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Benzo(a)pyrene and Hexachlorobenzene

(Draft for Discussion Purposes only -November 22, 2001)

November 14, 2001
BaP/HCB Workgroup Meeting

Workgroup Leaders: U.S. workgroup co-chair: Steve Rosenthal Canadian workgroup co-chair: Tom Tseng

1.0 Update Coke Oven B(a)P Releases
Dave Ailor reported that the steel sector was still in dire straits with Bethlehem Steel closing its Lackawanna coking facilities at the end of September, Acme Steel Company looking at a shutdown of its Chicago (Riverdale) facilities, and other mill closures probable. To this already heavily regulated sector, it was noted that the EPA clean air proposed MACT Standards for coke ovens, to be finalized during the latter part of 2002, went out for comments at the beginning of October; and that last December the EPA presented its proposed rule to be finalized in April 2002 for wastewater discharges from iron and steel facilities. Also discussed was the EPA's residual risk assessment of industrial sources that have implemented MACT technology-based standards and what this may mean for coke production facilities.

With respect to the estimated B(a)P and PAH releases from cokemaking, Dave pointed out that the steel sector believe that the EPA emission factors used grossly overstated emissions and that this is a major issue to which the sector will be commenting on later this month.

2.0 HCB in Pesticides
Dave Maracus handed out a table listing a number of pesticide products found to have trace HCB contamination levels, along with information on product usage, the legal HCB product content limits, and the estimated quantities of HCB being applied. A number of issues were subsequently raised including how much of the HCB applied is volatilized - estimated from 8.4% to as high as 100%, the lack of adequate information on fate of the applied HCB, and the absence of data on actual HCB product content levels because of business confidentiality issues. It was emphasized that the current HCB inventory information, derived using maximum EPA content limits, suggests that the application of HCB contaminated pesticide products is the largest HCB source in the Great Lakes Basin.

Judy Shaw noted that in Canada pesticides are not regulated by Environment Canada but by Health Canada's Pest Management Regulatory Agency who is also responsible for implementing the federal Toxic Substances Management Policy within the pesticide management framework. Judy mentioned that many of the pesticide products of concern may disappear over the coming years and that the usage numbers for these products were going down. For example, lindane usage in Canada is to decline as a result of regulatory actions and, as pointed out by Dave Maracus, one of the listed pesticides DCPA has not been manufactured in the U.S. for the last 3 years.

Discussion centered around the difficulty of getting more accurate HCB application numbers in view of the fact that product use/content information is confidential. In order to arrive at more accurate HCB release numbers to assess the real significance of the pesticide sector, it was suggested that averaging the overall HCB contribution attributed to the listed pest products may alleviate problems associated with product confidentiality. The importance of getting assistance from the individual manufacturers to make this averaging approach work was highlighted.

Action Item: Judy Shaw is to discuss with Dale Phenicie whether some arrangement can be made with the specific manufacturers of the pesticides of concern to provide an estimate of the quantity of HCB applied, based on actual HCB content levels rather than on maximum permitted EPA limits.

3.0 B(a)P Emissions from Petroleum Refineries (Catalytic Cracking Units)
Bob Elvert outlined the overall concerns that the American Petroleum Institute and the Canadian Petroleum Products Institute have regarding B(a)P release data being used by the GLBTS, since it grossly overestimates releases from the petroleum sector. Bill Simon presented information on the number of fluid catalytic cracking units (FCCUs) in U.S. and Ontario, type of controls used, and details on the various emission factors. Bill pointed out that, rather than the 60,000 lbs/year being reported, their calculations indicate the U.S. B(a)P release ranges from 0.1 to 4.0 lbs/yr (for FCCUs), while the Ontario release is a maximum of 4.0 lbs/yr (includes all point sources). Bill also mentioned that the refinery MACT II, expected to be finalized during the 1st quarter of 2002, meets New Source Performance Standards for CO (500 ppm) and PM.

Bob Elvert summed up the presentation with the following conclusions: 

Action Item: It was agreed that the B(a)P/HCB Workgroup will review the release information provided and make a recommendation to the Great Lakes Inventory Group on the appropriate FCCU BaP emission factorfor refineries.

4.0 Chemical Manufacturing HCB Emissions
Joe Stearns noted that major HCB sources such as India and China have agreed by convention (United Nations Economic Commission for Europe Convention on Long-range Transboundary Air Pollution) to cut back on persistent organic pollutants, and that these countries should have POP inventories not long after the convention is signed.

Steve Risotto reported that GC testing of wastes from a chlorinated solvent manufacturing operation found some 22 lbs/yr of HCB, all of which is captured and incinerated. At this particular facility, plant staff believe HCB is not released in the wastewater or to the air.

5.0 Wood Stove Change-out Update
John Crouch reported that the final report on the "Great Stove and Fireplace Changeout Program" held in Illinois, Indiana, Iowa, Kansas, Michigan, Minnesota, Nebraska, New York, North Dakota, Ohio, South Dakota and Wisconsin from February 1 to April 30, 2001, should be completed within the next 10 days. John is pleased with the program which has introduced many to the residential wood combustion issue and has resulted in 1300 old wood stoves/fireplaces replaced with EPA certified stoves, or with pellet or gas appliances.

Possible future changeout activities - Minnesota and Wisconsin is intending to apply for a GLNPO grant in 2003, and the Canadian group is considering further changeout programs in Ontario.

6.0 Data Gaps
The B(a)P/HCB Workgroup recognizes the need for more accurate release numbers, and the need to fill data gaps, and where possible will be working towards updating both the HCB and B(a)P inventories.

Meeting handouts: 

  1. Overheads used for reporting on the B(a)P/HCB Challenge at the GLBTS forum meeting on November 14, 2001 (Steve Rosenthal) 
  2. Table - "Estimated HCB Content of Pesticide Applications & Estimated Ultimate Air Emissions" (Dave Macarus) 
  3. Presentation: B(a)P Emissions: Petroleum Refineries (Bill Simon/Bob Elvert)

Participant's Rooster

Name

Telephone

E-Mail
Dave Macarus   Macarus.David@epamail.epa.gov
Steve Rosenthal (312) 886-6052 Rosentahl.Steven@epamail.epa.gov
Joe Stearns (703) 741-5815 Joseph_Stearns@americanchemistry.com
Bob Bailey (989) 835-3410 Bob.Bailey@tm.net
Steve Risotto (202) 775-0232 Srisotto@hsia.org
Darryl Hogg (416) 483-6563 hoggrd@home.com
John Crouch  (916) 536-2390 crouch@hearthassociation.org'12'12
Dale Phenicie  (770) 487-7585 DKPhenicie@mindspring.com
Bob Elvert  (815) 521-7580 Robert.S.Elvert@exxonmobil.com
Brad May  (416) 739-5835 bradley.may@ec.gc.ca
Jim Downes  (314) 674-2918 jefown@solutia.com
Bill Simon  (815) 521-7749 bill.c.simon@exxonmobil.com
David C. Ailor  (202) 452-1140 Dailor@accci.org
Judy Shaw  (519) 837-5328 judy.shaw@syngenta.com
Tom Tseng (416) 739-5853 Tom.Tseng@ec.gc.ca

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