Thursday, October 31, 2013

The Cat in the Hat Comes Back: PCBs found in South Carolina Waste Water Treatment Plants

PCBs (Polychlorinated Biphenyls), what a rascally substance. Nearly 40 years after Congress “banned” them, they continue to turn up in the places we would least expect: caulk in schools, commercial paint pigments, and now, in wastewater treatment plants.

PCBs just won’t go away.

In September, the South Carolina Department of Health and Environmental Control (DHEC) issued emergency regulations for the management of wastewater treatment system sludge in response to the discovery of PCBs in four publically owned treatment works (POTWs) located in upstate SC. The DHEC is concerned that PCBs have been or are currently being illegally dumped into sewer systems, after discovering the contaminant in a significant number of grease traps of several commercial businesses in the treatment districts.

The DHEC has also issued a cease and desist letter to one waste oil hauler, American Waste Septic Tank Service, after discovering PCB contamination in its tanker trucks.  As part of an effort to “delineate the movement of PCBs within the Upstate region,” a number of other waste haulers and storage areas were also tested, and several have been found with PCB contamination (Kitzmiller, 2013).

Emphasizing the seriousness and ongoing criminal nature of the situation, the DHEC has issued a Be On the Lookout (BOLO) alert through the State Law Enforcement Division to encourage law enforcement attention; likewise the city of Columbia has urged private businesses with grease traps to be on alert for suspicious activity.

"Whoever is doing this has got to be an idiot,” said Larry Brazell, director of the East Richland Public Service District (one of the affected POTWs). “This could be big. If they’ve dumped enough of it, it could be bad. And where are they getting it from? This stuff should have been out of here since the 1970s,” (TheState, 2013).

Then why are PCBs still a problem? 

One of the reasons is although Congress technically “banned” the manufacture of PCBs and the use of the chemical compound in 1976 under the Toxic Substances Control Act (TSCA); as regulated by the EPA, PCBs are permitted to remain in use in certain applications (e.g. transformers and capacitors), and as inadvertent byproducts in chemical manufacturing if less than 50 ppm. As initially promulgated, this left 99% of PCBs in use (EDF v. EPA,1980) and potentially allowed (as the EPA estimated in 1984) 1,000 pounds of new PCBs to be introduced to the environment per year as inadvertent byproducts (e.g. like those found in paint pigments) (49 FR 28206).

Unfortunately the public often conflates the ban to mean that PCBs are no longer in use, period.  The assumption is typically that all that remains of PCBs are legacy (i.e. abandoned at former industrial sites prior to the 1980s). Yet this is simply not the case. While certain uses have been phased out and restricted, there are still thousands of transformers and millions of large capacitors currently in use, which will require disposal in the near future as they reach the end of their usable lifetimes (75 FR17645).
A few examples highlight the ongoing management challenge of PCBs. In August, 218 gallons of oil spilled in front of Sag Harbor local businesses after a ground-level transformer ruptured – only within the last month was it disclosed that the contents contained PCBs (Quinn, 2013). Also, in September, the City of Tacoma settled with the EPA for unknowingly shipping 750 gallons of PCB contaminated waste oil to a recycling and reuse company (EPA, 2013). The city, which had collected the oil from a drop-off available to residents, does not normally test for PCBs, and does not know how the PCBs got there (Krell, 2013).

So where are the PCBs coming from?

It’s a question that does not have an obvious answer. It has been suggested that the PCBs illegally dumped into the grease traps in South Carolina could be coming from former industrial facilities undergoing remediation: there are several sites within the upstate area, and dumping PCBs down a sewer is without a doubt less costly than disposing of them in a TSCA-approved chemical waste landfill or incinerator. This is likely what most would assume, however, that “cost-savings” incentive also exists for anyone who still has PCBs in their possession. As noted above, still owning PCBs is much more common than it sounds.

 The take away?

Ultimately, PCBs are not banned from use in the U.S. and their presence isn’t isolated to only Superfund sites. Unfortunately the South Carolina DHEC, like the city of Tacoma and others, are facing the vexatious consequences of that reality. For as these examples show, the task of managing  PCBs more than 30 years after they were “banned” is no easy or straightforward task, nor one that will disappear anytime soon. Modern management of this pervasive class of chemicals is filled with surprising pitfalls and unanticipated difficulties: unmarked PCB-contaminated electrical units, forgotten or assumed to be out of use applications (caulk, sealants, and light ballasts), and materials that have simply come in contact with PCBs (sumps, building materials, and of course, all manner of environmental media).

The PCB problem is reminiscent of the pink stain in the classic children’s book The Cat in the Hat Comes Back that dirties everything it comes in contact with – for most of the book no matter what is done, the stain refuses to disappear.  And, while persistent is an apt descriptor, the PCB problem is not only dogged, but also multifaceted; truly the hydra of environmental problems. It’s enough to make the average Joe throw up his hands in exasperation, and for environmental professionals to shake their head in consternation.

Here at M&A, we’re extremely familiar with PCBs. We have had significant experience with tracing and identifying historical sources of contamination, as well as understanding the complexities of use and standards of pollution prevention and disposal. For us, the situation in South Carolina is a reminder that PCBs are not a contaminant we can close the chapter on just yet, and the fact that they are still in use will reinforce this conclusion for some time. 

Submitted by Kate McMahon, Research Associate

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