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RE: MDI Emissions
Chun,
Can you send me your MDI revisions so that I can revise the 2002 NEI?
We have a delisting petition for MDI and I had highlighted MN data as a
discrepancy with petitioner's data .
Has the GLC looked at spray on truck bed liners as a source of MDI in
their inventory? This is a new use of MDI and has not appeared in any
inventories yet. We think it may a significant source of emissions as a
lot of small shops do this kind of activity. CDC is concerned about
this new source of MDI as part of the petition, but we have no inventory
data.
There is also concern about sensitivity of individuals to MDI. Studies
from CDC/OSHA show increased sensitivity to individuals who live near
facilities releasing MDI and to workers who use MDI.
I would interested in receiving any info you may have re health studies
on MDI or inventory data for spray on truck bed liners.
I hope your are doing well. I wish our cold blast this week would go
back up to your area -- so our temps would return to the high
sixties/low seventies as they usually are.
Are you coming to the STAPPA/ALAPCO Air Toxics Workshop in December of
this year? GLC may be interested in hearing about Residual Risk
Technology Rule and use of NEI data for individual facility risk
assessments that we have conducted. I will be giving presentation and
demo at the workshop of review data base that will be published in FR in
late November/early December of this year. Several of the categories
included in the rule have facilities in the GLC area.
anne
"Wu, Chun Yi"
<Chun.Yi.Wu@stat
e.mn.us> To
Sent by: dettling@glc.org, "Wu, Chun Yi"
owner-airtoxics@ <Chun.Yi.Wu@state.mn.us>
great-lakes.net cc
Airtoxics
<airtoxics@great-lakes.net>
10/18/2006 01:03 Subject
PM RE: MDI Emissions
Jon,
Thanks for the data extraction. Looking at the spreadsheet, I found
facilities with more than 3000 lbs of MDI emissions in the region were
in WI and ID. I guess these emission values were reported by facilities
and seem not right.
I have contacted with about 70 facilities and provided them information
on MDI calculation. Two facilities obtained direct help from the
Regulatory Compliance Assistance Program (RCAP), Alliance for the
Polyurethanes Industry (API). As a result of this effort, the 2002 MN
state point source MDI emissions dropped from 19.81 tons to 2.93 tons
while the emitting sources increased from 20 to 51. I also did the
QA/QC for 2005 MDI emissions at the same time.
I think at least we need to have QA/QC for the 9 facilities with MDI
emissions more than 3000 lbs either by respective states or by the
Regulatory Compliance Assistance Program (RCAP).
Chun Yi
-----Original Message-----
From: Jon Dettling [mailto:dettling@glc.org]
Sent: Monday, October 16, 2006 8:41 AM
To: 'Wu, Chun Yi'
Cc: 'Airtoxics'
Subject: MDI Emissions
Chun Yi,
You raised the issue of MDI emissions at the Toronto meeting and passed
out
an article describing efforts done at the national level to correct what
were believed to be substantial overestimates of these emissions in the
NEI.
I've taken a look at the article and have done a query on our 2002 data
(attached) to see what our emissions look like. There are about 50
sources
in the inventory with emissions of more than 100 lbs, including a
handful
with emissions of several to 100 tons. In addition, there are about 100
more
sources with emissions of 10-100 lbs. The information in the article
suggests that the sources of more than 100 lbs. are almost certainly
over-estimates and those of 10-100 lbs. may be overestimates also in
many
cases.
The issue was raised at the meeting of how relevant this pollutant is to
address, especially regarding deposition to the Great Lakes. Using the
PBT
Profiler (www.pbtprofiler.net), it appears that the compound in
moderately
persistent and moderately bioaccumulative. It shows a tendency to
partition
to soils and sediments, where it has a half-life as high as about a
year. As
HAPS go, it appears to be in the mid-range between those that are very
relevant for deposition to the Great Lakes (e.g., dioxins) and those
that
aren't (e.g., benzene).
I think given the clear evidence presented that our emission for this
compound are likely much too high, it may be worthwhile to attempt to
correct some of those emissions if it is feasible to do so. In
particular,
there appear to be some "low hanging fruit" for which applying
corrections
would significantly decrease (and presumably make more accurate) the
total
regional emissions.
We've often encountered difficulty in correcting facility emissions and
it's
difficult to make these corrections permanent, as facilities will often
re-report the high numbers each year. The article you passed out
mentions a
"worksheet" tool that can be used to estimate emissions, however I can't
find this on the EPA's website that is referenced. Do you have any
recommendations as to how to go about examining our data further and
possibly making corrections or about how to incorporate this information
into future years' inventories?
We can discuss this as a group on Wednesday's call and see what the
thoughts
are from the rest of the team. Can you scan the article you have and
send an
electronic version for anyone who wasn't at the meeting? I could scan
mine,
but most of the tables are very dark and hardly legible in my version
already.
regards, Jon
______________________
Jon Dettling
Great Lakes Commission
734-971-9135
dettling@glc.org
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