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Great
Lakes Binational Toxics Strategy
Dioxin / Furans
Stakeholders Meeting - September
7, 1999
Workgroup Teleconference Minutes
Workgroup Leaders:
Sandro Leonardelli, EC
Nan Gowda, EPA
Facilitator:
John Menkedick, Battelle
The objectives for the day were briefly reviewed. They included:
presentation and review of the (revised) decision tree, and decision
on the process the work group will use to prioritize future
dioxins/furans reductions actions. The meeting opened with a
presentation on Health Care Without Harm by Jackie Hunt Christensen.
Information Presentation and Discussion
Health Care Without Harm
Jackie Hunt Christensen presented a brief overview of Health Care
Without Harm (HCWH). Jackie is affiliated with a HCWH member
organization, the Institute for Agricultural Trade Policy, which is
concerned with preventing dioxin contamination of food products.
- Health Care Without Harm is a collaborative campaign for
environmentally responsible health care. The campaign was
initiated in 1996 by 28 organizations with the intent of
addressing the environmental impacts of medical waste,
particularly medical waste incinerators (MWI).
- 185 different organizations in the health care industry and
other interests now participate in Health Care Without Harm. One
of the primary concerns of the group is reducing dioxin (and
mercury) emissions from medical waste incineration.
- HCWH discourages unnecessary incineration of hospital waste
materials, especially recyclable materials, with a focus on
eliminating the need to burn wastes. In addition, HCWH is also
specifically concerned with products made with polyvinyl chloride
(PVC) plastic, due to the potential for PVC to release dioxin
during its manufacture and incineration, and DEHP leaching from
flexible PVC products.
- Activities HWHC has conducted include:
- Meeting with hospitals to encourage / discuss means for
waste reduction (e.g., materials separation)
- Encouraging the use of non-PVC alternatives in hospitals
(e.g., polyethylene IV bags)
- Encouraging non-incineration alternatives to waste disposal
- Encouraging more aggressive measures for MACT standards
- Jackie emphasized that in general, hospitals have been very
receptive to waste reduction efforts promoted by HCWH.
Guy Williams noted that the National Wildlife Federation (NWF) is
a member of HCWH and is very supportive of their efforts.
A question was asked regarding HCWH’s perspective on the
potential impact of new MACT standards:
In general, HCWH felt the estimates of expected reductions were
relatively premature and that they were calculated from baseline
data that were not determined with a high degree of confidence in
the first place.
A group member made the comment that in Minnesota, with the
closing of the smaller MWIs, there has been no conclusive evidence
that less waste has been burned overall (i.e., the waste may just
be shipped to other states or commercial regional facilities).
A question was asked regarding whether the chlorine content of
the waste had a significant effect on the level of dioxin emissions,
and if you could really expect dioxin reductions by reducing PVCs:
Jamie Harvie (WLSSD) noted that in their incineration studies,
during times of poorly-controlled combustion, the chlorine content
of the waste had the potential to have a big impact on dioxin
formation. Dwain Winters’ (EPA) presentation at a previous meeting
that recognized chlorine content as a factor in poorly controlled
combustion, but not so in well-controlled combustion, was also
cited.
Jackie responded that for PVCs, dioxin generation potential is
part of the whole PVC life-cycle, and thus HCWH felt their use in
general should be discouraged. However, with other materials
(e.g., paper), they simply encouraged recycling rather than
incineration.
A question was asked on what types of non-PVC alternatives exist
for medical supplies:
Jackie responded that for IV bags, alternatives included
polyethylene and polyolefin blends, however, for blood bags,
substitution was not easy at this point. She noted that there is a
non- PVC bag distributed in Europe, and that DOW Chemical Company
also had alternatives in development that were awaiting FDA
approval. Jackie also mentioned options for other materials such
as ID bracelets and latex gloves.
Dale Phenecie (CGLI) suggested that contacts in the vinyl
industry may be able to supply the group with additional
information concerning their data, etc. on dioxin emissions
associated with PVCs.
Jamie mentioned that in Minnesota, Dr. Pat Eagan was developing
a PVC/mercury program for the health care industry and could be
contacted off-line for additional information.
A question was asked if any hospital supply companies were member
of HCWH:
Jackie responded no, but HCWH had participated in meetings with
hospital suppliers. She noted that a common problem was the length
of hospital - supplier contracts. For example, suppliers may have
a binding contract with a hospital to supply a certain type (PVC)
of IV bag for the next seven years. Within this purchasing system
though, HCWH has encouraged hospitals to consider non-PVC
alternatives when their next contract renewal comes up.
Decision Tree Presentation
John Menkedick reviewed workgroup progress to date and how the
need for the decision tree arose:
- In April, the group agreed to focus on primary sectors and
discuss options at subsequent conferences.
- Conference calls have focused on MWC and MWI, open burning,
cement kilns, diesel engines, utility coal, landfill fires, and
PCP treated wood.
- Several action items have been committed to, but are currently
outstanding (e.g., open burning activities).
- On the last call, CGLI presented a decision tree as a means to
target, define and implement actions.
- Since the last meeting, Sandro Leonardelli (EC), Nan Gowda and
Dan Hopkins (EPA), and Dale Phenecie (CGLI) have worked together
to refine the tree as a tool for guiding implementation of
priority actions.
Dan Hopkins provided some background on the evolution of the
decision tree:
- The decision tree was originally developed by CGLI for use in
the BNS octachlorostyrene (OCS) workgroup.
- The decision tree was refined with the intention of helping
the dioxins/furans work group members identify the top [five]
priorities for the work group to focus on.
- The revised decision tree is not intended to limit any
workgroup member from seeking any other project or options; it is
just meant to respond to the group’s need to prioritize resources
and focus on action, and identify the projects that make sense to
most people.
- Dan characterized the decision making process outlined in the
tree as being guided by the best use of existing inventories
Dan stepped through the tree with the group.
[see attachment - DRAFT Dioxin Decision Tree]
John Menkedick followed up with some illustrative examples of how
the decision tree would actually be applied:
- For example, ethylene chloride production does not have a
reliable emission estimate, BUT there are no facilities in the
basin. THEREFORE, this source is a low priority for action.
- Backyard burning does not have a reliable emission estimate.
However, it is likely to be a significant source, AND is thought
to be prevalent in the basin. Regulatory controls vary, THEREFORE
this source gets directed towards identifying potential reduction
projects and initiatives (...which is where the group left off on
this source on previous meetings)
- For medical waste incinerators (MWI), a quantitative inventory
emission estimate exists, AND evidence suggests MWI are a
significant source, AND regulatory controls exist. THEREFORE, the
key question is whether further reductions opportunities exist
after regulations. The group discussed possible differences of
opinion on this question. For example, if one accepts estimates of
expected post-regulation dioxin emission, this source would become
low priority. However, if one disagrees with those estimates, this
source may still be considered a target for further reduction
actions.
Discussion of the adequacy of the decision tree process followed.
Ideas and concerns included:
- the addition of another box or loop at the beginning which
would reflect the simultaneous need to get more information for
some sources, and still investigate actions to identify further
reduction opportunities.
- correcting gaps in regulations that exist due to insufficient
inventories (concern was raised over the fact that reductions
expected to result from MACT implementation may not be a s
effective as estimated - this should be taken into account when
running through the tree so a MACT regulated source isn’t
automatically moved to low priority status)
- the addition of another box/series of boxes to reflect the
importance of pollution prevention (not only end of pipe
solutions),
- Dan Hopkins noted that it is very important in this process
not to be limited by the lack of emissions estimates. For example,
we may never be able to get emission factor estimates that
represent any specific burn barrel. Variability from barrel to
barrel can be expected. However, general emission factors can be
used meaningfully in estimating emissions from the category "burn
barrels", collectively.
- Tom Hornshaw (Illinois EPA) cited a recent USEPA report on
opening burning which also identified problems with emission
estimates, as well as comparisons of waste management practices in
different households. [This report can be obtained through the
USEPA website at:
http://www.epa.gov/ttncatc1/products.html#aptecrpts ]
- It was noted that at any point in the decision tree, needs for
additional information may be identified. However, as we may need
to work for years on generating more reliable emissions estimates,
we should also continue to work with the estimates we currently
have.
Discussion turned to the question of whether the workgroup felt
the decision tree was a useful tool, and where the workgroup wanted
to progress from here:
- The group generally agreed the decision tree would be a useful
guiding principle for identifying 4-5 major targets for
dioxin/furans reductions activities
- It was agreed that EPA/EC will apply the decision tree process
to a list of primary sectors and share results on the next call
(with the workgroup providing feedback). Sectors to be assessed
will include the significant sources as reflected in Canada and
U.S. inventories, as well as other sources that may be
particularly important in the Great Lakes Basin. (EC noted it
would be more appropriate to select sectors based on the Ontario
inventory, rather than the Canadian inventory).
This led to a brief update on action items as well as the
addition of several new items:
Action Items and Next Steps
- Minutes from the September 7 conference call will be drafted
and distributed
- EPA/EC will revise the decision tree per comments made by the
workgroup at today’s meeting (revised version to be distributed
before next meeting)
- EPA/EC will apply the decision tree to as many of the primary
candidate sectors as possible and present the results for
workgroup focus
- The Action Items list will be updated and distributed.
Workgroup members will review this list, and where possible, offer
to report out on progress at the next conference call.
The workgroup will continue work on current action items
identified in the action item update. The next conference call is
scheduled for October 5.
Participant Roster
Jackie Hunt Christensen, Institute for Agriculture and Trade
Policy and Health Care Without Harm
Hugh Eisler, Canadian Chlorine Coordinating Committee
Dan Hopkins, USEPA
Nan Gowda, USEPA Region 5
James Harvie, Western Lake Superior Sanitary District (WLSSD)
Jeffrey Lynn, International Paper
John Menkedick, Battelle
Stephane Gingras, Great Lakes United (GLU)
Mark Johnson, Weyerhauser
Tom Hornshaw, Illinois EPA
Alec Macpherson, Great Lakes United (GLU)
Dale Phenicie, Council of Great Lakes Industries
Guy Williams, National Wildlife Federation
Robert Hyde, Canadian Portland Cement Association
Anita Wong, Environment Canada
Maureen Wooton, Battelle
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