Spokane Riverkeeper, alongside several other environmental stakeholders, have been working hard to clean up the PCB contamination in the Spokane River and Little Spokane River. Earlier this year, the EPA released a long-awaited draft PCB Total Maximum Daily Load (TMDL) aiming to address PCB contamination and meet Spokane Tribal water quality standards. Though this is a monumental step in reducing PCBs in the River, the draft plan fails to adequately address PCB contamination in the Spokane River. We submitted a comment letter to the EPA asking them to address significant concerns we have with the draft plan, particularly to ensure that the plan adequately addresses the human health concerns with PCBs.
Background
Once widely used in everything from electrical insulators to underwater paint, PCBs are now considered a long-lived pollutant associated with increased risk of cancer, reduction of immune function and impairment of the neurological development of fetuses. PCBs are toxic in extremely small quantities. The family of chemicals, polychlorinated biphenyls, lasts for years in the environment and are passed along through the food chain when one animal eats another.
Sampling shows that PCBs in the Spokane River increase downstream from the Idaho border to the Long Lake Dam, with hot spots between the Sullivan Road area and the Green Street Bridge in Spokane. The concentrations of PCBs in our water are significantly higher than state and Spokane Tribal water quality standards. PCBs make the fish in our river unsafe to eat, and right now, there is a fish consumption advisory because of this.
This issue has profound environmental justice implications as toxics like PCBs collect in fish tissue making them inedible and dangerous over certain amounts. The Spokane River has many users, including tribal subsistence fishers, who rely on our river as a primary source of food. Due to differences in culture and lifestyles, sport anglers and subsistence fishers may consume up to 10 times more fish and seafood than average U.S. consumers. Many of these fishers are BIPOC individuals or immigrant populations. The higher consumption rates of these populations can lead to significant exposures. (Hovinga et al. 1993; Judd et al. 2004).
Problems with the Draft TMDL
Our primary concern with the draft plan is the scope of data monitoring and methods used for analyzing compliance and progress. The current draft looks at the water column, but it doesn't consider enough data about PCBs in the river's sediments and in fish tissues. PCB congeners, with their varying characteristics such as solubility and toxicity, require a more comprehensive approach that includes sediment and fish tissue data. Fish tissue data is particularly informative and was the basis for the current fish consumption advisory.
Other rivers, like the Delaware River and Fox River, have used more detailed plans that look at the sediments and different types of PCBs. These plans have been more successful at cleaning up the rivers. These models consider factors like sediment reservoirs and congener-specific analysis, which are crucial for accurate assessments and effective interventions. The draft model for the Spokane River assumptions about “permanent burial” of PCBs and reliance on harmonic flows do not adequately represent the complex dynamics of the Spokane River system.
The selection of appropriate analytical methods is critical. Older methods like EPA Method 8082 can’t detect small amounts of PCBs, which is necessary to ensure the river is safe. Newer, more sensitive, congener-specific methods, such as EPA Method 1668C, can find even tiny amounts of PCBs, such as to ensure accurate monitoring and compliance. Discharge Monitoring Reports (DMRs) should emphasize comprehensive monitoring, including wet and dry conditions, sediment, and biological tissue, to capture the full scope of PCB contamination.
As drafted, the TMDL excludes many potential PCB sources across the watershed, such as hatcheries, dams, and all sources upstream of the stateline. The plan must address all known sources of PCBs to adequately clean up the contamination. Ignoring any source means PCBs will keep entering the river, making it harder to clean up. It is important to include all known sources of PCBs into the plan, as well as measures to identify sources of contamination that may not yet be identified.
Conclusion
Spokane Riverkeeper is committed to working with the EPA and other stakeholders to ensure the effective implementation of the PCB TMDL. We hope our comments and recommendations contribute to a robust and comprehensive plan that will achieve the necessary PCB load reductions and restore the health of the Spokane River watershed.
If you would like to read our full comment letter, you can find it here.