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Dioxin / Furans

Stakeholders Minutes - May 2, 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 complete discussions of the remaining targeted sectors, assign a priority level to each sector, and discuss plans for the May Stakeholders Meeting.

Materials distributed to workgroup members prior to the teleconference included: the teleconference agenda, and minutes from the March 7 and April 4 conference calls.

Sandro Leonardelli (EC) asked the group if there were any comments in regards to the email messages distributed, which reviewed the priority level decisions made at the last call and proposed priority level assignments for several of the sector to be discussed today.

There were no comments

A question was asked on where the May 16 Stakeholders Meeting was to take place

- It will take place in Toronto. It was noted that email messages announcing the meeting had been distributed by the organizers of the conference; it was offered that if a workgroup member had not received this information they could contact Maureen Wooton (wootonm@battelle.org) and she would forward the information to them.

It was noted that Dwain Winter (EPA) would be joining the call late today.

Sector Specific Analysis: Using the Decision Tree Process

The meeting moved on to continued sector analysis discussions.

Steel Manufacturing (EAF)

John Menkedick (Battelle) reviewed discussions on this sector from the April 4 conference call.

He recalled that Dwain Winters (EPA) proposed that this sector be considered a high BNS priority for gathering additional testing data. This designation would not imply that risk management / pollution prevention activities also should be high BNS priority for this sector.

Gary Allie (Ispat-Inland) reported that since the last conference call, he had contacted a company that conducts industrial emissions testing.

They estimated the cost for a single test run would be approximately $30,000 - 35,000.
This cost would include sampling and dioxin/furan analysis; however, this price would not include any additional expenses such as setting up sampling platforms and probe stations.
Sandro noted that the cost of testing was approximately the same in Canada.

Anita Wong (EC) reported that in Canada, the standard stack test procedure included three test runs per facility, which could usually be completed in 1 day, given 1-1 2 hour test intervals.

Gary Allie said that his facility had no current budget for testing.

Dale Phenicie (CGLI) noted that EC provided financial assistance for facilities in Canada that were voluntarily conducting testing, and suggested that EPA might provide similar assistance.

Dale added that there were really two important questions at this time in determining whether dioxin/furan testing would be feasible at US EAF facilities:

Is EPA in a position to fund or provide financial assistance for testing?
Are there any US EAF facilities that are interested in conducting voluntary testing?

Dale proposed that the workgroup follow-up with industry and with EPA to investigate opportunities to conduct EAF testing.

An EAF industry representative noted that many facilities do not have actual stacks, but rather roof vents, as part of their design; therefore, modifying sampling procedures to account for this may also result in additional expense.

John Menkedick asked the group if they were comfortable with currently designating steel EAF as a high priority for testing, which would translate into action items to investigate potential EPA funding of testing and to investigate industry interest. He emphasized that this high priority designation would not apply to investigating risk management / reductions options at this time.

Sandro added that this designation would apply to U.S. EAF facilities only, because EC feels that the current information gathering efforts in Ontario are sufficient with regards to steel EAF.

Gary Allie agreed that there is little data on steel EAF in the U.S.; however, he suggested that U.S. data would likely not be much different than the Canadian data, and also expressed his doubt that U.S. EAF facilities would volunteer to conduct testing in the absence of EPA funding.

Discussion followed on whether it was likely that U.S. data would be similar to Canadian data:

It was noted that in general, the raw materials and processes used in U.S. and Canadian facilities were similar; for example, while some European facilities accept municipal solid waste, most US/Canadian facilities only use pure scrap.
It was added that although EAF facilities are all similar process-wise, they are often are quite unique with regards to the system configuration (e.g. fuel delivery, gas cooling systems).

A question was asked on availability of the Canadian EAF testing data:

Anita reported that so far, only the testing of the Dofasco facility had been completed; testing of other facilities was in the planning stage although no final dates had been set yet.
Sandro noted that preliminary analysis indicated that the Dofasco emissions are much lower that the European emissions.

No further objections were raised regarding creating action items to investigate U.S. data gathering opportunities (i.e., EPA funding and industry interest).

Secondary Copper Smelting

Dale Phenicie (CGLI) reported that he had investigated this sector, and had so far found one true secondary copper facility (Noranda) in Quebec. However, he did not have good information on the significance of this sector with respect to the Great Lakes Basin.

Herb Estreicher (Covington & Burling) reported that there were two secondary copper smelters in the U.S., Southwire and Chenecto, although he was unsure of their locations. He also noted that in 1997, there were 390 metric tons of secondary copper smelted in the US.

Dale provided some details on the Noranda facility in Quebec:

The facility primarily processes computer scrap into copper ingots
Concern over dioxin/furan releases was mostly associated with the old Franklin smelters in which copper wire encased in insulation material was processed to liberate the copper.
He also reported that this industry has undergone significant consolidation in recent years, i.e., many facilities have closed down.
The Noranda facility also told Dale that they had conducted some emissions testing previously, and that the emissions were low.

A question was asked on whether secondary copper smelting was included in the Canadian inventory:

Sandro replied that no, it was not, primarily due to difficulties in determining the precise criteria for defining a facility as a secondary copper smelter.

It was pointed out that key information with regards to this sector and the BNS, was whether the two U.S. facilities were in close proximity to the Great Lakes Basin.

Dale Phenicie volunteered to follow-up on investigating the locations of these two facilities.

The workgroup decided to tentatively designate secondary copper smelting as a low priority, given that follow-up investigations on locations of facilities verified that there were no facilities in the Great Lakes basin.

Hazardous Waste Incineration, Wood Waste Combustion, Utility Coal Combustion, and Diesel Fuel Combustion

John Menkedick reviewed for the group the proposal (raised in the previous week's email distribution) that these sectors all be designated as low BNS priority:

This designation would be based on the fact that all these sectors (with the exception of diesel fuel in Canada at 8.9 %) are all between 2-3% of one of the inventory totals
The purpose of the BNS workgroup process of assigning priority levels is intended to identify the most obvious/important sources for BNS workgroup focus.

Sandro added that all of these sectors are small sectors in the current inventories, and taking into account some of the revised estimates being developed now, these sources will likely become even smaller percentages of the total inventories in the future.

Sandro also noted that the only source which is slightly above the 2% criteria is diesel fuel in Canada, which is already in the process of being addressed by EC under the new NEPA authority released this April.

vehicle engines used to be solely regulated by the Ministry of Transportation, but with the new NEPA, EC will have new authority to regulate both engine emissions and fuel content.
there is a workshop meeting planned for May 25-26th in which the role of EC in implementing the new NEPA authority will be discussed; stakeholder input on opportunities and areas for further research may be solicited.
it will be possible to bring additional diesel fuel-related issues, such as dioxin/furan emissions, to the table at this workshop.
Sandro noted that one area for research would be to determine if dioxin/furan emissions are due to the diesel fuel engine combustion process, or to the composition of the diesel fuel itself (i.e., non-diesel engines are not associated with similar dioxin/furan emissions)

Dale Phenicie also reported that there was an announcement in last week's Federal Register that EPA would be / is in the formative stages of looking at greenhouse gas emissions from heavy diesel engines.

John Menkedick asked the workgroup, acknowledging that there were no representatives from environmental organizations present at the meeting today, if they were comfortable with designating hazardous waste incineration, wood waste combustion, utility coal combustion, and diesel fuel combustion all as low BNS priorities on the basis of low emissions relative to other sources in the basin.

There was some further discussion regarding the wood waste combustion category:

it was clarified that salt-laden wood was not included in the wood waste combustion category in the Ontario Inventory, because this was associated with a strictly west coast practice
different types of facilities that may burn waste wood products were discussed, including: pulp and paper mills, sawmills, and general forestry product operations.

John Menkedick suggested that maybe it would be useful to think of this / these sectors in terms of size (i.e., big / little) and difficulty of opportunities (i.e., hard / easy).

It was noted that in the U.S., wood combustion is already fairly heavily regulated via NSPS for particulates, fuel restrictions, and boiler specifications.

The issue of potential for land application as a means of disposal for wood waste was raised:

although this waste has value as fuel, it is not hazardous and in theory could be put back into areas where clear cuts had occurred.
hauling costs may be an important consideration

Mark Johnson (Weyerhaeuser) reported that the industry had looked into land application of wood waste as a disposal alternative:

In the U.S., a large quantity of the timber harvested comes from private lands and these areas generally do not want the wood waste back.
logistically, economics are a problem: different types of trucks are required to haul wood waste and, because the wood scrap material is light, the cost of transportation per ton greatly increases.
wood waste also has preferred value as a fuel source and as a mulch / landscaping product (wood material mixed with soil, etc. are often composted because they are not good to burn in industrial boilers).

It was noted that the issue of private lands are not an issue in Canada because about 99% of the logged lands are government owned.

After discussing these alternatives for wood waste disposal, the group agreed to designate all of these sources (i.e., hazardous waste incineration, wood waste combustion, utility coal combustion, and diesel fuel combustion) as low BNS priority at this time.

Forest Fires

John Menkedick noted that it was proposed that forest fires be designated a low BNS priority because there are not really many good opportunities for further reductions. Reasons include:

Other issues beside dioxin/furans have a greater influence on forest fire management
EPA has issued a woodland fire management plan to control particulates
Other agencies (e.g., US Forest Service) already have the lead on forest fire management in the U.S.

Sandro brought up the point that it has also been theorized that prescribed burns result in no net increase in dioxin/furan emissions because they are used to control natural forest fires.

A question was asked regarding whether prescribed burning and / or agricultural burning were included in the "forest, brush and straw fire" category.

The answer was unknown; this issue was noted as a follow-up item to ask Dwain Winters (EPA) about.
Sandro noted that this issue had also come up in the open burning subgroup

The workgroup decided to classify forest fires as a low BNS priority at this time, but with the condition that the open burning subgroup would look further into the significance of agricultural burning.

Landfill Fires

The workgroup discussed landfill fires, but generally, was lacking in verifiable information on this sector:

emissions estimates were only order of magnitude estimates so had low confidence, but the estimate was very large (i.e., 1000 g TEQ / yr)
current regulations regarding landfills were reviewed (e.g., permits, reporting requirements, management plans), but details were unknown
it was also noted that older landfills not under RCRA may be important, and that in past years (pre-regulation) landfill fires were often set intentionally
opportunities for gathering information on the occurrence/incidence of landfill fires (e.g., state solid waste records) were discussed
the need for more information on landfill practices in both the U.S. and Canada was acknowledged, regarding emission factors, but especially regarding activity levels (i.e., frequency)

The group agreed to follow-up on information gathering efforts for this sector, but to hold off on priority designations at this time.

May 16 Stakeholders Meeting

The group status in the decision tree process was reviewed:

As of today, most of the targeted (>2%) sectors have some sort of priority level assignment
There will be new information brought to the table regarding municipal solid waste (MSW) on May at the MSW workshop that should be useful for revisiting MWC and MWI at the dioxin workgroup meeting; hopefully these sectors can also be brought to closure then.

Sandro noted that at the May 16 meeting, all of the priority assignment / decision tree results obtained so far will be presented; however, discussions should be able to mostly focus on plans for identifying and implementing opportunities for reduction in high priority sectors.

Herb Estreicher expressed concern over the medium priority designation that PCP treated poles had received, in light of the fact that these were only potential / latent sources, while all of the other sectors examined had actual ongoing emission to air. He suggested that it would make sense to open the decision tree process to other waste oriented sources, such as POTWs and ash.

Sandro noted that releases to all media were factored into the Canadian inventory, and that the ash disposal issue had been included in the workgroups discussions of MWC and MWI.

Dwain Winters (EPA) joined the conference call. Dwain noted that the U.S. inventory did not leave out releases to other media, but the lack of emissions estimate, e.g. to water, was just a function of the fact that there were no data available.

John Menkedick noted that these issues would overall work well within the context of the May stakeholder meeting, i.e.:

identified priorities for obvious workgroup focus could be discussed regarding plans for risk management opportunities
identified information gaps could be reviewed and assignments for gathering information could be incorporated in to the action items (e.g., ash disposal details, agricultural burning questions, landfill fire information)

Regarding secondary copper smelters Dwain noted:

neither of the two remaining smelter facilities are of the type that was previously associated with the high emissions, as reflected in the 1998 Inventory (i.e., these facilities types had all closed).
He agreed that the workgroup should designate this sector as low BNS priority unless some of the high emission facilities reopened.

Regarding landfill fires, Dwain reported:

the U.S. inventory had used a Swedish emission factor in deriving the U.S. inventory estimate for landfill fires.
there are two types of landfill fires: accidental and underground methane fires.
higher priority research is needed on the frequency of landfill fires, i.e., the activity level is more uncertain than the emission factor
however, even with limited occurrence, the emission factor indicates that landfill fires have the potential to be a large dioxin/furan source.
he suggested that the workgroup could really help with gathering information on the frequency of landfill fires (e.g., via communication with state contacts, etc.)

Regarding agricultural burning, Dwain agreed that the appropriate place for this to be addressed was by the open burning subgroup.

In summary, the group agreed that at the May stakeholder meeting, the agenda would tentatively include:

review of the priority level assignments (using the draft summary matrix as a discussion guide)
revisiting the MWC and MWI designations
review of the action items, including information needs
discussion of candidates for reduction options and next steps for the workgroup.

The conference call adjourned

New Action Items

The workgroup agreed to investigate whether EPA is in a position to fund or provide financial assistance for testing of steel EAF (no assignment made)
The workgroup agreed to investigate whether there are any U.S. steel EAF facilities that are interested in conducting voluntary testing (no assignment made)
Dale Phenicie volunteered to follow-up on investigating the locations of the remaining two secondary copper smelting facilities in the U.S.
The open burning subgroup committed to look further into the significance of agricultural burning.
The workgroup committed to follow-up on information gathering efforts regarding the frequency of landfill fires (no assignments made).

Next Steps:

The BNS Stakeholders Meeting is scheduled for May 16, 2000.

Participant Roster

Gary Allie, Ispat-Inland Inc. / Steel Manufacturer's Association
Tom Barnett, Ispat-Inland Inc.
Herb Estreicher, Covington & Burling
Greg Filyk, Environment Canada - Transboundary Air Issues Branch
Nan Gowda, USEPA Region 5
Doug Strought, The Coke Institute
Mark Johnson, Weyerhaeuser
Sandro Leonardelli, Environment Canada
Jeff Matthews, Kodak
John Menkedick, Battelle
Dale Phenicie, Council of Great Lakes Industries
Edward Pietring, MOE?
Janet Remmers, USEPA
Jim Roewer, Utility Solid Waste Activities Group
Joe Stepun, Western Lake Superior Sanitary District
Tom Wesolowski, Co-Steel Lasco
Dwain Winters, USEPA
Anita Wong, Environment Canada
Maureen Wooton, Battelle