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Dioxin / Furans

Stakeholders Minutes - April 4, 2000
Workgroup Teleconference Minutes

Workgroup Leaders:
Sandro Leonardelli, EC
Anita Wong, EC
Nan Gowda, EPA

Facilitator:
John Menkedick, Battelle

Introduction

The objectives for the day were to continue application of the decision tree process, identify and discuss plans for implementing reduction projects, and discuss the status of outstanding action items.

Materials distributed to workgroup members prior to the teleconference included: a summary matrix of decision tree analysis outcomes through the March 7 conference call, the teleconference agenda, and a forwarded message from Michelle Lusk (CKRA) with information on cement kilns.

Sector Specific Analysis: Using the Decision Tree Process

As there were no updates or announcements from the group, the meeting moved directly to continued sector analysis discussions.

John Menkedick (Battelle) reviewed for the group the first draft of the summary matrix showing workgroup progress in the decision tree process:

John reminded the group that the goal of the decision tree was to provide a formal, systematic process for deciding which sectors should receive priority attention from a BNS perspective and that the priority designations being assigned were only in regards to BNS related opportunities for those candidate sectors that met the 2% criteria for either the U.S. or Canadian inventories.
He emphasized that the document was in draft form, and would be updated as workgroup discussions progressed
He noted also that the document was intended only to provide an overview of the priority levels assigned so far, and to help guide the group in efficiently completing discussions and priority designations for the remaining sectors, as possible, before the May Stakeholders Meeting

The goals of the day’s sector discussions were stated:

to reach closure on PCP and the cement kiln sector
to discuss the iron sintering and steel manufacturing sectors

John asked the group if there were any preferences regarding the order of discussions.

The group agreed to stick to the agenda as it was distributed

It was noted that for closure of PCP and cement kilns, discussions would be limited to about 15 minutes each.

Pentachlorophenol (PCP)

The workgroup had discussed available information related to PCP treated poles at the last meeting, but due to time constraints, had not reached consensus on a priority level designation.

The issues remaining at the last meeting were recapped:

USEPA considers the fate of PCP poles taken out of service to be largely unknown, with only one study (Walsch, 1999) available as a source of information on utility pole management
utility solid waste managers consider life-cycle management of poles to currently be the dominant practice due to CERCLA liability issues

Dwain provided details on the utility pole study:

the study was presented at the utility pole conference in Florida (Walsch, 1999), and was based on a survey of predominantly large utility companies in the southeastern United States.
results of the survey showed that about 23% of the poles went into landfills, about 14% were disposed of in incinerators, 31% were given away, and 18% were sold (i.e., less than 50% of utility poles taken out of service have a controlled disposal fate)
the survey covered all utility poles, not just PCP-treated poles
Dwain also noted that the survey statistics might have reflected even less management if smaller, rural, or utilities in the western states were included in the survey.

Jim Roewer (USWAG) noted that his group has been working with members to encourage the distribution of safety information along with the poles when they are being passed to another user, and suggested that the survey information used by EPA is outdated. He also asked if it was known who specifically answered the questions, i.e., were the proper sources, such as environmental department heads, asked.

Dwain thought that the survey data was about two years old, but suggested that it should be used as the default data until better information is gathered.

Doug Green (Piper Marbury Rudnick and Wolfe LLP / USWAG) reported that he talked with Mr. Walsh, and that Mr. Walsh indicated some utilities want to sell poles for reuse and that they consider reuse a form of recycling. He asked if give-away was considered a form of recycling that was of concern from an environmental standpoint.

Dwain responded that the important question was whether there is an infrastructure in place to trace these recycled/reused poles, and to assure that they find an ultimate proper disposal.
Dwain suggested that to give PCP poles a “low” priority designation, we would need to verify that all PCP treated utility poles (recycled poles included) are being properly managed to the end of life.

Jim Roewer noted that the consumer safety sheets which are distributed with reused poles identify appropriate / inappropriate uses (e.g., PCP treated poles may not be used for residential burning). In addition, he noted that after the secondary user is done with the poles, they become industrial solid waste which is subject to disposal requirements in some cases.

Dwain and Doug agreed that they could talk more off-line about the available information on PCP poles, and to report back to the workgroup.

Sandro Leonardelli (EC) asked if the eventual goal for PCP was to form a subgroup similar to subgroup on open barrel trash burning

it was suggested that this might be a possible goal for PCP

Sandro also noted that as part of the Canadian Wood Preservers SOP, a life-cycle analysis study of treated poles was being conducted, and that EC would report back to the workgroup on results. It was suggested that PCP treated utility poles be tentatively classified as “medium” priority in terms of the BNS, but acknowledging that more information was needed.

Cement Kilns

Dale Phenicie (CGLI) reviewed for the group that a detailed discussion on cement kilns had taken place at the last conference call, but that time hadn’t allowed for final consensus on a priority designation.

Dale proposed that cement kilns be designated as “low” priority, due to well established voluntary initiatives, MACT and RCRA requirements, etc. that are already in place.
Michelle Lusk (CKRA) also reviewed the information presented last week from the CKRA issue paper 3 (which was also distributed to the workgroup electronically):
most of the information presented can be found in detail in the HWC MACT ruling
in the MACT development process, over the past 6 years CKRA has worked with EPA to obtain testing data from all facilities
currently, EPA’s OSW has the most current, accurate data on cement kiln emissions (obtained as a result of BIF testing requirements)
between 1990-97, EPA recognizes that cement kilns have had about a 97% voluntary reduction in dioxin/furan emissions from cement kilns (e.g., by using quench technology, inlet temperature controls, etc.)
in 1997, emissions were estimated to have dropped to 13.1 g TEQ / yr (from 431 g TEQ / yr in 1990); by 2002 emissions are predicted to drop to less than 8 g TEQ/yr with full MACT compliance
approximately 50% of all test data show emissions that are less than the 0.5 ng /m3 dioxin limit

The issue of cement kilns dust was raised:

Dwain Winters noted that EPA has proposed land disposal requirements / limits for dioxin / furans
Ann Dougherty (PCA) also noted that because cement kiln facilities are controlling dioxin stack emission by preventing formation in the first place, this type of strategy also prevents the accumulation of dioxins/furans in the cement kiln’s dust.

Sandro Leonardelli added that in Ontario, dioxin/furan emissions from cement kilns are very low.

Following this information review, the workgroup reached agreement that cement kilns should be assigned a “low priority” status, based in progress already made in emission reductions, voluntary activities by the industry, and adequate management that will be in place regarding cement kiln dust.

Next, discussion moved on to the steel and iron sectors.

Iron Sintering

Dwain Winters (USEPA) provided a brief overview of available information on the U.S. side:

the previous inventories only had order of magnitude estimates due to a lack of test data available for iron sintering
the EPA has now obtained quantitative testing data from 2 facility types
the new (reference year 1995) estimates are 32.7 g TEQ / yr, with a high enough confidence rating to move this sector into the quantitative inventory

Sandro Leonardelli (EC) provided a brief overview of available information on the Canadian side:

in the Canadian Great Lakes Basin there were 2 iron sintering plants; one plant (Algoma) shut down, and the remaining plant (Stelco) has a published emission estimate of 23.5 g TEQ / yr with scrubber technology (which is the single largest point source remaining in Ontario)
in 1998, Stelco re-conducted emissions testing and results showed dioxin emissions of 5.7-6 g TEQ / yr.
the Iron and Steel SOP, which is linked also to the CWS development, is underway to work on limiting emissions;
the new testing data was presented at the CWS meeting last month, and under the SOP technology options are currently being researched

Rick Lane (Stelco) reported that the Stelco facility has been working on the development of reduction options, with a goal of 50% reduction in dioxin/furan emissions by 2005 (this has been proposed to the MOEE). They are currently designing new equipment (considering using a pretreatment nozzle system before the scrubber) which they hope to get in place.

It was noted / clarified that the goal of the decision tree process is to determine if the BNS workgroup can provide any added value (i.e., by designating a sector as high priority) to reduction processes already in place.

Don Perander (AK Steel) added that according to a meeting between 3 U.S. facilities and the EPA last week, water discharges of dioxins from iron sintering facilities were very low, especially as compared to air emissions.

In summary:

in the U.S., the 32 g TEQ / yr estimate is relatively low compared to the total inventory
in Ontario, the 5.7 g TEQ / yr estimate is high relative to the total inventory; however, in Canada, the SOP and CWS P2 programs are in place or are being developed

It was suggested that there probably wasn’t any value to be added to the SOP and CWS processes by the BNS at the current time

A question was asked regarding EPA’s satisfaction with the current U.S. database:

Dwain indicated that although it would be ideal to have more testing data (i.e., a broader range of facilities), the database now was much better than several years ago and additional testing would probably not fall into a high priority designation

It was suggested, and agreed to, by the workgroup members present, that the iron sintering sector be designated “low priority”, dependent on the success of the Canadian reduction mechanisms. It was added that the status of the Canadian progress should therefore be closely tracked in this sector, possibly on an annual basis or as new information becomes available.

Steel Manufacturing (EAF)

Dwain reported that the U.S. currently does not have sufficient emissions data available on steel manufacturing (EAF) to include a quantitative estimate in the inventory:

they have used the European emission factor to develop a preliminary sense of what level of priority should be placed on added testing of EAF (estimates using this method are about 44 g TEQ / yr plus or minus 2 orders of magnitude)
one of the concerns with the available test data is that the majority of measurements were taken in the midst of operating conditions, as it is known that most of the emissions occur during start up.
the number of steel EAF in the U.S. is currently unknown

Sandro Leonardelli (EC) reported that there are 5 steel EAF facilities in Ontario.

Tom Wesolowski (Lasco) noted that some of these facilities were tested, and that results showed emissions were much (about 5 times) lower than in Europe.

It was also noted that under the CWS development, additional testing had been conducted in Canada; indications were that the European emission factor was significantly higher (e.g., for a 1.3 to 1.5 metric ton / yr production rate, dioxin emissions were 0.7 g TEQ / yr)

A question was raised regarding the reasons for differences in North American and European emissions:

it was suggested that in some cases Europe does not have the infrastructure in place to dispose of some wastes (e.g., chlorinated solvents) and that as a result, they were throwing everything into their scrap pits
it was also noted that North American facilities are using cleaner scrap, which comes from in-house recycled sources as well as purchased scrap (mostly from automobiles)

Generally, representatives from the Canadian steel industry and the EC agreed that significant new testing data was forthcoming for EAF, and that it would be sufficient to assess whether this sector should be a high, medium, or low priority for the BNS in Canada:

Courtice, Stelco, and IPSCO steel were all in the process of or planning testing

A question was asked on whether this testing included start-up conditions:

Tom Wesolowski reported that the testing of the Dofasco EAF was representative of a full operation cycle, including all cycle process (i.e., charging, initializing batch, refining, etc.)
it was also noted that European studies had shown that the quality of the scrap doesn’t affect dioxin emissions as long as the fuel system is properly operating and has proper cool-down (i.e., quench) technology in place to prevent dioxin formation.

Dwain Winters suggested that the critical question is whether more accurate data on steel EAF emissions in the U.S. is needed:

neither Dwain or the U.S. industry representative were aware of any testing currently being conducted
it was suggested that as a default, the U.S. could draw some conclusion based on the Canadian data

It was reported that two EAF facilities in New Jersey had been tested and results reported to the NJ Department of Environmental Protection:

one facility has emissions at de-minimus levels
one facility was slightly above, although this plant had an operation setup that was the worst case scenario

Dwain noted that the issue of high variability in EAF emissions was important, and that in order to lay the question of emissions to rest, additional test data from a wide variety of facilities would be needed.

he said that although expectations were that EAF may not be a huge source, there was no basis for a final conclusion.
additionally, if the process of information gathering on the U.S. side was either in progress or planned, EAF would a low priority in the sense that the data need was being addressed.
he suggested that U.S. steel EAF industry could address this need by developing a voluntary testing program

Industry representatives cited the high expense of testing and lack of incentives as barriers to voluntary industry efforts towards obtaining additional data.

It was suggested that the EAF sector should be designated as low priority at this time due to lack of data, but that this lack of data should be acknowledged and ideas for encouraging additional testing should be developed.

Anita Wong (EC) noted that in Canada, EC and industry work together on developing testing programs. She asked whether the US had any sort of framework or guidance for industries developing testing programs.

Dwain said that information gathering efforts conducted by the Pulp and Paper industry had been developed similarly to the Canadian programs.

Options for information gathering and developing incentives for steel EAF were summarized:

Canadian data could be used and applied to developing US estimates
further conversation could be held with the steel industry trade associations on voluntary testing
incentives to help encourage testing could be identified
EPA could provide detailed guidance for testing (i.e., hand-in-hand testing)
EPA could provide peer review of industry-conducted testing

Dale Phenicie suggested that it would be useful to talk to Bruce Steiner of the American Iron and Steel Institute (AISI) about developing an information gathering process, in collaboration with EPA, in the U.S..

Gary Allie (Ispat-Inland) noted that the primary trade organization for EAF was the Steel Manufacturers Association (SMA), and that Tom Danjczek (president) should also be contacted regarding testing program development.

Sandro Leonardelli proposed that the steel EAF sector be designated high priority with regards to data gathering in the U.S., but low priority with regards to actions at this time.

The concept of the decision tree having different focus areas (i.e. priority for action versus priority for data gathering) was discussed. It was noted:

the tree has a loop to explore how information will be gathered for data gaps
information gathering efforts fall under step 1 of the 4 step BNS process

A question was raised on whether this sector met the criteria (i.e., is this likely to be a significant source in the basin?) to merit putting a high priority on further testing

industry representatives thought that the preliminary data available indicated that EAF were not likely to be a significant source in the basin
it was suggested that EAF could be tentatively designated as low priority, with the condition that more information is needed to verify this.

It was noted that the Dofasco facility in Canada that had low emissions is a very new facility, and thus may not be representative of the entire sector.

industry representatives explained that it is the design of the fuel system, not the age of the facility, that determines level of emissions
the point was made that additional information gathering was especially important in light of the fact that there is such variety in the fuel systems

John Menkedick notified the group that the meeting time was running short and that it a priority designation would probably need to be resolved at the following conference call. He noted that the discussions today had seemed to indicate that the biggest issue was whether the concern was sufficient enough to warrant a high priority designation for additional data gathering efforts.

John asked the group if they thought another call in addition to the May 2 call would be necessary before the May 16 Stakeholders Meeting.

no group members indicated that they thought this would be necessary
Dwain suggested that preparing a document of information to date would help to facilitate discussion at the next meeting

It was noted that the SMA Environmental Committee was having meetings on the 11th and 12th of May, and that 95% of the facilities would have representatives participating.

Action Items

Time did not allow for workgroup review of the outstanding action items.

Next Steps and New Action Items:

Next teleconference the workgroup will:

finish prioritization of the steel manufacturing (EAF) sector
complete discussions of the other remaining targeted sectors and assign a priority level to each sector
discuss plans for the May Stakeholders Meeting.

New action Items:

The workgroup will continue work on current action items identified in the action item update.

The next conference call is scheduled for May 2, 2000.

Participant Roster

Dave Ailor, Coke Institute
Gary Allie, Ispat-Inland Inc. / Steel Manufacturer’s Association
Tom Barnett, Ispat-Inland Inc.
Doug Bley, Bethlehem Steel Corporation
Ann Dougherty, Portland Cement Association
Herb Estreicher, Covington & Burling
Dick Fillman, Bethlehem Steel Corporation
Nan Gowda, USEPA Region 5
Doug Green, Piper Marbury Rudnick and Wolfe LLP / Utility Solid Waste Activities Group
Tom Hornshaw, Illinois EPA
Dave Ingall, The Coke Institute
Rick Lane, Stelco Inc.
Sandro Leonardelli, Environment Canada
Michelle Lusk, Cement Kiln Recycling Association
Jeff Lynn, International Paper
John Menkedick, Battelle
Don Perander, AK Steel Corporation
Dale Phenicie, Council of Great Lakes Industries
Jim Roewer, Utility Solid Waste Activities Group
Tom Shepker, WCI Steel Inc.
Brent Steele, Dofasco Inc.
Joe Stepun, Western Lake Superior Sanitary District
Diane Thompson, City of Superior, Wisconsin WWTP
Tom Wesolowski, Co-Steel Lasco
Dwain Winters, USEPA
Anita Wong, Environment Canada
Maureen Wooton, Battelle