Office of Pollution Prevention and Toxics
U.S. Environmental Protection Agency
401 M Street SW
Washington, DC 20460
January 30, 1997
This document has been subjected to internal review at the U.S. Environmental Protection Agency (US EPA); however, the contents of this document do not necessarily reflect the views and policies of the EPA, nor does mention of trade names or commercial products constitute endorsement or recommendation for use. This document is intended only as an informative summary document of the PCB experience in the United States.
7.0 FACTORS AFFECTING A PCB MANAGEMENT PROGRAM
For countries that are considering developing a PCB management program, several key factors might include:
Evaluation of the scope of the problem
Infrastructure
Cost
Identification of PCB contamination
Cleanup of contaminated sites
Disposal capacity
7.1 Scope of the Problem
Before action can be taken to develop a PCB management approach, it is important to understand the nature and extent of the PCB problem. As an initial step, it will be useful to undertake an assessment of the amount and types of products containing PCBs that are in use or storage in the country. To identify potential sources of contamination, it will also be helpful to locate information on prior disposal of PCB items, as well as information on past spills.
7.2 Infrastructure
An evaluation of existing infrastructure may be useful as an initial step. For example, does the country already have storage facilities that would require only minimal alterations to safely store PCB materials? Does any infrastructure already exist for safe destruction or disposal of PCBs? If no or inadequate PCB destruction currently exists, could some technologies be obtained without the need for a large amount of new technical expertise and equipment, at a reasonable cost?
7.3 Cost
Cost is often a key factor for governments in determining the type of PCB management program that is chosen. In some cases, incineration or chemical waste landfills may be the most appropriate disposal option for PCB materials. While incineration of PCBs may achieve the lowest PCB concentrations, the costs of incineration capable of achieving such low levels may be considered unaffordable in some cases. Policies that encourage high-efficiency incineration without consideration of their cost may be ineffective. The cost of an adequate chemical waste landfill also can be high (e.g., the cost of an adequate synthetic liner at the landfill to prevent contaminant transport offsite ). If certain types of low-risk PCB materials are adequately treated (e.g., properly drained), they may be appropriate for disposal in a municipal, non-hazardous waste landfill, which is much less costly.
Some of the other, less costly technologies described in this paper have performed reasonably well as destruction or disposal options for PCB wastes, and could be considered. Oftentimes mobile PCB technologies may be less expensive than stationary technologies. Laws or other regulatory requirements or policies will be most effective if they take into consideration realistic testing, storage, destruction, and disposal infrastructure and associated costs.
7.4 Identification of PCBs
Many countries may find that it is too costly to require testing of all PCB materials and materials suspected of containing PCBs to determine whether PCBs in fact exist in the material, and the concentration of PCBs. While this type of testing is required for hazardous waste cleanup sites in the U.S., it is not required for many other PCB materials. Instead, assumptions of PCB concentrations are made, based on the original use of a material, its age, and related knowledge regarding how likely it is that the material might contain PCBs and the possible concentration. Facility operators can choose to perform testing if they wish to indicate whether PCBs are present and at what concentrations. A similar "assumption"-type approach might be considered as an alternative to requiring comprehensive, expensive testing of all materials that might contain PCBs.
7.5 Cleanup of Contaminated Sites
Cleanup of sites contaminated with PCBs can be expensive and time-consuming. In the U.S., location and access concerns are used to determine adequate cleanup levels. That is, sites where human exposure to PCBs are the greatest must be cleaned up to a higher degree than sites where potential exposure is less (e.g., areas with restricted access).
7.6 Disposal Capacity
Even after a country develops a PCB management program, it may find that not enough destruction and disposal capacity exists. Addressing this need can be a challenge. If land disposal of PCB wastes is needed even after PCB destruction occurs (which can be the case for several PCB destruction technologies), and land is available at a reasonable cost, this may help meet the need. However, constructing a chemical landfill in a manner that adequately protects human health and the environment can be expensive.
Countries that lack disposal capacity and the resources needed to develop their own capacity may be tempted to explore export/import arrangements with other countries that are willing to accept such waste. All countries considering such agreements should be aware of the provisions of the Basel Convention, which encourages countries to develop their own hazardous waste management capabilities and prohibits shipping of hazardous waste to countries that do not have adequate management capacity.
7.7 Summary
While developing a PCB management program is a major commitment, there may be ways to make it more practical and affordable, including:
Making reasonable assumptions regarding whether PCBs exist in a material in lieu of requiring testing of all suspect materials.
Modifying existing infrastructure, if possible, to inexpensively serve PCB waste needs (e.g., storage facilities).
Using less costly but effective PCB destruction technologies, if more costly options are unaffordable.
Cleaning up sites contaminated with PCBs to levels that adequately protect human health and the environment (not necessarily to the highest possible level, if the site poses no unreasonable risk).
Developing disposal capacity for PCBs as much as possible within the country (i.e., using cost-effective destruction technologies, and if land is available and affordable, adequate and safe landfill sites). Any consideration of import/export agreements should be made in accordance with accepted international policies.