From:
<
bushman.
daniel@
epamail.
epa.
gov>
To:
Betsy
Bicknell
<
Betsy.
Bicknell@
erg.
com>
Date:
10/
15/
03
2:
52:
08
PM
Subject:
Re:
TRI­
reported
PACs
and
dioxin
and
dioxin­
related
compounds
Hi
Betsy,
In
response
to
your
questions:

How
reliable
are
the
reported
releases
of
dioxin
and
dioxin­
like
compounds
and
the
reported
releases
of
PACs?

A:
We
think
the
data
are
reliable
but
you
must
remember
that
under
TRI
facilities
are
only
required
to
report
a
reasonable
estimate
of
their
releases.

How
are
facilities
estimating
releases
for
these
compound
categories?

A:
Facilities
use
a
variety
of
methods
for
estimating
releases.
Some
have
site
specific
emission
factors,
others
use
generic
emission
factors,
and
some
use
monitoring
data.
Our
dioxin
and
PACs
guidance
documents
provide
generic
emission
factors
for
a
number
of
processes.
The
Form
R
captures
the
basis
of
the
estimate
using
4
codes
(
M,
C,
E,
and
O).
M
is
for
monitoring
data
or
measurements,
C
is
for
mass
balance
calculations,
E
is
for
published
emission
factors,
and
O
is
for
other
approaches
such
as
engineering
calculations
(
see
page
43
of
the
2002
TRI
Reporting
Forms
and
Instructions
for
more
information).
If
you
need
it,
a
search
could
be
done
to
see
how
many
facilities
used
each
of
these
various
methods
for
these
categories.

How
do
facilities
typically
handle
concentrations
reported
as
less
than
the
method
detection
limit
when
calculating
discharge
masses?
­­
or
when
estimating
dioxin
distributions?

A:
Our
general
guidance
is
that
if
you
know
the
chemical
is
present
but
its
below
the
detection
limit
then
you
should
use
one
half
the
detection
limit
in
you
estimations.
We
have
a
slightly
modified
approach
for
dioxin
which
I
have
attached
to
this
e­
mail
(
see
below).

What
do
you
see
as
the
shortcomings
of
EAD's
approach
to
prioritizing
categories
(
we
use
primary
SIC
code
to
define
category)?

A:
I
don't
know
enough
about
their
program
to
say
whether
or
not
there
are
any
shortcoming
to
their
approach
since
it
depends
on
what
they
want
to
accomplish.
We
specifically
added
the
primary
SIC
code
designation
to
the
Form
R
so
that
we
could
get
a
better
idea
of
what
the
main
activities
are
at
a
reporting
facility
since
many
facilities
report
more
than
one
SIC
code.

I
would
be
happy
to
talk
with
you
if
you
need
more
on
this.
I
am
in
Thursday
but
out
Friday.
Dan
From
the
TRI
dioxin
guidance
document:

Section
2.2.
Consideration
of
Non­
Detects
When
detected
in
emissions
and
effluents
from
facilities,
dioxin
and
dioxin­
like
compounds
are
found
in
minute
quantities,
e.
g.,
one
part­
per
trillion
(
1
ppt)
or
less,
and
as
mixtures
of
dioxin
and
the
dioxin­
like
compounds.
Detection
is
with
high
resolution
gas
chromatography
combined
with
high
resolution
mass
spectrometry.
For
example,
EPA
Method
1613
(
USEPA,
1994a)
(
used
to
quantify
CDDs
and
CDFs
in
wastewater,
solids,
air,
and
tissue
samples)
can
reliably
detect
these
compounds
at
or
below
one
part
per
trillion
(
i.
e.,
10
parts
per
quadrillion
(
ppq)
in
water;
1
ppt
in
solid
waste).
This
presents
a
challenge
in
terms
of
interpretation
of
results
in
which
a
CDD/
CDF
compound
is
reported
by
the
analytical
laboratory
as
`
Not
Detected'
(
shown
as
the
abbreviation
`
ND'
on
lab
sheets).
Even
with
these
extremely
low
levels
of
detectability
with
current
laboratory
methods,
it
is
not
possible
to
know
with
certainty
if
`
not
detected'
(
ND)
is
actually
zero
(
i.
e.,
that
dioxin
and
dioxin­
like
compounds
are
not
present
in
the
sample)
or
if
dioxin
and
dioxin­
like
compounds
really
are
present
in
the
sample
at
some
concentration
below
the
minimal
detection
limit
(
MDL).
The
monitoring
data
and
emission
factors
determined
for
your
facility
should
be
reported
in
a
manner
consistent
with
the
methods
and
procedures
that
EPA
has
developed
for
determining
if
these
compounds
are
present
in
various
industrial
processes.
For
example,
EPA
Method
1613
(
USEPA,
1994a)
indicates
that
laboratory
results
below
the
minimum
detection
level
should
be
reported
as
not
detected
(
ND)
or
as
required
by
the
regulatory
authority.
For
purposes
of
threshold
determinations
and
the
reporting
of
releases
and
other
waste
management
quantities
for
dioxin
and
dioxin­
like
compounds
under
EPCRA
section
313,
either
with
monitoring
data,
or
by
using
the
emission
factor
approach,
non­
detects
are
treated
as
`
zero'
if
that
is
how
the
method
being
used
treats
non­
detects
(
e.
g.,
Method
1613,
Method
23).
However,
facilities
should
use
their
best
readily
available
information
to
report,
so
if
a
facility
has
better
information
than
provided
by
these
methods
then
that
information
should
be
used.
For
example,
if
a
facility
is
not
detecting
dioxin
or
a
particular
dioxin­
like
compound
using
a
particular
method
but
has
information
that
shows
that
they
should
be
detecting
them
the
facility
should
use
this
other
information
and
it
may
be
appropriate
to
estimate
quantities
using
one
half
the
detection
limit.
If
the
method
being
used
by
a
facility
to
detect
dioxin
and
dioxin­
like
compounds
is
not
an
EPA
approved
method
and
the
detection
level
being
used
is
not
as
sensitive
as
those
approved
for
use
under
EPA
methods
then
EPA's
EPCRA
section
313
guidance
with
regard
to
non­
detects
should
be
followed.
This
guidance
states
that
facilities
must
use
reasonable
judgement
as
to
the
presence
and
amount
of
a
listed
toxic
chemical
based
on
the
best
readily
available
information.
An
indication
that
a
reportable
chemical
is
below
detection
is
not
equivalent
to
stating
that
the
chemical
is
not
present.
If
the
reportable
toxic
chemical
is
known
to
be
present,
EPA
recommends
that
a
concentration
equivalent
to
half
the
detection
limit
be
used.
Facilities
should
not
estimate
releases
solely
on
monitoring
devices,
they
should
also
rely
on
their
knowledge
of
specific
conditions
at
the
plant.

Betsy
Bicknell
<
Betsy.
Bicknell@
e
To:
Daniel
Bushman/
DC/
USEPA/
US@
EPA
rg.
com>
cc:
Subject:
TRI­
reported
PACs
and
dioxin
and
dioxin­
related
10/
15/
03
01:
33
PM
compounds
Dan:

I
am
looking
for
insights
into
how
facilities
report
releases
of
"
dioxin
and
dioxin­
like
compounds"
and
PACs
to
TRI.
Kurt
Rindfusz
suggested
that
I
talk
with
you
about
the
issues
outlined
below.
I'll
give
you
a
call
and
see
if
we
can
set
up
a
time
to
talk
this
week.

BACKGROUND
ERG
has
been
supporting
EPA
Office
of
Water/
Engineering
and
Analysis
Division
(
EAD)
in
their
development
of
the
effluent
guidelines
2004/
05
plan.
This
plan
is
required
by
CWA
Section
304(
m)
.
To
prepare
the
2004/
05
plan,
EAD
is
evaluating
all
industrial
point
sources
discharging
toxic
or
non­
conventional
pollutants.
The
purpose
of
this
evaluation
is
to
establish
a
schedule
for
the
annual
review
and
revision
of
all
existing
effluent
guidelines
(
i.
e.,
a
prioritized
list
of
existing
effluent
guidelines).
EAD's
analysis
is
also
being
used
to
identify
categories
of
point
sources
discharging
toxic
or
non­
conventional
pollutants
for
which
EPA
has
not
published
effluent
guidelines
(
i.
e.,
new
categories).

ERG
has
supported
EAD
in
analyzing
readily
available
information
to
rank
industries
based
on
potential
hazard.
The
"
readily
available"
information
we've
used
is
the
TRI
and
the
PCS
database,
for
calendar
year
2000.
We
used
output
from
the
OPPT
RSEI
model
to
estimate
releases
of
TRI
parameters
from
POTWs
to
receiving
streams.

To
estimate
the
"
potential
hazard"
of
the
discharges,
we
multiplied
the
mass
discharged
by
"
toxic
weighting
factors"
(
TWFs)
that
EAD
has
used
over
the
years
to
estimate
the
hazard
of
pollutant
discharges.
EAD
assigns
chemical
toxicity
based
on
both
aquatic
life
effects
and
human
health
effects
and
additively
combines
them
in
one
pollutant­
specific
TWF.
EAD
uses
the
calculated
"
toxic­
weighted
pound­
equivalents"
in
the
cost
effectiveness
analysis
it
conducts
when
it
develops
new
effluent
guidelines.

RSEI
model
output
is
limited
to
the
TRI­
reported
mass
of
"
dioxin
and
dioxin­
like
compounds"
­
reported
dioxin
congener
distribution
information
is
not
used
in
RSEI.
EAD
has
a
TWF
for
each
of
the
17
dioxin
and
furan
congeners,
so
for
our
first
"
screening
level"
analysis
we
used
the
TWF
for
1,2,3,6,7,8­
HxCDF
(
the
median
of
the
TWFs
for
the
dioxin
congeners)
to
estimate
the
potential
hazard
of
the
reported
dioxin
and
dioxin­
like
compounds.
For
our
second
level
analysis
we
would
like
to
use
the
reported
congener
distributions.

For
our
"
screening
level"
analysis,
we
also
estimated
the
potential
hazard
for
PACs.

QUESTIONS
How
reliable
are
the
reported
releases
of
dioxin
and
dioxin­
like
compounds
and
the
reported
releases
of
PACs?
How
are
facilities
estimating
releases
for
these
compound
categories?
How
do
facilities
typically
handle
concentrations
reported
as
less
than
the
method
detection
limit
when
calculating
discharge
masses?
­­
or
when
estimating
dioxin
distributions?

What
do
you
see
as
the
shortcomings
of
EAD's
approach
to
prioritizing
categories
(
we
use
primary
SIC
code
to
define
category)?

Betsy
Bicknell
P.
S.
Our
EAD
client
for
this
work
is
Carey
Johnston,
(
202)
566­
1014
CC:
<
price.
michelle@
epamail.
epa.
gov>
