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Dioxin / Furans

Stakeholders Minutes - July 11, 2000
Workgroup Teleconference Minutes

Workgroup Leaders:
Anita Wong, EC
Nan Gowda, EPA

Facilitator:
John Menkedick, Battelle

Introduction and Summary of the May 16 Stakeholder Meeting

The objective for the day was to finish discussion from the May Stakeholder meeting, focusing on:

addressing information gaps and outstanding action items;
developing plans for implementing reduction and/or information gathering projects for those sectors designated high or medium priority; and
deciding on process changes for future workgroup activities.

Materials distributed to workgroup members prior to the teleconference included:

the teleconference agenda;
minutes from the May 2 conference calls and May 15 stakeholders meeting; and
a revised Overview of Decision Tree Analysis Outcomes for targeted sources of dioxins/furans in the Great Lakes Basin (updated 5/16/00).

John Menkedick (Battelle) briefly reviewed events at the May 16 stakeholders meeting:

the meeting was very successful, with the workgroup finishing the decision tree process, including revisiting and finalizing BNS priority designations for all targeted sectors.

Anita Wong (EC) noted that for today’s call, comments on the May 16 meeting were welcomed, but that they would also like to focus on moving on to next steps for the workgroup, including how to pursue information gaps and address priority sectors. Anita also noted that volunteers for these tasks would be needed.

Next the workgroup reviewed the final BNS priority designations in greater detail, within the context of addressing outstanding workgroup action items and information needs, and developing plans for implementing reduction and/or information gathering projects.

Results of the Decision Tree Process and Identifying Opportunities

Municipal Waste Combustion (MWC) and Medical Waste Incineration (MWI)

At the May meeting, it was agreed that more information was needed on the management of fly and bottom ash from waste incineration and that it was an open issue to be addressed through workgroup action items. Acknowledging this, the workgroup designated final priority levels for MWC and MWI based on air emissions only.

For MWC, a low priority assignment was made on the basis of significant reduction efforts for air emissions already in place in both the U.S. (MACT standard implementation) and Ontario (Canada Wide Standard development), with the caveat that progress in compliance would be assessed by the workgroup periodically in both countries.
For MWI, the low priority assignment in the U.S. was also made on the basis of significant reduction efforts already underway with MACT standard implementation, again with the condition that compliance would be monitored. In Ontario, although the Canada Wide Standard development would also potentially reduce MWI air emissions, a medium BNS priority level was assigned due to new data suggesting that stack emissions from MWI in Ontario may be much greater than estimated in previous inventories.

Anita Wong reported that fly ash is considered toxic in Canada and must go to a stable landfill, whereas bottom ash is usually not considered toxic. She reported that some research was currently being conducted on alternative technologies for destruction/reduction of dioxins and furans in ash. This research, however, is primarily being driven by the expense of landfill disposal in Canada, rather than by exposure concerns.

Dwain Winters (EPA) said that in the U.S., the primary issue regarding ash was not the concentration level of dioxins/furans in the ash, because it is required to go to a monofill which would prevent release of the dioxins and furans into the environment. Rather, information was needed on the land disposal practices actually occurring with the Great Lakes Watershed. He suggested that a more systematic inventory on ash disposal and fate was needed.

He noted that tracking down disposal information for MWCs would probably not be too difficult because there are a limited number of facilities in the basin.
However, because there are many more MWI facilities in the basin, gathering information on medical ash disposal might more challenging. To begin an information gathering effort, the question of whether to conduct a full inventory or representative sampling would need to be considered.

It was suggested and agreed to by the workgroup that the first question to be answered should be whether the information on ash disposal is already available somewhere, or if it requires a new data collection effort.

Nan Gowda (EPA) and Anita Wong (EC) volunteered to check what information on ash disposal is available at their respective governments, such as state reports to federal government. This investigation would include an assessment of ease of accessibility of data and the rigorousness of any reporting records.

Dale Phenicie (CGLI) also suggested that state agencies, such as Solid Waste Authorities, and industry experts may have information on ash disposal. Dale volunteered to check with Katie Cullin (MWC industry) and his other industry/state contacts on data availability.

It was suggested and agreed to by the workgroup that, if following assessment of the ash disposal data availability it is determined that the information is not readily available, then the workgroup’s next step will be to design a plan on where and how to get the information.

John Menkedick asked the group if there were any other waste incineration related comments or updates on any outstanding action items related to waste incineration:

Dwain Winters reported that EPA is currently working on an improved centralized database to hold all information being collected on control technology compliance, including emissions from MWC, MWI, hazardous waste incinerators, cement kilns, and the pulp and paper industry. This data is being collected as part of MACT and BAT regulations and compliance testing reports. The EPA goal was to have this information for all sectors regulated for dioxin/furan through federal, regional, and state air/water/RCRA programs.
USEPA committed to work with states and regions to compile the new dioxin/furan emissions data, and to update the workgroup on progress and results of this effort.
Anita Wong reported the EC will soon release the revised Canadian dioxin/furan inventory and it will be posted on the Environment Canada Greenlane website. MWI emissions estimates are expected to increase significantly.

However, Anita proposed that the primary issue as related to waste incineration for this workgroup at the current time should remain ash management.

Backyard Trash / Open Burning

The status of workgroup progress related to open burning, which had been designated by the workgroup as a high BNS priority sector in the decision tree process, was reviewed:

a subgroup has formed for this sector and they are currently in the initial stages of planning
Joe Stepun (WLSSD), who is involved in the open burning subgroup, reported that the group is trying to set up a conference call sometime in August, and is also in the process of recruiting additional members.
Joe reported that the first task the subgroup has discussed was conducting a complete assessment of regulations related to open burning in the Great Lakes region.
The subgroup has also discussed the potential for conducting educational outreach on open burning, possibly as an extension of a Duluth, Minnesota open burning campaign that is planned.

Dan Hopkins (EPA) remarked that one of the problems related to open burning is that the local regulations that are in place are not stringently enforced.

Joe agreed, and noted that in Minnesota, open burning is generally illegal but little enforcement of the regulations occur, and in Wisconsin, there is no mechanism to penalize violators of open burning laws who are burning without a permit. Therefore, the major challenge regarding open burning is to encourage changing behavior.

Joe noted that at the next subgroup meeting in August, they would be considering options for outreach. If it was determined that a basinwide campaign should be conducted, the subgroup would probably require additional assistance, such as more support from the dioxin workgroup, and/or advertising agency support.

Dwain Winters observed that overall, there are three main areas related to open burning that need attention to affect reductions:

Public education
Strengthening of local regulatory mechanisms
Development of infrastructures to provide alternatives to open burning

It was suggested that EPA and EC support sector-based approaches that address multiple BNS chemicals where applicable, and encourage the coordination of reduction activities, as possible, with other BNS workgroups. It was noted that open burning may provide a good opportunity for coordination with other BNS workgroups, particularly the B(a)P workgroup.

It was also confirmed that agricultural burning would be addressed by the open burning subgroup. Dwain Winters added that EPA’s dioxin program intends to expand it’s research on agricultural burning to include better characterization of stubble-field, grassland, and silvicultural burns. He also noted that agricultural burning fundamentally differs from open burning of trash in that the burn cycle is often an integral part of certain ecosystems, such as grasslands and douglas-fir forests.

Residential Wood Combustion (RWC)

John Menkedick recalled that at the end of the May 16 stakeholder meeting it was proposed that efforts for this sector be combined with the B(a)P workgroup efforts.

However, he also noted that there were several outstanding action items related to RWC that were specific to dioxins/furans, including:

presenting and discussing the implications of the results of the Canadian wood stove study on the relationship between dioxin/furan levels and particulate matter.
checking on any EPA-conducted studies on dioxins/furans in wood stove emissions.

Anita Wong reported that the Canadian wood stove study testing phase has been completed and that the report is currently being finalized. Anita volunteered to give a report on this data to the workgroup when the study report was finalized, and the workgroup agreed to reassess the need for more information on wood stove at that time.

Anita also reported that EC had some preliminary talks with the Hearth Products Association, and that they expressed interest in pursuing a wood stove change out in the U.S. and Canada. A talk will be scheduled sometime this summer between the wood stove industries, states, provinces, and the dioxin/furan and B(a)P workgroup representatives. Although this talk is just to initiate discussions between the EPA/EC and industry representatives, Anita said anyone who is very interested is welcome. Otherwise, Anita committed to send out a message with an update to the workgroup after the initial call. Anita volunteered to lead-up the initial efforts to coordinate with the Hearth Products Association and the B(a)P workgroup on a wood stove change out program.

Pentachlorophenols (Treated Wood)

At the May stakeholders meeting it was agreed that PCP treated poles in the U.S. would be designated as a medium BNS priority due to a lack of information on ultimate disposal fate. In Canada, PCP treated wood was designated as a low BNS priority due to significant controls and a life-cycle analysis study of PCP treated wood that are underway through the Canadian Wood Preservers SOP.

Doug Green (Piper&Marbury/USWAG) reported that Dwain Winters (EPA) had recently attended a Utility Solid Waste Activities Group (USWAG) meeting and gave the group a presentation on information gaps and data limitations related to the fate of PCP-treated wood.

As a result, USWAG, which is a consortium of utility industry representatives, is planning to conduct a broad (nationwide) information gathering survey amongst its member companies on the actual disposal and fate of utility poles that have been taken out of service. This effort is being planned on an accelerated schedule, as possible.

Dwain remarked that this effort on the part of USWAG is a great first step to getting more concrete information on the fate of utility poles. Once all the information is complete, then a better assessment of risk due to this source can be conducted.

Doug Green volunteered to report back to the workgroup on the results of the survey when complete. It was noted that one problem, regarding the overall characterization of utility pole fate, was that if the USWAG survey only focused on utilities, then the secondary reuse market fate may still remain an unknown.

Doug Green agreed that this was a fair point, and suggested that after the initial information is gathered, more questions may still exist that need to be investigated further.

Anita Wong agreed to report on progress under the Canadian Wood Preserver SOP as it developed, including the life-cycle analysis study for utility poles/railroad ties and the development of best management options.

Steel Manufacturing (EAF)

The workgroup has not assigned a BNS priority designation to steel manufacturing (Electric Arc Furnaces) due to a lack of test data.

In Canada, the Dofasco EAF facility has conducted testing and remaining Canadian data gaps will be addressed with additional testing that is being pursued at other facilities.

Stack testing is planned to be conducted in August at Gerdau Courtice steel.
CGLI is coordinating with EC in the development of a voluntary stack testing guidance document.

Dwain Winter asked if the testing to be conducted would include monitoring during startup conditions:

Anita reported that the details of the monitoring plan had not yet been finalized, but that monitoring of this sort may be possible if it was determined to be a significant need
Dwain noted that some research has indicated that the majority of the dioxin emissions occur during startup in some cases.

Regarding U.S. activities to gather more information on steel EAF dioxin emissions:

Dwain reported that more data is definitely needed and EPA is in the initial stages of planning to define its highest priority testing needs, although no firm schedule is yet in place.
Dale Phenicie confirmed his action item to follow-up with U.S. industry contacts (e.g. the New Jersey facility) on the possibility of conducting some voluntary testing.

Anita Wong observed that, in general, it would be good to also try and get emissions data for other substances, such as mercury and PAHs, at the same time dioxin testing is taking place; she suggested that the steel EAF sector is a good candidate for combining BNS information gathering efforts.

Dwain Winters agreed, and suggested that with the increased interest in mercury emissions, for example from auto scrap use at EAF, this may be a good opportunity to incorporate dioxin/furan monitoring.
Dale proposed that this was an important issue to raise to the integration group.
As a first step, Anita volunteered to look into coordination opportunities by talking with other BNS workgroup co-leads, and following-up on the issue with the integration group.

Gary Allie (Ispat-Inland Inc. / Steel Manufacturer’s Association) commented that when planning monitoring, it should be kept in mind that dioxin emissions testing is very expensive. Due to economic burdens, mandated testing for dioxins might possibly have the result of dampening industry willingness to participate in other voluntary activities, such as the voluntary mercury reduction and PCB phase out activities underway at Indiana steel mills.

Anita Wong noted that there were no plans on the Canadian side to mandate dioxin testing at steel plants without providing financial assistance.

A question was asked regarding the status of the action item to investigate whether EPA is in a position to assist steel mills in financing dioxin testing.

Nan Gowda reported that the only development he was aware of was that the BNS mercury workgroup co-lead, Alexis Cain (EPA), was exploring possibilities for emissions testing of steel plants in Ohio.

It was noted that Gary Allie’s comments emphasized the importance of using a sector-based approach and fully understanding the potential ramifications of activities being considered on other reductions/monitoring efforts.

Secondary Copper Smelting

At the conclusion of the May stakeholders meeting, this sector remain designated as a low BNS priority in the U.S., and received no priority designation in Canada due to a lack of information.

In Canada, Anita reported that some emissions data was received recently from the Falconbridge facility, and that it indicated there were low levels of dioxin. Additional information gathering for the secondary copper sector in Canada is probably needed.

In the U.S., as discussed at the May 16 meeting, dioxin/furan emissions from the two remaining secondary copper facilities were estimated to be relatively low.

At today’s call, Dwain Winters reported that current emissions were estimated to be less than 5g TEQ/yr.

Tom Hornshaw (Illinois EPA) reported that one of the two facilities (Chemetco) was located in Illinois near St. Louis. He also noted that this facility was in the process of a lawsuit regarding an illegal discharge to water (this discharge was reported to contain levels of dioxin above background). Regarding air emissions of dioxins from this facility, Tom was not aware of any testing that had been conducted.

Landfill Fires

The workgroup has no assigned landfills fires a BNS priority designation due to a lack of information regarding significance of this source.

There was an outstanding action item regarding information gathering on the frequency of landfill fires in both Canada and the U.S., but no assignment had been made. The workgroup discussed who would lead this information gathering effort, and where the information may potentially be found.

Dale noted that all landfill fires must be reported under the conditions of a facility’s operating permit. He suggested that some of the information regarding frequency may be found by talking with states/solid waste authorities who issue landfill permits.
Anita and Nan committed to investigate whether this sort of information was submitted to a central repository with their respective federal governments.

New Action Items

The workgroup committed to periodically assess progress in compliance with dioxin air emission reduction programs for MWC and MWI, including MACT standard implementation in the U.S. and Canada Wide Standard development in Ontario.
Dwain Winter committed to update the workgroup on progress and results of an EPA effort to work with states and regions to compile the new dioxin/furan emissions data.
Nan Gowda (EPA) and Anita Wong (EC) volunteered to check whether their respective governments have compiled information on MWC and MWI ash disposal, such as a state report database.
Dale Phenicie (CGLI) volunteered to check with his MWC/MWI industry contacts on data availability related to ash disposal.
Following assessment of the MWC/MWI ash disposal data availability, the workgroup committed to designing a plan on where and how to get the information if it is determined that the information is not available.
Anita Wong volunteered to give a report on the Canadian wood stove study to the workgroup when the study report was finalized
The workgroup committed to reassessing the need for more information and opportunities for wood stoves after the Canadian wood stove study is reviewed.
Anita Wong volunteered to lead-up initial efforts to coordinate with the Hearth Products Association and the B(a)P workgroup on a wood stove change out program.
Anita Wong committed to send out a message to the workgroup with an update on the results of the preliminary call between the wood stove industry and EPA/EC.
Doug Green (Piper&Marbury) volunteered to report back to the workgroup on the results of the USWAG information gathering survey on the disposal and fate of utility poles in the Great Lakes basin.
Anita Wong agreed to report back to the workgroup on progress under the Canadian Wood Preserver SOP as it developed, including the life-cycle analysis study for utility poles/railroad ties and the development of best management options.
Dale Phenicie confirmed his action item to follow-up with U.S. industry contacts on the possibility of conducting voluntary testing at steel manufacturing (EAF) facilities.
Anita Wong volunteered to look into coordination opportunities for monitoring multiple BNS chemicals in steel EAF emissions, by talking with other BNS workgroup co-leads, and following-up on the issue with the integration group.
Anita Wong and Nan Gowda committed to investigate what information on the frequency of landfill fires in both Canada and the U.S. is readily available in their respective federal governments.

Next Steps:

The frequency of future calls for the workgroup was discussed. It was suggested and agreed upon that future calls would take place approximately every two months, or as needed.

The next conference call is tentatively scheduled for September 12, 2000 (the second Tuesday in September).

At the next conference call, plans are to: hear progress updates from the open burning subgroup and on today’s assigned action items/information gathering tasks; discuss sector-based strategies, especially related to informing any Integration Group discussion; and discuss plans for the November Stakeholder Meeting.

Participant Roster

Dave Ailor, Coke Institute
Gary Allie, Ispat-Inland Inc. / Steel Manufacturer’s Association
Herb Estreicher, Covington & Burling
Dick Fillman, Bethlehem Steel Corporation
Nan Gowda, USEPA Region 5
Doug Green, Piper & Marbury, LLP / Utility Solid Waste Activities Group
Dan Hopkins, USEPA Region 5
Tom Hornshaw, Illinois EPA
Mark Johnson, Weyerhaeuser
Jeffrey Lynn, International Paper
John Menkedick, Battelle
Dale Phenicie, Council of Great Lakes Industries
Joe Stepun, Western Lake Superior Sanitary District
Dwain Winters, USEPA
Anita Wong, Environment Canada
Maureen Wooton, Battelle