetings were scheduled, but it was suggested that future
meetings will be necessary.
- There will be a check-in around May 15, 1998 and the first Due
date for the various action items will be June 15, 1998.
- The workgroup will use e-mail and internet resources to gain
momentum. However, there were some concerns about the efficacy of electronic
communications. If e-mail or internet is extensive or if limited progress dictates holding
a meeting, we can re-assess the need for a meeting.
- The next meeting should have more focus on actual reductions
strategies and actual reductions achieved.
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