Proposed amendments to Canada’s PCB regulations would spare museum operators from having to cull items from their collections. Current rules mandate decommissioning of goods and equipment that contain a concentration of polychlorinated biphenyls (PCBs) greater than 50 milligrams per kilogram or 50 parts per million (ppm) by December 31, 2025, but a handful of specified facilities are in line for a deferral.
The proposed amendments, which have been posted in the Canada Gazette for public response until February 21, would also provide a reprieve for nuclear facilities, coal-fired electricity generating plants scheduled for shutdown by year-end 2029 and specified military applications. All are meant to address implementation issues that were not foreseen when the regulations were enacted in 2008 and updated in 2014.
Notably, it is difficult to even quantify the amount of PCBs in museum artifacts without damaging or destroying them. The existing regulations do not identify museums as a permitted use, meaning that operators face the prospect of having to remove all PCB-containing items from their collections even though the potential health or environmental risks are deemed to be low.
Under the proposed amendments, “any concentration” of PCBs will be permitted in objects of “historical value” if the PCBs are sealed within the item and removal would destroy it. Such items must already be part of the museum’s collection at the time the updated regulations come into force; fire suppression systems would be required in areas where PCB-containing items are kept; and museum operators would have to keep records and annually submit documentation to the Ministry of Environment and Climate Change.
“The Department understands that the PCB concentration in the objects is unknown, and that testing cannot be completed without destroying the objects themselves. The PCBs are contained in sealed objects and consequently, the risk of release is minimal,” the accompanying regulatory analysis states. “Therefore, allowing museums to retain objects of historical value containing PCBs has been added to this proposal. This would allow for the possibility of preserving the historical significance of such objects.”
Proposed exemptions for nuclear facilities and military purposes deal with other kinds of practicalities including the challenges of handling radioactive equipment and PCB waste, and absence of non-PCB alternatives to maintain older ships and aircraft. The proposed extended time period for coal-fired electricity generating plants would align with the December 31, 2029 deadline for taking them out of service.
Military administrators and operators of coal-fired generating plants would have to apply for and received approval from the Ministry of Environment and Climate Change to keep PCB-containing equipment in service past 2025, whereas the amendments would more simply confirm that it is a “permitted activity” for museums. Meanwhile, it is considered safest to refrain from removing PCB-containing equipment from nuclear facilities.
“There are no facilities in Canada able to destroy radioactive PCBs, and therefore it is preferred to leave them in place where they are contained, rather than removing them from use. As the radioactive PCBs are located in contained and confined areas within nuclear facilities, it has been determined that there are minimal environmental risks associated with leaving the equipment in place,” the regulatory analysis advises.
