Mr. Miller, I believe you have talked at some length with Chun Yi Wu of the Minnesota PCA concerning the emissions of 4,4'-Methylenediphenyl diisocyanate (MDI). Chun Yi brought this issue to the attention of our Steering Committee for the Great Lakes Regional Toxic Air Emissions Inventory. This group is a collaboration among the air agencies of the eight Great Lakes states (IL, IN, MI, MN, NY, OH, PA, WI) and the Canadian province of Ontario. We discussed the issue among our group at a meeting last month and again on a recent conference call. In short, if the Alliance for the Polyurethanes Industry is willing to offer support, many member of the group are open to receiving input and assistance regarding their MDI emissions. In most cases, implementing changes will need to be achieved by contacting facilities directly and encouraging them, where appropriate, to correct their approach to calculating and reporting emissions. It makes sense to make several things clear up front in an effort to ensure that the expectations of everyone are accurately portrayed and reasonable: Based on the information in the EM article that Chun Yi provided to the group, we did a quick assessment of our regional data for 2002 and determined that there are many emissions sources that could potentially be over-estimating MDI emissions, at least in comparison to the information in the article. In weighing the relative importance of this issue relative to the many other items our group is in the process of addressing, it was generally considered that this is an item of moderate priority. My guess is that if left to the agency staff to fit into their schedules, substantial updates to the MDI emissions for our region would take place in a piecemeal fashion over an extended timeframe. For this to take place more quickly, work on data analysis/ compilation and contacting facilities would need to be borne substantially by API. Within our regional inventory, each jurisdiction is given complete control over the curation of the emissions data for their state. Changes to the data would therefore be decided and implemented on a state-by-state basis and changes to past years' facility-reported data can be difficult. Each state may have a different set of constraints that could prevent them from implementing changes that you might recommend. This could particularly come into play regarding past years data, where state policies might exist that make it difficult to modify the emissions data that has been submitted and validated by a facility. There may be other reasons for which a state or province may prefer to keep their existing data. I want to raise this issue upfront so as to ensure that we're not creating an expectation that recommended changes would necessarily be accepted in their entirely. If you are agreeable to it, the general approach I am recommending is for our group to provide you with whatever data from our inventory you would need to conduct an assessment on it. If based on that assessment you'd like to promote that certain changes be made, it would require either contacting the facilities in question and/or reporting your findings for our group to consider as to whether they'd like to make any suggested modifications. In addition to contacting facilities that may be over-reported, we would also be interested in identification and emission estimations for sources that aren't currently included in our inventory. As I mentioned before, it isn't possible to guarantee that all suggestions would be incorporated and we will defer to each state to make such determinations. We would also like to ensure up-front that as part of this activity an emphasis is put on future emissions inventory years and ensuring that adjustments that are made are done so in a way that can carry over easily to future years. I believe that with little exception, the MDI emissions in the inventory are attributed to facilities and are obtained by the states/province either directly from those facilities as part of a state reporting program or are obtained from TRI or a similar database. It is therefore likely that the originating facilities will need to be contacted in most cases. I've attached here an initial summary of the MDI data from our 2002 data repository. It gives a general overview of what the emission levels are and what sources are included. To do a thorough analysis, I imagine you may need a greater level of detail. If so, please let me know what data you need and I will work on pulling it out of the database for you. While 2002 is the latest year for which we have a full set of data to analyze, I want to reiterate that the primary concern of our group at this point is achieving the correct numbers for 2005 and beyond. When you've had a chance to review the above information, please let me know if you have an interest in working with our states and how you'd like to proceed. As I understand, you've already done a substantial amount of work with Minnesota's emissions data and there would be little or nothing left to address for that state. Sincerely, Jon Dettling ______________________ Jon Dettling Great Lakes Commission 734-971-9135 dettling@glc.org
Attachment:
MDI_Great Lakes.xls
Description: MS-Excel spreadsheet