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Great Lakes Binational Toxics Strategy

IMPLEMENTING THE BINATIONAL TOXICS STRATEGY
Implementation

Stakeholders Forum
November 16-17, 1998 - Chicago, Illinois

PCB Workgroup Attendance

Workgroup Leaders:
Tony Martig, US EPA, Region 5
Hamish St. Rose, Environment Canada, Ontario Region

Facilitator:
Allison Pedley, Ross & Associates Environmental Consulting, Ltd.

Attendees

Objective and Review of Progress:

The meeting began with Tony Martig describing the desired objectives of the afternoon session. It was hoped that by the end of the day, the Workgroup would have a plan of activities to undertake for the next 6-18 months that will lead the group towards completion of the 4-step process. The meeting then turned to a "Review of Progress" since the Workgroup last met on March 23, 1998, reviewing Workgroup activities accomplished to date. These activities included: drafting a PCB Outreach Plan; submitting a memorandum to the Integration Group on how contaminated sediments should be addressed under the BNS; and web site posting of the PCB Sources and Regulations report, and PCB Options Paper.

As follow-up to these items, Tony suggested that the Outreach Plan and PCB Sources and Regulations report and PCB Options Paper review continue as key workgroup activities. Other tasks identified at the first Workgroup meeting (such as identifying data gaps, formulating inventories) will be addressed as the PCB Sources and Regulations report and PCB Options Paper are reviewed and updated. Although the Workgroup will not address sediments specifically, it can include information about sediment contamination in the PCB Sources and Regulations report, as appropriate.

Tony also spoke briefly about the U.S. reduction activities that are underway. In addition to the specific reduction activities mentioned in the PCB Workgroup Progress Report (copies of the progress report can be found on the BNS web site), Tony discussed finalization of amendments to the Federal PCB regulations which became effective in August 1998 and require U.S. Companies with transformers over 500 ppm to register the equipment with EPA by December 28 of this year. The amendments also contain modified disposal requirements which expand disposal options and decontamination requirements. It is expected that complete data on the registration of PCB transformers will be gathered from March - June 1999.

Hamish St. Rose then provided an overview of progress in Canada. Hamish first discussed progress by way of increased PCB awareness through education and outreach activities. This has included: (1) small quantity owner outreach across Ontario; (2) increased outreach to the Municipal Electric Association (which includes 250 utilities) and the Ontario Mining Association (29 mineral and ore producers); and distributing information on PCB management to the City of Toronto. Various forms of outreach included (or will include): web site linkages; newsletter articles; in-person meetings; and mass mailings. Hamish also mentioned a new disposal option in Canada for PCB equipment owners -- TransCycle Industries -- which recently opened in Kirkland Lake, Ontario. This is a new transformer/capacitor/ballast destruction facility.

Hamish also discussed proposed regulatory reform initiatives in Ontario. The public comment period for the General Waste Management Regulation closed in September. The amendments address PCB management to facilitate PCB destruction. This includes mandatory registration of PCB use and mandatory PCB removal at defined "sensitive sites" (locations close to food processing facilities, ambulatory care, schools, etc.).

Hamish stressed the need for active, effective, user-friendly communication in making progress with the BNS. This includes working with EPA to strengthen information capacities (e.g., creating an electronic Binational information clearinghouse), engaging additional stakeholders, and continuously highlighting success stories on the website. This can help provide essential information to small-quantity owners and others who may want to take action, and can provide an opportunity for those who have taken action to communicate both problems and successes.

The "review of progress" then continued with brief discussion of specific stakeholder activities. Brief presentations and/or discussion proceeded surrounding: the Northern Indiana Public Service Co. (NIPSCO) advances towards virtual elimination; the National Oil Recycler’s Association (NORA) PCB Cleansweep program; the Cook County (Illinois) PCB/Mercury Cleansweep Partnership; PCB Management at Ontario Hydro; and Small Quantity PCB Owner Outreach in Ontario, the U.S. Automotive P2 Project, and Bethlehem Steel Corp. PCB reduction efforts at the Burns Harbor Division.

Discussions of key issues surrounding these efforts are outlined below.

Barriers to Obtaining Commitments and/or Reductions

Lack of sufficient disposal option
Lack of funding to undertake elimination activities (e.g., lack of available/alternative destruction technology and/or disposal sites) and/or lack of funding to make necessary equipment replacements, in some cases
"Disconnect" between those who make the commitment and those who write the budgets
Complicated rules and requirements for storage and disposal create compliance uncertainties and potential disincentives
Challenges for smaller dischargers:

may be less aware of the problem
little chance of inspections
small volume disposal may be more of a "hassle"

Mixed media and different regulatory requirements complicate compliance
Difficult to determine the risks associated with elimination

Eliminating Barriers to Creating Working Partnerships

Dischargers can hire "environmental" staff who understand requirements
Governments can offer subsidies for the creation and use of new/alternative destruction technologies
Include user-friendly explanation of regulatory requirements as part of outreach activities
Communicate the availability of risk assessment tools more broadly

Additional Workgroup-specific Barriers

Insufficient time and resources to accomplish all goals
Inconsistent understanding of the types of efforts that can contribute to BNS goals
Identification of adequate levels of incentives/recognition necessary for partner commitments
Finding the most efficient way to "segment" and optimize outreach activities
Reaching and obtaining commitments from the "small emitters"
Sustaining stakeholder participation

PCB Outreach Plan

The meeting then turned to a detailed discussion of options for moving forward with PCB Outreach Activities. The Workgroup agreed that an important first step is to identify potential candidates. One suggestion was to target commitment opportunities using the registration list that will arise out of the new U.S. PCB rule requirements. A potentially "streamlined" approach involving outreach via industry associations was also forwarded. The group agreed that no single approach will work, and that multiple outreach activities will need to be developed. Ultimately, a top-down, incremental approach was suggested, where commitments from larger entities can serve as examples and "lessons learned" for smaller dischargers. Some ideas for industry association outreach included:

getting time on association meeting agendas
getting space on association newsletters
soliciting links to association/industry websites
creating a "speakers circuit" and visit state/regional association chapters

The Workgroup also discussed the potential value of drafting a letter that could be sent from "high level" EPA/EC administrators describing the BNS and inviting company participation and/or commitments. Some group members thought this should be an approach undertaken by the Integration Group, and should represent all Workgroup substances. Others thought this type of outreach should remain PCB-specific. Regardless, it was agreed that companies will need to be "ready" to receive this type of letter, or it could potentially go un-noticed. This would necessitate prior outreach by the Workgroup.

The "PCB Use Tree," which can be found in the PCB Sources and Regulations document (Appendix A) was also mentioned as a tool for obtaining updated information about PCB emitters. The Workgroup discussed the possibility of sending the PCB Use Tree to sources, ask them if they still belong on the "tree" as a source of PCBs, and ask them to provide updated information.

In discussing the type of "incentives" that could be provided to partners, it was agreed that some form of recognition will be the most likely option. However, recognition is not always the most attractive incentive for sources. It was mentioned that in some cases, sources prefer to remain anonymous. Therefore, as with the entire outreach strategy, the proper incentives will likely need to be decided on a case-by-case basis. In discussing options for actual commitment language, the Workgroup again agreed that language may need to vary, depending on the partner. It was suggested that the Workgroup look to the Green Lights and 33/50 programs for examples of actual commitment language. Ultimately, the Workgroup agreed that the most effective way to address PCB outreach is to create a smaller group (such as a "communication sub-group") that can work on more specific details of strategy options. A detailed path forward for PCB outreach activities, utilizing the sub-group option, is identified below under "Next Steps."

Communications

The Workgroup first discussed ways in which inter-group communication could be improved. Several members stated that direct e-mail communication is preferable to having to read and review information by accessing the BNS PCB website. There was general agreement that the Workgroup would increase direct e-mail communication, but continue to post relevant information on the BNS PCB website.

The Workgroup intends to post all information regarding existing efforts and success stories on the BNS PCB website. Ultimately, it is hoped that this site will serve as a primary source of information regarding PCB elimination opportunities. The Workgroup hopes to identify other PCB-related links that can be placed on the BNS website, so potential partners can access this additional information easily. As well, links to partner websites will be made to the BNS PCB website, as appropriate. The Workgroup also discussed the possibility of targeting industry newsletters.

Measuring Progress

Before discussing potential options for measuring progress, some Workgroup members inquired as to what exactly "success" means under the BNS. In particular, questions were raised regarding the value of considering a broad spectrum of sources, when the challenge is limited to transformers and capacitors. Tony clarified that while the Workgroup is to focus on the specific challenge, looking at the broader spectrum of sources and options should not be discouraged in any way.

In discussing ways to evaluate short-term progress, the Workgroup brain stormed the following measures. Goals will be considered "met" if achieved by the next Stakeholder meeting, tentatively scheduled for April:

Monthly conference calls of the Communication Sub-group;
At least one conference call of the entire PCB Workgroup (first call tentatively is scheduled for the 2nd week of January, specific date and time TBA);
Completion of the PCB Sources and Regulations report;
Completion of the PCB Options Paper;
Revisions to the Activities by Partners report;
Initial implementation of the PCB Outreach plan

identification of sectors
letter(s) seeking commitments
identification of new partnerships;

Additional stakeholders (e.g., from other Great Lake states, provinces, and cities) committed to participate in the PCB Workgroup.

It was also decided that long-term progress will be measured using PCB electrical equipment inventories and the same measures included in U.S. EPA’s Multimedia Strategy for Priority Persistent, Bioaccumulative and Toxic (PBT) Pollutants, dated November 16, 1998, as applicable and as the data is available.

Next Steps

Overall, the following is a course of action that the PCB Workgroup intends to undertake over the course of the next year, by Step:

Steps 1 & 2

Update and revise to the "PCB Sources and Regulations" background information document. This document will address the new federal (U.S.) PCB regulations, as well as existing data on PCB holdings and releases;
Investigate government owned PCBs at federal facilities;

Step 3

Existing

Continue to identify incentives and enforcement/compliance strategies for facilities nationwide to commit to remove PCB equipment under the Region 5 PCB Phasedown Program and Environment Canada’s PCB Outreach Activities in the Province of Ontario.

New

Update and revise the draft "PCB Options Paper" on virtual elimination of PCBs;
Optimize use of the new US EPA PCB transformer registration requirement to identify new partners;
Send letters to Great Lake States, Provinces, and major metropolitan areas not currently involved in the process. This letter will explain the BNS, Workgroup, and invite participation and reduction commitments (when possible);
Investigate Risk Assessment "tools" (example - Electric Power Research Institute software)
Create a "Communications Sub-group" that will:

identify sectors and/or organizations for outreach activities (immediate focus will likely be the Steel Industry, and Council of Great Lakes Industry)
identify the most effective strategies for reaching select outreach targets
research other incentive programs for ideas
work with local governments and other local groups which may already have target lists of smaller equipment owners
draft letters to request stakeholder participation in the BNS and/or commitment to work towards virtual elimination (and identify who at EPA/EC might sign the letters)
develop commitment language
help improve overall awareness of the PCB challenge and the Binational Strategy by broadening and enhancing communication opportunities (see below)
seek regular input from the broader PCB Workgroup

Step 4