With increasing knowledge of the harmful health effects of polychlorinated biphenyls (PCBs), state agencies are beginning to incorporate PCB requirements into permits. In Virginia, Virginia Pollutant Discharge Elimination System (VPDES) permit reissuances for both Individual and Industrial Stormwater General Permits have included requirements for some facilities to develop and implement a PCB Pollutant Minimization Plan (PMP).
EPA and Virginia have been working to develop Total Maximum Daily Loads (TMDLs) for PCBs in watersheds across the state which assign Waste Load Allocations (WLA) in these watersheds. Although TMDLs are currently being developed in several sections of the James River and its tributaries, the following watersheds in Virginia have approved TMDLs for PCBs:
- Shenandoah River,
- Roanoke River,
- Levisa Fork including Garden Creek and Slate Creek,
- New River, and
- Potomac River.
Although many of these TMDLs were approved over a decade ago, the permit requirement to develop and implement a PCB Pollutant Minimization Plan is just being realized with the 2020 permit reissuance.
Pollutant Minimization Plans are designed to investigate potential sources and reduction of PCBs in a facility’s discharge. In general, a facility’s PMP provides the following information:
- Site contact,
- Actions to identify and control known, probable and unknown sources of PCBs,
- Proposed minimization activities and an implementation schedule,
- Previous minimization activities,
- Methods for measuring, demonstrating and reporting progress,
- Estimate of PCB load reductions,
- Schedule to monitor discharges and report results, and
- Methods for continuing assessment of progress.
PCB monitoring and analysis associated with the PMP must be conducted according to EPA Method 1668, a low-level analysis that detects individual PCB congeners, and in accordance to Virginia Department of Environmental Quality’s (VDEQ’s) PCB Point Source Monitoring Guidance No. 09-2001.
Once the PMP is approved by VDEQ and implemented, an Annual Report summarizing activities under the PMP and proposed revisions to the PMP will be submitted to VDEQ by February 10th for the previous year’s activities. The intent of these PMPs is not necessarily for a facility to meet its WLA in the first year of implementation, but PMPs are living documents that are adapted over time to a facility’s changing PCB reduction achievements and goals.
If you have questions regarding these requirements or are preparing your PCB Pollutant Minimization Plan, please contact us.