Messages From Mike: Episode 4
Mike James | May 13, 2020 | Blog
Virginia – PCB Sampling
I have recently been talking about the fact that across the country the regulatory agencies are not easing up; they are actually making the regs tougher and they are, in many cases, enforcing them much more rigorously. Three states currently require sampling for PCBs and the winner of the race for being tough is Virginia. Most of the rivers in Virginia have, in one way or another, been impacted by PCBs.
A large number of auto recycling and scrap metal facilities are now required to sample for low-level PCBs. The new buzzword is “congener”, which refers to related chemical substances. PCBs are a family of 209 congeners. There are very few laboratories that have the equipment to run this analysis and, without fail, it is an expensive sample. Because the rivers in the area are contaminated, the states are developing a TMDL (total maximum daily load; basically this is the total amount of pollutant you can discharge). If you have to sample for this, you must take the samples, prepare a Corrective Action Plan, and you must get all of this approved by VADEQ. The state has recently started to enforce on those facilities not performing the sampling. The toughest region is Northern Virginia, with Tidewater coming in second. We have seen penalties of as much as $25,000, plus required monthly site inspections and reporting.
You can avoid this kind of oversight by simply performing your sampling and submitting your reports to the state on time.
Let me say it again. Do your sampling and submit the reports on time; not one day late!
Stay Safe Out There!