LEED TSAC PVC Study Database > Outreach Forum > TRI
TRI
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Information request:
Plant-level dioxin emissions are available in EPA TRI. One way of estimating dioxin emission factors for PVC is to use the TRI data along with the annual production of EDC/VCM/PVC. Several facilities produce chlorine/EDC/VCM and some produce PVC in addition. However, some plants produce chemicals (e.g., chlorine) to serve as an input to other plants while others produce other chlorine-based chemicals than EDC/VCM/PVC, in both cases leading to additional dioxin emissions outside of EDC/VCM/PVC production activities.
(1) Selection of relevant PVC plants Based on the national production of chlorine, EDC and VCM, the mass balance ratio for production of Cl: EDC: VCM: PVC was estimated to be 1: 3: 1.7: 1.5. Based on these ratios and individual plant production capacity, three plants were selected as those potentially producing only the chemicals that would be used for EDC/VCM/PVC, without extra purchase from or sales to external facilities. The selected plants were Georgia Gulf (Plaquemine, LA), OxyVinyls (Deer Park, TX) and OxyVinyls (La Porte, TX). These plants account for 24% of the total EDC production capacity for the US. Based on the average US EDC generation rate of 89% (i.e., relative to the capacity. see “US total production” tab), the production level of EDC at these plants was estimated to be 1,009,723, 848,167 and 1,575,168 tonnes, respectively. Note that we assume that dioxin emissions are solely related to Cl/EDC/VCM production.
(2) Preliminary dioxin emission factors calculation Next, TRI 2002 data (TRI explorer, facility emissions) was used to extract the dioxin emissions to air, water and land from these three plants (see tabs 2002TRI GG 70764, 2002TRI oxyvinyl 77536 and 2002TRI oxyvinyl 77571). Using the dioxin speciation information along with WHO’s toxicity equivalency factors (TEFs), annual dioxin emissions in TEQ g were estimated.
Based on (1) and (2), as well as the estimated production level at each plant, the average dioxin emission factors for air, water and land are: 0.37, 0.06 and 52.78 TEQ ug/tonne EDC, respectively. Note that these high values are largely driven by OxyVinyls (La Porte, TX), which reports 181g of dioxin transferred to landfills in 2002.
TG looks for insights from the stakeholders about the above calculation of dioxin emission factors as well as the elevated release of dioxins to landfills from EDC manufactures.
Citation of information sources is required. If it is possible to email PDFs of original source documents, this is encouraged and we will post the original source documents on this web page for others to download. Please email source document PDFs to tsac@greenriver.org.
Stakeholder Submissions
First of all, while the question raises issues associated with landfills, The Vinyl Institute (VI) wishes to reiterate that the emissions of greatest relevance are those to the open environment. While the Toxics Release Inventory (TRI) includes dioxin sent to hazardous waste and other landfills, EPA’s Dioxin Sources Inventory focuses on releases to the circulating environment (Air, Water, land SURFACE). Dioxin placed in landfills is not considered in the Sources Inventory. According to US EPA "Properly designed and operated landfills are considered to achieve long-term isolation from the circulating environment (The Inventory of Sources and Environmental Releases of Dioxin-Like Compounds in the United States: The Year 2000 Update (External Review Draft, March 2005; EPA/600/p-03/002A) http://www.epa.gov/ncea/pdfs/dioxin/2k-update/."
While stipulating that releases to the open environment are the relevant releases to be considered, VI also notes that those streams also constitute the richest data set. Little if any comparable solid waste disposal data is available for processes associated with alternative materials being considered by the Task Group, thus complicating rather than simplifying risk assessment and LCA comparisons of vinyl to alternative materials. VI respectfully suggests that comparison of streams emitted to the circulating environment should be the streams of choice for this analysis.
With that said, and without conceding the advisability of including them, the VI will attempt to answer the question asked regarding solid waste. The question correctly notes that many of the plants manufacturing EDC and VCM also manufacture other chlorinated organics. It is difficult if not impossible to separately analyze emissions from those different processes. For this reason, VI understands that the questioner chooses to narrow the number of plants examined to a set that manufactures only EDC and VCM.
While in one sense this is logically sound, in another it introduces another source of error. Technologies used in the manufacture of EDC and VCM as well as technologies for isolation and destruction of side products differ significantly among facilities. Reducing the number of plants has the effect of isolating a given technology rather than identifying emission factors that could be generalized.
The spreadsheet shown in the comment is apparently intended to include material deposited in landfills for consideration. It contains a number of errors.
In sheet 2002TRI GG 70764, cell D17 apparently wants to reflect the amount of material deposited in landfills. It refers to cell S4, which is “Storage Only.” It should apparently refer to cell R4. Cell E17 refers to cell AF4, which is unlabeled, and I am unsure of the intent of the authors. Perhaps by analogy with sheet 2002TRI OXYVINY 77571 it is intended to refer to cell AC4, a subtotal of other disposal methods. The difficulty arises because the three spreadsheets are set up differently.
Additionally, the questioner includes only material that is landfilled offsite. At least one facility landfills onsite, although not on land surface.
In the spirit of answering the question asked, the VI has calculated emissions to air, water and solids for all the facilities manufacturing EDC. The result of this analysis, for years 2002 and 2003 is shown in the spreadsheets which will be posted. All data has been obtained from EPA’s TRI Explorer, available on the EPA website (http://www.epa.gov).
EDC capacity data shown is obtained from CMAI. No attempt is made to normalize for actual production, however, that capacity utilization varies between about 85 and 90% and does not constitute a significant difference.
Emissions are shown in WHOTEQ; while EPA does not calculate this quantity on its website a reasonable reconstruction can be obtained from the data available on the EPA website. This is the basic methodology used by the questioner. Other TEQ data can be obtained from the Chlorine Chemistry Council (CCC) at http://www.trifacts.org.
It should be noted that only one congener distribution is submitted for each plant. Different streams may have somewhat different congener distributions, which can make significant difference in the TEQ calculation. In fact, the TEQ values shown on the CCC website differ slightly from those obtained from our calculation. This is because companies submitting data to the CCC website have used the congener pattern obtained from analysis of each stream to determine the emissions to attribute to that stream rather than one distribution for the entire facility. This method is probably more precise, but the values are not unreasonably different.
Although we are including all the EDC plants, we recognize that the analysis is complicated by other processes in operation in these plants. We have included them for robustness against an individual technology; moreover, including them constitutes a conservative case, since some CDD/CDF from those processes may be mistakenly included with that from EDC and VCM. Emissions will be over- rather than under-estimated.
Some corrections to EPA data should be noted. There are two plants misnamed in the TRI and one plant that misreported its distribution. Two plants are given the name “OxyVinyls LaPorte VCM”. The first, in fact, refers to the LaPorte VCM plant. The second plant is a chloralkali facility co-located at the same site. Two plants are given the name Deer Park Chloralkali. The more emissive of the two is, in fact, the chloralkali facility. The other plant is the PVC polymerization facility, which is co-located. Finally, the Deer Park Chloralkali plant misreported its congener distribution for 2003 by submitting the congeners in IUPAC chemical order rather than EPA’s proprietary order. These calculations use the correct distribution.
From the calculations as described, air emission values are about 0.22 ug WHO98TEQ/tonne EDC capacity in 2002. This emission falls by a factor of 3 to about 0.07 in 2003 due to significant reductions in air emissions.
Water emission values are approximately 0.39 ug WHO98TEQ/tonne EDC capacity in 2002. This emission falls by about a factor of 2 in 2003 to about 0.19 ug WHO98TEQ/tonne EDC capacity, again because of significant emission reductions.
Solids emissions are distinctly skewed by one facility. Utilizing all plants, emissions to landfills and other are about 18ug WHO98TEQ/tonne EDC capacity in 2002. If the outlier plant is not included, that emission falls to about 8 ug WHO98TEQ/tonne EDC capacity. In 2003 the result is a bit lower (17 and 6.5).
In conclusion, the best emission factors for CDD and CDF from EDC facilities in the US is consistent with, and in many cases lower than those previously reported, and significantly lower than the emission factor for solids reported by the questioner.
We appreciate the opportunity to communicate with the Task Group. Unfortunately our ability to respond fully to this latest request is circumscribed by a number of issues.
First the timing of the request coincides with business and vacation travel of some of our key analysts (including myself) and so there has not been time to fully evaluate the requested information.
Second, we continue to have serious concerns at the effort being expended by the TG – and requested of us - in an effort to find numeric data to fill gaps in the LCA-RA model when fundamental questions remain unanswered about the appropriate manner to address the charge of the TG. It is frustrating to watch time passing and see resources being used to further develop this model when we have not yet agreed upon the question much less the scientific approach to answer it. It has recently come to our attention that BRE has published statements concurring with many of the concerns that we have raised about the reliance on LCA to address the concerns about PVC: “A particular problem with the debate surrounding PVC is that Life Cycle Assessment is often seen as a solution that will provide a definitive answer on the relative advantages and disadvantages of using PVC and alternative materials. In fact, the issues that caused the debate have often not been included within LCA (e.g., toxic releases, workforce exposure and fire hazards).” (Green Guide to Specification, 3rd Edition by Jane Anderson and David E Shiers, Building Research Establishment, 2002)
That said, we have made some preliminary comments specific to approaches outlined in the query. See our response to Dioxin EF for comments on some of the shortcomings of TRI as a data source for this type of analysis.