RE: Benzo(a)pyrene emissions from MI area sources

["Dennis McGeen" <MCGEENDD@michigan.gov>]

I can recall a recent discussion with AQD toxicology staff about the
mercury emission factor for crematoria, and it is possible the same
concern affects the benzo(a)pyrene factor.  Supposedly the test data for
EPA's mercury factor came from the crematory at Woodlawn, which is
unusual in that it is one of the very few crematoria equipped with
control devices, thereby making it unrepresentative of the category. 
However, from looking at the documentation for the base year 1999 NEI
inventory, other sources of test data were utilized besides Woodlawn. 
Benzo(a)pyrene wasn't one of the listed factors, so I don't know if it
came from the Woodlawn data or from one of the other sources.

>>> "Jon Dettling" <dettling@glc.org> 08/10/06 2:11 PM >>>
Dennis,

These are good questions. Regarding the data upload, I suggest we hang
onto
these until we have a final set of updates and then make the
modifications
to the repository all at once. I think this will simplify keeping track
of
what changes are made and which have been uploaded and which haven't.
Let's
make a folder on the FTP site for the import files.

Regarding records with zero emissions: this is probably something
worth
discussion with the group on our next call. For the current purposes,
as
long as you can let us know that this is the reason for the missing
records,
I think that's adequate. However, for future inventories, we may want
to ask
people to include zeros. This would save us some effort when looking at
the
data and trying to identify who is or isn't reporting certain sources.

For human crematoria, I also show that Illinois reported emissions for
both
31502101 and 31502102. Their emissions for 2102 were nearly 100lb,
which
falls into the range of being significant. Their and your estimates for
2102
were less than thousandths of pounds. If there is an issue with the
emission
factor, perhaps we should remove these emissions. If not, perhaps the
other
states should include them. Does anyone have a summary of what the
"issue"
is with the current emission factor?

For woodstoves, I think the way you've reported them is fine. It's
important
to include fireplaces as well. I believe the NEI guidance has separate
emission factors for 80001, 80002 and 80003. Ontario, Pennsylvania and
Wisconsin also did not report fireplaces. I know Orlando is still
waiting
for some clarification on the use of emission factors for fireplaces
without
inserts.


______________________
Jon Dettling
Great Lakes Commission
734-971-9135
dettling@glc.org 

-----Original Message-----
From: Dennis McGeen [mailto:MCGEENDD@michigan.gov] 
Sent: Thursday, August 10, 2006 1:30 PM
To: Cabrera-Rivera, Orlando
Cc: Buzz Asselmeier; dettling@glc.org 
Subject: Benzo(a)pyrene emissions from MI area sources

I have created the RAPIDS import files for B(a)P for area source fuel
combustion.  To whom should I send these?

I've created files for some of the area fuel combustion categories
where activity data was zero, or point source deductions were larger
than total estimated activity (residential and industrial combustion
of
distillate/residual oil).  Should I remove these files, or send them
to
document that no activity data was identified?

A couple of other questions:

Human crematoriums:  I presume I should refrain from estimating this
category since none of the other states did, and since there may be
problems with the emission factor.

For 2104008051, noncatalytic woodstoves: Michigan used 2104008001 and
2104008010 for reporting pollutants for residential woodburning. 
B(a)P
was reported under 2104008010 so I think that if I reported B(a)P
under
8051 it would duplicate what's under 8010.  However, I could estimate
B(a)P for 2104008001 using the factor 2.48e-03 lb/ton (borrowed from
the
SCC 2104008010), I believe that is the appropriate factor to use.

Dennis




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