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- and Suggested Strategies for
Solutions
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- 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.
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- 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.
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- 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.
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- 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].’“
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- 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.
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- Reason given by NPI Site: “rank 1 being highest perceived risk”.
- It seems that the NPI rankings do not appear in one list…
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- Rank 1: Oxides of nitrogen
- Rank 2: Chromium (VI) compounds
- Rank 3: Carbon monoxide
- Rank 4: Sulfur dioxide
- Rank 5: Dichloromethane
- Rank 6: Cadmium and compounds
- Rank 7: Particulate matter
- Rank 8: Sulfuric acid
- Rank 9: Xylenes
- Rank 10: Arsenic compounds
- Rank 11: Lead compounds
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- 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.
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- Magellan mine scored 8 (low) for lead
- to air
- Perilya mine scored 1 (low) and
- Pt Pirie smelter scored 21 (low).
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- 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?
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- "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…
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- “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."
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- 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.
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- 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."
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- 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.”
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- “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.”
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- I can find online, statements like: “one ounce of gold - creates up to
30 tons of toxic waste”
- Can you please provide data on the tonnage of waste produced by lead
mining, smelting & recycling companies?
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- 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
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- “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”.
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- 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.
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- 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.
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- 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.
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- Emission Estimation Technique Manual
-
for
- Aggregated
Emissions
- From Architectural Surface
Coatings
- Version
1.124
- March 2003
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- Correct title when you consider
the content:
- VOC Emission Estimation Technique
- Manual
- For Aggregated
Emissions
- From Architectural Surface
Coatings Sold in the Report
Period
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- 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
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- 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.
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- "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."
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- 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
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- 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
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