Tackling Polychlorinated Biphenyls (PCBs) & Toxins Through TMDLs

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1 Tackling Polychlorinated Biphenyls (PCBs) & Toxins Through TMDLs 2015 Virginia Water Monitoring Council Conf. Exploring Emerging Water Issues November 19, 2015 Mark Richards Virginia Department of Environmental Quality Office of Watershed Programs

2 DEQ s Fish Tissue Monitoring Monitor to assess the Fishable Goal of the CWA PCBs, Pest. (fatty tissue) Mercury (muscle tissue) Compare to trigger values (protect human health) Listed on dirty waters report if exceeds 303(d) Monitoring Locations

3 VA Fish Tissue Thresholds and Water Quality Criterion Total PCBs VDH Fish Tissue Consumption Advisory Threshold (ppb) DEQ s Fish Screening Value (ppb) Water Quality Criterion (ppb) FDA Threshold (1984) for prohibition of interstate commerce in fish tissue = 2.0 ppm (or 2,000 ppb) Listed on dirty waters report if exceeds i.e., 303(d) report

4 VA Designated Use Non Attainment Taken from Draft (b)/303(d) Integrated Report

5 >1,000 river miles > 70,000 lake acres > 2,000 estuarine sq miles

6

7 Polychlorinated Biphenyls Monsanto manufactured from 1929 until 1977 Sold under trade name of Aroclor Known as Miracle Chemical Highly valued properties chemically inert, nonflammable, heat resistant Used as a coolant and insulating fluid in electrical transformers and capacitors Other uses: plasticizers, lubricating oil, hydraulic fluid, carbonless copy paper

8 Polychlorinated Biphenyls 209 Distinct PCB compounds (Aroclor = mixtures) PCB 11 PCB 118 Non water loving (hydrophobic) Attaches to suspended particles in water Not detected in river water samples since the 1980 s Historic studies were designed to look at river mud where PCBs concentrated. Commonly referred to as a Legacy Contaminant Improved analytical methods now available

9 PCB Analytical Methods SW846 Method 8082 or 608 (water compliance) Includes Aroclors Does not account for weathering Likely underestimates environmental conc. EPA Method 1668 Targets 209 PCB congeners Quantification more accurate than Aroclors Incl. weathered, degraded & metabolized PCBs Fingerprint source(s) EPA Region 4 Tech. Services Issue Paper for PCB characterization, 2013

10 PCB Analytical Method Resolution Comparison Aroclor based Compliance Method for Water Permit Program (40CFR) EPA Method 1668

11 PCBs Continue to be an Issue Fish impairments based on human health concerns Fish consumption is significant exposure pathway Probable carcinogen (EPA) IARC upgraded to carcinogen Immunotoxicity, reproduction and developmental, hepatotoxicity (liver), etc. Persistent, bioaccumulates at low conc. (pg/l) & biomagnifies Confirmed on going releases

12 Toxics Substances Control Act (TSCA) 1976 Law regulates PCBs Bans the manufacture, processing, use and distribution in commerce Non PCB Transformer defined as containing < 50 ppm PCB Inadvertent manufacture of PCBs products up to 50 ppm allowed to leave site as long as annual average is < 25 ppm Unintentional by products of manufacturing processes 50 ppm compared to DEQ s WQC 6.4 X 10 7 ppm ( )

13 PCBs Legacy Misconception Myth: PCBs are no longer manufactured. Fact: PCBs are allowed as an inadvertent contaminant. Myth: A product designated PCB free has no PCBs. Fact: A product can contain up to 50 ppm PCB and can be categorized as PCB free. Myth: PCBs in the environment are only from historical spills. Fact: PCBs continue to be produced and are continuously released to the environment.

14 Unintentional PCB By Products 65% of all diarylide yellow is used in printing Produced inadvertently during the making of titanium tetrachloride Rodenburg 2012

15 PCB 11 Marker of Non Legacy Contamination

16 Non Aroclor PCBs

17 PCB TMDL Load TMDL End Point Load (WQC/Fish Tissue Threshold) Existing Condition TMDL Goal is to restore water quality Requires multi media approach to address and resolve problem

18 PCB Source Assessment 5 Wet Deposition 4 Dry Deposition Air Emissions 1 2 Off gas Contaminated site 3 6 PCB Contaminated sediment

19 Tidal James River Watershed PCB Source Investigation Monitoring PCB model development applicable to entire tidal watershed

20 WQC WQC

21 Monthly tpcb Results Collected for One Year from the Tidal James River Near Hopewell, VA (RM074.44) WQC

22 Elizabeth River Watershed Ambient Water tpcb Results (Mean Conc.) WQC (pg/l)

23 Challenge How clean is clean? The PCB clean up level of 1 mg/kg is not low enough to protect the fish consumption use. Significant need to develop an environmentally relevant PCB clean up level when contaminated sites are co located within PCB fish impaired waterbodies Current Guidance used for PCB site remediation developed during 1990 s Based on TSCA WQC = 640 pg/l WQC

24 TMDL Source Category Pt. Sources ~65% Above Criterion

25 Example PCB TMDL Roanoke River Completed 2009 Existing load = g/yr TMDL = 39.1 g/yr Existing load = g/yr TMDL = 25.8 g/yr

26 PCB TMDL Implementation Pollutant Minimization Plan (PMP) Objective Reduce PCBs through adaptive implementation to meet WLA Management action measurement readjustment based on results Provides flexibility and creativity Must measure and demonstrate progress e.g., backtrack source(s), eliminate/isolate contamination, influent conc. reductions Addressed within Water Permitting Programs

27 PMP Example (Textile Facility Staunton R. aka Lower Roanoke R.) Aeration Basin Polishing Pond 7 8 Million Gallons tpcb = 13,100 pg/l water tpcb = 1,210 ng/g (ppb) sludge tpcb = 17,200 pg/l water (n = 2) tpcb = 1,290 ng/g (ppb) sludge

28 Observed PCB Reductions WATER TREATMENT PROCESS Coagulant Feed Polymer Feed (0.1 HP, 100 ml/min flow rate) ~ 0.5 HP feed pump through center ring 2 4, 10 or 20 HP Pumps on skid (in line mix) Submersible sump/sewage Aeration Basin Top 578.7' 2 HP X 2 Top: 585' North Clarifier South Clarifier Sump Pump in eff. Ring Splitter WL = 574' WL = 574' Box close and plug BOP ' BL: 570' BL = ' 18" DI pipe Polishing Pond 6" Top: 576' To South Clarifier scum 2 4, 10 or 20 HP Pumps on skid TMDL Baseline Load (mg/yr) WLA Load (mg/yr) 56, GAC PUMP WL : 570' Bottom : 556.8' To scum sump close valve Close Valve to effluent close valve flume GAC Unit Recycle Sludge Sump 20 HP existing pump Bag Filters GAC Bag Filters 6 or 8" PVC GAC PUMP, 15 HP each x 2 To Effluent Flume To bag filters & GAC *Results Achieved 99.8% Reduction 85.3% below allocation > 450 g tpcb was kept out of the Staunton River

29 PCB TMDL Implementation Contaminated sites (remediated) If located in a PCB impaired waterbody, does the remedy protect the fish consumption use? Disconnect between clean up level and protecting resource Potential pathways not evaluated using sensitive analytical method If TMDL determines the site is an on going PCB source that requires a reduction, is it too late to address the problem? Contaminated sites (not remediated)

30 Roanoke (Staunton) River Watershed 28 acre remediated site >15% PCB load to entire watershed

31 TSCA Pre/Post Clean up Results Storm water prior to Clean up Maximum 31.5 ppb (Method 8082) Average 4.3 ppb Post clean up water testing was <0.5 ppb (method 8082) TMDL Source Investigation > 1.0 ppb with Method 1668 How clean is clean? TMDL determined site contributes 15.5% of PCB load to Staunton River (after TSCA clean up) Assigned WLA under 2009 TMDL (0.12 mg/yr)

32 Thank You!

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