Evidence for Unique and Ubiquitous Environmental Sources Of
Environ. Sci. Technol. 2010, 44, 2816–2821 the production and use in commerce of PCBs was banned Evidence for Unique and Ubiquitous by a series of legislative acts, including the 1973 act that prohibited the use of PCBs in open applications. These open Environmental Sources of applications included the use of PCBs as a transfer agent in 3,3′-Dichlorobiphenyl (PCB 11) carbonless copy paper. An important and often overlooked loophole in the various laws regulating PCB use was that the ,† † inadvertent production of PCBs was allowed to continue as LISA A. RODENBURG,* JIA GUO, long as monitoring requirements were met. Despite this SONGYAN DU,† AND exclusion, PCBs in the United States and in many other GREGORY J. CAVALLO‡ countries are regulated as the sum of all 209 congeners Department of Environmental Sciences, Rutgers University, (∑PCBs). In the United States, the Clean Water Act requires 14 College Farm, Road, New Brunswick, New Jersey 08901, that waterways in which ∑PCBs exceed the applicable water and Delaware River Basin Commission, 25 State Police Drive, quality standard must be subjected to a process in which a West Trenton, New Jersey 08628 total maximum daily load (TMDL) is calculated, promulgated, and implemented. Thus, although inadvertent production Received April 16, 2009. Revised manuscript received July of PCBs is not banned in the United States, it will increasingly 29, 2009. Accepted August 7, 2009. be subject to regulation via the Clean Water Act and the TMDL process. The dichloro congener 3,3′dichlorobiphenyl (PCB 11) is produced inadvertently during the production of diarylide The non-Aroclor congener 3,3 -dichlorobiphenyl (PCB 11) has ′ yellow pigments, which are the most common yellow been recently detected in air, water, biota, sediment, and pigments used in printing as well as a wide variety of other suspended sediment.
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