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Great Lakes Binational Toxics Strategy

IMPLEMENTING THE BINATIONAL TOXICS STRATEGY
Implementation

Stakeholders Forum
November 16-17, 1998 - Chicago, Illinois

Octochlorostyrene Meeting Minutes

Attendees:

Step 1 - Identification of OCS sources:

The work group focused on potential OCS sources and information needs. OCS presents a contrast to, for instance, mercury, which has many recognized uses and sources. OCS has never been produced as a product and trace generation of OCS may be unknown even to sources themselves. A draft report prepared by Battelle for the USEPA was made available. Based on a comprehensive review of scientific literature, it aims to document the presence of OCS in the environment including its geographic dispersion and temporal trends, consider potential past or present sources, and estimate current U.S. atmospheric emissions of OCS. Frank views the document as a starting point; work-group members were encouraged to comment on any aspects of the document by January 15, 1999. Thereafter, a second draft will be prepared by March 1999.

Discussion of the tabled report included: $ One source previously known to generate OCS, chlor-alkali production, may no longer do so, since graphite electrodes have generally been replaced by metallic ones; however, it was asked if chlorinated hydrocarbons could form elsewhere in these factories (e.g., decomposer units of mercury cell factories, since these contain graphite). $ Because there has been little or no characterization of atmospheric emissions for OCS, Batelle made a best estimate of OCS emissions by basing these on better known emissions for hexachlorobenzene and chlorinated dioxins, other chlorinated hydrocarbons which may form in similar ways. $ Darryl noted that Environment Canada has atmospheric deposition monitoring data on OCS from a limited number of sites since 1996 and also some data on OCS levels in Lake Ontario lake trout that will be provided for the next draft of the report. Darryl also noted that HCB to OCS ratios obtained from air monitoring suggest in his view that OCS deposition to the Great Lakes may be orders of magnitude lower than estimated in the first draft of the Batelle report.

There was discussion whether OCS should be combined with the Hexachlorobenzene (HCB) or Dioxins groups. There is evidence that these three classes of polychlorinated hydrocarbons may form under similar conditions. In addition, it may be reasonable to coordinate prospective source assessment or environmental monitoring activities with these groups.

Werner reported on his efforts to obtain information regarding possible sources. The draft OCS report provides some new candidates that he will contact. In several instances, companies have already furnished Werner with information and in some cases wished this information to be treated as confidential. Frank suggested that Werner provide what he can to the group, while respecting confidentiality concerns. On a case by case basis, this will allow consideration of whether the information resolves or does not resolve the issue of possible generation by a source type. Werner plans to furnish an initial report by the end of 1998.

Werner asked that EPA identify the source of the hypothesis raised at a previous meeting that OCS may be generated by medical and municipal waste incinerators. Also, Frank indicated that waste sites were not sources of OCS, but recipients of it, hence waste sites should be eliminated as a source category.

Bob Olsgard emphasized the need for more information on sources and OCS levels in the environment. He suggested taking advantage of any upcoming permitting processes to obtain additional information. He also asked whether chlorine use should be curtailed; Werner indicated that chlorine products were safe; Frank noted that OCS was not a deliberate product and that when and if OCS sources are identified that they will be encouraged to prevent its formation by appropriate means.

The Binational goal for OCS is to determine if there are current releases of OCS by the end of 1998. Based on the draft paper, Frank's preliminary view is that there are reasonable grounds to think that there are or may be current sources of OCS, though it is encouraging to note that the limited temporal information suggests that OCS is declining in the environment.

Future Activities: Darryl and Frank report to the Integration Committee if there are or may be current releases of OCS, by 31 December. · Darryl and Frank consider the case for combining the OCS group with those for HCB and/or polychlorinated dioxins/furans, and make appropriate recommendation to the Integration Committee, by 31 December. · Frank pose questions to the U.S. chlor-alkali industry regarding residual use of graphite anodes and the possibility of OCS formation in decomposer units, by 31 December. · Werner provide update on his discussions with potential sources, by 31 December. · Work group members review first draft Batelle paper and provide comments, by 15 January. · Darryl provide data on OCS levels in fish and atmosphere by 15 January. · Frank and Darryl host a conference call for workgroup members to review comments on the Batelle draft report, by 15 January. · Batelle revise paper accordingly and prepare a second version by 31 March.

Step 2 - Assess current environmental management regulations, initiatives, and programs which manage or control OCS:

In general, there are few regulations pertaining to OCS, nor is the substance often monitored under water, waste, or air regulatory programs. While the USEPA has identified OCS as bioaccumulative under its Great Lakes Water Quality Guidance, we are unaware of associated permit limits and compliance monitoring. OCS is not included in the US Toxics Release Inventory. In Canada, OCS not assessed as toxic under CEPA

Future Activities: Darryl and Frank request that the Integrated Atmospheric Deposition Network include OCS in its monitoring program. · Darryl and Frank support analysis of sediment cores in several of the Great Lakes for OCS in order to indicate its temporal trend and geographic dispersion.

Step 3 - Identify cost-effective options to achieve further reduction:

As the production of OCS may be linked to production of HCB and Dioxins, a cost-effective option is to coordinate OCS data needs and reductions with potentially related activities in the HCB and Dioxin work groups.

Step 4 - Implement actions to work toward the goal of virtual elimination:

No prevention/control actions specific to OCS have been identified at this time

See DRAFT ACTION PLAN FOR OCTACHLOROSTYRENE

 

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