PCB: the Pollution Prevention Approach Adriane P. Borgias MSEM, CHMM Presentation to USEPA April 27, 2017

Commitment SRRTTF Established by Memorandum of Agreement 2012. Members of the community, stewards of the river.

Case Study: PCBs and the Spokane River The Problem: The Spokane River does not meet the Water Quality Standards for polychlorinated biphenyls and other toxics. > 98% reduction in PCB loading is needed. Permitted discharges have a disproportionate responsibility for cleanup. End of pipe clean up is expensive and may not be possible. Using Pollution Prevention principles is the only viable option.

Can We Achieve our WQS? Assume all PCB from pigments becomes available to the river. (trash, decomposition, burning, wastewater, stormwater, etc.) 225 cf/s average annual flow into Long Lake 7x1012 kg water/yr. PCB Concentrations in the river: From pigments alone: 2 x 10-7 ppm Current WQS target: 0.07 x 10-7 ppm

Why this is important PCB is a national water quality concern A quick look at the EPA Watershed Assessment, Tracking and Environmental Database shows: 5598 water body listings for impairments due to PCB 488 Water Quality Clean up Plans (also known as Total Maximum Daily Load Implementation Plans) Compare this to the relative numbers of listings and clean up plans for other types of pollutants. There is a big disparity in how PCB is managed. EPA Watershed Assessment, Tracking and Environmental Database

The Moving Pieces Regulation Cross Media Actions Eliminate new sources Share Information Education Consumer choice Health information Best Management Practices Remove Legacy spills Treatment Regulation Cross Media Actions Eliminate new sources Manage Discharges Permits Toxics Reduction Plans Understand the Watershed Identify Sources Model movement Research Green Chemistry Graphically, this is how we are addressing the issue. This is another way of depicting the actions in the Pollution Prevention Hierarchy, or source control strategy shown earlier. The bigger cogs represent major activities that lie in various places of the hierarchy. Smaller cogs are more specific targeted actions. At any moment in time, certain cogs begin to move and they impact others. Sometimes we have a cooperative effect happening and other times cogs get stopped. Example 1: We know that PCBs continue to be manufactured and are a contaminant in pigment manufacture. That affects a paper recycling industry in Spokane, because PCBs are in the pigments of the recycle stock. EPA issued an ANPRM in 2010 to address the regulatory exclusions that allow inadvertent production. The regulation gear starts turning, specifically, the “eliminate new sources,” which is at the top of the hierarchy. Recently we learned that EPA has stopped movement on that revision to the regulations. The cog stops moving. Example 2: On a more positive note, we have some specific activities in Spokane that help remove sources of PCB from the watershed. The City of Spokane recently received a municipal stormwater grant for a project of statewide significance. The grant involves a cooperative approach to identify and test road products that have the potential to introduce PCB into stormwater. The “Understand the Watershed” cog begins to move, ultimately leading to “Identifying Sources” and potentially incorporating into their “Toxics Reductions” plans and implementing “Best Management Practices.” Example 3: Recently an independent initiative by students at WSU resulted in the creation of a student challenge. Their project, “Saving the Spokane River,” is a student scholarship. Interdisciplinary teams are studying the river and proposing solutions for implementation. Their focus is the “Education” cog, potentially leading to better public education about the issue.

Waste Management Hierarchy Prevent Waste Generation Minimize Waste Generation Reuse Waste Materials Recycle Wastes: Doesn’t work for PCB! Utilize for Energy Recovery Disposal

In Other Words: Don’t make it Don’t use it Use less of it Manage it better Dispose of it properly Clean up and/or Treat at End of Pipe

In Other Words: Don’t make it Don’t use it Use less of it Manage it better Dispose of it properly Clean up and/or Treat at End of Pipe

In Other Words: Don’t make it Don’t use it Use less of it Manage it better Dispose of it properly Clean up and/or Treat at End of Pipe

In Other Words: Don’t make it Don’t use it Use less of it Manage it better Dispose of it properly Clean up and/or Treat at End of Pipe

In Other Words: Don’t make it Don’t use it Use less of it Manage it better Dispose of it properly Clean up and/or Treat at End of Pipe

In Other Words: Don’t make it: Stop or reduce inadvertent production. Don’t use it: Regulatory & market incentives. Use less of it: Public awareness. Manage it better: Enforcement of rules. Dispose of it properly. Clean up and/or Treat at End of Pipe.

End

But, Is This Really a Problem? Color Pigments Manufacturers Association (2010): 90 million lbs pigments imported/manufactured in US. Estimated 1000-2000 lbs PCB/year. Estimated amount released in Spokane metro area based on per capita consumption. 2000/lb x 0.5 million Spokane/ 316 million USA 1435 g/yr “inadvertently produce PCB” potentially enters the Spokane River watershed. Correlation with the 2005 loading assessment: Total PCBs at Long Lake: 3664 mg/day = 1337 g/year. http://oehha.ca.gov/prop65/public_meetings/CIC101211/comments/prior/CPMA3_3dichloroRobinson.pdf CPMA, comments to EPA August 18, 2010. http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OPPT-2009-0757-0195

Why this is important PCB is a Spokane River health concern.

Source Reduction Strategies Six strategies to achieve source reduction: Toxic chemical substitution Production process modification Finished product reformulation Production modernization Improvements in operations and maintenance In-process recycling of production material

Green Chemistry Solutions Green Chemistry is doing chemistry the way nature does: “ the design, development and implementation of chemical products or processes that reduce or eliminate the generation of hazardous substances” PCB – free pigments are a green chemistry opportunity.

References References: http://www.cpcb.nic.in/123-132.pdf http://www.iswa.org/web/guest/home http://envisempri.kar.nic.in/Mannual_files/Hazardous%20Waste%20Management.html

PCB in Paint Pigments 33 commercial pigments > 50 PCB congeners Several dioxin-like Pigments also used in Inks Textiles Paper Cosmetics Leather Plastics Food Hu and Hornbuckle, 2010: http://www.ncbi.nlm.nih.gov/pmc/articles/PMC2853905/figure/fig2/

Yellows, Oranges, Reds Baso et al. 2009 in Guo, Praipipat, and Rodenburg: http://www.p2.org/wp-content/uploads/june-27-pcbs-webinar.pdf

Blues and Greens Hu and Hornbuckle, 2010: http://www.ncbi.nlm.nih.gov/pmc/articles/PMC2853905/figure/fig3/

Whites Guo, Praipipat, and Rodenburg: http://www.p2.org/wp-content/uploads/june-27-pcbs-webinar.pdf