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So you want to use the National Pollutant Inventory to know and compare heavy So you want to use the National Pollutant Inventory to know and compare heavy metal emissions by source? Good luck with that! Download Power. Point Presentation NPI Heavy Metals Emissions Problems Download Notes for presentation NPIheavymetals. htm 23 May 2008 1

NPI Heavy Metals Emissions Data Problems and Suggested Strategies for Solutions 23 May 2008 NPI Heavy Metals Emissions Data Problems and Suggested Strategies for Solutions 23 May 2008 2

Acknowledgements: • Written by Elizabeth O'Brien, Manager, Global Lead Advice & Support Service (GLASS) Acknowledgements: • Written by Elizabeth O'Brien, Manager, Global Lead Advice & Support Service (GLASS) run by The LEAD Group Inc. • Presentation prepared by Orlando Aguirre. Lopez, Volunteer, GLASS • Thanks to Alex Taylor, NPI, for the invitation. 23 May 2008 3

ABSTRACT • How the NPI process fails to estimate numerous sources of emissions, or ABSTRACT • How the NPI process fails to estimate numerous sources of emissions, or to estimate accurately or fairly those it does report on. • Using “perceived risk” in order to rank the 90 NPI substances will be compared to using environmental health information to prioritise hazardous substances. 23 May 2008 4

Comments Received by • 90 kgs of mercury is emitted in Australia per annum Comments Received by • 90 kgs of mercury is emitted in Australia per annum according to the NPI. • UN says: It is 90 tonnes just from Australia’s coal power plants, in 1995. 23 May 2008 5

More Problems CEILING DUST REMOVAL COMPANY OWNER: “We have a broken link on our More Problems CEILING DUST REMOVAL COMPANY OWNER: “We have a broken link on our dust removal site because NPI has changed the webpage address and I can’t find the statement: ‘Lead and compounds was ranked as 11 out of 400 [substances considered for inclusion on the NPI reporting list]. “ Update 24 March 2015 [Reporting List - Priority Order] www. npi. gov. au/system/files/resources/9 d 7 e 8 b 40 -863 c-8 be 4 -5502 -c 3 b 643 bcf 5 ce/files/npi-tap-report. pdf Page 59 23 May 2008 6

NPI Web page : “Rank 11 of 90 substances” • I advised: the Agency NPI Web page : “Rank 11 of 90 substances” • I advised: the Agency for Toxic Substances & Disease Registry (ATSDR) in the US had in 1995 determined lead to be the top priority substance in public health terms so why not link to the ATSDR website instead? • CERCLA (developed under the Comprehensive Environmental Response, Compensation and Liability Act) Priority List of Hazardous Substances places 4 heavy metals (all of which are found in ceiling dust) in the top 7 of 275 ranked priority toxic substances. 23 May 2008 7

ATSDR’s eight top priority hazardous substances 2007 Rank SUBSTANCE NAME Total Points 2005 Rank ATSDR’s eight top priority hazardous substances 2007 Rank SUBSTANCE NAME Total Points 2005 Rank 1 Arsenic 1672. 58 1 2 Lead 1534. 07 2 3 Mercury 1504. 69 3 4 Vinyl Chloride 1387. 75 4 5 Polychlorinated Biphenyls 1365. 78 5 6 Benzene 1355. 96 6 7 Cadmium 1324. 22 8 8 Polycyclic Aromatic Hydrocarbons 1368. 98 7 23 May 2008 8

Why the difference in ranking? • Reason given by NPI Site: “rank 1 being Why the difference in ranking? • Reason given by NPI Site: “rank 1 being highest perceived risk”. • It seems that the NPI rankings do not appear in one list… • Update 24 March 2015 [Reporting List - Priority Order http: //www. npi. gov. au/system/files/resources/9 d 7 e 8 b 40 -863 c-8 be 4 -5502 -c 3 b 643 bcf 5 ce/files/npi-tap-report. pdf Page 59] 23 May 2008 9

List of 10 NPI substances that are perceived to be of higher risk than List of 10 NPI substances that are perceived to be of higher risk than lead • Rank 1: Oxides of nitrogen http: //www. npi. gov. au/resource/oxides-nitrogen-0 • Rank 2: Chromium (VI) compounds http: //www. npi. gov. au/resource/chromium-vicompounds • • Rank 3: Carbon monoxide http: //www. npi. gov. au/resource/carbon-monoxide-0 Rank 4: Sulfur dioxide http: //www. npi. gov. au/resource/sulfur-dioxide Rank 5: Dichloromethane http: //www. npi. gov. au/resource/dichloromethane Rank 6: Cadmium and compounds http: //www. npi. gov. au/resource/cadmium-and • • Rank 7: Particulate matter http: //www. npi. gov. au/resource/particulate-matter-pm 10 -and-pm 25 Rank 8: Sulfuric acid http: //www. npi. gov. au/resource/sulfuric-acid Rank 9: Xylenes http: //www. npi. gov. au/resource/xylenes-individual-or-mixed-isomers Rank 10: Arsenic compounds http: //www. npi. gov. au/resource/arsenic-and-compounds- -compounds 0 • Rank 11: Lead compounds http: //www. npi. gov. au/resource/lead-compounds 23 May 2008 10

Comparison of Priority on CERCLA list to RANK IF ranked by NPI for perceived Comparison of Priority on CERCLA list to RANK IF ranked by NPI for perceived risk ATSDR Priority CERCLA Priority list of hazardous substances NPI Rank 1 ARSENIC 10 2 LEAD 11 3 MERCURY 35 4 VINYL CHLORIDE 65 5 POLYCHLORINATED BIPHENYLS Unranked 6 BENZENE 14 7 CADMIUM 6 8 POLYCYCLIC AROMATIC HYDROCARBONS 18 9 BENZO(A)PYRENE 18 10 BENZO(B)FLUORANTHENE 18 11 CHLOROFORM 66 23 May 2008 11

 Comparison of RANK by NPI for Perceived Risk, to Priority on CERCLA list Comparison of RANK by NPI for Perceived Risk, to Priority on CERCLA list ATSDR Priority Hazardous substances from NPI and CERCLA Priority list NPI Rank Not prioritised Oxides of nitrogen 1 18 Chromium (VI) compounds 2 189 Carbon monoxide 3 Not prioritised Sulfur dioxide 4 Not prioritised Dichloromethane 5 7 Cadmium and compounds 6 Not prioritised Particulate matter 7 Not prioritised Sulfuric acid 8 58 Xylenes 9 1 Arsenic compounds 10 2 Lead compounds 11 23 May 2008 12

Research for an interview for ABC’s Stateline Queensland the most recent NPI data is Research for an interview for ABC’s Stateline Queensland the most recent NPI data is for the period 1 st July 2005 to 30 th June 2006 [and that covers the first 9 months of Esperance Port Authority shipping lead ore] and the: • Port Authority scored 1 for lead (designated "low"). • Mt Isa Mines on the other hand scored 100 (the highest score possible) for lead (and for Zn, Sb, As, Cu, Cd and SO 2) emissions to air. 23 May 2008 13

Research for an interview for ABC’s Stateline Queensland [continued] • Magellan mine scored 8 Research for an interview for ABC’s Stateline Queensland [continued] • Magellan mine scored 8 (low) for lead to air • Perilya mine scored 1 (low) and • Pt Pirie smelter scored 21 (low). 23 May 2008 14

Question asked of Dept of Environment & Water Resources: • can you please advise Question asked of Dept of Environment & Water Resources: • can you please advise me why the lead emissions data from Mt Isa scores 100 when all the other Pb mines & smelters I had time to check eg Esperance where 9, 000 birds died of LEAD POISONING, is 1, or <22? 23 May 2008 15

The Answer: • The Answer: • "For Mt Isa Mines, the estimated emissions to air have doubled over the last 3 yrs and the measured emissions to water have doubled over the last 3 yrs and we have no information on whether that is due to some change in processing or increase in production but the mine has submitted the data to Qld EPA and EPA would have questioned it if they thought the data needed to be questioned… 23 May 2008 16

Answer [continued] • “It is not compulsory for the facility to report any emission Answer [continued] • “It is not compulsory for the facility to report any emission reduction efforts that they have made. MIM has not reported any emission reduction efforts that they may have made. " 23 May 2008 17

The “hidden answer” • NPI just web-publishes the data in a database, the company The “hidden answer” • NPI just web-publishes the data in a database, the company is responsible for either measuring or estimating it and then supplying it and the state environment authority is responsible for vetting it. 23 May 2008 18

The Question was put to Qld EPA Comment from the media person in Qld The Question was put to Qld EPA Comment from the media person in Qld EPA: "In validating the data Qld EPA basically only checks it against the earlier years' data. I don't think that they check it against data from similar facilities in other states. " 23 May 2008 19

A question for Xstrata • Why are you not decrying the NPI process if A question for Xstrata • Why are you not decrying the NPI process if it unfairly makes you out to be the top polluter? • Comment made by Darren Nelson, ABC Radio Reporter in Mt Isa: “I interviewed a guy from Xstrata who said yes we have the highest emissions & NPI is accurate. It got a run all round Australia including in Resources News WA. ” 23 May 2008 20

A notion put forward in Xstrata’s 2006 sustainability report “The recent results reported by A notion put forward in Xstrata’s 2006 sustainability report “The recent results reported by Xstrata’s Mount Isa Mines in the National Pollutant Inventory (NPI) database are only estimations of emissions generated on site, and they do not relate to exposure in the community. ” [Source: http: //web. archive. org/web/20091005090640/https: //www. xstrata. com/media/news/2008/04/11/13 47 CET/200804110801. en. pdf Also see page 16 of http: //web. archive. org/web/20091004102503/https: //www. xstrata. com/assets/pdf/xcu_sus_%20 nql d_2006. en. pdf] 23 May 2008 21

A Question raised to NPI during the Mining Sustainability conference in 2005 to NPI A Question raised to NPI during the Mining Sustainability conference in 2005 to NPI • I can find online, statements like: “one ounce of gold - creates up to 30 tons of toxic waste” Ref: http: //www. oursouthwest. com/low-waste/ • Can you please provide data on the tonnage of waste produced by lead mining, smelting & recycling companies? 23 May 2008 22

FIRST PART OF THE ANSWER: • In general, the NPI does not provide direct FIRST PART OF THE ANSWER: • In general, the NPI does not provide direct measurements of emissions. • Facilities required to report are allowed to provide data that has been calculated from: - Direct measurement; - Mass balance - Emission factors, or - Fuel analysis 23 May 2008 23

Second part of the answer • “Whilst mass balance is probably the most accurate Second part of the answer • “Whilst mass balance is probably the most accurate way to measure emissions, it is also complex and hence expensive. Some of the facilities that you are interested in may have used a mass balance measurement, but the NPI does not record the method used. You can find out the method employed by contacting each facilities 'public contact' officer, whose contact details will appear on the facilities data sheet”. 23 May 2008 24

Third part of the answer • NPI: Fugitive emissions can be defined as releases Third part of the answer • NPI: Fugitive emissions can be defined as releases not confined to a stack, duct or vent. These emissions generally include equipment leaks, emissions from the bulk handling or processing of raw materials, windblown dust and a number of other specific industrial processes. http: //www. npi. gov. au/system/files/resources/c 6 afec 68 -468 c-d 994 -41 d 7 -bcd 8 c 8 b 1 bcbe/files/ffugitive. pdf 23 May 2008 25

Third part of the answer [continued] • NPI: A transfer is when an NPI Third part of the answer [continued] • NPI: A transfer is when an NPI substance is not emitted directly to the environment but instead goes into landfill, sewers or tailings dams. If the substance is removed from a facility for recycling, reprocessing or reuse it is also a transfer. Transfers are not currently included in the NPI but are being considered following a review of the current NPI NEPM. http: //www. npi. gov. au/system/files/resources/4 ab 3 f 3 da-1877 -4 a 14 -bd 4 e-1 ce 071 fd 40 de/files/transfers-information. pdf 23 May 2008 26

Third part of the answer [continued] • FOLLOWING THE JULY 2007 DECISION ON THE Third part of the answer [continued] • FOLLOWING THE JULY 2007 DECISION ON THE REVIEW OF NPI NEPM: NPI: reporting is mandatory only for those NPI substances destined for containment or destruction. Reporting of the transfer of NPI substances to a destination for reuse, recycling, reprocessing and other similar practices is to be voluntary. http: //www. npi. gov. au/system/files/resources/0 cc 8537 a-4 fbe-e 624 -45 ea-ef 4 d 63 f 22 d 67/files/npi-review 290405. pdf 23 May 2008 27

 Emission Estimation Technique Manual for Aggregated Emissions From Architectural Surface Coatings Version 1. Emission Estimation Technique Manual for Aggregated Emissions From Architectural Surface Coatings Version 1. 1 24 March 2003 • 23 May 2008 http: //www. npi. gov. au/system/files/resources/253 a 136 a-c 9 cd-4 c 54 -d 9 c 4 f 3 e 3 fe 70 a 42 b/files/archcoat. pdf 28

 Correct title when you consider the content: VOC Emission Estimation Technique Manual For Correct title when you consider the content: VOC Emission Estimation Technique Manual For Aggregated Emissions From Architectural Surface Coatings Sold in the Report Period 23 May 2008 29

Omitted emissions include those from: • new coatings emitted to water (when cleaning brushes Omitted emissions include those from: • new coatings emitted to water (when cleaning brushes etc) • old coatings emitted to land, air and water if stripped or scraped or sanded prior to repainting • old coatings which flake off or chalk off due to weathering, and are emitted to land, air and water 23 May 2008 30

EXTRACTS from NPI Emission Estimation Technique Manual for Fugitive Emissions, December 1999 3. 12 EXTRACTS from NPI Emission Estimation Technique Manual for Fugitive Emissions, December 1999 3. 12 Surface Coating 3. 12. 1 Description: The preparation and coating of surfaces can result in the release of volatile organic compounds to the atmosphere. 3. 12. 3 Further Information: Fugitive emissions from equipment cleaning and solvent degreasing are suitably covered in other EET Manuals. No other EETs are therefore required. 23 May 2008 31

Paint Film Components - National Environmental Health Forum Monograph Paint Film Components - National Environmental Health Forum Monograph "Hundreds of kilograms of lead in paint are readily present on the walls of older houses. A 'typical' painting regime is outlined for a house built in 1900, having 280 m 2 of wall area that resulted in a paint lead loading value of 103 mg Pb/cm 2 such that the wall coatings would contain some 288 kg of lead. A worst case scenario indicated that some 364 to 644 kg of lead in paint on the walls is possible. " http: //www. health. vic. gov. au/archive 2014/nphp/enhealth/council/pubs/pdf/paint. pdf 23 May 2008 32

 Suggestions for improvements to the NPI state process and website: • report on Suggestions for improvements to the NPI state process and website: • report on examples of Cleaner Production or Waste Minimisation by Industry or Business or Government. • tell industry how they most need to lift their game • show time trends in for instance, emissions from home combustion heaters or architectural surface coatings emissions • trends in lead and other heavy metal emissions should be specifically commented on every year in the State Summary Report 23 May 2008 33

Suggestions for federal NPI process and website: • the new transfer info must be Suggestions for federal NPI process and website: • the new transfer info must be mandatory, not voluntary • the basis of prioritising must be made relevant & clear & priorities listed in one place & reviewed • industry must provide accurate mass balance data on all their releases • NPI estimation manuals must include all emissions • NPI must provide capacity-building to enable people to actually use the data 23 May 2008 34