PCB Pollutant Minimization Plans: Background and Guidance New Jersey Water Environment Association PCB Pollutant Minimization Workshop July 28, 2005 Rutgers University EcoComplex Bordentown, NJ John Yagecic, P.E.
In December 2003, EPA Regions 2 & 3 issued TMDLs for PCBs in the Delaware Estuary. Zones 2 through 5 River Mile 133.4 at the head of tide at Trenton, NJ down to the head of Delaware Bay at River Mile 48.2.
Why? Ambient Concentrations Vs. Criteria (Log( Scale) 100,000 Zone 6 Zone 5 Zone 4 Zone 3 Zone 2 Water Column Total PCB Concentration (pg/l) 10,000 1,000 100 Mouth of Bay Ambient Concentrations exceed criteria by 2 to 3 orders of magnitude 10 7.9pg/L C&D Canal 44.8pg/L Ben Franklin Bridge 44.4 pg/l Head of Tide 1 0 20 40 60 80 100 120 River Mile 9/18/2001 3/15/2002 4/11/2002 5/6/2002 10/8/2002 3/19/2003 4/2/2003 8/19/2002 9/3/2002 9/23/2002 11/21/2002 Maximum Concentration Minimum Concentration Water Quality Criteria
Load Vs. Fluxes Upstream Boundary Load Schuylkill River Upstream Boundary Load Delaware River at Trenton, NJ C&D Canal (tidal boundary) Tributary Loads Atmoshpheric Wet / Dry Deposition Atmoshpheric Gas phase flux Contaminated Site Loads Non-Point Source Loads Point Discharge Loads CSOs LEGEND Ocean Boundary Mouth of Delaware Bay Sediment Sediment Flux External Loads (forcing functions) Fluxes and tidal boundaries
Estimated Loads by Category and Uncertainty 1000.00 834.81 Max Legend 175.13 80th Percentile 100.00 Calculated Load 20th Percentile Penta PCB Load (kg) 10.00 1.00 15.89 1.37 17.38 5.45 9.22 0.77 23.59 2.85 37.70 6.56 4.27 7.31 5.40 27.98 5.26 0.90 6.93 3.18 34.30 4.00 0.78 5.10 2.36 14.30 3.47 1.82 3.98 2.87 Min 22.18 5.47 2.34 2.69 2.19 1.95 1.20 2.99 1.32 0.32 0.10 Contaminated Sites Non-Point Sources Point Discharges Delaware at Trenton Schuylkill All other Tributaries Atmospheric wet and dry deposition CSOs Source Category
Original Sources of PCBs not the same as Loading Source Categories Atmosphere Wet & Dry Atmospheric Deposition Gas Phase Flux Transformer Combined Sewer WWTP WWTP Point Load Industrial Discharge Contaminated Site Load Non-Point Source Runoff Load Storm Sewer MS4 Load CSO CSO Load Tributary & Boundary Loads
WHY? PCB sources and pathways may be readily identified!
Total PCB concentrations with existing sediment condition as a sole source of PCBs Long Duration Problem Concentration, pg/l 10000 1000 100 10 1 0.1 0.01 2000 2010 2020 2030 2040 2050 Year RM122.6 RM99.4 RM84.8 RM68.1 WQC WQC Modeling showed that even if all PCB loads could be instantaneously shut off, criteria wouldn t be achieved for ~35 years due to sediment alone
Implementation of the Stage 1 PCB TMDLs Dischargers to receive non-numeric water quality-based effluent limits (WQBELs) consistent with their WLAs; 40 CFR 122.44(k)allows non-numeric, BMP-based WQBELs where appropriate DRBC may require other actions to implement TMDLs; Typical permit will include discharge monitoring with Method 1668A and Implementation of a PCB pollutant minimization program; From TOTAL MAXIMUM DAILY LOADS FOR POLYCHLORINATED BIPHENYLS (PCBs) FOR ZONES 2-5 OF THE TIDAL DELAWARE RIVER December 15, 2003 Executive Summary, Pages xii and xiii
2 Tracks in Developing the PMP Approach Outlines Developed by interagency workgroup To articulate a consistent recommended framework Communicates the elements we think are necessary for success Rule Authorizes DRBC to require plans sooner rather than later Adopted May 18, 2005 Can require PMPs from non-point sources Resolution expressed a goal of achieving 50 percent reduction in aggregate loads within the next 5 years
Interagency Workgroup PA NJ DE EPA II EPA III DRBC Jenifer Fields Melisse Carasia-Auriti Pilar Patterson John DeFriece Maureen Krudner Brian Trulear Roberta Riccio John Yagecic Bob Tudor Pam Bush
General Minimization Plan Components Facility Description Statement of Support and Identification of Team Proposed Schedule Actions for Known / Probable Sources Actions to Find and Control unknown Sources Previous Minimization Activities Measuring, Demonstrating, and Reporting Progress Establishing a Baseline Estimated Load Reduction Continuing Assessment
Guiding Principles Dischargers know best how to reduce loads PMP requirement not prescriptive Provides a consistent framework for communicating the plan Dischargers know their facilities better than regulators Wide flexibility for achieving reductions Different facilities will have different approaches What works for one may not work for another Encourage creative solutions
Guiding Principles (continued) Plans need to articulate specific actions Other examples (from outside the basin) we considered were insufficient. We ll look for the pollutant. If we find it, we ll get rid of it. Need a real plan of action What, when, how, and what s the impact
Guiding Principles (continued) Measuring and Demonstrating Progress is the highest priority Allows for an iterative Adaptive Management approach Pollutant minimization approach is a risk Will succeed or fail depending on demonstration of reducing loads to the estuary
Guiding Principles (continued) Many ways to measure and demonstrate progress For some sites, analytical uncertainties may mask effluent concentration reductions consider other options Influent concentration reductions PISCES effluent sampling PCB mass removed from site / system Demonstrate reductions in a surrogate parameter such as solids, OC Effluent volume reductions (if likely to reduce PCB mass) Ultimately need to compute an estimated PCB effluent load reduction
The Rule DRBC Water Quality Regulations Section 4.30.9 Pollutant Minimization Plans for Toxic Pollutants Adopted May 18, 2005 Authorizes Commission to require pollutant minimization plans from both point and nonpoint discharges impacting water bodies where: Commission determines that assimilative capacity for toxic pollutant has been exceeded; or TMDLs for toxic pollutants have been established.
PMP Procedures DRBC will notify facilities by letter that they must develop a PMP; Plans to be submitted within 90 days of notification by DRBC; Plans submitted to DRBC and state; Completeness Review by DRBC; Peer Review Advisory Committee to evaluate PMPs in light of 50% / 5-year goal and circumstances of each site.
Will PMP Approach Work? Early Signs of Success Rail facility in Wilmington, DE demonstrated ~ 90% reduction in PCBs in surface runoff via erosion control; Chemical manufacturer in Wilmington, DE demonstrated initial 22 to 32% load reduction through raw material change with a 90% goal by 2007 through raw material changes, process changes, settling, and sand filtration; Refinery in southeast PA eliminated PCB equipment years ago but identified contaminated sediments in a stormwater drainage ditch.
PCB Pollutant Minimization Plans Rule and Guidance available on DRBC web site www.drbc.net Contact John Yagecic at 609-883 883-9500 x271