PCB Pollutant Minimization Plans: PCB Pollutant Minimization Plans: Background and GuidanceBackground and Guidance

New JerseyWater Environment Association

PCB Pollutant Minimization WorkshopJuly 28, 2005

Rutgers University EcoComplexBordentown, 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?Why?Ambient Concentrations Vs. Criteria (Ambient Concentrations Vs. Criteria (Log Scale)Log Scale)

1

10

100

1,000

10,000

100,000

0 20 40 60 80 100 120

River Mile

Wat

er C

olum

n To

tal P

CB

Con

cent

ratio

n (p

g/L)

9/18/2001 3/15/2002 4/11/2002 5/6/200210/8/2002 3/19/2003 4/2/2003 8/19/20029/3/2002 9/23/2002 11/21/2002 Maximum ConcentrationMinimum Concentration Water Quality Criteria

44.4 pg/L44.8pg/L

7.9pg/L

Zone 2Zone 3Zone 4Zone 5Zone 6

Head of Tide

Mouth of B

ay

Ben Franklin Bridge

C&D

Canal

Ambient Concentrations exceed criteria by 2 to 3 orders of magnitude

Load Vs. FluxesLoad Vs. Fluxes

Contaminated Site Loads

Upstream Boundary LoadDelaware River at Trenton, NJ

SedimentFlux

AtmoshphericWet / Dry

Deposition

AtmoshphericGas phase

flux

Upstream Boundary LoadSchuylkill River

Non-Point Source LoadsTributary Loads

Point Discharge Loads

Sediment

C&D Canal(tidal boundary)

Ocean BoundaryMouth of Delaware Bay

CSOs

LEGEND

External Loads(forcing functions)

Fluxes and tidal boundaries

Estimated Loads by CategoryEstimated Loads by Categoryand Uncertaintyand Uncertainty

15.89

9.226.56

5.264.00 3.47

2.34 2.19

175.13

834.81

37.7027.98

34.3022.18

1.37

0.77

4.27

0.90 0.78

1.821.20

0.32

5.45

1.321.95

2.872.363.18

5.40

2.85

5.47

14.3017.38

2.992.693.985.10

6.937.31

23.59

0.10

1.00

10.00

100.00

1000.00

ContaminatedSites

Non-PointSources

PointDischarges

Delaware atTrenton

Schuylkill All otherTributaries

Atmosphericwet and drydeposition

CSOs

Source Category

Pent

a PC

B L

oad

(kg)

Max

Min

80th Percentile

20th Percentile

Calculated Load

Legend

Original Sources of PCBs not the same as Original Sources of PCBs not the same as Loading Source CategoriesLoading Source Categories

Transformer

Atmosphere

Wet & DryAtmospheric

Deposition

GasPhaseFlux

MS4 L

oad

CSO Load

WWTPPoint Load

Non-

Poin

t Sou

rce

Runo

ff Lo

ad

Cont

amin

ated

Site

Load

Tributary &Boundary Loads

WWTP

CSO

CombinedSewer

StormSewerI

ndus

trial

Disc

harg

e

WHY?WHY?PCB sources and pathways may be readily identified!PCB sources and pathways may be readily identified!

Long Long Duration Duration Problem

Total PCB concentrations with existing sediment condition as a sole source of PCBs

0.010.1

110

1001000

10000

2000 2010 2020 2030 2040 2050Year

Con

cent

ratio

n, p

g/L

RM122.6 RM99.4 RM84.8 RM68.1WQC WQC

Problem

• 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 theImplementation of theStage 1 PCB TMDLsStage 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, 2003Executive Summary, Pages xii and xiii

2 Tracks in Developing the PMP Approach2 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, 2005Adopted May 18, 2005•• Can require PMPs from Can require PMPs from

nonnon--point sourcespoint sources•• Resolution expressed a Resolution expressed a

goal of achieving 50 goal of achieving 50 percent reduction in percent reduction in aggregate loads within aggregate loads within the next 5 years the next 5 years

Interagency WorkgroupInteragency WorkgroupPA Jenifer FieldsNJ Melisse Carasia-Auriti

Pilar PattersonDE John DeFrieceEPA II Maureen KrudnerEPA III Brian Trulear

Roberta RiccioDRBC John Yagecic

Bob TudorPam Bush

General Minimization Plan ComponentsGeneral 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 Measuring, Demonstrating, and Reporting

ProgressProgress– Establishing a Baseline– Estimated Load Reduction

• Continuing Assessment

Guiding PrinciplesGuiding Principles

Dischargers know best how to reduce loadsDischargers 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)Guiding Principles (continued)

Plans need to articulate specific actionsPlans 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)Guiding Principles (continued)

Measuring and Demonstrating Progress is Measuring and Demonstrating Progress is the highest prioritythe 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)Guiding Principles (continued)Many ways to measure and demonstrate Many ways to measure and demonstrate

progressprogress

– 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 RuleThe RuleDRBC Water Quality Regulations Section 4.30.9DRBC Water Quality Regulations Section 4.30.9

“Pollutant Minimization Plans for Toxic Pollutants”“Pollutant Minimization Plans for Toxic Pollutants”

• Adopted May 18, 2005• Authorizes Commission to require pollutant

minimization plans from both point and non-point 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 ProceduresPMP 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?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 PlansPCB Pollutant Minimization Plans•• Rule and Guidance Rule and Guidance

available on DRBC web available on DRBC web sitesite

www.drbc.netwww.drbc.net

•• Contact John Yagecic at Contact John Yagecic at 609609--883883--9500 x2719500 x271

PCB Pollutant Minimization Plans: Background and GuidanceWhy?Ambient Concentrations Vs. Criteria (Log Scale)Load Vs. FluxesEstimated Loads by Categoryand UncertaintyOriginal Sources of PCBs not the same as Loading Source CategoriesWHY?PCB sources and pathways may be readily identified!Long Duration ProblemImplementation of theStage 1 PCB TMDLs2 Tracks in Developing the PMP ApproachInteragency WorkgroupGeneral Minimization Plan ComponentsGuiding PrinciplesGuiding Principles (continued)Guiding Principles (continued)Guiding Principles (continued)The RuleDRBC Water Quality Regulations Section 4.30.9 “Pollutant Minimization Plans for Toxic Pollutants”PMP ProceduresWill PMP Approach Work?PCB Pollutant Minimization Plans