|Notes for NPI Heavy Metals Emissions Data Problems presentation 23 May 2008|
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So you want to use the NPI to know and compare heavy metal emissions by source? Good luck with that!
NPI Heavy Metals Emissions Data Problems and Suggested Strategies for Solutions
Written by Elizabeth
O’Brien, Manager, Global Lead Advice and Support Service (GLASS), run
by The LEAD Group Inc.
Elizabeth will present a community information service user’s findings on how the NPI process fails to estimate (at all) numerous sources of emissions to land, air and water of lead and other heavy metals, and on how it fails 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.
The Global Lead Advice and Support Service (GLASS) received the following comment from an inquirer in June 2007:
“The NPI states that 90 kgs of mercury was emitted in Australia per annum yet the United Nations estimates it is 90 tonnes just from Australia’s coal fired power plants in 1995. Peter Nelson [Professor of Environmental Studies, Macquarie University], says that's too high & NPI too low.”
(Update April 2010) In April 2007, one of the leaded ceiling dust removal companies from a referral list on The LEAD Group’s website rang to say:
“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 [Reporting List - Priority Order www.npi.gov.au/publications/tap/pubs/npi-tap-report.pdf page 59] [substances considered for inclusion on the NPI reporting list].’“ [Continued next slide]
After locating the new NPI webpage [ www.npi.gov.au/database/substance-info/profiles/50.html#comparisonto] which has since changed again to www.npi.gov.au/substances/lead/index.html and is now “Rank 11 of 90 substances”] I also advised him that 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? Their 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. Just to give you a feel for the rankings, uranium-235 is ranked at 107 and chrysotile asbestos is 119). [continued next slide]
This all led me to wonder why the difference in ranking and it seems to be given away by the following phrase from the NPI site “rank 1 being highest perceived risk”.
The NPI rankings do not appear in one list as far as I could tell, [(Update April 2010) Reporting List - Priority Order www.npi.gov.au/publications/tap/pubs/npi-tap-report.pdf page 59] nor are they always written with the same (easily searchable) phrase so it took me some two hours to assemble the following list of NPI substances that are perceived to be of higher risk than lead, and to (in the following slide) compare the top 11 ATSDR Priorities as to how they are ranked by NPI.
SLIDE 10 (Update April 2010)
NPI substances of highest perceived risk
Comparison of Priority on
CERCLA list to RANK
Comparison of RANK by NPI
In March 2007, a professor contacted GLASS and I provided the following information for an interview on 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:
So I put the question "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 birds died of Pb is 1, or < 22?" to the NPI at DEW who said I'd have to ask Michelle Parsons in Media Relations. [Continued next slide]
She responded after researching the answer for half an hour:
"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. [Continued next slide]
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." [Continued next slide]
When you read between the lines, you will see that the answer is "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." [Continued next slide]
So I said to Michelle, then I should probably call Qld EPA and she agreed that I should. So I did and despite both the technical people who report to NPI having gone home (at 4:30), I got the following out of the media person Jane Binstead:
"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."
I started to wonder why Xstrata was not decrying the NPI process if it unfairly makes them out to be the top polluter, when around the same time, Darren Nelson, ABC Radio Reporter in Mt Isa told me during a phone interview “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.”
However, an 11th April 2008 Xstrata media release repeats 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: www.xstrata.com/media/news/2008/04/11/1347CET/200804110801.en.pdf - Also see page 16 of www.xstrata.com/assets/pdf/xcu_sus_%20nqld_2006.en.pdf ]
You can find on various websites, statements such as “one ounce of gold - creates up to 30 tons of toxic waste.” [Ref: www.oursouthwest.com/low-waste/]
So, in preparing a slide presentation for the Mining Sustainability conference in 2005 I sent the following question to NPI:
QUESTION: Can you please provide data on the tonnage of waste produced by lead mining companies?
The next two slides give the answer which would have been so much work it stopped me from proceeding with covering the issue in my presentation.
ANSWER: “I am sorry but 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:
“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.”
According to the NPI website: “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.” [Ref: www.npi.gov.au/publications/emission-estimation-technique/pubs/ffugitive.pdf ]
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 [Ref: www.npi.gov.au/publications/pubs/transfers-information.pdf]
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. [Ref: www.npi.gov.au/npi/review/index.html]
Other omitted emissions only become obvious when you read such NPI documents as: Emission Estimation Technique Manual Aggregated Emissions from Architectural Surface Coatings, Version 1.1, 24 March 2003 [FRONT PAGE GRAPHIC FROM www.npi.gov.au/publications/aedmanuals/pubs/archcoat.pdf]
The document would more accurately be titled:
VOC Emission Estimation Technique Manual for Aggregated Emissions from Architectural Surface Coatings sold in the report period
Omitted emissions include those from:
EXTRACTS from NPI Emission Estimation Technique Manual for Fugitive Emissions, December 1999
3.12 Surface Coating
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.
By comparison, according to Mike van Alphen in "Paint Film Components - National Environmental Health Forum Monograph" http://enhealth.nphp.gov.au/council/pubs/pdf/paint.pdf
"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."
When I was asked in July 2006 to check out the South Australian NPI website and make comments that might help to produce a marketing plan for the NPI in that state, I made the following suggestions:
For instance, it would be excellent if you were able to report on examples of Cleaner Production or Waste Minimisation by Industry or Business or Government and report on how your marketing team managed to get an article in the news media telling South Australian industry how they most need to lift their game, and how householders or consumers can best change their habits to assist in making for a cleaner environment etc. You could have a section for the individual consumer which shows 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.
Regarding the federal NPI process and website, one of the most important things for improvement is to ensure the new transfer info must be mandatory, not voluntary. If the list is going to be prioritised, then the basis of the prioritising must be made clear and the resulting list of priority substances should be in one place and reviewed periodically. Ranking should be on the basis of environmental health risks, not perceived risks. Industries profiting from hazardous substances should be forced to provide accurate mass balance data on all their releases to the environment. NPI estimation manuals must include all emissions, not just fugitive or VOC emissions. NPI should provide far more publicity and training and capacity-building to enable people to actually use the data meaningfully.
IN CONCLUSION, I am totally in agreement with Erin Brockovich who says: “I am an advocate for awareness, the truth, and a person's right to know. I believe that in the absence of the truth, all of us stand helpless to defend ourselves, our families and our health, which is the greatest gift we have… I believe that people can accomplish anything if given the proper information.”
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