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Dioxin / Furans

Stakeholders Minutes - March 7, 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 discuss the Western Lake Superior Sanitary District (WLSSD) report on open barrel burning, 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: minutes from the January and February conference calls, an updated Action Item list, and a summary report on open burning provided by Joe Stepun (WLSSD), "Increased Awareness: Insight into Public Patterns and Perceptions”.

General Workgroup Progress, Updates and Announcements

Update on NPRI

Sandro Leonardelli (EC) gave the workgroup an update on recent changes to the National Pollutant Release Inventory (NPRI) in Canada:

Dioxins / furans are being added to the NPRI reporting requirements for the year 2000 (only the 17 most toxic congeners are included)
Reporting requirements will be triggered at a minimum concentration threshold
Some of the sectors subject to reporting will include those associated with metals manufacturing, portland cement and organic solvent manufacture, electric power generation, and various types of incineration facilities (i.e., some medical, municipal, sewage sludge incinerators).
Areas sources will not be subject to reporting (e.g., residential heating)
Details on the ruling can be obtained on the Environment Canada Greenlane Website at http://www.ec.gc.ca/ (in draft form now; detailed guidance to come out at a future date)

CWS

Sandro also announced that a meeting on Canada Wide Standards (CWS) for dioxins and furans was going to be held on March 15 - 16th, for the purpose of receiving feed back from industry, incineration facility operators, etc. on the standards. Sandro indicated that those interested in participating should contact him.

IADN

Nan Gowda (USEPA) reminded the group that those interested in making a coordinated effort to nominate dioxin as a candidate substance for addition to IADN monitoring, could contact him for details on how to submit their nomination.

Western Lake Superior Sanitary District (WLSSD) Open Burning Report

Joe Stepun (WLSSD) and Amy Mizia (WLSSD) gave the group some background on a recent study conducted by WLSSD on public perceptions of open burning.

the study was funded under a 2 year grant from USEPA’s Great Lakes National Program Office (GLNPO), with the goal of increasing understanding of open burning practices and perceptions in order to better target future outreach and education on reduction options.
the study consisted of phone surveys of 780 area residents, 380 each in Minnesota and Wisconsin
questions asked focused on public opnion regarding open burning, such as type and quantity of garbage burned, frequency of garbage burning, reasons for burning, and other demographic information

Amy provided the group with a summary of key findings of the study:

the most common reasons for burning garbage were convenience and to avoid the high cost of garbage service in many areas
when asked about environmental and health concerns associated with open burning, perceptions were that it was an important, but only moderate danger
fire danger was ranked as the number one concern associated with open burning of garbage
when asked about possible incentives for stopping open burning, many respondents said it was likely that there was nothing that would convince them to cease the practice

Additional results of the study were discussed, and are reviewed in detail in the summary report.

Joe and Amy noted that the information collected in the study would be used to put together an educational campaign, which is scheduled to begin this spring. An attempt will be made to tie this campaign to outreach related to the fire season. There are also possible plans for conducting a workshop on open burning outreach.

A comment was made that it may also be useful to ask these same questions and assess opinions on open burning, but in a survey limited just to those who are actively practicing open burning. Joe said that comments of this sort were appreciated, and said that any group members who would like to make additional comments could send them to him via email at joe.stepun@wlssd.duluth.mn.us.

Plans were made to address comments and further discuss the report at a follow-up session of the open burning subgroup. Sandro committed to set this up, and said he would send out an email announcement to interested parties with the details once arranged.

Sector Specific Analysis: Using the Decision Tree Process

Discussion then moved on to continued sector analysis using the decision tree. As there were several participants new the decision tree process joining the call, John Menkedick (Battelle) provided the workgroup with a brief history of the decision tree process in the dioxin workgroup:

the decision tree was adopted by the workgroup, with the goal of providing a systematic means of analyzing the various sources and sectors of dioxin /furan emission in the Great Lakes basin
the process was being used to prioritize sectors amongst the major sectors (>2% of either the draft US or Canadian dioxin inventories), and to help the group to identify areas which have the best potential for reductions options

Pentachlorophenol (PCP)

Dwain Winters (USEPA) provided the workgroup with a summary of available information and EPA’s current assessment of PCP:

the most significant mass of PCP is that present in utility poles
evidence suggests that a minimal amount of dioxin is released from PCP manufacturing facilities and in-use utility poles
however, uncertainty exists on whether the PCP (and dioxin contamination) present in in-use utility poles poses a significant environment risk, especially with respect to ultimate disposal; the best available information (February conference on utility poles in Florida) suggests that only about 50% of utility poles currently have a controlled / known disposal fate

Herb Estreicher (Covington & Burling) raised a question regarding uncertainty associated with the significance of PCP-treated poles in the basin

he noted that only 5% of the PCP currently (over the past 5 years) used in Canada is used in Ontario, and that the primary utility in Ontario (Ontario Hydro) uses copper chromium arsenate to preserve their utility poles
he also noted that wood preserving facilities which currently use PCP are also very limited on the US side of the Great Lakes basin

A question was asked if there is a current inventory of remaining PCP poles in use.

It was noted that Ontario Hydro is currently conducting an assessment of remaining poles in service
regarding disposal, information is being collected for the Canadian SOP

A question was asked regarding PCP in railroad ties

PCP is generally not used to treat railroad ties anymore
Tom Hornshaw (Illinois EPA) cited a study on a former railyard which showed high levels of PCP and dioxin/furan contamination
the amounts of PCP previously used to treat railroad ties is not known

John Wilkinson (Wilkinson Chemical) suggested that it may also be possible that the contamination at that site might have been due to past applications of PCP as a herbicide, as PCP was largely used as a herbicide in the past. Dwain Winters noted that the dioxin contamination could also have been due to past application of 2,4,5,-T, another widely used herbicide.

Dwain also noted that although the largest mass of PCP is in treated utility poles, people should keep in mind that this does not totally dismiss other PCP sources, including those outside the basin.

there are some geographically limited problems at manufacturing / wood preserving sites that will require remediation
however, the primary concern now is the fate / life-cycle management of the remaining poles; in particular, how many are being actively managed to the end of their lives (e.g. via landfill disposal, as cement / co-generation fuel)

It was noted that the American Wood Preservers Institute (AWPI) is working to get more penta-treated poles to be used as fuel.

Doug Green (USWAG) reported that for the utilities, end use of the PCP treated poles is also a big concern; they are aware of the value of the poles as fuel, and in addition recognize that use of PCP treated poles as an energy source helps to prevent some of the potential environmental liability associated with poles that are not being properly disposed of. Doug also noted that there is a viable market for re-use of these poles, and that and poles sold for re-use are accompanied by a MSDS sheet explaining the use restrictions. He asked a question regarding thought on how the perception has evolved that PCP treated poles are not being properly disposed of.

Stephane Gingras (GLU) said that in Canada, the SOP on treated wood has greatly reduced use and reuse of PCP treated poles, largely due to increased awareness of potential liability. He also noted that the SOP process is helping greatly with gathering documentation on current management practices. The point was raised that the SOP process is primarily voluntary, while other mechanisms that help to ensure proper disposal of PCP treated wood, such as CERCLA, are regulatory.

A question was asked, given that PCP treated wood is not a designated waste that requires special disposal, how do US environmental regulations apply to PCP pole disposal?

Doug Green explained that if PCP treated poles are stockpiled or otherwise improperly managed, they have the potential to become a cause for remedial actions; thus potential liability associated with improper management encourages proper management and disposal or re-use.
Herb Estreicher reported that recently there has been a shift towards responsible disposal due to this increased awareness of liability potential.

Stephane noted that it is good that industry is making this effort, but also suggested that thorough documentation is needed to ensure we have a good tracking system.

Herb Estreicher reported that the SOP is promoting research on this issue in Canada, under several task management groups, including the guidance groups conducting life-cycle assessment / impact studies, a waste management group (e.g., working on an approved hierarchy of methods), and an outreach group. It was noted that if the voluntary approach of the SOP is not deemed successful, EC and Health Canada will consider a regulatory approach.

John Menkedick summarized a few points of this discussion for the group:

Canada is ahead of the US with regards to PCP treated wood life-cycle management through the SOP
more information is needed in the US on the fate of PCP treated poles and on the regulatory drivers that may affect pole disposal (i.e., poles are not a RCRA regulated waste, but are there other drivers?)

George Harriss (AWPI) emphasized that although PCP treated wood is not a RCRA regulated waste, it may be a CERCLA liability if disposed of improperly.

Stephane also suggested that more information is needed on dioxin/furan emission associated with incineration disposal (e.g., cement kiln fuel).

Dwain Winters reported that cement kilns using PCP treated wood as fuel generally do not impair those facilities ability to meet MACT standards (i.e., as long as quench technology is present) It was noted that local sensitivities associated with burning certain types of fuel were also important.

Discussion turned to making a decision on how PCP treated poles should be prioritized in the context of dioxin workgroup reductions opportunities

Dwain Winters proposed that this source might be considered a “fuzzy medium”, dependent on more information becoming available regarding de facto disposal; due to the very large masses of PCP involved, the burden of proof is to support the conclusion that environmental contamination is not occurring
Dale Phenicie (CGLI) proposed holding off on prioritizing this sector until more information is gathered
Dwain suggested that although the data currently available on PCP pole disposal (i.e., information presented at the February 1999 utility pole conference in Florida which showed that about 50% of poles taken out of service did not have controlled disposal) is now old, it is the best data currently available and should be used as default until new information surfaces.
Dwain committed to looking into the availability of more recent information; he mentioned a survey conducted last year by the utility industry, although he noted this report was only published internal to the industry and might not be available

To keep on schedule with the agenda, the workgroup agreed to move on to discussion of cement kilns and complete discussions on prioritization of PCP treated poles at the next meeting.

Cement Kilns

Dwain Winters (USEPA) provided the workgroup with a summary of EPA information on cement kilns in the US:

cement kilns are divided for regulatory purposes and in the inventory into hazardous and nonhazardous waste burning facilities; however, with current technology many facilities are indistinguishable with regards to dioxin emissions
since the ‘95 inventory estimates were made, significant changes have occurred in control technology (i.e., most facilities now use quench to control inlet temperatures); therefore, the ‘95 emissions estimates are not reflective of the technology in place today.
emissions from cement kilns are probably much lower now than are reflected in the ‘95 inventory, and EPA is working on making new estimates

Sandro Leonardelli (EC) provided the workgroup with a summary of the available information from EC on cement kilns in Canada:

in Ontario, cement kilns account for approximately 2.2% of the total inventory of emissions; these emissions estimates were based on actual testing of 50% of Ontario kilns in 1997
the 1997 test data shows that stack concentrations are <0.158 ng/M3, which is comparable to the world’s strictest emission standards (i.e. EPA’s 0.14 ng/M3 MACT standards) - Pollution control technology (e.g. ESP, baghouses) was installed with the primary intention of controlling other parameters (e.g. Particulate Matter), not Dioxins/Furans.

A question was asked regarding the bag-house dust and whether it was considered hazardous.

Ann Dougherty (PCA) reported that this ash is called cement kiln dust and is generally considered a product. The dust may be put back into the cement product, or is sometimes used as a soil amendment similar to lime. She also noted that in the US sometimes cement kiln’s dust is put into landfills. Dwain Winters said that in the proposed land application restrictions, EPA has set dioxin/furan limits that are low enough so that the resulting soil concentrations will not be altered significantly.

Next, Ann Dougherty provided the group with an overview of the significance of cement kill facilities within the Great Lakes basin:

there are a total of 118 cement kilns in the US, with 26 facilities in the US Great Lakes region (there are no facilities in Minnesota or Wisconsin)
there are a total of 17 cement kilns in Canada, with 10 in Ontario and Quebec.
between 17 and 19 of these facilities are within 160 miles of the Great Lakes waterways

As part of the MACT development process, the cement kiln industry conducted several studies on emissions and dioxin formation chemistry. Ann presented the group with some of the findings of these studies (she noted this data is also available in EPA’s docket on the cement kiln rulings):

between 1989 and 1996 there were about 25 reports on dioxins/furans emissions; all the emissions documented were lower than the current EPA emissions estimates by a factor of 0.1 to 0.33.

Regarding the estimated reductions expected by EPA with MACT compliance, Ann noted that improvements may be much greater than expected due to current improvements in understanding of the temperature window necessary for dioxin formation, and because the original emission estimates were too high.

Dwain Winters (EPA) cited a study which demonstrated the importance of temperature control in dioxin formation; in this study, at temperatures greater that 450 EF, dioxin emission of about 28 g TEQ were measured. At temperatures less than 450 EF (i.e., where quench was used), dioxin emissions dropped to about 1 g TEQ.

Regarding a question asked on the use of quench technology in Canada, there was uncertainty amongst the workgroup. Anita Wong (EC) volunteered to check on whether any Canadian facilities use quench technology to control D/F.

Next Michelle Lusk (CKRA) provided the workgroup with an overview of regulatory control of cement kilns that burn hazardous waste:

plants that recover energy from hazardous-waste-derived fuel comply with RCRA industrial furnace rules and the hazardous waste combutors MACT rules promulgated 9/30/99 (non-hazardous waste burning facilities must comply with a separate set of rules under the portland cement source category MACT)
in the process of reaching compliance with the RCRA rules and in the MACT development process, a significant database of emissions data has been complied by the cement kiln industry

Michelle reported that results of these studies, as cited in EPA’s rulemaking, showed that the burning of hazardous waste in cement kilns facilities does not have an impact on dioxin/furan emissions.

Michelle also noted that OSW currently has the most up-to-date database on emissions from cement kilns, which represents real-time data on all facility types. CKRA has provided comments to other offices at EPA to promote the updating of their information databases. The OSW database contains data from actual testing (versus emission estimates) carried out as a requirement of RCRA certification requirements.

Dwain Winters agreed that the ‘95 emission estimate for cement kilns was made before quench technology was in place, and that better information in now available due to actual testing data. He noted that similar improvements in emissions data will occur with the other industries subject to MACT, i.e., because there are testing requirements which will generate real data, there will no longer be a need to extrapolate emissions from emission factors.

As the scheduled meeting time was nearing conclusion, the group agreed to continue discussion of cement kilns, with a focus on prioritization, at the next conference call.

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 PCP and cement kilns, and begin discussion of the steel manufacturing and iron sintering sectors within the decision tree context.

The workgroup will continue work on current action items identified in the action item update. The next conference call is scheduled for April 4, 2000.

Participant Roster

Werner Braun, Council of Great Lakes Industries
Craig Chrispell, Lonestar
Alicje Cornelissen, Canadian Portland Cement Association
Mike Dayo, Giant Cement
Ann Dougherty, Portland Cement Association
Tim Eagan, Canadian Electric Association
Herb Estreicher, Covington & Burling
Stephane Gingras, Great Lakes United
Nan Gowda, USEPA Region 5
Doug Green, Utility Solid Waste Activities Group
George Harriss, American Wood Preservers Institute
Dan Hopkins, USEPA
Tom Hornshaw, Illinois EPA
Jackie Hunt Christensen, Health Care Without Harm
Ajay Kumar, Holland Cement
Sandro Leonardelli, Environment Canada
Michelle Lusk, Cement Kiln Recycling Association
Jeff Lynn, International Paper
John Menkedick, Battelle
Amy Mizia, Western Lake Superior Sanitary District
Fardin Oliaei, Minnesota Pollution Control Agency
Dale Phenicie, Council of Great Lakes Industries
Joe Stepun, Western Lake Superior Sanitary District
Henry Walser, Canadian Wood Preservers Institute
John Wilkinson, Wilkinson Chemical
Dwain Winters, USEPA
Anita Wong, Environment Canada
Maureen Wooton, Battelle