San Francisco Bay PCB TMDL proposed

By CMTA Staff

Capitol Update, Aug. 3, 2007 Share this on FacebookTweet thisEmail this to a friend

The San Francisco Regional Water Quality Control Board is pursuing the adoption of a TMDL (Total Maximum Daily Loading) for PCBs (polychlorinated biphenyls).  PCBs have been banned since the 1970s, but residual levels exist in the environment, including in San Francisco Bay and the watersheds that drain into it.  

Although residual levels are low compared with many other parts of the country, the Regional Board wants them reduced at least 10- to 20-fold more to achieve a water column goal of 20 to 50 parts per quadrillion.  This is much more stringent than the California Toxics Rule.  

After reviewing the proposal, concerns have been raised as to the potential economic impact the proposed amendment will have on a wide array of businesses, construction activities, public agencies, and infrastructure projects without providing a commensurate environmental benefit.  For example, the proposal deals with stormwater runoff and will focus on "all current and future permitted discharges, including but not limited to, CalTrans roadway and non-roadway facilities and rights-of-way, atmospheric deposition, public facilities, properties proximate to stream banks, industrial facilities, and construction sites."  

The proposal also states that "stormwater permittees will be required to develop and implement a monitoring system to quantify PCBs urban runoff loads and the load reductions achieved through treatment, source control and other actions; support actions to reduce the health risks of people who consume PCBs-contaminated San Francisco Bay fish; and conduct or cause to be conducted monitoring, and studies to fill critical data needs identified in the adaptive implementation section."  Huge sums of money would be necessary to physically remove PCBs from the Bay margin, where the Regional Board calls for mass removal of PCBs through dredging and capping, without regard to risk reduction benefits.  

The ostensible benefits of this TMDL are minimal and speculative.  This TMDL is another example of an unsound regulatory proposal that is not supported by science and that will likely impose very significant costs on California in general, and the San Francisco Bay Area regional economy specifically, without commensurate environmental benefit.  

Comments on the TMDL have been extended until Monday, August 20th, at which time the Regional Board plans to close the record and proceed to a September 11th hearing.  CMTA has joined a coalition in opposition to this action.

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