by Mr. John C. Hilborn and Dr. John Buccini

Presented by Dr. John Buccini

In Canada, federal and provincial governments share responsibility for the management of PCBs. The federal government regulates PCBs in commerce (e.g. manufacture, use, sale, import, export), and the management and disposal of PCBs on federal land. The provinces regulate PCB management and disposal within their jurisdictions, and generally control these activities by issuing permits to manage or dispose of PCBs. Transportation of PCBs is regulated by federal and provincial Transportation of Dangerous Goods Regulations.

Canadian federal and provincial Ministers of the Environment establish policy, and provide scientific and technical guidance on PCB management, through an organization known as the Canadian Council of Ministers of the Environment (CCME). The CCME has produced a number of guideline documents on managing PCBs that set out criteria that both levels of government can adopt in their respective jurisdictions. More stringent requirements can be implemented, if necessary, through provincial regulatory and permitting processes.

The federal government became involved in the management of PCBs in the 1970's in response to scientific evidence that these substances were harmful to the environment. In 1973, the Organization for Economic Cooperation and Development (OECD) issued a Decision document titled "Protection of the Environment by Control of PCBs", which called for measures to keep these substances out of the environment. To implement the OECD Decision in Canada, regulations were made in 1977 to control the dispersive use of PCBs. PCB use was permitted in situations where the PCBs are well contained, such as in electrical transformers and capacitors.

A number of initiatives were undertaken to promote better management of PCB wastes. In 1977, an inventory and labelling program was initiated to identify and keep track of PCB-containing electrical equipment. To assist PCB owners, the federal government produced a number of reports, including "Guidelines for the Management of PCB Wastes" in 1978; "Guidelines on Central Collection and Storage Facilities for Waste Material Containing PCBs", also in 1978; the "Handbook on PCBs in Electrical Equipment", in 1981; and "Fires in Electrical Equipment Containing PCBs", in 1985. A number of these publications have been updated, and some were the basis for future Canadian PCB regulations.

The CCME also commissioned an Action Plan for PCB management in Canada. The 1979 Action Plan called for the establishment of PCB destruction facilities and the development of a long-term PCB phase out strategy. The objective of the phase-out strategy was to accelerate the removal of PCBs from service. The plan also called for the development of national codes and standards for storage, handling and destruction of PCBs.

By 1985, many Canadian provinces had enacted hazardous waste legislation that could be used to control the management and disposal of PCBs in their jurisdictions. The province of Ontario had gone a step further, and had developed regulations specifically for PCBs. Disposal of PCB wastes was still a problem since there were no provincially-permitted high level PCB destruction facilities in the country. There was little opportunity to export PCB wastes for disposal because the United States had closed its border to PCB waste imports and exports in 1980, and many European countries would not accept international PCB waste shipments. Although a small amount of Canadian PCB waste was shipped to Europe for disposal, most of Canada's PCB wastes were simply stockpiled at more than 3,000 locations across the country. A number of provinces were considering siting hazardous waste facilities that would be capable of handling PCB wastes, but only one had advanced beyond the planning stages. The province of Alberta had made good progress, expecting to have a facility operational by 1987.

Beginning in 1985, a number of high-profile events involving PCBs occurred in Canada that raised public sensitivity to PCB issues to an unprecedented high level, and set the tone for future public debate on PCB issues in this country. As a direct result of these events, more regulations were enacted by the federal government to control how these substances were to be managed.

The first major incident occurred on April 13, 1985, when a PCB transformer that was being transported across Canada on a flat-bed truck leaked PCB fluid over 100 kilometres of the Trans-Canada Highway. The contaminated highway pavement was ultimately torn up and replaced. There was great concern expressed in the media about the potential health implications for people travelling the highway behind the truck.

The second major incident occurred in 1988, three years later, when a large stockpile of PCB wastes caught fire. Several thousand residents of the town of Saint-Basile, in the province of Québec, had to be evacuated because of that fire.

Immediately after the 1988 PCB fire, the federal government enacted strict PCB waste storage regulations and launched the $15 million Federal PCB Destruction Program. The objective of the federal program was to site mobile PCB destruction facilities in several regions of the country. The key features of the federal program were that it provided limited financial assistance to get projects underway; federal lands were considered as potential destruction sites; both federal and private-sector wastes were to be destroyed; temporary, mobile facilities were to be used; facilities were to be sited in several regions of the country; and facilities would not be imposed on communities. Financial support was potentially available for studies to characterize the PCB waste inventory, public education and consultation, the site selection process, environmental assessment, and environmental monitoring. In late 1989, a mobile PCB incinerator was commissioned to destroy PCB wastes at Goose Bay, Labrador. However, despite a concerted public consultation and education process over the next five years, public opposition to siting similar facilities in other regions of the country prevented the siting of more mobile facilities.

These were not the only events that Canada would experience where PCBs were implicated. An abandoned stockpile of PCB wastes in the town of Smithville, Ontario was discovered to have leaked PCBs and contaminated the community groundwater supply and a costly clean-up program was initiated. In 1989, a shipment of PCB waste originating from the 1988 PCB fire in Québec, which had been sent to the United Kingdom for destruction, had to be returned to Canada. British dock-workers had refused to unload the dangerous cargo. There was also strong public opposition when the preferred site for a hazardous waste management facility in southern Ontario was announced.

Concern about PCBs continued into the 1990's. PCBs were discovered on a sunken barge that was to be raised from the Gulf of St. Lawrence, and it was feared that the PCBs would leak when the barge was lifted. An industrial site in Atlantic Canada was also discovered to contain high levels of PCBs. Collectively the events described above led to the introduction of a series of regulations and guidelines in Canada for the management of PCBs, and an intensive effort to secure more PCB destruction capacity.

The federal government has enacted four PCB regulations.

These regulations were introduced in 1977 to implement the OECD decision to control non-dispersive uses of PCBs, and have been amended several times since then. They prohibit all dispersive uses of PCBs from the time the regulations were made in 1977; set out allowable PCB concentrations in products; prohibit commercial activities involving PCBs, such as manufacture, processing, use, offer for sale and import (except import for destruction of PCB wastes); and prohibit PCB use in servicing and maintaining equipment, except for electromagnets and transformers, and as new filling or make-up fluid in this equipment. The only remaining uses of PCBs in Canada are in electrical transformers and capacitors existing in Canada before July 1, 1980, and in certain other "closed-use equipment" (specifically heat transfer equipment, hydraulic equipment and vapour diffusion pumps) that were in Canada before September 1, 1977. The regulations also limit environmental releases, as a result of a spill or leak, to 1 gram of PCB per day.

Immediately after the PCB fire in 1988, regulations governing the storage of PCB wastes were made. The regulations require anyone who owns, controls or possess PCB material to maintain control over entry to the storage site, store PCB materials in specified containers and in a specified manner; make stored equipment and containers accessible for inspection; protect stored equipment; have fire protection and emergency plans and clean-up procedures; and provide the specified fire alarms, fire suppression systems, fire extinguishers, and clean-up materials.

Storage sites must be inspected monthly and maintained as prescribed in the regulations. Labels must be affixed to specified equipment and containers; records pertaining to the PCB equipment and containers of PCB material at the storage site must be maintained and available for review by inspectors. A copy of the records of wastes stored and material received at, or removed from, storage sites must be submitted to Environment Canada within specified periods. Changes in the name or address of the owner or manager, or the location of the site, must also be reported.

These regulations were made in 1989 in conjunction with the Federal PCB Destruction Program. They apply to mobile systems that destroy the PCB molecule by chemical or thermal means, and only apply on federal land, or to operations under federal contract. Under these regulations, there is a duty for federal departments to ensure that the person who operates a mobile PCB treatment system or a mobile PCB destruction system under contract with them complies with the requirements of the regulations. The regulations require persons operating these systems to operate them such that they do not release pollutants to the environment in concentrations in excess of the emission standards specified in the regulations. Before operating the system, an operator must provide the Minister of the Environment with information on the design and performance of the system to demonstrate that the emission standards can be met, and obtain written authorization from the Minister to operate the system. If performance information cannot be provided, the operator can obtain a federal authorization to test the system to determine if it is capable of meeting the emissions standards. During commercial operation of the system, the operator can be required to conduct compliance tests to determine if the system continues to meet emission standards. The sampling and analytical methods to be used to test emissions are also specified in the regulations.

The export of PCB waste was banned in 1990 after the PCB waste shipment was sent back from the United Kingdom in 1989. An exception was made for the export of PCBs to the U.S. In November 1995, the federal government amended the regulations and closed the border to PCB waste exports to the United States (U.S.-owned PCBs in Canada could still be exported to the U.S.). The border was re-opened in February 1997 under new PCB Waste Export Regulations that allow export for treatment and destruction at U.S. Environmental Protection Agency-approved facilities, but do not allow export for landfilling of PCB wastes. However, in July 1997, a U.S. court decision overturned the U.S. rule that allowed import of PCB wastes into the U.S., and therefore at present no PCB wastes are crossing the Canada-U.S. border.

The CCME has developed guidelines for the management and disposal of PCB wastes.

The "Guidelines for Mobile PCB Treatment Systems (1990)" and the "Guidelines for Mobile PCB Destruction Systems" (1990) address the technical requirements for these systems, recommended permitting procedures, selection of sites for the operation of these systems, operating requirements and procedures, monitoring and inspection, occupational health, waste transport, process waste disposal, emergency response and contingency planning, and site clean-up and closure. Under the PCB treatment guidelines, PCB-contaminated mineral must be decontaminated to below 2 ppm PCB. Under the destruction guidelines, a PCB destruction and removal efficiency (DRE) of 99.9999 percent is required, which in practice means that no more than one molecule of PCB is released to the air in the stack gases for every million PCB molecules entering the system. Criteria for dioxin, furan, hydrogen chloride, particulate matter and other substances are also specified.

The 1989 "CCME Guidelines for the Management of PCB Wastes" define a PCB waste as any PCB liquid, PCB solid or PCB equipment containing more than 50 parts per million PCB that have been taken out of service for the purpose of disposal. The guideline addresses decommissioning and decontamination of PCB equipment, storage of PCB wastes, labelling and record-keeping, transportation, and gives an overview of PCB disposal capacity in Canada at that time.

The 1995 CCME "PCB Transformer Decontamination Standards and Protocols" were developed in response to demand for more detailed information on how to clean transformers than was given in the 1989 general PCB waste management guidelines. This document outlines the management options in Canada for the reuse of transformers and for the recycling of both PCB-contaminated and askarel transformer components. Transformer management practices in other countries are also reviewed.

Based on available data, the report concludes that if a transformer that contains PCB liquid at a PCB concentration below 200 ppm is carefully drained, the metal surfaces are considered to meet the criteria of 10 micrograms PCB per square metre or less, and can be landfilled, or preferably, recycled. In addition the porous components of such a transformer are considered to contain less than 50 ppm PCB and can be landfilled without further testing. In order to dispose of a transformer that contains PCB liquid with a PCB concentration above 200 ppm, however, the transformer must be cleaned, and all metal and porous components tested before disposal or recycling.

Mobile PCB treatment systems have operated routinely since 1983 in Canada, under both federal and provincial permits, to service low level PCB contaminated mineral in electrical transformers. Operating permits limit the maximum PCB concentration in the untreated oil to up to 14,000 ppm PCB, depending on the process. An estimated 75% of the contaminated mineral oil in Canada contains less than 500 ppm PCB, and 95% contains less than 1,000 ppm. Most of the mobile treatment systems use technology based on the reaction of sodium with the chlorine on the PCB molecules to produce sodium chloride and non-chlorinated biphenyl. Four companies in Canada operate commercial mobile systems, and have been permitted under federal regulations to treat federal PCB contaminated mineral oil: PPM Canada Ltd., RONDAR (ENSR), Sanexen, and TASSCO.

With the advent of the Federal PCB Destruction Program, mobile and transportable PCB incinerators were investigated to help solve Canada's PCB problems. Smaller systems, capable of processing about 2 tonnes of PCB waste per hour, and larger transportable incinerators, capable of processing 5-10 tonnes per hour were both considered. The smaller systems were attractive because Canada has over 3,000 PCB storage sites, some of which contain very small amounts of PCB wastes. The larger systems were generally considered, as a rule of thumb, to be applicable where about 3-5000 tonnes of PCB waste was available to process at one location. Consolidation of PCB wastes in Canada is not widely practised, a legacy of past experiences where waste stockpiles were mismanaged.

The mobile incinerators that have been used in Canada were developed in the United States for the clean-up of contaminated sites. Some of the incinerators were also approved for PCB destruction under the U.S. Toxic Substances Control Act, although more recently, dedicated stationary hazardous waste incinerators have been used for PCB waste destruction in the U.S. These mobile technologies were designed primarily to handle soil and sludge, but some rotary kiln incinerators were built that could also handle liquid PCBs. The use of mobile technologies became a logical option for Canada because stationary facilities were not available, except in the province of Alberta.

The federal government has been involved in both demonstration tests of PCB destruction technologies and in the use of this technology for commercial PCB destruction projects. Demonstration tests are designed to show if a PCB treatment or destruction system is capable of meeting regulatory requirements. In contrast, destruction projects are conducted with commercially available proven technology. Environment Canada defines the latter to mean technologies that have operated successfully under sustained, routine field conditions, and have received regulatory approval. In theory, a demonstration project can be carried out in tandem with a destruction project, however this is not encouraged. Experience has shown that the assessment of demonstration test results invariable is slow, may be controversial if not all tests are judged to be successful, and may therefore delay a planned PCB destruction project.

For both demonstration projects and regulatory compliance testing during PCB destruction projects, it is essential to have a quality assurance plan to document the proposed program, emissions and environmental sampling and analysis protocols, quality assurance and quality control procedures (external and internal), and to specify data quality objectives. It is also very important to define clearly the roles and responsibilities of all parties to a test program, and to develop a clear understanding of how test results will be interpreted and used.

The Vesta 100 mobile PCB incinerator demonstration test program was conducted at the Alberta Special Waste Treatment Centre between November 1989 and May 1990. The Vesta 100 system is a small mobile, rotary kiln incinerator. The pilot-scale Eco Logic hazardous waste was tested at Bay City Michigan under a cooperative program with the U.S. EPA in 1992. This is a unique system, developed in Canada, which destroys PCBs by hydrogen reduction. The Vesta 200, a second generation system, was tested at Baie Comeau, Québec in 1992. The full-scale Eco Logic system is being tested in Ontario this year on PCB liquids, solids and electrical equipment. The Cintec Environnement Inc. fluidized bed incinerator is also being tested at full-scale at Baie Comeau, Québec. Final test results for the Cintec and EcoLogic full-scale systems are not yet available.

Demonstration test programs provide the operators with valuable experience working with regulatory authorities in designing and conducting tests that will satisfy regulatory requirements. These companies also acquire valuable operating experience which enables them to redesign and improve their systems, if necessary, before scale-up or commercial operation.

The only stationary PCB disposal facility operating in Canada is the Alberta Special Waste Treatment Centre, located near the town of Swan Hills, Alberta. That facility began operating in 1987, and expanded its rotary kiln incineration capacity in 1994 to 35,000 tonnes per year. A transformer furnace is used to decontaminate the casings and internal transformer components. Since February, 1995, the facility has been available to destroy PCB wastes from across Canada. The overall nominal hazardous waste treatment capacity of the facility is 55,000 tonnes per year.

The Goose Bay, Labrador PCB destruction project was conducted on Department of National Defence property in 1989-90. The majority of the PCB wastes destroyed were owned by the Canadian military and originated in Labrador. Over the next five months, about 3,500 tonnes of PCB waste belonging to the federal and Newfoundland governments were destroyed using a mobile infrared incinerator operated by O.H. Materials Ltd.

In 1985 the province of Ontario took over the management of the PCB waste that was contaminating the community water supply in the town of Smithville, Ontario. A contract was awarded to the U.S. company Ensco Inc. of Little Rock, Arkansas to perform the PCB destruction work using the ENSCO MPW-2000 transportable rotary kiln incinerator. The incinerator underwent compliance testing at Smithville beginning in February 1991, and operated until December 1992. During this period, the incinerator destroyed about 18,000 tonnes of liquid PCBs and shredded PCB-contaminated electrical equipment, concrete and soil.

Significant quantities of PCBs are still in use in Canada, mainly in electrical equipment, and large quantities of PCB wastes are still in storage awaiting destruction. PCB destruction capacity in Canada is available, and new PCB destruction technologies are undergoing demonstration tests this year. Entrepreneurs continue to explore opportunities to introduce new, emerging technologies. Canadian PCB waste owners have indicated that they want more disposal options, including the option of shipping PCBs to the U.S. for disposal.

The Council of the Commission for Environmental Cooperation adopted resolution #95-5, "Sound management of Chemicals" in October 1995, creating a framework promoting regional (North American) cooperation on chemicals of mutual concern, one of which is PCBs. To implement the resolution, a PCB Task Force was struck, which developed a Regional Action Plan for the management of PCBs in North America. The draft plan embodies the principles of sound regional environmental management, life cycle management, pollution prevention, shared use of treatment-disposal capacity, treatment and disposal in reasonable proximity to the wastes, consistency with international and domestic obligations, transfer of technology, and periodic review and assessment of the plan. The draft Regional Action Plan call for developing a code of practice for managing PCB wastes; open controlled borders; phase out of PCBs in sensitive locations; elimination of dispersive uses of PCBs; elimination of non-dispersive uses of high concentration PCBs; harmonized sampling and analysis, waste classification, labelling; and PCB waste storage time limits.

Good progress has been made in Canada in putting in place the regulatory and administrative framework that is necessary to manage these substances. These efforts continue, and there is every reason to believe that there will be a successful resolution of the PCB problem in Canada in the foreseeable future.