Great Lakes Binational Toxics Strategy

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Dioxin / Furans

Stakeholders Minutes - December 3, 2002
Draft Meeting Minutes: Workgroup Breakout Session

Workgroup Leaders:
Anita Wong, EC
Erin Newman, EPA

Introductory Remarks and Announcements

Erin and Anita welcomed the workgroup participants and announced that in addition to the items on the agenda, they were also interested in feedback from the workgroup regarding potential sectors for future workgroup focus, based on the outcomes of the decision tree process over the past two years.

Dioxin Reassessment Update and Discussion

Dwain Winters (USEPA) provided the group with an update on the Dioxin Reassessment. He reported that the main change in the revised Reassessment will be a strengthening of the discussion of cancer and non-cancer effects. The Reassessment will be going to an Inter-Agency Working Group (IWG), who will be focusing revision efforts largely on the scientific backing with regard to health effects. The IWG will also work on developing a strategy that includes other Agencies beyond EPA and includes the development of a communications strategy. Dwain reported that, as a result of findings that indicated it would not be helpful, a RfD was not specified in the Reassessment. However, the marginal dose approach was expanded significantly.

Dwain highlighted some new studies since the last published reassessment for the workgroup. He also described a statistically valid survey of meat and dairy, to be completed in another year, that should provide an analysis of dioxin decreases since 1995.

Dwain also noted that the 2000 Inventory will be a stand-alone document and it will provide three points of reference: 1987, 1995 and 2000 (hopefully they will have a public comment draft by this summer).

In response to a workgroup question on what work remains to be done regarding dioxin sources, Dwain suggested that in the future it may be beneficial to narrow the focus from all sources to primary exposure sources, exposure intervention, and reservoir sources. The workgroup discussed nuances of the exposure scenario including the air to leaf pathway, food and diet supplements for dairy cattle, inadvertent ingestion of soil at contaminated sites, and the erosion of soil into surface waters. A member of the group suggested that the food/agriculture industry should be involved in the workgroup and it was noted that EC has already passed dioxin-related regulation on feed and food.

Burn Barrel Subgroup Update and Discussion

Bruce Gillies (EC), the lead of the Burn Barrel Subgroup, gave an update on current Burn Barrel Subgroup activities. He referred the group to the burn barrel subgroup’s website (www.openburning.org ) for background information on household garbage burning, emissions studies, a draft open burning strategy, outreach materials, and more. The subgroup has primarily been working on gathering and organizing information to create outreach messages for use in various open burning campaigns. He also gave an overview of other education initiatives and outreach materials that have been developed in the Great Lakes region over the past couple of years, such as the EcoSuperior environmental programs in Ontario, Western Lake Superior Sanitary District activities in Minnesota, the University of Wisconsin’s outreach brochure, and the Chlorine Chemistry Council’s new outreach brochure. Bruce reported that household garbage burning issues have been receiving national attention in both the U.S. (e.g., U.S. EPA Office of Solid Waste education outreach) and Canada (Canadian Council of Ministers of the Environment inventory and trench burning study).

After the review of recent activities, Bruce introduced the issue of a letter addressed to manufacturers or advertisers of open burning products such as burn barrels. In general, the importance of conducting education and outreach regarding open trash burning was noted, with justifications including: (1) dioxin emissions associated with open burning of trash have been fairly well characterized, (2) there are alternatives, and (3) the problem is of large enough magnitude to be of concern in the context of national dioxin emissions. Also, it was mentioned that the public advertising of burn barrels clearly undermines the subgroup’s outreach efforts. Bruce encouraged the workgroup to discuss how such a letter might be constructed that would effectively support states.

Erin gave some history on the original request for this letter, which came from Minnesota and asked for support in sending a letter to a burn barrel manufacturer in Illinois. Since that original request, the subgroup has identified other manufacturers and advertisers of burn barrel-type products on the web. Since the burning of trash is illegal in some states, the advertisements have switched from marketing products for burning garbage to products for burning brush and leaves.

The question was raised as to whether different approaches would be necessary for addressing uncontrolled burning other than garbage burning, like brush burning, agricultural burning, or trash burning to heat garages or other indoor spaces. Requiring dioxin testing through regulation was also noted as anther possible approach.

There was discussion of problems with EPA writing a letter, given that:

Burning trash is not illegal in many states.
There is no test data to back up brush burning as a source of dioxin.
There is no test data on the individual products or applications a company may be manufacturing or advertising.

It was also mentioned that a letter from a state government might actually be more effective than a letter from EPA anyway. The workgroup decided that EPA cannot send a letter, but they would be willing to support states in their efforts to contact manufacturers and advertisers. Bruce said that he would explain the rationale behind the workgroup’s decision at the next burn barrel subgroup teleconference on January 21, 2003.

The workgroup then discussed issues related to infrastructure and regulations on burn barrels. Bruce mentioned that they seem to be going backwards on infrastructure improvement. Issues and potential projects discussed by members of the workgroup included:

Looking for success stories for models (e.g., transfer stations or other waste collection strategies that have been successful).
Having stores responsible for taking back packaging.
Helping incorporated townships where there is no responsible government unit or landfill capability.
Focusing education campaigns on areas where the infrastructure does allow for change.
Gathering information on “hand-warming” barrels at construction/industry sites (i.e., what is being burned, how prevalent the practice is, etc.).
Gathering information on coke barrels in steel mills, used for warming equipment and people. However, another workgroup member mentioned that there should not be burn barrels inside of industrial plants for safety reasons, and that most industrial safety practices should preclude this practice. It was also notes that blast furnaces and sinter plants were tested by EPA and no dioxin was found (study published in the Federal Register).
Gathering information on burning in outdoor boilers, which heat water by burning wood very slowly in an outside box. There is anecdotal information that in Ontario this practice is growing and there may be safety concerns related to this practice. A workgroup member mentioned that there are other groups looking into this (e.g., the Hearth, Patio and Barbecue Association and groups in New York State), and that the workgroup may want to consider this as an agenda item for a future meeting.

Incineration Ash and Landfill Fires Update

Anita reported that there is still a need for information on dioxin levels in ash from incinerators. She said that she will bring data from EC’s contractor on dioxin levels in ash in Canada to the workgroup. Dale Phenicie said that he will check on progress with locating data on dioxin levels in ash from the Medical Waste Incinerator (MWI) sector in the U.S.

On the Canadian side, landfill fires are illegal, but they are still reported to occur. On the U.S. side, there are permitted fires, as well as accidental and underground fires at landfills. The U.S. is planning to test upwind and downwind from landfills both in normal operation as well as those with underground fires. It was noted that the occurrence of landfill fires may be a confounding factor in encouraging people to send their garbage to the municipal dump rather that dispose of it in burn barrels. The U.S. is also hoping to test emissions from intentional landfill fires in another country, such as Mexico. The issue of intentional landfill fires would be covered in the Burn Barrel Strategies as a part of dealing with municipalities.

Update on MACT Standards

Erin distributed data on large Municipal Waste Combustor (MWC) emissions post-MACT that showed a greater than 99% reduction. In the 2000 Inventory, the U.S. will have a facility by facility inventory of emissions. Dwain estimated that there will be a major reduction in dioxin produced after the implementation of MACT rules.

Discussion on PCP-treated Wood

It was noted that the USWAG guidelines on treated wood need to be distributed to the workgroup. Anita mentioned that EC plans to work with a national group on addressing PCP-treated wood and associated waste management issues, including work on a pilot project. The national effort in Canada will be directed at all types of treated wood.

Dwain mentioned that EPA is working with USWAG in trying to develop a Memorandum of Understanding (MOU) with the utilities industry related to PCP-treated wood, and including other treated wood as well. The MOU will reach beyond simply addressing secondary use and disposal of treated wood, but rather it will focus on the whole waste management hierarchy and it will consider a suite of acceptable management options (including energy recovery). The plan is to get an MOU in place and then to turn to the workgroup for help in developing implementation plans. In terms of a time- line for the MOU, Jim Roewer (USWAG) explained that he expected it could be a relatively quick process, depending on the degree to which the MOU is memorialized in the USWAG guidelines.

Erin mentioned that the BTS dioxin workgroup would be ready to help out and it was recognized that the BTS can and should claim this as a success story for the Dioxin/Furan Workgroup.

Discussion on Information Gaps and New Data

Secondary Copper Smelting. This is a source that must be addressed according to the Stockholm Convention on Persistent Organic Pollutants (i.e., POPs treaty). It was noted that the scrap that used to go to secondary copper smelting is now being mechanically separated so that pure copper is being recovered and remelted. On the U.S. side, there is only one facility still operating. On the Canada side, there are copper wire smoldering facilities that will need to be addressed under the Stockholm POPs treaty, but these are not considered secondary copper smelters (information gathered to date suggests there are no secondary copper smelting facilities in Canada).

Electric Arc Furnaces. In Canada, there are Canada-Wide Standards (CWS) proposed for electric arc furnaces that are quite stringent. Also in Canada, they will be requiring all facilities with electric air furnaces to do stack testing. The U.S. is waiting for Canadian data to establish an emission rate.

Ceramics. The U.S. is conducting stack testing of ceramic manufacturers (bathroom manufacturers and tile manufacturers) and ball clay processors to better understand the role of ball clay in dioxin emissions.

Foundries. On U.S. side, the big engine block foundries (Ford, GM, etc.) have reported emissions.

Uncontrolled Burning. The U.S. has placed priority on addressing uncontrolled burning (i.e., agricultural burning, brush burning, and burning structures) as a separate issue from household trash burning. Emission are being studied both upwind and downwind from uncontrolled fires and by using chamber studies. The U.S. already has some field wheat stubble burning data from Washington state, which they are especially interested in because (1) some grasses have high chlorine content and (2) animals often feed underneath after burning.

Plans for Next Meetings / Activities for the Workgroup

Anita suggested looking at poorly characterized sources to find information to share at the next meeting. If the workgroup is unable to find any data, she suggested inviting representatives from those sectors to the next meeting.

Discussion topics (for a future meeting) included:

Survey work to assess things like compliance with guidelines for management of PCP-treated wood.
Crematoria (including animal crematoria). Anita mentioned that EC will be performing stalk testing on crematoria.
The U.S. is hoping to have a public comment draft of the 2000 inventory by this summer. The goal is to report facility specific data whenever possible. They will use this data to drive 3 models: H4SPLIR, REAL MAP, and new model.
RAPIDs data for 8 Great Lakes states for 1999 is available. This data is run by Great Lakes Commission. The issue of using RAPIDs data for inferences before all the data is in was raised

Action Items

Anita Wong will bring data from EC’s contractor on dioxin levels in ash in Canada to the workgroup.
Dale Phenicie will check on progress with locating data on dioxin levels in ash from the Medical Waste Incinerator (MWI) sector in the U.S.
All workgroup members: Gather information regarding dioxin levels in ash from incinerators in the U.S. post-MACT standard implementation.
Jim Roewer: Distribute USWAG guidelines on treated wood to the workgroup.
All workgroup members: Gather information as possible on poorly characterized sources to share at the next meeting.
If the workgroup is unable to find data on poorly characterized sources, invite representatives from those sectors to the subsequent meetings.

Participants Roster

Todd Abel, Chlorine Chemistry Council
Herb Estreicher, Covington & Burling
Bruce Gillies, Environment Canada
John Jackson, Great Lakes United
John Menkedick, Battelle
Shawn Michajluk, Environment Canada
Erin Newman (formerly Erin White), USEPA
Patty O’Donnell, Grand Traverse Band of Ottawa and Chippewa Indians
Darrell Piekarz, Environment Canada
Dale Phenicie, Council of Great Lakes Industry
Jim Roewer, Utility Solid Waste Activities Group
Joe Santarcangelo, Environment Canada
Ted Smith, USEPA
Evelyn Strader, Council of Great Lakes Industry
John Wilkinson, Wilkinson Chemical
Dwain Winters, USEPA
Anita Wong, Environment Canada
Cindy Yang, Environment Canada