Manufacture of Polychlorinated Biphenyls (PCBs) was banned in the United States in 1979 due to concerns about the toxicity of these chemicals. However, until that time they were incorporated in a wide range of products and materials, much of which is still in use across the country. Ongoing concerns regarding PCBs, including their persistence in the environment, have resulted in extensive regulation.
Avista manages PCBs and mineral oil that contains low levels of PCBs in a manner that meets or exceeds the federal Toxic Substances Control Act (TSCA) and Washington State’s stringent regulations. Our goal is to minimize risk associated with PCBs, to avoid spills or releases, and to clean up any releases to levels of non-detection.
The vast majority of the equipment in service at Avista is non-PCB. The first wave of removal efforts, following TSCA, focused on “PCB equipment” containing 500 ppm or greater of PCBs. This type of equipment, as identified, was removed and properly disposed of during the 1980s. Rarely, through testing, we discover PCB equipment in service, and it is scheduled for removal.
We have also implemented an accelerated effort to remove PCBs from our system in several ways. As equipment is replaced during system upgrades or expansions, equipment containing any level of PCBs is retired rather than retro filled. There are rare exceptions to this approach for unique equipment that we must maintain as backup; such equipment is appropriately stored.
We have implemented a sampling/testing program to determine whether some older equipment contains PCBs, where information was unavailable from the original manufacturer. As equipment is discovered to contain PCBs, immediate removal is scheduled for any items with 500 ppm or more; typically, removal is also planned for equipment containing 50 ppm or more PCBs as a precautionary measure. In addition, Avista implements targeted removal, through a process termed Serial Number Sequencing. In that effort, as testing reveals the presence of PCBs, we target for removal any other equipment that was manufactured and shipped with the tested item. In these efforts, Avista is committed to managing PCBs in a manner that protects our environment and meets or exceeds all regulatory requirements, and that will lead to the elimination of PCBs from our system.
“RCRA waste” represents hazardous waste as defined in the Resource Conservation and Recovery Act. Avista looks for ways to reduce generation of hazardous waste and manage waste streams. The largest single source of hazardous waste is represented by aerosol cans, which are collected from throughout the company, and if determined to be not completely empty, treated as hazardous waste. We manage all RCRA wastes in accordance with state and federal regulations. This includes, as appropriate, treatment or disposal at permitted landfill or incineration facilities.
“Non-RCRA” wastes include waste streams that are not deemed “hazardous,” but which we manage as special wastes. These include waste oils, greases, antifreeze, and a range of miscellaneous wastes that can be recycled, blended into fuels, or responsibly disposed of. These are managed and disposed of in accordance to state and federal regulations.
“Universal wastes” include specific waste streams designated by federal and state law that are excluded from being treated as “hazardous” if they are managed according to specific standards. These include items such as fluorescent light bulbs. We manage all universal wastes in accordance with these standards.
In 2009, the most recently reported year, we disposed of 103.4 Kg of PCB wastes managed in accordance with the Toxics Substance Control Act (TSCA) via incineration.