Great Lakes Binational Toxics Strategy

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______________________

Dioxin / Furans

Stakeholders Minutes - May 17, 2001
Workgroup Meeting Minutes

Workgroup Leaders:
Anita Wong, EC
Nan Gowda, EPA

Introduction

Nan Gowda (EPA) and Anita Wong (EC) opened up the meeting with a brief introduction. The objectives for the day were to review progress made by the GLBTS Dioxin/Furan (D/F) workgroup in addressing high GLBTS priority D/F sources and information needs, and to discuss next steps for the workgroup. Specifically, the group planned to discuss issues and progress made on open burning and pentachlorophenol-treated wood, including a review of the draft Backyard Trash Burning (Barrel Burning) Strategy/Implementation Plan and updates on information gathering and management efforts in the U.S. and Canada for the PCP-treated wood sector.

Materials distributed to the workgroup included:

The meeting agenda
A draft “Strategy/Implementation Plan for Reducing the Prevalence of Backyard Trash Burning (Barrel Burning) in Rural Areas of the Great Lakes” and overheads from the open burning workgroup
A summary, “Treated Pole Usage Summary-All Poles” from the Utility Solid Wastes Activity Group (USWAG) Utility Survey
A report, “Characterization of Organic Compounds from Selected Residential Wood Stoves and Fuels” from Environment Canada (EC) as part of the Residential Wood Stove Combustion study
Progress summaries of information gathered on Landfill Fires and Incinerator Ash Management in the Great Lakes Basin.

Workgroup Progress Updates

Backyard Trash/Open Burning

Bruce Gillies (EC), the leader of the Burn Barrel Subgroup, provided the workgroup with an overview of progress on the open burning strategy, “Strategy/Implementation Plan for Reducing the Prevalence of Backyard Trash Burning (Barrel Burning) in Rural Areas of the Great Lakes.” He noted that, since the first presentation of the draft strategy at the workgroup meeting last fall, the document has evolved considerably. The hope for today’s meeting was to get the workgroup’s general approval and any additional input on the strategy, in order to present it to the Integration Group (IG) tomorrow.

The strategy currently provides a brief discussion of the problem, goals, strategic plan to address barrel burning, draft generic implementation plan (including the role of the burn Barrel Subgroup), synopsis of existing information, and discussion of information gaps and controversies.
The strategy does not address agricultural burning, although barrel burning of household wastes in rural areas is included.

It was noted by a workgroup member that barrel burning in rural areas may contribute disproportionately to food chain contamination due to proximity to agricultural lands.

The current elements of the Burn Barrel Reduction Strategy include:

Education of the public and public officials – it was noted that cultivating concern and informing people about options to barrel burning was a very important element of the strategy
Developing an infrastructure to provide alternatives to barrel burning
Establishing and/or enforcing regulations

Bruce cited the successes of the Western Lake Superior Sanitary District (WLSSD) project on open burning, and noted that the subgroup was also attempting to develop some outreach materials modeled after the materials used by the WLSSD project.

The role of the Burn Barrel Subgroup in a coordinated campaign (e.g., as a resource to link various partners, information sources, and funding sources) was discussed. Bruce noted that the subgroup was currently in the process of identifying target groups for education and other efforts.

Bruce requested general feedback on the strategy. Depending on the feedback from the D/F workgroup, the burn barrel subgroup would like to present the draft strategy to the IG for input and backing.

Joe Stepun (WLSSD), a member of the Barrel Burning Subgroup, reported that outreach on open burning issues is currently being conducted in a local program in the WLSSD through 30-second TV spots, including 6 and 10 o’clock news viewings. Obstacles encountered in this effort have included:

The staff and media consultants have found the project somewhat challenging, because up until now, there has not been good data to support the existence of problems (release of pollutants) associated with the open burning of trash.
In particular, they found that making statements on health effects associated with pollutants released during open burning of trash (i.e., how much dioxin is bad?) was difficult.
They have also found it hard to get a message out that is palatable to a variety of audiences, but also sensitive to the need to not single out or finger-point at particular groups.

Joe reported that they had a press release to announce the launching of the campaign. In response, they received numerous calls, some with concern over wood burning.

Joe also noted that because camping/recreational fires can be an open burning issue, they are talking with officials from these areas. He cited this as an example of the fact that open burning is not just a problem for the public, but that various public officials and regulation makers are also key players.

Dwain Winters (EPA), who has also been involved in the development of the strategy, noted that this version of the strategy is a draft, but the subgroup needs input now from a broader audience so that it can eventually be ready for a public review audience. Bruce added that specific comments would also be welcomed later at the ongoing subgroup meetings, and that they would also be seeking input from other relevant GLBTS substance workgroups. The D/F workgroup could look into posting the document for broader review on a BTS web site.

A question was asked on whether the strategy focuses on reducing all trash burning or just barrel burning specifically:

Bruce responded that it had been decided to refer to this effort as a barrel burning strategy because the emissions inventories are based on barrel burning (i.e., there isn’t much information on other types of trash burning). However, he did note that of the 24% of households that burn their waste in Ontario, only ~1/3 of trash is burned in barrels - the rest is in pits, wood stoves, and fireplaces.
The underlying goal of the strategy is to reduce all uncontrolled trash burning.
Dwain added that we know the most about uncontrolled combustion of household waste, and that the focus of the analyses on uncontrolled waste combustion had been in 55 gallon drums (household and related waste). However, all types of uncontrolled residential trash burning could be addressed under this Barrel Burning Strategy, with the exception of agricultural waste (e.g., feed bags) and stubble burns.

It was suggested that the term “Barrel Burning” be better clarified in the next version of the strategy.

A question was asked about why fireplaces are not included, and if wood burning is addressed:

Dwain responded that fireplace/wood burning are a different class of burning. For now, the focus of the burn barrel strategy is on stopping trash burning where alternatives exist.

It was noted by a workgroup member that, with public service announcements, it is important to keep the message tight in focus.

Based on this discussion, terms suggested as clarifications for ‘Barrel Burning’ included:

Household Waste/Trash Burning
Residential Waste Combustion
Barrel Burning (plus another term in parentheses)
Another term (plus the term Barrel Burning in parentheses)

Dwain suggested that, especially in certain age groups, the term ‘Burn Barrel’ is a powerful identifier and it would probably be helpful to keep this term, at least in parentheses.

A question was asked regarding any available information on the geographical distribution of rural waste burning, and if there were differences in household waste burned in burn barrels versus municipal waste burned in incinerators.

Dwain responded that overall, most rural populations live east of the Mississippi, but open burning of trash is fairly common throughout the U.S. However, the concern is not as big with trash burning in certain areas (e.g., Wyoming) due to dispersed populations and where contamination of agricultural food crops is not as big of an issue.
He also said that, in general, household waste is fairly uniform. In some cases, slight differences may exist, such as the separation of cans and bottles from the bulk waste to be burned at municipal waste incinerators.

In light of the meeting agenda, Anita Wong asked if the group could start to move towards some sort of tentative consensus (e.g., were there any big concerns regarding the burn barrel strategy?)

A question was asked on why it was necessary to take the strategy to the Integration Group.

The strategy would be taken to the IG to keep them informed of workgroup activities.
In addition, if an informal approval of the strategy document can be obtained from the IG, it may help in bringing in a broader participation from other groups such as environmental groups.
It was generally agreed that if the term ‘Burn Barrel’ was clarified, the strategy was sufficient at this point to bring up at the IG meeting.

Discussion continued for several minutes on the need for creating viable alternatives to open burning of trash (e.g., creation of a waste management infrastructure), including:

where the trash diverted from open burning will go (municipal waste incinerators, landfills, etc.),
development (expanding metro areas) pressure on existing waste management systems,
public attitudes towards waste incinerators and landfills near their homes,
environmental groups’ attitudes towards waste incineration.

To stay on schedule, the group moved on to the next agenda items. It was noted again that any final comments on the Burn Barrel Strategy could be sent to Bruce.

Action Item Updates

Pentachlorophenol-Treated Wood

Terry Mah (Environment Canada) provided the group with a progress update on the Canada Wide Standards for Treated Wood, including a review of the Canadian Environmental Protection Act and the Strategic Option Process (SOP), work on life cycle analyses, the role of the Pest Management Regulatory Agency in addressing PCP an other wood preservatives, and voluntary versus mandatory requirements in the overall process:

Updates on the SOP are posted on the EC website (http://www.pyr.ec.gc.ca/dryclean/sor_e.shtm )
The SOP recommendations are now in year 2 of implementation (90% voluntary action)
Regarding manufacturing, PCP is only an issue in the U.S. (PCP is not manufactured in Canada). Discussions with manufacturers of CCA and creosote in Canada are planned.
Regarding treated wood management, all treatment facilities opted for the voluntary program recommendations, with a baseline assessment currently being conducted on how well facilities are complying with the SOP recommendations
Software is being developed for use by wood treatment facilities to standardize their reporting estimates under the SOP

Terry reported that full implementation plans/actions plans for wood treatment facilities and annual progress reports will be publicly available under the SOP.

Helga Blackman of the Canadian Electricity Association (CEA) then gave the workgroup a presentation on some activities conducted by CEA members prior to, under, and beyond the Treated Wood SOP.

Prior to the development of the SOP, the industry already had practices in place regarding treated utility poles (e.g., for poles taken out of service, purchaser intended use and vendor use restrictions are required to be reported on disclosure forms upon resale)
Under the SOP, the industry has been highly involved in the process, including participating in information sharing, planning, guideline development, and addressing waste management issue
Beyond the SOP, the industry participates in the Environmental Commitment and Responsibility (ECR) program, which is a voluntary program specific to utilities. (Additional information and reports on ECR are available on the CEA website at http://www.ecrprogram.ca/english/home.html )

In general, Helga indicated that the utility industry was well on its way to addressing environmental concerns associated with treated wood before the SOP, but that they got there much faster with the help of the SOP.

Next Jim Roewer provided the group with an overview of the National Rural Electric Cooperative Association (NRECA):

The association was initiated to assist its members with their environmental obligations
The association is national in scope and includes a diverse group of small and large companies, as well as 4 major consortiums

Jim noted that, in general, efforts by the utility industry and other groups to address possible issues associated with utility poles and other treated wood were not as far along in the U.S. as in Canada.

As a first step in addressing information gaps, however, the Utility Solid Wastes Activity Group (USWAG) initiated a survey study to find out what the actual end uses were for utility poles taken out of service among member organizations. Jim gave a preliminary report on some of the survey results regarding management practices:

The Number of Utilities Responding to Treated Wood Survey: 315
Number of Utilities Using Treated Poles (Out of 315 Survey Respondents): 315 (100%)

Management Practices for Wood Taken Out of Service on an Annual Basis (Data Provided by J. Roewer, NRECA)
	All Poles ¹
No Information Available Reuse by Utility Sell/Give to Employees ² Sell/Give to Public ² Mill into Lumber Bury in Place Sanitary Landfill Construction/Debris Landfill Hazardous Waste Landfill Burn for Fuel Non-Hazardous Incinerator Hazardous Waste Incinerator Other	0.2% 4.2% 8.0% 55.3% 2.1% 0.0% 16.5% 11.6% 0.3% 0.2% 1.2% 0.0% 0.3%	517 9,872 18,786 129,145 4,845 12 38,443 27,173 715 490 2,271 -- 753
	100%	469
¹ Percentages based on the total number of treated poles quantified by the USWAG Treated Wood Survey [(% reported x No. of Poles)/233469 Poles] ² Of those utilities that sell or give treated wood poles to employees and/or the public, 82% include notification (e.g., MSDS’s, waiver/indemnification, restrictions) about the wood.

Jim indicated that the results in full were not available yet, but that they were also just starting the development of a

Best Management Practices (BMP) document, including a waste management hierarchy. The BMP will look at:

life extension for existing utility poles
options for disposal of treated poles taken out of service
reuse issues
alternatives to reuse
disposal issues (e.g., guidance for members for applying regulations)

Questions on PCP-treated wood management and discussion followed. These included questions on:

The potential for PCP-treated wood to serve as an important reservoir source
The possibility of PCP-treated wood, in the future, being treated as a hazardous waste in the development of BMPs and SOPs
Trends in dioxin/furan emissions with the initiation of the Canadian SOP, including reductions from U.S. manufacturers of PCP
Shifts in dioxin/furan congeners in PCP formulations, improved PCP formulations
Looking for other wood preservatives besides PCP (i.e., eventually eliminating PCP and dioxin contamination, in the spirit of virtual elimination)
The role of the customer (utilities) and the market in what types of preservatives are used in treated wood

Dwain Winters (EPA) noted that information from the USWAG Utility Pole survey would be considered in the development of the U.S. Dioxin Strategy.

Terry Mah noted that in the Treated Wood SOP Users Steering Committee, there are ongoing efforts to look at wood treatment alternatives. They are trying to coordinate efforts with the BNS and CWS, and they are looking for additional input.

Jim Roewer noted that in many areas, disposal of treated poles via fuel recovery is the preferred option due to lack of landfill capacity. He also said some utilities have already switched from treated wood poles in certain areas where special environmental or other concerns are present.

Residential Wood Combustion

Next, Anita Wong gave the group an overview of the Canadian Residential Wood Combustion Study:

Results show that for CO, particulate matter (PM), PAHs and VOCs, the lowest emissions were from EPA certified stoves burning hard wood. The highest emissions were from conventional stoves burning soft wood.
HCB levels were non-detects.
Dioxin levels showed the opposite trends as those for CO, PM, etc. (dioxin levels appeared higher from EPA certified stoves, and most dioxins were in gaseous form).
Variability in the results was high.
Additional research is warranted.

Anita reported that the results of this study resulted in revision to the Canadian Dioxin Inventory, with dioxin emissions estimates from wood stoves decreasing in the 2001 revision from 36 g TEQ/yr to 3.3 g TEQ/yr using the new factor of 0.5 ng/kg wood burned.

A workgroup member commented that statistical conclusions were not valid with a sample size as small as the one in the Canadian study. It was also noted that because the units reported were in picograms (pg), the emissions measured from the conventional and the certified wood stove were actually very close.

Discussion followed on the impact this study would have on the endorsement of the newer wood stoves (e.g., especially as they are known to reduce emissions of other toxics)

Dwain noted that the wood stove data is suggestive, but that the range/variation is so big that these tests may or may not be accurate. He suggested that a fairly ambitious (e.g., in the range of $1/2 million) testing program is needed to resolve remaining questions re: wood stoves and dioxin emissions.

Landfill Fires and Ash Management

Nan Gowda (EPA) briefly introduced the materials distributed to the workgroup with information gathered to date on landfill fires and waste incineration ash management. He requested that workgroup members review these materials and provide input on how best to fill in the remaining information gaps.

The meeting adjourned.

Participant Roster

David Ailor, American Coke and Coal Chemicals Institute
Bob Bailey, Council of Great Lakes Industries
Robert Bilyea, Ontario Ministry of the Environment
Helga Blackman, Canadian Electricity Association
John Crouch, Hearth Products Association
Tom Dann, Environment Canada
Tony DeFalco, National Wildlife Federation
Herbert Estreicher, Covington & Burling
Bruce Gillies, Environment Canada
Nan Gowda, USEPA
Douglas Green, Piper, Marbury, Rudnick & Wolfe LLP / Utility Solid Waste Activities Group
Darryl Hogg, Environment Canada
Dan Hopkins, USEPA
Mark Johnson, Weyerhaeuser Company
Dennis Kemp, Falconbridge Limited
Steve Kratzer, Michigan Dept. of Environmental Quality
Terry Mah, Environment Canada
W. M. McLeod, Hearth Products Association Canada
Dawn McDonald, Environment Canada
Octavio Melo,
Darrell Piekarz, Environment Canada
Dale Phencie, Council of Great Lakes Industries
Steve Risolto, Halogenated Solvents Industry Alliance, Inc.
Jim Roewer, National Rural Electric Cooperative Association
Steve Rosenthal, USEPA
Greg San Martin, Pacific Gas & Electric Company
Eric Sanderson, Environmental Labs, McGill University
Sam Sassnett, USEPA
Joe Stearns, Chlorine Chemistry Council
Joe Stepun, Western Lake Superior Sanitary District
Laura Summers, Ontario Ministry of the Environment
Tom Tseng, Environment Canada
Rich Whate, Toronto Environmental Alliance
John Wilkinson, Vulcan Materials
Dwain Winters, USEPA
Anita Wong, Environment Canada
Maureen Wooton, Battelle