Thursday, February 26, 2015

Update: PCBs in the Carolinas

We blogged about the illegal dumping of PCBs into sewer systems in North Carolina and South Carolina a couple months ago, and wanted to provide an update. Today, both states continue to struggle with disposing of this persistent compound even as federal investigations have yet to uncover the responsible parties.

Meanwhile, wastewater treatment facilities and their customers are the ones paying the price. According to an area news source, the director of the Charlotte-Mecklenburg Utilities reported that PCB cleanup at its plants has to date cost nearly $4 million. He estimates that completing the job could cost anywhere from another $6 million to $9 million.

Consultants from Synterra Corporation presented at the 2014 South Carolina Water Resources Conference summarizing what is known about the incidents. They provided a great summary of the events in the past year as well as some updates from last summer and fall. They observed that at least 23 food service establishments in the Greenville-Spartanburg have been impacted by the improper disposal. Testing last summer and fall revealed multiple contaminated grease interceptors, and those establishments will likely be forced to shoulder the cost of remediation, as this op-ed notes.

Unfortunately, investigations may never reveal the culprit(s) but the cost, resources required, and potential harm has emphasized evaluating lessons learned. The Synterra paper discussed potential opportunities for prevention including: securing access to grease interceptors, better oversight of haulers, and sampling before grease pumping. However as they point out, the public sewer system (like the storm water system) is a largely an open system. As a result, one of the considerations is whether this is a one-time incident or something to be concerned of in the future. If it is the latter, Synterra asks, “what steps do water supply providers need to consider to secure water intake systems?” And, “[a]re there measures that should be taken to regulate the hazardous materials at former industrial sites more tightly?”

The problem is that there is a long and unfortunate history of “midnight dumping” or illegally abandoning hazardous waste - including PCBs (e.g. the well known “midnight dumpings” of 1978 where PCB contaminated oils were discarded along North Carolina highways; or incidents of tossed PCB transformers in 1984 in Southern California or abandoned drums containing PCBs in 1988 in Pennsylvania (here, see pg. 31). The North Carolina DCNR has noted that trends show the illegal behavior is on the rise, likely in part a result of increasing disposal costs, and perhaps as a result of industrial equipment finally reaching the end of its useful life, as San Joaquin County, CA has observed.

Similarly, many of those interviewed in the local article acknowledge that disposing of PCBs is a challenge. They raise the question as to whether there is a better option for disposal: some sort of a state driven solution to stop violators from illegally dumping. However, as the EPA representative points out, states don’t have too much control. Unlike RCRA, TSCA is a federally administered program with no ability to delegate primary responsibility to states. Though as the article hints, something like a collection program or event - in the same style as e-waste, used oil, or prescription drugs –sounds nice, there may be hurdles to implement at the state level. Granted, there have been state and municipality initiated PCB light ballast collection programs, and places like Dane County and the City of Madison, WI sponsor Clean Sweep Small Business Hazardous Waste Disposal Programs, and San Joaquin County assists in disposing PCB contaminated oil in quantities of less than 55 gallons. The problem in designing a solution is the derivation of the dumping: if it is waste haulers, rather than individuals or small businesses, than the program would need to be targeted to address that.

Regardless, the events emphasize the need for a solution that combines incentivizing compliance and reinforcing the threat of enforcement; while also instituting protective measures on behalf of potentially victimized businesses and water utilities.


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