PCB Variances For The Spokane River - Washington
PCB Variances for the Spokane RiverConnecting to Audio: After joining the webinar, look for the ‘AudioConnection’ pop-up. Select the ‘Call Me’ option (best audio quality) The webinar will call your phoneWe will do a sound check 10 and 5 minutes beforethe scheduled start of the webinar.Having technical difficulties? Let us know via the chat box, or email swqs@ecy.wa.gov.
Photo By Adriane BorgiasPCB Variances for the Spokane RiverWednesday, April 8, 2020, 6 pmOpen House Webinar
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Agenda1Background on PCBs2What is a Variance?3Overview of technology4Preliminary rulemaking decisions5Next steps6Questions
OPENING REMARKSVincent McGowan, Water Quality Program Manager
BackgroundBryson FinchWater Quality Program Toxics Specialist
2018OutreachMarchSpokane Permitting WorkshopMarch 14, 2018AugustWater Quality Permitting Tools WorkshopAugust 8, 2018NovemberWater Quality Permitting Tools Workshop #2:Decoding the Variance ProcessNovember 5, 201810
2019 - 2020OutreachNovember2019April 2020Workshop on PCB Variances for SpokaneRiver DischargersNovember 14, 2019Statewide Webinar on Variances in theSpokane RiverApril 8, 2020Summer2020Public informational workshops and hearingsDuring public comment period11
Water Quality Standards12
Designated UsesDefinition: Those uses specified in the water quality standardregulations for each water body or segment whether or not they arebeing attainedoInterpretation: Goals/Objectives/Desired conditions of a water body Ex. Fish harvest useDesignated uses establish water quality goalsooDetermines appropriate criteria to meet goalsRequires protection of downstream waters13
Water Quality CriteriaDefined: Elements of state/tribe water quality standards, expressed as a constituentconcentration, levels, or narrative statements, representing a quality of water thatsupports a particular useoWhen criteria are met, water quality will generally support the designated use MagnitudeoHow much of a pollutant or measure of a condition (e.g. concentration) DurationoPeriod of time over which the concentration is averaged FrequencyoHow often the average concentration can be exceeded14
What are PCBs? Polychlorinated biphenylso Historically used as coolants in electrical equipment,plasticizers, wax and pesticide extenders, and lubricantso 209 different PCB moleculeso Found almost everywhereo Long-lasting in the environment15
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PCB Criteria: Spokane RiverRegulatory levels forTotal PCBs (ppq)total PCBs(ppq parts per quadrillion)Human healthcriterion (HHC)AcuteAquatic lifecriterion Chronic72,000,00014,000 Upstream Idaho HHC is 190 ppq Downstream Spokane Tribe HHC is 1.3 ppqBasisFish ingestionby peopleFish health17
PCBs in our 1soap2ToothpasteBody carePrinted2products2materials/newsprint*Results are based on sampling of some products1-City of Spokane, 20152-Department of Ecology, 2016174,000 ppq83,000 ppq100,000 – 110,000 ppq100,000 – 7,800,000 ppq2,4000,000 – 53,500,000 ppq
PCBs in the Spokane RiverRM 58RM 8619
Measuring PCBsTwo methods are available to measure PCBsMeasuresMethod 608Method 1668EPA Approved forYesNopermit complianceSensitivityHighVery HighDetection Limit50,000 ppq7-30 ppqBlank InterferenceLimitedHighPurposeComplianceSource tracking Human health criterion for PCBs is 7 ppq20
State and Regional PCB ReductionEfforts21
Cleaning up Contaminated Sites Toxics Cleanup ProgramReducingPCBs in theEnvironmentSafer products for WA Implements Chapter 70.365 RCW PCBs in printing inks Safer alternativesState purchasing policy Avoid products and packaging that containPCBs Set PCB restrictions in state-purchased yellowroad paint22
Chemical Action Plan for PCBs Recommends actions to protect human healthand environment, including:ReducingPCBs in theEnvironmento Identify sources of PCBs in buildings andproductso Address regulatory differences in TSCA andWater Quality StandardsGreen Chemistry Promotes creating fewer toxicchemicals Uses 12 principles to guide saferchemical development and processes23
Spokane River Regional Toxics Task ForceReducingPCBs in theEnvironment Conduct studies that identify PCB levels, andpollution sources Identified PCBs in products and support reductionor elimination Developed Comprehensive Plan (2016) thatcontains 29 control actions Engage in public outreach and education activitiesStormwater controls Municipal Stormwater Permits City of Spokane Integrated Clean Water Plan24
Photo by Adriane BorgiasQUESTIONS?Please use the “raise hand feature,” or type your question in the chat box
Strategies to reduce PCBsChad BrownWater Quality Standards Unit Supervisor26
TMDL approach to reducing PCBsDevelop a Total Maximum Daily Load(TMDL) or Cleanup Plan Identifies reductions needed by point sources& nonpoint sources Not self implementing Point source reductions are put into NPDESpermits Nonpoint sources addressed through “other”efforts27
Variance approach to reducing PCBsIssue variance to 5 dischargers and placerequirements in rule and permits Highest attainable condition applies at point of discharge andis used in each permit Compliance with effluent limit based on Method 608 whichmeasure to 50,000 ppq Requires implementation of Pollution Minimization Program(PMP) actions PMPs address waste stream sources, emerging technologies,and requirements for highest level of reductions28
Permit-only approachAlternate option: Issue permits withoutadopting a variance 7 parts per quadrillion (ppq) effluent limit NPDES regulations use method 608 which measures PCBs tolevels only as low as 50,000 ppq Discharger remains in compliance with the regulatory levels ifmeeting less than 50,000 ppq A variance is a uniquely suitable tool to further the reductionof PCBs (and other pollutants that have regulatory limits wellbelow the ability of the approved analysis to detect them.29
What is a Variance andhow does it work?Chad BrownWater Quality Standards Unit Supervisor
What is a Variance?Clean Water Act and Water QualityStandards Tool40 CFR 131.14 173-201A-420 WAC WQS cannot be attained Enforceable conditions Progress meeting standards by working towardsthe highest attainable condition Regular evaluation of progress31
Variances can apply to dischargers or waterbodiesDischargervariance Individual ormultipleWaterbodyvariance Only applies at points of compliance for thefacility Stretch of water or waterbody Dischargers of pollutant on waterbody canbe covered as long as they meet variancerequirements32
A dischargervarianceatpipethe end of theA discharger varianceapplies atappliesthe end of thepipe A discharger variance does not apply to the entire river. The new interim criterion (HAC) and designated use apply only atthe point of discharge (see red circle in graphic).Discharge pipeRiverA discharger variance does not changeother uses or criteria on the river3333
Reasons why a variance may be needed12Natural,ephemeral,intermittent, or lowflow conditionsNaturally occurringpollutionconcentrationsPhysical conditionsrelated to thenatural features ofthe water body534Dams, diversion, orother types ofhydrologicmodificationsHuman causedconditions orsources of pollutionSubstantial andwidespreadeconomic andsocial hardship6Lake, wetland, orstream restorationactivities734
Variance is a path to clean water over time35
Highest attainable condition (HAC)Must be maintained throughout the term of the varianceFor dischargers that will be installingtreatment technologies during thevariance Best effluent condition, oncetechnology is installed Pollution minimization program2For dischargers with treatmenttechnologies installed Interim effluent condition that reflectsthe greatest pollutant reductionachievable Pollution minimization program336
Core Components of HACQuantifiableEffluent QualityImprovementThe highest attainableeffluent condition expressedas a measurementActions to reduce pollutionthroughout the term of the varianceActions that thedischarger shall take tocontinue pollutantreductionsActions that that the stateshall take to continuepollutant reductions37
How Does a Variance Work?A Variance is a path to cleaner water over timeVarianceProcessPLANIMPLEMENTEVALUATELEARN Evaluate HighestAttainable Condition(HAC) Implement actions toreduce pollutantentering the facility Monitor river andeffluent to make sureHAC is achieved Review variance every atleast every five years Establish a PollutionMinimizationProgram Install and optimizebest feasiblepollution controltechnology at thefacility Monitor treatmentefficiency andprogress to reducepollutant Get public input onvarianceA Pollutant MinimizationProgram (PMP) provides amulti-pronged approachto address PCBreductions. A PMP looksat sources, improvedtreatment technologies,and education.ADAPT Ensure that theadditional pollutantreductions are occurring Demonstrate that thevariance is still neededUse adaptive management to further reduce PCBsentering the environment.
Re-evaluation every 5 yearsLearn Review varianceevery five yearsEnsure that thefurther pollutantreductions areoccurringDemonstrate thatthe variance is stillneededThe re-evaluation isseparate from thepermit process butcan be coordinated(or more often if necessary)Ecology re-evaluates the data and PMP implementation In river data – demonstrates that the variance still necessary Facility treatment data – tracks progress to determine what isthe level of reduction is being achieved Review reports on all other actions to reduce PCBsProcessEcology’s evaluation determines if the variancerequirements being met and what more is needed.Ecology conducts a public reviewEcology submit the evaluation to EPA and modifies thenext permit issuance as necessary.3939
Photo by Adriane BorgiasQUESTIONS?Please use the “raise hand feature,” or type your question in the chat box
Overview of treatment technologyPat HallinanDepartment of Ecology
Overview of current technologySpokane County (Installed in 2011)WastewaterPrimaryTreatment:removal of lEffluentSolids Treatment42
Overview of current technologyLLSWD (2017), IEP (2020), City of Spokane (2021)WastewaterPrimaryTreatment:removal of solidsBiologicalTreatmentAeration basinSecondaryClarifier:removal ofmicroorganismsTertiaryTreatmentEffluent orReclaimedWaterFilterReturn activated sludgeSolids RemovalSolids Treatment43
Overview of current technologyKaiser Aluminum iltrationSolids RemovalSolids Treatment44
Treatment Technologiesfor PCB RemovalTechnology in-place vs determined infeasible atfull scalePhysicalMembrane filtration (all except Kaiser)ChemicalMost are resource (energy and/orchemical) intensiveBiologicalConventional already in placeThermalDegradationEnergy Intensive45
Treatment Technologiesfor PCB RemovalPotential future technology (TBD)Activated CarbonPhysicalReverse OsmosisChemicalAdvanced Oxidation Process(uv/H2O2 or similar)BiologicalBiological Activated Carbon46
Highest Attainable Condition (HAC)Pat HallinanWater Quality Program
Preliminary Decision -- HAC#3The interim effluent condition that reflects the greatestpollutant reduction achievable with the installed technologies(City of Spokane, Spokane County, LLSWD, IEP)Effluent Concentration (pg/L)HAC#3Effluent Loading (mg/day)Treatment System Removal (%)48
Preliminary Decision -- HAC#3The interim effluent condition that reflects the greatestpollutant reduction achievable with the installed technologies(City of Spokane, Spokane County, LLSWD, IEP)Effluent Concentration (pg/L)HAC#3Effluent Loading (mg/day)Treatment System Removal (%)49
Analysis -- HAC#3Treatment System Removal Must be quantifiable! % ��𝑅 ��𝐼𝐼𝐼 𝐼𝐼𝐼𝐼𝐼𝐼𝐼x 100 Used discharger data if available Estimated when discharger data was limited/unavailable50
Preliminary decision -- HAC#2The interim effluent condition that reflects the greatestpollutant reduction achievable (Kaiser) Complete flow reduction projects Evaluate treatment alternatives Install technologies that reflect the greatest pollutantreduction achievable (next level of treatment for PCBs) Ten year timeline51
Preliminary decision -- HAC#2Also requires knowledge of the best quality effluent that is achievable Must be quantifiable! Treatment system removal Estimated based on PCB removal from existing walnut shellsystem plus additional suspended solids removal52
Alternative ActionsPat HallinanWater Quality Program
Alternative actions consideredActions that would result in meeting effluent limits based on theunderlying water quality criteria Municipalitieso Reclaimed water, land treatment, infiltration/injection,evaporation ponds Industrieso Reducing water use, elimination of paper recycling54
Next StepsBryson FinchWater Quality Program Toxics Specialist
What to expect when yousee the draft rule package- CR-102May 20201. Draft rule language2. Draft State Technical SupportDocument3. Draft Implementation Plan4. Draft Environmental ImpactStatement5. Draft Regulatory Analyses56
1. Draft Rule LanguageComponents of the RuleoJustification for the variance (what factor is used) Factors 1 – 7 from the Code of Federal Regulations (CFR 131.10)oHighest attainable condition including quantification method E.g. percent removaloPollutant Minimization Program (statewide and discharger specific)oHighest interim use (e.g. limited fish harvest)oVariance pathway from code of federal regulation (CFR 131.14)oVariance durationoProcedures used to reevaluate the variance57
2. Draft State Technical Support DocumentAnalysis of the variance applicationsoBackground information on PCBs in the Spokane RiveroJustification for the varianceoTechnology overview (current and feasibility analyses)oRecommendations on a numeric value that describes the greatestpollutant reduction achievableoDetails of pollutant minimization programs including a schedule ofactions to reduce PCBsoReevaluation procedures of the HAC58
3. Draft Implementation PlanExplains how the rule will be implemented across all of our waterquality actionsoHow variance review will be conductedoHow the variance review will be coordinated with permit updatesoTranslation of the variance to permitsoPublic notification process59
4. Draft Environmental Impact Statement Evaluate alternatives for the rulemaking Identify our draft preferred alternative Will discuss:oooooRegulatory context (federal and state regulations and statutes)Comments we heard during the scoping period (June-July 2019)Role of a Total Maximum Daily Load (TMDL or cleanup plan)Assessment of issuing permits without a varianceAssessment of variances as an option60
5. Draft Regulatory AnalysesDraft rule analysis for two state statutesoAdministrative Procedures Act determinations:̶ Cost-benefit analysis̶ Least-burdensome analysisoRegulatory Fairness Act requires:̶ Analysis to determine impacts on small business61
Rulemaking ScheduleAprilMayJuneJulyAugSeptOctPublic CommentPeriod (Begin CR-102)Review commentsMake decision62
Thank you!63
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Designated uses establish water quality goals. o Determines appropriate criteria to meet goals o Requires protection of downstream waters. 14. Water Quality Criteria. Defined: Elements of state/tribe water quality standards, expressed as a constituent concentration, levels, or narrative statements, representing a quality of water that
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In earlier times, the Spokane Tribe lived on, protected, and respected over 3 million acres of land. Tribal members fished the Spokane River, the Columbia River, and utilized the grand Spokane Falls as a gathering place of family and friends. The Spokane's lived along the river in three bands known as the Upper, Middle and Lower Spokane Indians.
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