So you want to use the National Pollutant Inventory to know and compare heavy metal emissions by source?

1. So you want to use the National Pollutant Inventory to know and compare heavy metal emissions by source? Good luck with that!

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

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. 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. 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. 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 1 April 2010 [Reporting List - Priority Order www.npi.gov.au/publications/tap/pubs/npi-tap-report.pdf] Page 59

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. ATSDR’s eight top priority hazardous substances

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 1 April 2010 [Reporting List - Priority Orderwww.npi.gov.au/publications/tap/pubs/npi-tap-report.pdf] Page 59

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/substances/oxides-nitrogen/index.html • Rank 2: Chromium (VI) compoundshttp://www.npi.gov.au/substances/chromium-vi/index.html • Rank 3: Carbon monoxide http://www.npi.gov.au/substances/carbon-monoxide/index.html • Rank 4: Sulfur dioxide http://www.npi.gov.au/substances/sulfur-dioxide/index.html • Rank 5: Dichloromethane http://www.npi.gov.au/substances/dichloromethane/index.html • Rank 6: Cadmium and compounds http://www.npi.gov.au/substances/cadmium/index.html • Rank 7: Particulate matter http://www.npi.gov.au/substances/particulate-matter/index.html • Rank 8: Sulfuric acid http://www.npi.gov.au/substances/sulfuric-acid/index.html • Rank 9: Xylenes http://www.npi.gov.au/substances/xylenes/index.html • Rank 10: Arsenic compounds http://www.npi.gov.au/substances/arsenic/index.html • Rank 11: Lead compoundshttp://www.npi.gov.au/substances/lead/index.html

11. Comparison of Priority on CERCLA list to RANK IF ranked by NPI for perceived risk

12. Comparison of RANK by NPI for Perceived Risk, to Priority on CERCLA list

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. 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. 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. 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. 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. 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. 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. 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. 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.pdfAlso see page 16 of www.xstrata.com/assets/pdf/xcu_sus_%20nqld_2006.en.pdf]

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. 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. 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. 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/publications/emission-estimation-technique/pubs/ffugitive.pdf

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/publications/pubs/transfers-information.pdf

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/npi/review/index.html

28. Emission Estimation Technique Manual for Aggregated Emissions From Architectural Surface Coatings Version 1.124 March 2003 http://www.npi.gov.au/publications/aedmanuals/pubs/archcoat.pdf

29. Correct title when you consider the content: VOCEmission Estimation Technique Manual ForAggregated Emissions From Architectural Surface Coatings Sold in the Report Period

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. 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. 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://enhealth.nphp.gov.au/council/pubs/pdf/paint.pdf

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. 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