NPI Heavy Metals Emissions Problems Presentation

Hakunana Matatan Speech

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

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

3. 23 May 2008 3
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.

4. 23 May 2008 4
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.

5. 23 May 2008 5
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.

6. 23 May 2008 6
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/9d7e8b40-863c-8be4-5502-c3b643bcf5ce/files/npi-tap-report.pdf Page 59

7. 23 May 2008 7
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.

8. 23 May 2008 8
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 Hydrocarbons1368.98 7

9. 23 May 2008 9
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/9d7e8b40-863c-8be4-5502-c3b643bcf5ce/files/npi-tap-report.pdf Page 59]

10. 23 May 2008 10
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-vi-compounds
•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-compounds
•Rank 7: Particulate matter http://www.npi.gov.au/resource/particulate-matter-pm10-and-pm25
•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-0
•Rank 11: Lead compounds http://www.npi.gov.au/resource/lead-compounds

11. 23 May 2008
11
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

12. 23 May 2008
12
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 prioritisedDichloromethane 5
7 Cadmium and compounds 6
Not prioritisedParticulate matter 7
Not prioritisedSulfuric acid 8
58 Xylenes 9
1 Arsenic compounds 10
2 Lead compounds 11

13. 23 May 2008 13
Research for an interview for ABC’s
Stateline Queensland
the most recent NPI data is for the period 1st July
2005 to 30th 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 SO2) emissions to air.

14. 23 May 2008 14
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).

15. 23 May 2008 15
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?

16. 23 May 2008 16
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…

17. 23 May 2008 17
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."

18. 23 May 2008 18
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.

19. 23 May 2008 19
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."

20. 23 May 2008 20
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.”

21. 23 May 2008 21
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
47CET/200804110801.en.pdf
Also see page 16 of http://web.archive.org/web/20091004102503/https://www.xstrata.com/
assets/pdf/xcu_sus_%20nqld_2006.en.pdf]

22. 23 May 2008 22
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. 23 May 2008 23
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

24. 23 May 2008 24
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”.

25. 23 May 2008 25
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/c6afec68-468c-d994-41d7-bcd8c8b1bcbe/files/ffugitive.pdf

26. 23 May 2008 26
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/4ab3f3da-1877-4a14-bd4e-1ce071fd40de/files/transfers-information.pdf

27. 23 May 2008 27
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/0cc8537a-4fbe-e624-45ea-ef4d63f22d67/files/npi-review290405.pdf

28. 23 May 2008 28


Emission Estimation Technique Manual
for
Aggregated Emissions
From Architectural Surface Coatings
Version 1.1
24 March 2003
•http://www.npi.gov.au/system/files/resources/253a136a-c9cd-4c54-d9c4-f3e3fe70a42b/files/
archcoat.pdf

29. 23 May 2008 29

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

30. 23 May 2008 30
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

31. 23 May 2008 31
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.

32. 23 May 2008 32
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
m2 of wall area that resulted in a paint lead loading value
of 103 mg Pb/cm2 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/archive2014/nphp/enhealth/council/pubs/pdf/paint.pdf

33. 23 May 2008 33
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

34. 23 May 2008 34
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