RE: Updated b(a)p report draft

["Jon Dettling" <dettling@glc.org>]

Orlando,

I think this is a great suggestion. It might help identify some additional
reasons for differences in the inventory values among states. I think it
might also help provide some information to our "audience" regarding what
actions are being taken by the states to reduce b(a)p emissions and what
other actions might be possible or recommended.

Perhaps we should come up with a short questionnaire for the states to
answer. Here are a few questions, are there others?

What is your states reporting threshold for b(a)p from point sources?

Does your state have any programs to control emissions from major b(a)p
sources? For example: 
	Fireplaces and woodstove (such as woodstove changeout programs)
	Open burning (such as bans or regulations on this activity)
	Any specific emission controls on petroleum refining or metal
production (e.g., something beyond MACT)
	Inspection and Maintenance programs for on-road vehicles

Does your state have legislation that prevents the agency from implementing
rules that go beyond federal standards? (a recent GOA report noted that 26
states have such legislation)

An additional issue that looking at these items raises is how the existence
of such programs is reflected in emission estimation. For example, in
MOBILE6, you can specify areas that use reformulated gasoline or that have
inspection and maintenance programs and these factors are taken into account
when producing the emission estimates. However, I think that type of
feedback between regulations and emissions inventory is rather rare. For
example, if several counties within a state have bans on open burning, is
that reflected in the emissions inventory? This isn't probably something we
want to spend a lot of time on in the report, but might be something worth
mentioning briefly.

Jon

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

-----Original Message-----
From: Cabrera-Rivera, Orlando
[mailto:Orlando.Cabrera-Rivera@dnr.state.wi.us] 
Sent: Monday, August 14, 2006 2:59 PM
To: dettling@glc.org; Airtoxics
Subject: RE: Updated b(a)p report draft

Hi Jon,

We could discuss the draft report on Wednesday's call. One suggestion is
to include a section assessing the current B(a)P regulatory/inventory
practices of the states/province. That is, do states/province regulate
B(a)P emissions? What are the reporting thresholds?, etc. This could
give us some insight into possible recommendations for improving the
inventory.  

Orlando

-----Original Message-----
From: owner-airtoxics@great-lakes.net
[mailto:owner-airtoxics@great-lakes.net] On Behalf Of Jon Dettling
Sent: Thursday, August 10, 2006 3:39 PM
To: 'Airtoxics'
Subject: Updated b(a)p report draft


Hi everyone,

An updated version of the b(a)p report is attached. The most significant
change is an improvement to the table of emissions by SCC. I've rolled
these emissions up by similar SCC codes and broken it into multiple
tables so that they are shown by category. This makes it much easier to
see the overall trend in the regional emissions as well as to identify
significant discrepancies or omissions. As a result, I've added some
additional questions to the individual state/province sections later on
in the report.

The major categories I think we need to address as a group are the
following:

Fireplaces and woodstoves: Table 3 shows that New York's emissions for
this category is high and Pennsylvania shows none. Several states shoe
emissions for woodstoves but not fireplaces. In all, this is likely to
be the largest source category once all the changes are made.

FCCUs: This version of the report contains a letter from 1999 suggesting
FCCU emissions, at least at one facility, are much lower that previous
estimates. WebFIRE shows two emission factors. One is controlled, the
other is not. The controlled factor is similar in magnitude to that
suggested in the letter. Can states with these sources investigate
whether their FCCUs are controlled and if the appropriate emission
factor has been used. This will have a very significant impact on the
final numbers.

Open burning: Table 6 shows that there is a lot of inconsistency as to
the reporting of b(a)p from these sources, with 3-4 states reporting
emissions from household waste burning, wildfires and prescribed burning
(but not the same 3-4 states for each category). If these were
calculated for all states, this category would have a much larger impact
on the overall numbers. This also applies to commercial cooking (see
table 16).

On-road vehicles: Minnesota has not included b(a)p from on-road

Non-road vehicles: Ohio's nonroad numbers are abnormally high for all
categories. A few states are not reporting emissions from commercial
marine vessels and/or railroads (see table 12) 

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

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