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Great Lakes Binational Toxics Strategy
Polychlorinated Biphenyls (PCB) Workgroup
Draft Meeting Minutes
November 18, 1999 - Chicago
Below are minutes of the PCB Workgroup meeting of November 18, 1999. The minutes are organized per topic. Follow-up action items were identified for most of the topics discussed during the meeting. The workgroup will have to prioritize and determine which actions to pursue and who can and/or will contribute to the actions items. The next PCB Workgroup meeting is scheduled for May 16, 2000, in Toronto.
Progress Since April 27, 1999 PCB Workgroup Meeting
Progress since the PCB Workgroup meeting of April 27, 1999, was reviewed. A summary of the workgroup’s progress is included in the PCB Workgroup Update dated November 1999. The Update was distributed to attendees and will be posted on the Strategy’s web site.
PCB Reduction Commitments
The workgroup discussed PCB reduction activities and efforts to seek additional PCB reductions, such as the PCB reduction commitment letter. Both U.S. EPA and Environment Canada have sent PCB reduction commitment letters to major companies with PCB transformers and capacitors within the Basin and will continue to send letters. Representatives of Bethlehem Steel, Northern Indiana Public Service Company, ComEd, General Motors, Georgia Pacific and Ontario Power Generation noted that their companies continue to remove PCBs. General Motors should eliminate all of their high concentration PCBs in electrical equipment by the end of next year. Georgia Pacific should eliminate all of the high concentration PCBs from all of their facilities by 2000. Georgia Pacific currently has only 2 facilities which still have high concentration PCBs. The Georgia Pacific representative thought that most of the other pulp and paper manufacturers have made similar progress. The actions identified for seeking additional PCB reduction commitments are:
- Continue sending letters to businesses with PCB electrical equipment using the PCB Transformer Registration database for the U.S. and the National PCB database for Canada to identify businesses.
- Pursue ways to obtain more commitments with a single letter, for instance, by using trade associations. The Council of Great Lakes Industries (CGLI) representative noted that CGLI may not be able to make PCB reduction commitments for its members, and that each member would have to be contacted.
- Pursue with the integration group the possibility of sending letters which include the other challenges in the Binational Strategy to businesses.
- Government agencies will pursue efforts to address government owned PCBs.
- Seek assistance of workgroup members and associations to require their customers and suppliers to reduce PCBs, for instance, by including in their service or supply specifications that the companies have a PCB removal program in place.
Case Study Report: The workgroup discussed reasons why businesses remove PCBs and how a report compiling these reasons would be a valuable resource and tool by showing others why they should remove their PCBs. The General Motors’ representative explained that GM’s commitment to reduce PCBs was driven by business decisions, primarily related to energy efficiency, and that they found a payback period of 5 years. Georgia Pacific’s representative explained that their environmental strategy and decisions to remove PCBs considered management support, conservation, promoting community awareness, and protection of health and the environment. Specific actions include:
- Seek information from workgroup members on why their company removed PCBs, initially from CGLI and other attendees of the meeting. The reasons could involve: cost benefit analysis, energy efficiency, liability, cleanup costs, insurance costs, and/or protection of health and the environment.
- Compile the information into a hard and electronic report.
Outreach & Communication: The workgroup discussed the need for continued outreach and education on the Strategy and the PCB challenge. Outreach and education is still necessary as noted by workgroup members who stated that they still encounter facilities that have not registered PCB transformers or know if they have equipment with PCBs. The workgroup identified several outreach activities:
- Prepare a clearing-house of photographs of electrical equipment which may contain PCBs (transformers, capacitors, fluorescent light ballasts, etc.).
- Review and distribute United National Environment Programme (UNEP) Guidelines for Identification of PCBs and Materials Containing PCBs [PDF 290KB 40pps].
- Prepare a fact-sheet on the Strategy and the PCB challenge.
- Prepare a series of fact sheets or papers on equipment that may contain PCBs. This action item was developed by the workgroup leaders in a follow-up meeting.
- Work with associations of retired engineers to address possible PCBs within schools and/or small businesses.
- Coordinate with state and provincial P2 programs to take advantage of their efforts to outreach on the Strategy and the PCB challenge.
- Investigate regional, state and provincial efforts to track PCBs through waste water treatment plants.
- Prepare articles intended for the media and trade, environmental, or social journals on the sources and releases of PCBs and the Strategy’s PCB challenge and efforts to reduce releases.
- Issue public service adds or announcements on PCBs, risks, and the Strategy’s PCB challenge. The workgroup leaders think it may be difficult to convince media entities to run a public service add or announcement and suggest focusing on other actions at this time.
PCB Transformer Database: The new PCB Transformer Registration Database shows that there are 18,714 PCB transformers in the U.S. For the PCB challenge, it was estimated that 200,000 PCB transformers were in use in the U.S. in 1994. The implies that over 90% of the PCB transformers in use in 1994 have already been disposed. However, it is not clear if this is actually the case. In evaluating the PCB challenge and the use of the database, the PCB workgroup should:
- Evaluate the 1994 estimate, back calculating from the data in the PCB Transformer Database to the 1994 estimate using the amount of PCBs disposed of between 1994 and 1998 as reported in the annual PCB disposal reports submitted to EPA.
- EPA representatives will follow-up on the possibility of updating the database by adding those that have not yet registered and removing those that have removed all of their PCB transformers.
Coordination: Francine Norling, Lake Erie Team Leader, and Fred Luckey, EPA Region 2, noted that the workgroup should coordinate its activities or assist with other PCB reduction activities such as the development of Lakewide Management Plans (LaMPs). Specifically, the workgroup should:
- Coordinate activities with the LaMPs and the finalization of the LaMPs.
- Coordinate PCB reduction activities, such at the PCB reduction commitment letter with all EPA Regions.
Submersible Well Pumps: Jack Lewis of Sunpro gave a presentation on PCBs in submersible well pumps. Submersible well pumps containing PCBs can be found in wells at residences and at parks. When the pump or capacitor containing PCBs fail, the PCBs can be released, contaminating the well and the system and other areas. Releases have been observed to swimming pools, play areas, driveways, and creeks. The main issue is one of awareness. Several follow-up activities were identified:
- Form a subgroup to pursue activities to address problems concerning PCBs in submersible well pumps. Jack Lewis of Sunpro agreed to lead the subgroup.
- Collect information on the use of PCBs in the submersible well pumps by conducting a literature review.
- Prepare a fact sheet or letter containing summaries of the collected information for distribution to potential owners or services of well pumps with PCBs.
- Work with state licensing boards and well pump manufacturer to collect, compile and distribute the information.
Oil-Filled Cable: Paul Hebert of Trans-Cycle Industries discussed the use of PCBs in oil-filled cable. The main problem with the oil-filled cable is that companies may not know that the oil in the cable contains PCBs since there may not be a uniform distribution of PCBs in the cable. Several possible activities were identified (or considered by the workgroup leaders):
- Form a subgroup to pursue activities to address problems concerning PCBs in oil-filled cable.
- Prepare a fact sheet or letter containing a summaries of the issues
and management options concerning oil-filled cable for distribution to
potential owners of the cable. TCI’s web page at
www.TCI-pcb.com
contains information on oil-filled cable.
Automobile Shredder Fluff: Margaret Wooster of Great Lakes United raised the issue that fluff from the shredding of automobiles and white goods can be contaminated with PCBs and that the fluff can be used as a landfill cover. No specific activities were identified on this matter, but the following action is suggested by the workgroup leaders:
- The workgroup should educate each other on this matter.
Canadian Environmental Protection Act: A question was raised about what role the workgroup has concerning various issues related to CEPA which is scheduled to be renewed next year. The issues with the regulations were that there are no time limitations on the storage of PCBs in Canada and the siting of disposal facilities in Canada is not consistent with the siting requirements within the U.S. The workgroup leaders offered to consider the matter of the role of the workgroup. However, no specific activities were identified. Upon consideration of the issues, the workgroup leaders’ position is that these issues should be addressed, independently, as part of the rulemaking process.
- The workgroup leaders will attempt to keep people informed of the regulations and the comment periods.
Base Catalyzed Decomposition (BCD): Dr. Alfred Kornel of BCD Group
Inc. gave a presentation on BCD for treatment of PCB contaminated materials,
including soil and oils. The BCD process is a non-incineration catalyst
based hydrogen cleaner which dechlorinates the PCB molecule. The process can
handle askarel and treat up to 300,000 ppm materials in 15-60 minutes. It is
mostly used for soils, treating them to less than 2 ppm per congener. A 2000
gallon capacity facility was just permitted in Mexico. There is a cost
factor however and there is a need for 2 lbs. of sodium hydroxide per 1 lb.
of PCBs. BCD Group Inc.’s web site at
http://www.bcdgroup.ie/
contains
more information on the BCD process.
Insurance: A presentation was made on the insurance and financial implications of on-site management of PCBs. The presentation focused on types of insurance and the accounting considerations of having sites contaminated with PCBs. Some points were mentioned that could be considered in the development of the Case Study report: 1) that disclosure of sites containing PCBs is a concern for property owners and 2) that PCB contamination on a site typically draws more attention than contamination of other substances. The follow-up item from this presentation is:
- The workgroup leaders will pursue this issue further and will contact other insurance companies with more experience in the coverage of electrical equipment, discuss that coverage, and share that information with the workgroup.
PCB Sources and Regulations Report: The PCB Sources and Regulations report is available for comments on the Strategy’s web site at www.epa.gov/bns/ until December 31, 1999. Comments can be submitted directly to Tony Martig of U.S. EPA. A summary of the source, release, and emission data in the report was reviewed.
PCBs Released During Storage and Remediation: There was not enough time to address this issue or identify follow-up activities. However, a point was made that transformers in storage can release through fugitive emissions as much PCBs as transformers that are still in use. The Trans-Cycle representative noted that they occasionally find that the solvents that used to be in the oils of transformers that have been stored for a long time have volatilized, leaving only a solidified or crystallized material.
The workgroup leaders will follow-up with workgroup members with information on this subject and distribute the information to the entire workgroup.
Attendees
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(note-taker) |
77 W. Jackson, DT-8J Chicago, IL 60604 bezerra.joana@epa.gov |
312/353-4788 f |
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P.O. Box 248 Chesterton, IN 46304 dbley@bsco.com |
219/787-4973 f |
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4905 Dufferin Street Downsview, Ontario M3H 5T4 carl.chenier@ec.gc.ca |
416/739-4405 f |
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77 W. Jackson, G-17J Chicago, IL 60604 doyle.philip@epa.gov |
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OPPT/NPCD 401 M Street SW Washington DC 20460 |
202/260-1724 f |
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700 University Avenue, H14 F2 Toronto, Ontario M5G 1X6 j.a.hall@hydro.on.ca |
416/592-7844 f |
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455 Archer Drive Kirkland Lake, Ontario P2N 3J5 paul.hebert@attcanada.net |
450/458-2760 f |
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1875 Eye Street NW, #775 Washington DC 20006 phill@gapac.com |
202/223-1398 f |
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5265 Hohman Ave. Hammond, IN 46320 rehuffman@nipsco.com |
219/647-5271 f |
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77 W. Jackson, SE-5J Chicago, IL 60604 khanna.kaushalya@epa.gov |
312/886-0573 f |
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485 W. Milwaukee, MC 482-302-205 Detroit, MI 48202 T.L.KLINE@GM.COM |
313/556-7629 f |
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Cincinnati, OH kornel_a@bcdinternational.com |
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7392 Whipple NW North Canton, OH 44720 sunpro@cannet.com |
330/966-1954 f |
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290 Broadway, 24th floor DEPP-CEPB-Freshwater New York, NY 10007 luckey.frederick@epa.gov |
212/637-3889 |
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77 W. Jackson Blvd., DT-14J Chicago, IL 60604 martig.anton@epa.gov |
312/353-4788 f |
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Hollister Building 106 W. Allegan Lansing, MI 48909 mehang@state.mi.us |
517/335-4053 f |