Great Lakes Binational Toxics Strategy

IMPLEMENTING THE BINATIONAL TOXICS STRATEGY
Implementation

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

Octochlorostyrene Meeting Minutes

DRAFT ACTION PLAN FOR OCTACHLOROSTYRENE

(Note to PBT Workgroup members: Although comments have been received and incorporated, it must be emphasized that actions proposed in this plan have not been formally discussed with EPA and must therefore be considered only as reasonable candidates proposed by Battelle that need evaluation from an EPA Program perspective. Further structural and organizational changes will be made to the document after Workgroup consensus on a standard format is reached, hopefully at the January 12/13 meeting.)

INTRODUCTION

The Great Lakes National Program Office (GLNPO), Office of Research and Development (ORD), and members of the PBTI plenary group, with contract support from Battelle, are the primary contributors to the action plan for octachlorostyrene. Octachlorostyrene (OCS) has been identified as an environmental pollutant of industrial origin in diverse western nations, including the US, Canada, and Europe. It has been detected in water, sediment and fish tissues in the Great Lakes (Lake Michigan and the St. Clair River between Lakes Huron and Erie, in particular), in the Bayou d'Inde area south of Lake Charles (Louisiana), Norwegian fjords, coastal regions of the Netherlands, the North Sea, Rhine and Elbe rivers of Germany. OCS has been designated as a Level 1 substance in the Great Lakes Binational Strategy and targeted for virtual elimination there, and has Zero Discharge status in the Lake Superior Binational Program. OCS is also a Bioaccumulative Chemical of Concern (BCC) in the Great Lakes Water Quality Initiative.

Although sources of OCS are fairly-well identified, little is currently known about industry-specific emission rates (effluent, stack, and fugitive), affected ecological and human populations and their exposures. Due to the paucity of data, state and regional involvement in the development of the action plan has been minimal.

PROFILE SUMMARY

Octachlorostyrene (OCS) has no natural sources and is not produced commercially. OCS can be produced as a by-product in chlorine production, in chlorination reactions, and in metal production/finishing operations. High temperature incineration of chlorinated hydrocarbons (e.g., PVC, chlorinated solvents, PCBs) can also produce OCS.

The occurrence and toxicity of OCS may be inferred, in part, on the basis of its structural similarities to hexachlorobutadiene, hexachlorobenzene, and CDDs. Mammalian carcinogenic and toxicity testing results are limited at this time; acute and chronic mammalian toxicity have been assessed in only single 28-day, 90-day, and 12-month feeding trials in rats. Mutagenicity has been tested in only two Ames assays. Aquatic toxicity has been assessed with only one crustacean specie.

The bioaccumulation of OCS has been evaluated in the Great Lakes Water Quality Initiative; the bioaccumulation factor (BAF) for fish is 117,500,000 and the human health BAF is 2,481,000 for consumption of contaminated fish. These data provide the basis for designation of OCS as a bioaccumulation chemical of concern (BCC) and as a Binational Strategy Level 1 substance.

Persistence, Bioaccumulation, and Toxicity

OCS has not been scored using the Waste Management Prioritization Tool (WMPT) due to lack of critical data in both the Human Health Risk Potential and Ecological Risk Potential scores. Limited data are available for several of the subfactors, notably the Human Non-Cancer Effects, Aquatic Toxicity, and Bioaccumulation Potential, as summarized below and detailed in the attached appendix. The major WMPT subfactor data missing are the data on "Mass" of chemical present in the environment. While bioaccumulation and persistence are well-acknowledged, toxicity data are limited.

Status/Need: While bioaccumulation and persistence well-acknowledged, toxicity data is limited.

Sources, Pathways & Environmental Loadings

Overviews of sources and exposure pathways for OCS are given in Appendix A. Four major source categories include electrolytic chlorine processes, high temperature incineration of chlorinated hydrocarbons, metals processing, and chlorination processes. Emissions from these sources are distributed to air, water, sediment and biota so that human populations may be exposed via ingestion, inhalation and dermal contact.

Unfortunately, data gaps for OCS related to sources, pathways, and loadings are significant. The largest database of information on OCS is related to the sources of OCS, although these data tend to be episodic and/or limited to individual case-by-case analyses of effluent or stack emissions, or logically-deduced on the basis of proximity of a contaminated sediment or ecological population to a suspected source. Quantitative estimates of emissions factors, estimates of atmospheric deposition loadings, or other data to quantify known sources are lacking. The only reference to an industrial emission rate of OCS was the estimate of 75-80 kg of OCS/yr from a magnesium production plant in Norway.

One of the potentially important sources of OCS is the particular sector of the chlor-alkali industry (electrolytic production of chlorine gas and sodium hydroxide) which uses graphite electrodes. The US produced 12 million tons of chlorine and 13 million tons of sodium hydroxide in 1995 at 55 plants; world wide production of chlorine is about 40 million tons/year. OCS emissions from this source type may be significant.

Status/Need: Need number, size, and geographic distribution of all potential OCS sources; need emission factors by source type; need verification of OCS in vehicle exhaust; need environmental loadings by geographic or source-type area.

Sensitive Subpopulations and Geographic Areas

Human populations that reside in heavy industrial regions of the US, and which are near water bodies used for sport and commercial fishing, may be more highly exposed to OCS. Regions of the US that fit this profile include Tacoma, WA (aluminum smelters), Great Lakes industrial centers (Detroit, cleveland, Chicago, Gary, Buffalo), and the New York, Boston, and New Orleans harbor/estuary regions.

Pregnant women, breast-fed children of women who consume large quantities of contaminated fish, sport fishermen and subsistence fishermen (and their families) will also constitute sensitive and/or highly exposed populations

While not under EPA's jurisdiction for protection and legislation, those individuals which are employed in industries associated with OCS emissions may also be at significant risk for exposure. Since these workers may be more highly exposed than the general population, toxic symptoms and effects that are readily identified in these workers (together with assessments of frequency and dose) may help to establish those effects that can be expected and/or monitored in the above-named populations that have lower exposures.

Status/Need: Only limited data on OCS in breast milk of Canadian women. Need additional human body burden measurements to assess prevalence and exposure in diverse communities. Some joint work with OSHA may be beneficial.

Current Programs

Currently, the only EPA program dealing with OCS directly is the Region 5 Water Division, which deals with OCS as one of their BCCs under the Great Lakes Water Quality guidance. OCS has not been called out specifically in any regulations, and is not listed on the US EPA Register of Lists.

The New York State Department of Environmental Conservation, Division of Water, has recently prepared the draft "Combined Regulatory Impact and Draft Environmental Impact Statement" for protection of human health from consumption of OCS-contaminated water and fish (New York State Department of Environmental Conservation, 1997). The recommended ambient water quality value for drinking water protection is 0.2 µg/L; the recommended ambient water quality value based on human consumption of fish is 6 x 10-6 µg/L.

Ability to Make Risk-Based Decisions

The Environmental Protection Agency may elect to follow a course set by the state of New York, and make risk-based decisions on the basis of current, albeit limited, toxicological data, or may delay such action until further data are available. Since OCS water levels may be driven largely by atmospheric deposition, the setting of acceptable water quality levels may not provide effective control over many contributing sources. The extent to which stack and fugitive emissions of OCS affect water levels, and at what distance from the source, must be known before risk-based emission standards can be set.

Current US data are limited to measurements of OCS in ambient water (such as the Great Lakes, as opposed to drinking water), and OCS in sport fish from a limited number of fresh-water bodies. These data may not be sufficient for calculation of the risk reduction that will result from control strategies and/or regulation of sources. Additional information concerning the non-cancer effects (including the mode of action and dose-dependence) will be needed to establish clearly the nature of the risk for exposed humans.

RATIONALE FOR ACTION

The primary drivers for action related to OCS are:

• The toxicity and bioaccumulation characteristics of OCS, its similarity to carcinogenic hexachlorobenzene and hexachlorobutadiene, and its presence in fish cause concern for public health.
• The international regulation of at-sea incineration to eliminate deposition of OCS, and related compounds, in global oceans will set the pace for global action on this, and other chlorinated products of incomplete combustion.
• Designation of OCS as a Level 1 substance and BCC. Designation as a Level 1 substance results in commitments to action both as part of the Binational Strategy and the PBT Initiative.

DATA GAPS

The data gaps for OCS are quite large; defining actions to sufficiently address them would require a major commitment from the Agency. Therefore, it is important both to set priorities concerning which data gaps are most crucial, as well as to consider how integrated actions and programs directed at a suite of related PBT chemicals could affect releases of and exposure to OCS, and how these integrated actions could mitigate the need for information specific to OCS. Candidate high priority data gaps include:

• An inventory of OCS sources by type, number, size and geographic location.
• Determination of whether auto exhaust is a source of OCS.
• Emission factors for major source types, including waste-water effluent, stack, fugitive and hazardous waste land-fill disposal.
• Estimation of emission reduction and risk reduction feasible for each source type.
• Additional qualitative and quantitative assessment of toxicity.

Consideration should be given to an investigation of the extent to which all chlorinated aromatic compounds that result from incomplete combustion can and should be viewed similarly, both for emissions testing, monitoring and regulation. Compounds that may fall under the umbrella of hazardous chlorinated aromatics include CDDs, CDFs, tetra-, penta-, and hexachlorobenzene, tetra-, penta-, hexa-, hepta-, octachlorostyrene, PCBs, chlorinated naphthalenes, and their aliphatic chlorinated VOC/solvent precursors, such as hexachlorobutadiene, tetrachloroethane, tetrachloroethylene, etc. Chlorophenolics are not included here because of the reactivity introduced by the hydroxyl group.

Studies designed to fill data gaps in source emission factors should attempt to cover as many of these chlorinated aromatics as possible, so as to establish the correlations or relationships (or lack thereof) in concentrations among these species for specific combustion and/or industrial processes.

RECOMMENDED ACTIONS

Overarching Strategy for Action
To achieve virtual elimination of OCS discharges, four overarching strategies are suggested as the rationale for subsequent regulatory, non-regulatory, and stakeholder actions. These strategies are based on the current understanding of sources of OCS, and may need to be altered as a result of some important research/monitoring actions:

• Adopt actions that lead to virtual elimination of PVC incineration.
• Advance the technologies that lead to conversion of electrode composition and/or process technology in currently-used graphite electrode processes involving metals.
• Significantly reduce stack and fugitive emissions of chlorinated aromatics in combustion processes through application of MACT technologies.
• Adopt actions that eliminate use of chlorinated solvents in high temperature metals finishing operations.

Risk/Use/Exposure Reduction Actions
Following are recommended non-regulatory risk/use/exposure reduction actions:

1. Evaluate the LaMPs for each of the Great Lakes to determine target sectors for the reduction of OCS releases to the Great Lakes, and for synergy with methods/plans/actions for reducing other PBT chemicals.
2. Identify contacts in the chlor-alkali industry and create a workgroup with industry representatives (e.g. Chlorine Institute, Region 5, etc.) to develop a strategy for voluntary measures to reduce creation of OCS.
3. Identify contacts in the plastics industry and create a workgroup with industry representatives to develop a strategy for voluntary measures to reduce creation of OCS, including substitution of PVC in medical packaging that must be incinerated, conversion of non-essential PVC applications to non-chlorinated plastics, encouraging development of technology for plastics sorting in municipal waste incinerator streams, encouraging development of technology for salvage of PVC coating from recycled wire and cable, development of a plan for recycling PVC house siding.pan>
4. Work aggressively at state, city and regional planning levels to encourage waste sorting and recycling- using pamphlets and press releases, moratoriums on opening of additional landfills (see example of MA), tax incentives, and/or added fees for unsorted waste.

Risk/Use/Exposure Reduction Actions
Following are recommended non-regulatory risk/use/exposure reduction actions:

5. Coordinate with EPA's Industrial Combustion Coordinated Rule making committee on the possibility of including recommendations on the reduction of OCS to the air through combustion sources, on ways to implement the groups recommendations, and on the possibility of addressing OCS through actions targeted at other PBT chemicals.
   
6. Implement TRI reporting of octachlorostyrene at sufficiently low levels to assure usability in risk assessments.
   
7. Coordinate with Agency efforts to limit or ban various forms of incineration, especially PVC incineration. Drawing upon research actions listed below, communicate the types of incineration most likely to produce OCS to these Agency efforts.

Research or Monitoring Action

• RS-1. Identify archived samples or extracts from existing and/or prior national or local programs (e.g., EMAP) where stack emission samples, wastewater, air particulate matter, fish, clams, sediment or soil have been collected and analyzed over the last 10-20 years for various other chloro-aromatics of concern. Reanalyze samples or extracts for OCS and OCS-related compounds to assess temporal concentration trends and relationships among related compounds.
• RS-2. Support national fish survey.
• RS-3. Establish quantitative correlation between OCS and 2,3,7,8-TCDD; OCS and 2,3,7,8-TCDF; OCS and hexachlorobenzene; OCS and hexachlorobutadiene for various industrial processes.
• RS-4. Identify industry partners and conduct sampling of wastewater effluents, stack emissions, fugitive emissions, ash, and products from pollution control devices to assess emission rates and effectiveness of pollution control strategies. Assess whether controls are needed preferentially on wastewater or stack emissions.
• RS-5. Use data from action items RS-1 and RS-4 with current models to establish rate of atmospheric deposition to terrestrial and aquatic environments. Assess spatial distribution of atmospheric deposition across U.S. Facilitate interagency discussion of joint actions across media.
• Stakeholder involvement
• ST-1 Coordinate with stakeholder outreach efforts for other PBT chemicals
• ST-2 Convene workgroup of stakeholder representatives from chlor alkali industry (Chlorine Institute, Region 5, WI, OH, ME, NC, LA, KY, Minnesota Pollution Control Agency)
• ST-3 Convene workgroup with semiconductor industry to evaluate alternatives to dry-chlorine etching.
• ST-4 Review results of DOE/Industry Joint Association for the Advancement of Supercritical Fluids Technologies (JAST) work in precision parts cleaning as alternative, non-chlorinated metals degreaser technology; provide incentives for industry implementation. Coordinate with OST effluent guidelines.

Coordination with other Federal Agencies
Contact DOE on results of DOE/Industry Joint Association for the Advancement of Supercritical Fluids Technologies (JAST) work in precision parts cleaning as alternative, non-chlorinated metals degreaser technology.

International Coordination
Need input from Brian Muehling and EPA/OIA.

ROLES AND RESPONSIBILITIES WITHIN THE AGENCY, ESPECIALLY AMONG THE EPA REGIONS, AND THE STATES

Considering the significant data gaps for OCS, the most important short-term action that should be taken is to coordinate efforts directed at other similar halogenated aromatics to understand the potential effect on OCS production and whenever possible to modify those efforts to effect the greatest reduction in OCS. GLNPO personnel will have the lead in implementing most actions directed towards coordinating with regulatory efforts directed at other chemicals in the action plan. On these efforts they will work with the ??? branch in OPPT. The ??? Branch in ??? of ORD will have responsibility for carrying out the research efforts directed at understanding the PBT characteristics of OCS and the correlation between OCS and other PBT chemicals. The ??? branch of OPPT will have responsibility for field monitoring and measurement actions. Coordination of states and EPA regions will consist of ???. Roles and responsibilities associated with individual recommended actions are detailed in the Action Plan Matrix presented below.

MEASURABLE (GPRA) GOALS

(These are presented as additional [illustrative] measurable goals that might be established in addition to GPRA goals as specified in the Strategic Plan and Annual Performance Plan.)

The following goals have been established for the action plan for OCS. These goals, consistent with the proposed actions, focus on the link between OCS and other PBT chemicals.