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.
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].’“
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.
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.
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?
"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…
“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."
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.
"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."
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.”
“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.”
“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”.
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.
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.
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.
"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."