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San Francisco Bay PCBs TMDL Project

Background:

In 1994, California issued a sport fish consumption advisory cautioning people to limit their consumption of fish caught in San Francisco Bay. The advisory, updated in 2011, was issued because of concerns about high levels of several pollutants in San Francisco Bay fish. Some of the more serious of these pollutants are polychlorinated biphenyls (PCBs). PCBs were manufactured in the United States and widely used from the late 1920s through the 1970s. They are of particular concern because they are toxic, persist in the environment, and accumulate in the tissue of fish, wildlife and humans.

Addressing the PCBs problem illustrates the challenges of dealing with "legacy" pollutants. A significant proportion of PCBs pollution in San Francisco Bay happened decades ago, before the potential health effects of PCBs were widely understood. Because PCBs degrade very slowly in the environment, their toxic effects are still with us today. Another challenge of addressing PCBs pollution in San Francisco Bay is the potentially costly cleanup of sediment hot spots, localized areas in the Bay with particularly high levels of PCBs in sediments. Recognizing these challenges, the San Francisco Bay PCBs TMDL Project uses a phased approach to pollutant reduction and cleanup to restore the beneficial uses of the Bay.

For more, click on our fact sheet:

Cleaning up PCBs in San Francisco Bay, June 2012 (PDF file).
LandSat map of the Bay region

TMDL Approved by USEPA

On March 29, 2010, the U.S. Environmental Protection Agency approved a TMDL for Polychlorinated Biphenyls in San Francisco Bay. The TMDL was approved by the State Office of Administrative Law and became effective on March 1, 2010. The Water Board is now implementing the TMDL on the variety of fronts described below.

Regulatory Documents
The San Francisco Bay PCB TMDL was considered and adopted by the Regional Water Quality Control Board (Water Board) at hearings on September 17, 2007 and February 13, 2008. It was adopted by the State Water Resources Control Board on October 20, 2009.

  • The TMDL is set forth in this Basin Plan section.
  • The TMDL was adopted by the Water Board in Resolution R2-2008-0012
  • Supporting documentation is contained in the Final Staff Report (pdf, 5MB)
  • February 13, 2008 Water Board Meeting Minutes, Item 8 (adoption of the TMDL)
  • Transcript from the September 17, 2007, Water Board meeting (consideration of the TMDL)
  • The TMDL was adopted by the State Water Resources Control Board in Resolution R2-2009-0076

TMDL Implementation

This section summarizes how key implementation actions are carried out.

Watershed Permit – Discharge permit for municipal and industrial wastewater sources of PCBs
The Watershed Permit requires both municipal wastewater and industrial wastewater dischargers to take certain actions to reduce PCB discharges to the San Francisco Bay. Adopted on March 9, 2011 (Order No. R2-2011-0012, hearing materials, see Item 6), it amended the NPDES permit adopted by the Water Board in 2007 to implement the mercury TMDL. Some of the Watershed Permit’s requirements are: identify and manage controllable sources of PCBs; use best management practices to maintain optimum performance for solids removal; use updated analytical methods to test for PCBs; and undertake a program to reduce the health risks for people who eat San Francisco Bay fish contaminated with PCBs and mercury.

Municipal Regional Permit – Permit for municipal stormwater sources of PCBs
The NPDES Municipal Regional Permit (see Provision C.12), adopted October 14, 2009, requires municipalities in Alameda, Contra Costa, San Mateo and Santa Clara Counties and the cities of Fairfield-Suisun and Vallejo (Pemittees) to reduce controllable sources of PCBs that can be mobilized by stormwater runoff and transported to receiving waters. The Permit takes a phased approach by requiring several pilot-scale projects, which will be evaluated for effectiveness in reducing loads of PCBs. These include:

  • Evaluate managing PCBs in construction materials, such as caulk, that can be released to the environment during demolition and renovation. Click here for the project page.
  • Identify and abate areas with high PCB concentrations.
  • Evaluate enhanced sediment removal and management practices for stormwater conveyances, such as city street sweeping, pump station cleaning.
  • Evaluate on-site stormwater treatment retrofits,
  • Evaluate diversion of dry weather flows and first flush runoff for treatment (e.g. at a wastewater treatment plant).

Click here for a summary of these five projects.

Also, Permittees are developing a comprehensive monitoring program with fixed stations at the bottom of several key watersheds that will be monitored several times per year. The data will be used to estimate loads of PCBs and other contaminants from local tributaries and stormwater conveyances and to track these loads over time.

Finally, Permittees are required to undertake a program to reduce the health risks of people who eat PCBs- and mercury-contaminated San Francisco Bay fish; this project is described below. You can access reports submitted each year under the Municipal Regional Permit by clicking here.

Fish Consumption Risk Reduction Activities
Both the Watershed Permit and Municipal Regional Permit require dischargers to undertake a program to reduce the public health impacts of exposure to PCBs and mercury in San Francisco Bay fish. The dischargers are jointly funding the California Department of Public Health to lead efforts to engage stakeholders, such as local agencies, tribes, and community groups, in improving communication to the public about how to reduce their exposure to PCBs and mercury from consuming SF Bay fish. Further information can be found here: San Francisco Bay Fish Project.

PCBs in Cleanup/Remediation Sites
Guidelines for implementing the TMDL during site investigations and cleanups, including recommended analytical methods for soils, are given here.

Ongoing Monitoring of Fish and the Bay
To track progress on how PCB concentrations in the Bay and its fish are changing over time, the Regional Monitoring Program (RMP) measures PCBs (and many other contaminants) in water, sediment, and fish tissue collected at several locations around the Bay each year. You can view and download these data for yourself using their versatile web query tool.

The RMP has monitored contaminants in prey fish (small fish consumed by birds or larger fish) for several years, because these small prey fish, which tend to stay in localized areas, provide useful information on the spatial and temporal patterns of contamination in the Bay. Moreover, these prey fish are consumed by many birds and larger fish, so they provide an early warning for contamination higher in the food web. Small fish monitoring data and interpretation are contained in a summary report.

Since 1994, the RMP has also been monitoring the concentrations of PCBs and other contaminants in sport fish, which are commonly consumed by humans. A recent report comparing the concentrations of contaminants in sport fish caught in the Bay to those caught offshore is also available. The figure below shows how PCBs concentrations in sport fish change through time in different parts of the Bay and how these concentrations compare to the 10 parts per billion fish tissue target from the TMDL.

Links:

Health Information, Fish Consumption Advisories, and Outreach to Consumers of SF Bay Fish

Information about PCBs in Caulk

Proposition 13 Grant-Funded Studies: Urban Stormwater Best Management Practices (BMPs)
This project’s goal was to assist municipalities in implementing the San Francisco Bay mercury and PCB TMDLs through the development of specific information on drainage systems, sediment loads, distribution of mercury and PCB contamination, urban runoff loads, and BMP function in relation to trapping or removing mercury and PCBs. Click here for the project web site.

U.S. Environmental Protection Agency

For more information contact:
Jan O'Hara
Water Resource Control Engineer
San Francisco Bay Regional Water Quality Control Board
1515 Clay St., Suite 1400
Phone: (510) 622-5681
Fax: (510) 622-2460
E-mail: JOHara@waterboards.ca.gov