PCB Waste Minimization Plans: A Key Component for Achieving PCB Load Reductions in the Delaware Estuary

In December 2003, EPA Regions II and III issued Stage 1 TMDLs for Polychlorinated Biphenyls (PCBs) in the Delaware Estuary. These TMDLs were based on modeling and data assessments led by the Delaware River Basin Commission (DRBC). External daily loads of penta-PCBs were estimated for principal source categories that included contaminated sites, non-point sources, point discharges, tributaries, the non-tidal Delaware River, wet and dry atmospheric deposition, and CSOs. Summation of daily loads allowed direct comparison of the relative magnitudes of the different source categories. DRBC's assessment showed that PCBs were entering the estuary from a variety of regulated and unregulated sources, including point sources. Broad approaches for achieving load reductions would be necessary.The initial implementation of the Stage 1 PCB TMDLs includes issuing non-numeric water quality-based effluent limits (WQBELs) to NPDES regulated dischargers. These non-numeric WQBELs would take the form of requirements to monitor discharges using Method 1668A and to implement a PCB pollutant minimization program.Because NPDES permits in the estuary are issued separately by the States of New Jersey and Delaware, and the Commonwealth of Pennsylvania, DRBC convened of working group of permit writers from the three states to develop consistent Pollutant Minimization Plan (PMP) Guidance. Prior to developing the PMP Guidance, the working group reviewed existing plans for facilities outside the basin for a variety of pollutants. Consistently, those plans lacked the specificity and the accountability that would increase the likelihood of achieving real load reductions. The working group developed new guidance that specifically addressed the complexities associated with PCBs and the need for measuring, demonstrating, and reporting load reduction progress.Since the facilities themselves are in the best position to identify and implement strategies for load reduction, we proposed a Guidance document that would:Convey the specific elements necessary for a successful minimization plan;Suggest a consistent framework for communicating those elements to the regulators;Allow flexible, creative, site-specific load reduction strategies; andDocument load reductions.This paper discusses the specific elements in the Waste Minimization Plan Guidance with special emphasis on demonstrating progress. We will also describe how waste minimization fits within the larger framework of cross-cutting strategies, as well as the benefits of waste minimization versus end-of-pipe controls.