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Great Lakes Binational Toxics Strategy
Polychlorinated Biphenyls (PCB) Workgroup
May 16, 2000
Toronto Meeting Minutes
Below are minutes of the PCB Workgroup meeting of May 16, 2000. The minutes are organized per topic. Follow-up action items identified during the meeting are summarized under the Path Forward heading.
Progress since November 18, 1999 Workgroup Meeting
Progress since the PCB Workgroup meeting of November 18, 1999, was
reviewed. A summary of the workgroup's progress is included in the PCB
Workgroup - Progress Report of May 2000. The report was made available for
attendees and will be posted on the Strategy's web site.
PCB Reduction Commitments
The workgroup leaders reviewed the successes of the PCB reduction
commitment letters mailed to companies and associations to date (see
Progress Report). The workgroup will continue to use the PCB reduction
commitment letters, through Environment Canada and the U.S. EPA, to seek
commitments to reduce PCBs, targeting specific companies, primarily major
owners of PCB transformers and capacitors, and associations, such as CGLI.
One member commented that the focus of the workgroup should continue to be
the current use of PCBs, since they are a problem as long as they are in
use. This reiterated the majority position of the workgroup from the April
27, 1999, PCB Workgroup meeting in Toronto.
Case Study Report
As a specific example of a PCB reduction topic which should be
included in the case study report, energy efficiency was mentioned as one
benefit of removing PCB containing equipment and replacing them with newer
non-PCB equipment. One member had data to show new equipment is more
energy efficient. Another member commented that energy efficiency may not
be a payback for all companies. The workgroup will continue to develop a
case study report, reporting what various companies use as reasons to
remove PCBs, which may serve as incentives. There will be an
acknowledgment in the report that the cited cases may not be applicable to
all companies. In addition, the workgroup should consider how ISO 14,000
certification applies to management of PCBs or PCB phaseouts and should
identify more incentives for reducing PCBs. Workgroup members that have
specific ideas on incentives should send them to the workgroup leaders.
Outreach and Communication
Members commented that there is still a need to conduct outreach on
environmental issues to owners of PCBs. This was reiterated by a comment
that the real issue in meeting the PCB reduction challenge is education to
small to medium sized businesses since they still may not know they may
have PCBs. The workgroup, however, should also outreach to major owners.
At this time, the major outreach efforts are the PCB reduction commitment
letters, mentioned above. In addition, the workgroup leaders are working
on collecting photos of electrical equipment to help potential owners
identify the equipment they have.
Additional Sources of PCBs
Several workgroup members stated that the workgroup should also pursue
reduction of PCBs from other sources, such as landfills, soils, sediments,
incineration, and sewage treatment facilities. Prior to identifying
specific follow-up actions to address these sources, the workgroup should
try to gather supporting information on releases of PCBs from landfills,
contaminated soils (possibly available in RAPs), and sewage treatment
systems. Major comments concerning some of these sources of PCBs are noted
below.
Landfills: The workgroup discussed the concerns about releases of PCBs from landfills and the possibility of elevating the issue of continuing to allow PCBs to be landfilled to the Integration Group formed under the Strategy. Before the workgroup elevates this issue, more specific information on releases of PCBs from landfills should be collected and reviewed by workgroup members. Specific comments concerning releases from landfills are noted below.
- there are reports containing information about releases from landfills
- landfill liners are temporary and chlorinated benzene in PCBs can cause leaks in certain liners
- regulations in Canada and the United States are not consistent; the U.S. allows PCBs (solids) to be placed in landfills while Canada does not
- if a landfill liner fails and results in releases, PCBs are likely not the only substance released
Sediments/Incineration: It was suggested that the workgroup pursue a workshop on alternative destruction technologies as one way to focus discussions on the safe management of PCB contaminated sediments and alternatives to incineration. It was mentioned that discussions on a workshop may be held by the Integration Group.
Canadian Environmental Protection Act
Several members commented on the plans for amending the Canadian
Environmental Protection Act. Some commented that phaseout requirements
should be included in the new rule (as is being considered) and that the
regulations should include consistent standards for disposal or fugitive
emissions. However, standards at disposal sites are considered a
Provincial matter, not necessarily intended to be included in the
amendments, and permitting may be centralized. As part of the rulemaking
process, everyone will have an opportunity to comment on the amendments
when proposed and available for public comment. The workgroup leaders will
inform the workgroup when the proposed amendments are published and of the
comment period.
PCB Concentrations Near PCB Storage, Disposal and Cleanup Sites
William J. Mills, from the University of Illinois, School of Public
Health, gave a presentation on the evaluation of PCB emissions from
storage facilities. This presentation was a follow-up to questions raised
during previous meetings on the workgroup's focus on PCB equipment.
Three main conclusions of the study and presentation were:
- destruction of PCBs is necessary, not continuing use, storage or landfill disposal
- storage and in use ELECTRICAL equipment have similar environmental impact in terms of air emissions and ambient air concentrations
- fugitive emissions are more of a concern than process emissions with 99.9999% destruction removal technologies
The presentation and conclusions were based on a case study involving the Smithville CWML Site in Canada, an inactive PCB equipment, transfer and storage site. The site had diverse PCB wastes, including soil and other miscellaneous solid wastes, transformers and other miscellaneous equipment, uncontained PCB liquids, lab wastes, and drums of wastes. The Ontario Government took over the cleanup. A mobile incinerator was constructed at the site to destroy the PCB wastes. The destruction began in February 1991 and was completed in December 1992. In addition to the incinerator, a containment building was constructed on site to store PCB wastes, such as drums and equipment.
Extensive environmental monitoring for PCBs was conducted over this period, including samples of:
- ambient air (fixed and mobile, daily for PCBs, weekly for PCDD/DF)
- source (stack) tests
- effluents
- incinerated materials
- ambient water, sediments, soils
Results of the data showed:
- the main sources of PCBs in the air were the water treatment area and the shredder
- PCB emissions from the incinerator were fairly constant, its DRE was over 99.9999%
- the incinerator was normally 10% or less of the contribution of PCBs to the air samples
- the vast majority of observed concentrations were not from the incinerator, confirming receptor modeling results (as a result of the above finding)
- fugitive site emissions were the main source of PCBs in the air, not the incinerator
- there was a relation between the ambient PCB concentrations and the temperature
Suggestions for future PCB operations, based on the Smithville study are:
- the major focus should be on material handling, with less on the remediation technology
- additional air monitoring is suggested of storage sites, and in-service electrical equipment
- for future modeling, consider looking at PCBs in warm and cool weather, using congener specific analysis, and evaluating PCBs in particulate and the gas phase
In terms of prioritizing for destruction the suggested order is:
- Askarel and other liquids with high concentration (i.e. > 10,000 ppm) PCBs, this would include capacitors, and ballasts, etc., for electrical equipment, and hydraulic fluids, etc.
- PCB contaminated mineral oils in electrical equipment and other lower level PCB contaminated liquids
- High concentration PCB contaminated soils and sediments
- Lower concentration PCB contaminated soils and sediments This prioritization is based on the observations at Smithville that the highest ambient air concentrations occurred during the time periods when the Askarel liquids were still on site. Once the Askarel liquids had been destroyed the ambient air concentrations were significantly lower even though there were still over 4000 tonnes of PCB contaminated soil that were treated over the next year or so.
Financial Implications of On-Site PCB Management
George Boire, Senior Manager at Canadian Imperial Bank of Commerce (CIBC),
gave a presentation on a lender's perspective of managing on-site toxics,
including PCBs. In addition to considering financial information and
management capabilities for loans, credits, or other investments,
financial institutions look at environment risks as part of their overall
due diligence. PCBs and other toxic substances are typically discussed in
environmental site assessments, transactions, or compliance audits.
Specifically, lenders are concerned about direct liability risk and credit
risk. Under certain conditions, if a lender is perceived to have exercised
care management or control of a borrower's facility, they can potentially
be named as a responsible party and be liable for cleaning up a
contaminated property. Credit risks include a borrowers possession
(current or past) of contaminated assets, their liability for disposal
costs, how regulatory orders effect their operations, and how
environmental issues may impact their cash flow. Although environmental
risks rarely are the sole reason for declining a loan or investment, poor
environmental management may be a symptom of poor overall management and
can be the main source of liability. The workgroup will consider outreach
to banks since they are interested in regulations and it is important for
them to consider risks of PCBs. In addition, the workgroup leaders will
get and distribute information on the incentive program for removing
ballasts that was mentioned during the presentation.
Path-Forward
Below is a summary of the follow-up actions that were identified during
the meeting.
PCB reductions
- continue to send letters through Environment Canada and U.S. EPA to major owners of PCB transformers and capacitors and to trade associations representing the owners, seeking commitments to reduce PCBs
Case study report
- continue development of a case study report, including examples of incentives for removing PCBs
- workgroup members should submit ideas for incentives to workgroup leaders
Outreach
- conduct outreach to small to medium sized businesses on PCBs
- continue collection of photographs of PCB equipment
- include financial institutions in outreach
Additional sources
- collect information on releases of PCBs from landfills, contaminated soils as a source of PCBs, and on releases of PCBs from sewage treatment facilities - workgroup members possessing such information should submit it to the workgroup leaders
- investigate conference on alternative disposal technologies
Canadian Environmental Protection Act
- inform workgroup when proposed amendment is available for public review and comment
PCB Concentrations Near PCB Storage, Disposal and Cleanup Sites
- distribute copies of final presentation
- for future PCB operations, focus on material handling, with less on the remediation technology, and consider looking at PCBs in warm and cool weather, using congener specific analysis, and evaluating PCBs in particulate and the gas phase
- look for opportunities to collect more air monitoring of storage sites, and in-service electrical equipment
Financial Implications of On-Site PCB Management
- consider outreach to banks and distribute information on the Canadian incentive program for removing ballasts.
Attendees
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Name |
Organization/Email |
Phone |
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dbley@bsco.com |
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boire@cibc.ca |
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boyerp@windsor.ijc.org |
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j.a.hall@ontariopowergeneration.com |
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khanson@mnpower.com |
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pcbsales@contech.com |
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paul.hebert@attcanada.net |
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just1world@idirect.com |
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ghk@cgli.org |
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qintao.liu@utoronto.ca |
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martig.anton@epa.gov |
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KMCMANAMON@SAFETY-KLEEN.COM |
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o.t.melo@home.com |
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School of Public Health wmills1@icarus.uic.edu |
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mehran@senes.on.ca |
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bpreece@contrans.ca |
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radclist@ene.gov.on.ca |
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neil_ryan@bovar.com |
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hamish.st.rose@ec.gc.ca |
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talbotla@pathcom.com |
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wooster@glu.org |
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