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NORA Releases Coles Environmental PCB Report Submitted to EPA

Wednesday, April 20, 2016   (0 Comments)
Posted by: Kat Turner
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Gainesville, Virginia- NORA has just released the report to EPA by Coles Environmental concerning PCB's effects on the Used Oil Recycling System. Click here to view the full Coles PCB Report. 

On April 7, 2016, NORA submitted to EPA a lengthy report entitled PCB Infiltration Into the Used Oil Recycling System: Causes, Costs and Corrective Actions.  The report, written by an independent environmental consultant, David G. Coles,  discusses the widespread use of PCBs in the United States for over half a century (from 1929 to 1979).  Because PCBs were so “ubiquitous” for many decades, the Coles report pointed out that “the widespread assumption that PCBs would be ‘flushed out of the system’ within a decade or so after the manufacturing of PCBs was prohibited has turned out to be wildly over-optimistic.”  As a result, “it is clear that the oil recycling industry bears the brunt of the unknown but probably massive quantity of PCBs that continues to infiltrate used oil.”

A key component of the Coles report were the confidential interviews of 25 oil recyclers (most of whom also managed wastewater) who provided important statistics on the impacts of PCB contamination incidents.  According to the report,

For the companies that reported having had one or more PCB incidents, the total cost resulting from their largest incidents exceeded $33,000,000.  This amount does not include the more numerous smaller PCB incidents.  Overall, there were 132 PCB contamination incidents over the past 20 years at 17 of the 25 companies that were surveyed.  The average cost of the largest PCB incident was approximately $2,000,000. Eight companies reported that they encountered no PCB incidents.  However, two of these companies stated that they did not test for PCBs.

On a positive note, based on the survey of the oil recyclers, NORA’s effort to educate its members on the need to implement Best Management Practices has been “largely successful.”  Of the 25 companies surveyed all but one (a non-NORA member at the time of the survey) were knowledgeable about the BMPs and “22 out of the 25 companies are implementing at least some of the BMPs.”  However, the cost of implementation is substantial.  According to the survey results, “the average annual cost of implementing BMPs is $233,000.”

One finding in the Coles report will not surprise anyone that has experienced a PCB incident.  Even where the original PCB generator has been clearly identified, EPA will not launch an enforcement action against the generator.  Instead, EPA imposes heavy fines on the oil recycler who also has to pay for the remediation project.  The one and only EPA enforcement action against a “generator” occurred when EPA targeted the City of Tacoma that operated a DIY used oil collection facility at a landfill.  The actual culprit who disposed of the PCBs as DIY motor oil was never identified.
The Coles report also analyzed the costs involved in addressing a PCB incident under current TSCA regulations in comparison to the costs under NORA’s proposal to EPA.

Under NORA’s proposal, the cost of addressing a used oil/PCB incident would be significantly reduced in most cases -- but certainly not eliminated.  An oil recycler’s remediation costs under the current TSCA regulations are likely to be 3 to 5 times the costs under NORA’s proposal.  These remediation costs are in addition to the oil recycler’s expenses to implement NORA’s Best Management Practices.  Under NORA’s proposal these costs may be manageable; under EPA’s current rules, especially in today’s devastating energy market, the oil recycler’s costs would be catastrophic.  
The Coles report can be found on the NORA website by clicking on < PCB/TSCA Reform Efforts located on the bottom of the homepage, and scrolling down to more info.


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