NPRI
Unlike the U.S. database TRI (Toxics Release Inventory - see Emissions Inventory), reporting of PCB releases and transfers are not required.

 

Spills

There are no publicly-available reporting requirements.

 

Permitted Water Discharges

No publicly available database to assess this route of emissions to the Great Lakes

 

Waste Disposal

Due to gaps in the Ontario regulatory regime, some PCB wastes may escape regulation because of the threshold definitions; resulting in the unknown existence or location of many PCBs in diffuse locations. Over half of the PCBs manufactured were disposed of, but not necessarily destroyed, prior to enacted regulations. In the Quebec regulatory regime, there may also be gaps in coverage related to oil and grease where residual thresholds of PCBs are not met, or where the requirement for draining transformers does not provide for disposal of the contents.

 

Destruction

While there are statistics kept on PCB destruction, their accuracy may be affected by the accuracy and consistency with which PCB amounts and / or levels of contamination can be measured (some are by weight, some by liquid; for example, 40 tons of steel could be contaminated with PCBs with no information on what the actual PCB contamination level was.)

 

STORET  

The STORET systemdata reflects a lack of sampling for PCBs, rendering Basin-wide surface water levels of PCBs largely unknown. PCB loadings to land are not well quantified in terms of PCBs that escape or leach from confinement or during remediation. Existing PCB sources, such as equipment, auto fluff, and abandoned or illegal landfills/dumpsites also are not identified throughout the Great Lakes Basin, rendering estimates of loadings to the environment difficult to quantify.

 

Transformers

Voluntary retrofitting and inadequate and incomplete databases on both the continued use and the disposal of transformers make it difficult to know the actual numbers and locations of existing transformers.

 

Capacitors

Incomplete databases and inadequacy of reporting requirements make it difficult to know the actual numbers and locations of capacitors versus permit holder location. Lack of requirements addressing small capacitors - those with less than 50 ppm PCBs – allow the use and disposal millions of small capacitors with no reporting obligation.

 

See also, II. Gaps in U.S. PCB Policies and Strategies (p. 17).

IADN  

IADN (Integrated Atmospheric Deposition Network) network stations are few in number (17 in all of the Great Lakes) and may not adequately characterize the extent of atmospheric sources of PCBs.

 

Sediments

In general, it is difficult with the existing available data to measure PCB quantities in Great Lakes sediment. The data are either incomplete or not available for all Great Lakes and their tributaries. Data needed are both suspended solids in the water column as well as PCB sediment data, preferably surface and sub-surface. Although all media are affected by PCBs, sediments appear to be both the greatest sink and source of PCB deposition, with levels often exceeding the TSCA hazardous waste classification level of 50 ppm. At the same time, contaminated sediments remain largely uncharacterized in terms of the extent of PCB contamination.

 

Fish

While fish advisories for PCBs in the Great Lakes are frequent, not all of them are protective of the most sensitive and/or the most exposed individuals (pregnant/nursing women and children; subsistence fishers).

 

Other PCB Sources Not Quantified

Auto fluff and abandoned/illegal waste sites. According to U.S. EPA in September, 1999: "Between 1929 and 1975, closed electrical systems (e.g., capacitors and transformers) accounted for approximately 77% of industrial uses. Open-ended applications (e.g., plasticizers, carbonless copy papers, petroleum additives, and others) accounted for 15% of industrial uses. Finally, nominally closed systems (e.g., heat transfer fluids, hydraulic fluids, and lubricants) accounted for an additional 8% of industrial uses." (from: "Economic Analysis of the Final Rule to Modify Reporting of Persistent Bioaccumulative Toxic Chemicals Under EPCRA Section 313", p. I-2.

 

Other sources not quantified include capacitors in light ballasts, and municipal landfills that can accept PCB-containing equipment containing less than 50 ppm concentration.

 

 

Lack of communication among reporting and regulatory agencies  

Regulatory and reporting databases are not centralized. The TRI (Toxics Release Inventory) doesn’t “talk” to NRC (National Response Center), PCS (Permit Compliance System) is not user friendly and is also not linked with TRI, etc. One central clearinghouse could help estimate total PCB emissions. For example, it is not clear whether an “Accidental Release” indicated in the TRI is also be recorded as a “Spill” in the NRC.