Great Lakes Binational Toxics Strategy

         Draft Report for
   BENZO(A)PYRENE (B(A)P):
  SOURCES AND REGULATIONS
         NOVEMBER 1,1999

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                               TABLE OF CONTENTS


1.0    INTRODUCTION

2.0    ENVIRONMENTAL AND HEALTH CONCERNS

3.0    SOURCES OF B(a)P

4.0    REGULATIONS  AFFECTING B(A)P SOURCES

5.0    CURRENT PROGRAMS FOR B(A)P REDUCTION

6.0    CONCLUSIONS

7.0    REFERENCES

APPENDIX A-1


                                 LIST OF TABLES

Table 1.   Facilities in EPA Region 5 Issued NPDES Permits between
         1995 and 1999 to Release B(a)P
Table 2.   B(a)P Regulatory Overview
Table 3.   Current Domestic and International Efforts Targeting B(a)P


                                 LIST OF FIGURES

Figure 1.  1993 Great Lakes Estimated B(a)P Emissions by Source Category

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1.0    INTRODUCTION

       On April 7, 1997, Canada and the United States signed the Great Lakes Binational Toxics
Strategy: Canada-United States Strategy for the Virtual Elimination of Persistent Toxic
Substances in the Great Lakes (Binational Toxics Strategy or BNS). The Binational Toxics
Strategy identified twelve bioaccumulative substances having sufficient toxicity and presence in
water, sediments and/or aquatic biota of the Great Lakes system to warrant concerted action to
eliminate their input to the Great Lakes. They are called "Level 1 substances". Benzo(a)pyrene
(B(a)P) is one of the Level 1 substances.  B(a)P is the subject of this report, which is in response
to the "Challenge" written in the BNS:

       Seek, by 2006, reductions in releases that are within, or have the potential to
       enter the Great Lakes Basin,  ofB(a)Pfrom sources resulting from human activity.

       To guide Environment Canada (EC) and the United States Environmental Protection
Agency (USEPA), along with their partners, as they work toward virtual elimination of the
strategy substances, the BNS outlined a four-step analytical framework:

       1.  Information gathering

       2.  Analyze current regulations, initiatives, and programs which manage or control
          substances

       3.  Identify cost-effective options to achieve further reductions

       4.  Implement actions to work toward the goal of virtual elimination

       This report documents the analysis associated with Steps 1 and 2 of the four-step process
for B(a)P. Step 1 encompasses identifying all sources, both within and outside the Great Lakes
Basin, by economic sector, that contribute to loadings in the Basin.  Step 1 also requires
consideration of how the substance is used or released, its lifecycle, multi-media loadings, and
associated impacts.  Step 2 involves  assessing existing regulations and programs and how they
influence the presence of B(a)P in the Great Lakes Basin and long-range transport from other
areas into the Basin.  Both Steps 1 and 2 involve identifying gaps: information gaps as to sources,
loadings, and impacts, and regulatory or programs gaps where there is opportunity to achieve
greater reductions in substance releases.

       Section 2 of this report discusses B(a)P in the environment, its impact, and effects on
human health.  Section 3 describes the sources of B(a)P and the available data sources in the
Great Lakes states that characterize releases of B(a)P.  Regulations controlling sources of B(a)P
are outlined in Section 4, and non-regulatory programs aimed at reducing B(a)P releases are
described in Section 5. Conclusions are provided in Section 6.

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2.0    ENVIRONMENTAL AND HEALTH CONCERNS

2.1     DESCRIPTION OF B(a)P

       Benzo(a)pyrene [B(a)P, CAS number 50-32-8] is a member of a class of compounds
known as polycyclic aromatic hydrocarbons (PAHs).  PAHs generally occur as complex mixtures
and not as single compounds. Thus, B(a)P emissions are not typically reported alone but are
often reported with a class of PAHs.

       B(a)P is not manufactured or used commercially. It is primarily a by-product of
incomplete combustion but also occurs naturally in petroleum-based tars. B(a)P is formed when
gasoline, carbon-based waste, animal, or plant material burns. Because of its lower vapor
pressure, it is found largely on the soot (particulate matter), rather than in the vapor phase, of
combustion emissions. B(a)P is also found in coal tar pitch and creosote, both of which are used
as chemical wood preservatives.  B(a)P is a solid with limited solubility in water.

2.2     ENVIRONMENTAL IMPACTS AND LOADINGS

       B(a)P release to the environment is quite widespread since it is an ubiquitous product of
incomplete combustion. It enters the air through natural combustion processes, including forest
fires and volcanic eruptions,  and is emitted to air in vehicle exhaust, coke oven emissions, and
contemporary fossil fuel combustion releases. It is found primarily in condensed media such as
air particulate matter, soils, and sediments due to its low volatility, low water solubility, and
adsorption capability. Its presence in places distant from primary sources indicates that it is quite
stable in the atmosphere and undergoes long range transport.

       Urban runoff and industrial effluents also have elevated levels of B(a)P.  B(a)P in crude
oil and in refined petroleum products (e.g., gasoline,  kerosene, diesel fuel, motor oil) is suspected
of contributing to watershed  contamination from inadvertent leaks and spills, and from
combustion exhausts of these petroleum products that condense on particles and deposit on
roadways without significant airborne transport.

       Cooked and uncooked foods generally contain some level of B(a)P,  depending on the
source of the food and the method of cooking. Fruits and vegetables grown near sources of
B(a)P have higher concentrations than those grown in pristine areas. Cropland soils may be
contaminated by the  application of sewage sludge  containing B(a)P. Charcoal broiling and
smoking increase B(a)P levels in meat.  B(a)P can also accumulate in fish, shellfish, and other
aquatic organisms. B(a)P in  contaminated Great Lakes  sediments has been  reported to
accumulate in bottom-dwelling invertebrates and fish (ATSDR, 1999).

2.3     EXPOSURE  AND HEALTH EFFECTS

       Non-occupational human exposure to B(a)P occurs mainly through cigarette smoking,
inhalation of environmental tobacco smoke (second-hand smoke), and through the consumption
of food, especially meats and fish that have been smoked or charcoal-broiled. Indoor residential

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inhalation exposure to B(a)P also occurs as a result of using wood fireplaces and wood-stoves,
coal and oil furnaces, and kerosene heaters. High levels of occupational exposure via inhalation
or dermal contact can occur in coal-tar-production plants, coking plants, petroleum refineries,
smoke houses, trash incinerators, asphalt-production plants, or other facilities that burn wood,
coal, or oil. Occupational exposure to B(a)P may also occur in road sealing and roofing work
involving coal tar and asphalt, and in areas where high-temperature food fryers and broilers are in
use. Exposure to B(a)P also occurs for workers, vehicle occupants, or pedestrians via inhalation
of diesel and gasoline engine exhaust, and for residents living near industrial sources of B(a)P
(e.g., coke plants).

      B(a)P is considered a probable human carcinogen for long-term and/or high exposures.
Animal studies also suggest developmental and reproductive problems with long-term B(a)P
exposure.  Short-term health effects may include red blood cell damage, suppression of the
immune system, and anemia.

2.4   SENSITIVE SUBPOPULATIONS AND GEOGRAPHIC REGIONS

      Exposure to B(a)P is expected to be highest among occupationally exposed workers.
This includes workers exposed in aluminum plants, coke plants, graphite plants, creosote wood
treatment plants, those involved in the cleanup of coal-tar-contaminated dump sites, and  those
involved in petroleum coking, road surfacing, or the use of small two-cycle gasoline engines.
Individuals working extensively with roofing materials, asphalt, and coal tar may also incur
higher exposures. Other highly exposed populations include cigarette smokers and nonsmokers
living or working in close proximity to smokers. For the average non-smoker, the predominant
source of B(a)P exposure is dietary (ATSDR, 1999).

      Members of the general population who heat their homes with coal-, oil-, wood-,  or
kerosene-burning stoves, tribes and rural populations whose  predominant method of trash
disposal is open burning, residents in the vicinity of emission sources (e.g., high density traffic),
individuals using products containing PAHs (e.g., coal-tar containing psoriasis medication), and
people living in the vicinity of National Priority Listed (NPL) sites where PAHs have been
detected above background levels are expected to experience higher exposures than the general
population. Consumption of Great Lakes fish is not expected to contribute significantly to
dietary exposure unless the fish is smoked or appreciably high amounts offish from local
contaminated water bodies are consumed.  Fish consumption advisories had been issued  as of
September, 1993, for PAHs in the Hersey River in Michigan and the Black River, Little Scioto
River, and the Mahoning River in Ohio (ATSDR, 1999).
3.0    SOURCES OF B(a)P

       An inventory of B(a)P emissions in the Great Lakes Basin has been compiled as result of
the Great Lakes Regional Air Toxic Emissions Inventory Project. This project is an ongoing
initiative to provide basinwide data on source and emission levels of 49 toxic contaminants from
the best available data for point and area sources in the Great Lakes Basin.  Beginning with a

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report released in 1998 using 1993 data, the Regional Air Toxic Emissions Inventory is expected
to be updated every year.

       At present, there is no national emissions inventory for B(a)P.  Rather, B(a)P has been
grouped with a class of similar compounds known as polycyclic aromatic hydrocarbons or PAHs.
As PAHs are regulated under the Clean Air Act, a national emissions inventory, USEPA's 1990
Emissions Inventory of Section 112(c)(6) Pollutants, has been developed for a class of 7 PAHs of
similar molecular weight and carcinogenicity.  The inventory for this class of 7 PAHs, which
includes B(a)P, encompasses a broader range of source categories than the Great Lakes
inventory. Updates to USEPA's national emissions inventory, the 1993 and 1996 National
Toxics Inventories, are scheduled to be released before the end of 1999.  The source categories
reported for B(a)P in the Great Lakes inventory, as well as additional source categories identified
for 7 PAHs in USEPA's 1990 Emissions Inventory of Section 112(c)(6) Pollutants, are described
below.

3.1     AIR EMISSIONS

       Emissions of B(a)P were compiled in the Great Lakes Regional Air Toxics Emissions
Inventory Report (EPA, 1998) from five Great Lakes states using 1993 data. Total airborne
emissions  of B(a)P to the Great Lakes Basin were estimated to be approximately 121,563 pounds
(61 tons).  Figure 1 presents a breakdown of the 1993 estimated B(a)P emissions by source
category for  the Great Lakes basin.

Residential Wood Combustion

       According to estimates available from the Great Lakes Regional Air Toxics Emissions
Inventory Report, residential wood combustion accounts for the largest percentage (45.8%) of
B(a)P emissions in the Great Lakes basin. This category includes wood burned in  fireplaces and
wood-burning devices such as wood stoves, furnaces, and fireplace inserts.

       Emissions from wood-stoves are more of a concern than fireplace emissions due to the
greater frequency of wood-stove use. Whereas  fireplaces are typically used only a half-dozen
times a year, wood-stoves may be used daily as the main source of heat for a home (Van Buren,
1999).  Wood-stoves built after 1990 are required by EPA to be clean burning (see Section 4.0).
However,  the life of a wood-stove is very long,  and the majority of wood-stoves in use are the
older "non-EPA certified" devices. Of the  9.3 million wood-stoves in the U.S., approximately
10%, 1 million, are EPA-certified (Houck et al., 1999).

       In  addition to the type of wood-burning  device, wood-burning practices affect the
efficiency of combustion.  Smoldering combustion emits a more toxic mix and higher levels of
pollutants  than oxygen-rich combustion.  To some extent, smoldering combustion  can be avoided
through proper wood-burning techniques, such as the use of fully seasoned, dry wood.

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                     Blast Furnaces
                     and Steel Mills
                         7.6%
                                  Other Sources
                                     5.1%
         Petroleum Refining
              41.5%
                                                              Residential Wood
                                                                Combustion
                                                                  45.8%
                                                               Total Estimated
                                                               Emissions: 121,563 Ibs.
  Source: RAPIDS Report, August 1998.
       Figure 1. 1993 Great Lakes Estimated B(a)P Emissions by Source Category
Petroleum Refining

       The catalytic cracking units at petroleum refineries have been identified as a source of
B(a)P. Catalytic cracking is a process in which heavier weight, higher boiling hydrocarbons such
as gas oil are broken down by heat in the presence of a catalyst to lighter weight, lower boiling,
higher value hydrocarbons such as gasoline blend stocks and heating fuels. Fluidized-bed
catalytic cracking units (FCCUs) are predominantly used by petroleum refineries for catalytic
cracking.

       Each FCCU operation is customized on the basis of refinery  specific process, feedstock,
and product mix requirements. In general, catalyst and feedstock are introduced to the reactor
through a vertical tube leading to the reactor, the feedstock undergoes a cracking reaction, and
some reaction products are deposited on the catalyst.  As the mixture of catalyst and products
enter the reactor vessel, steam is injected to strip products from the catalyst. With use, the
catalyst in an FCCU loses activity, and coke and some metals remain deposited on the catalyst.
To restore catalyst activity, the used or spent catalyst is routed continuously from the reactor to a
regenerator vessel and the catalyst activity is restored substantially by burning off the coke in a
controlled combustion reaction. Burning the coke also provides process heat necessary for
FCCU operation. The source of emissions from FCCUs is the regenerator flue gas stream.

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       There are two basic types of FCCU regenerators: complete burn combustion regenerators
and partial burn combustion regenerators. In partial burn combustion regenerators, the controlled
burn involves addition of less than stoichiometric amounts of air, so that carbon monoxide rather
than carbon dioxide is generated.  Since B(a)P is a product of incomplete combustion, B(a)P
emissions can be expected from partial combustion units. In complete burn combustion (also
called high temperature) regenerators, the regenerator is operated with a slight excess of oxygen
(1 to 2 percent) to ensure complete combustion of the coke to carbon dioxide (63 FR 48889-
48924). Most FCCU facilities use the complete burn method for the economic advantage of the
heat recovered. Few partial combustion units are in operation.  Some evidence exists, though, to
suggest that a few units designed for complete combustion may not fully combust all the time
(Coburn, 1999).

Coke Ovens

       Blast furnaces and steel mills  produce coke in coke oven batteries. Emission points in the
coking process are associated with charging, pushing and quenching operations. Fugitive
emissions occur at doors, charging lids, and oven offtakes; stack emissions occur at the battery
stacks. The emissions are primarily fugitive emissions and are highly dependent on the
maintenance of the coke ovens and worker practice. The emission rates for doors are dependent
on how well the seals around the doors are maintained. The emissions from lids and offtakes are
dependent on worker practice in applying sealants around the gaps, the size of the gaps, and
pressure fluctuations around the coke oven. Charging emission rates are a function of the time
over which the coal is loaded into the oven, the pressure fluctuations around the oven, and the
gap size around the charging ports.

       There are 17 coke oven plants in operation in the Great Lakes region.  They are located in
the Chicago area, and in Ohio, New York, and Pennsylvania.

Other Sources

       The category of "Other Sources" in the 1998 Great Lakes Regional Air Toxics Emissions
Inventory Report did not specify source categories but indicated that individually they
represented less than five percent of the total. Other sources  of B(a)P identified from additional
references are described below.

Open Barrel Trash Burning

       B(a)P was detected in an emissions characterization study undertaken by EPA to quantify
emissions from the simulated burning of household waste material in barrels (EPA, 1997). An
emission factor was developed for B(a)P in units of pounds emitted per ton of waste burned, but
no estimate of emissions from  open trash burning was made.  Open trash burning is thought to be
a common practice in many rural townships and tribal communities of the Great Lakes.  It is
estimated that 95 percent of some 578 tribes in the U.S. practice open burning as a means of
reducing volumes of garbage (Cummings, 1999).

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Meat Charbroiling

       Commercial meat charbroiling was identified as source of B(a)P emissions by Rogge
(1991).  Although no estimates of B(a)P emissions from meat charbroilers have been made,
numerous eating establishments preparing food by this method exist in the Great Lakes Basin.
Residential charbroiling (i.e., charcoal and gas grilling) also contributes to B(a)P emissions, but
these activities are expected to contribute more to personal exposure than to regional air levels.

Sources Identified from 1990 Emissions Inventory of Section 112(c)(6) Pollutants

       USEPA's 1990 Emissions Inventory of Section 112(c)(6) Pollutants lists B(a)P in a class
of seven PAHs of similar molecular weight and carcinogenicity (EPA, 1998a). In this inventory,
as in the Great Lakes inventory, residential wood combustion comprises a large percentage of
emissions (29%). However, wildfires and prescribed burning are reported to account for 48% of
national emissions.  Primary aluminum production, coke oven charging topside and door leaks,
and open burning of scrap tires account for 7%, 4%, and 3%  of emissions, respectively. Source
categories representing less than 2% of total emissions in this inventory are commercial coal
combustion, on-road vehicles, residential coal combustion, non-road vehicles and equipment, and
petroleum refining.  The remaining sources individually account for less than 0.2% of total
national emissions.  Emissions estimates for the 7 PAH category from USEPA's 1990 Emissions
Inventory of Section 112(c)(6) Pollutants are provided in Appendix A.

       Wildfires and prescribed burning are reported to account for roughly half of 1990 national
7 PAH emissions. Each year, wildfires caused by human carelessness or accidents damage
millions of acres of public and private lands and natural resources. Wildfires on federal lands are
managed by the Forest Service, within the Department of Agriculture, and the Bureau of Land
Management, within the Department of the Interior. State and local firefighting organizations
respond to wildfires on state and private lands.  Various agreements among federal, state, and
local firefighting organizations allow for cooperative efforts in providing mutual support in the
suppression of wildfires.  Prescribed, or controlled burns, may be used to recycle nutrients,
reestablish native plant and animal communities, or to reduce the fuel available for dangerous
wildfires to ignite.

       Six processes involved in producing primary aluminum are associated with B(a)P
emissions: horizontal stud Soderberg cells, vertical Soderberg cells, pre-bake cells, casting
operations, paste production, and anode bake  furnaces (EPA, 1998a).  The emission factors vary
for each process, and various devices may be  used to control  emissions.

       Scrap tires are a problem in that stockpiled tires are susceptible to vandalism and
lightning strikes  that may cause the tires to burn for several days. It is estimated that two to three
billion scrap tires are in landfills and stockpiles across the U.S. and that one scrap tire per person
is generated every year (EPA, 1997a). Methods are recommended (e.g., proper storage site
design) to prevent and minimize open tire fires. In addition,  alternative applications that utilize
scrap tires as a resource opportunity have been developed.  For instance, tire-derived fuel is used

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to supplement other fuels in industrial boilers and kilns, crumb rubber can be used in asphalt
paving, and molded and extruded products such as brake pads can be made from ground rubber.

       The exhaust from millions of on-road vehicles is deposited onto roads, highways, and
parking lots each year, contributing to watershed contamination from runoff. The cumulative
effect of each poorly-maintained vehicle that leaks oil or produces excessive exhaust particulate
matter can be huge, particularly in high-density traffic areas.  One study determined that the
average American puts one quart of petroleum products on the roads each year from leaking
crankcases and exhaust emissions (Martin, 1999).

3.2    WATER RELEASES

       Atmospheric deposition is, in general, the main source of B(a)P to surface waters, with
lesser amounts contributed by industrial effluents, municipal waste water, urban storm water
runoff, road runoff, and oil spills. Among the industrial effluents contributing to B(a)P in surface
waters are releases from wood treatment plants, coke ovens, and petroleum refineries. See
Section 3.5 for more information on water releases from regulated facilities.

3.3    HAZARDOUS WASTES

       B(a)P is listed as a hazardous waste and is regulated under the Resource Conservation
and Recovery Act (RCRA). PAHs, including B(a)P, have been identified in commercial tars
(e.g., asphalt) and in the RCRA wastes of several source categories, including petroleum
refining,1 creosote wood preserving, coking operations, used oil PAH residuals, aluminum
production, combustion (cement kilns, boilers, energy recovery), and others.

3.4    NON-POINT AND RESERVOIR SOURCES

Long Range Transport

       B(a)P released to the atmosphere may be subject to moderately long transport, depending
mainly on the particle size distribution and climactic conditions, which will determine the rates
of wet and dry deposition. Since combustion particles comprise much of the fine particulate
matter in air, the presence of B(a)P in areas remote from primary sources demonstrates its
considerable stability in air and its potential for long range transport.
        It should be noted that B(a)P and other PAH compounds are intrinsic in the blending processes
associated with petroleum products (e.g., diesel fuels, tar, creosote, etc.) and are not residuals associated only with
the combustion process.

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So/7

       PAHs are ubiquitous in soil, primarily due to the abundance of anthropogenic
combustion processes.  Generally, background soil concentrations for PAHs are highest in urban
soil, followed by agricultural and rural soil, reflecting the predominance of combustion sources
in urban areas. Elevated B(a)P levels have been found in soil at wood preserving and coking
sites, manufactured gas plants, and hazardous waste treatment operations (ATSDR, 1999).

       Eighteen sites in EPA Region 5 are currently on the EPA Superfund Program's final
National Priority List (NPL) with B(a)P listed as a contaminant of concern for all media
(http://www.epa.gov/superfund/ sites/index.htm). NPL sites are the most serious hazardous
waste sites in the U.S. as identified by EPA's Superfund Program for long-term federal cleanup
activities.  The sites containing B(a)P in EPA Region 5 are listed in Appendix A.

Sediments

       Sediments are major sinks for PAHs. PAHs emitted from combustion sources and from
boating and shipping activities may eventually enter water bodies and accumulate in sediment.
EPA's 1998 report '"Hie Incidence and Severity of Sediment Contamination in Surface Waters of
the United States" indicates that atmospheric deposition, industrial discharges, municipal
discharges, and urban sources are all point sources contributing to PAH contamination in
sediments (EPA, 1999). The report does not consider sources that are difficult to categorize as
point or non-point: leaching landfills, recreational and commercial boating, and  dredging of
contaminated materials. In the Great Lakes, B(a)P was identified as a contaminant contributing
to the classification in the report of the following sites as Tier 1 or Tier 2:2 Ashtabula-Chagrin,
Buffalo-Eighteenmile, Cedar-Portage, Chautauqua-Conneat, Lake St.Clair, Little Calumet-
Galien, Lower Fox, Manistee, Niagara, Oak Orchard-Twelvemile, Ottawa-Stony, and St.Clair-
Detroit. Maximum concentrations of B(a)P in sediment samples of 107 and 75 ppm were
measured in the Buffalo-Eighteenmile and Chautauqua-Conneat watersheds, respectively. Both
areas are in eastern Lake Erie.

       The most important source of sediment contamination varies by location, and more than
one source category may contribute to significant contamination.  Atmospheric deposition is
often identified as a primary contributor of PAHs to aquatic systems.  Permit monitoring data
indicate that many municipal sewage treatment plants and major industrial facilities discharge
PAHs to watersheds, presenting the potential to adversely affect sediment quality. Runoff from
roadways, residential and commercial areas, construction sites, and marinas and shipyards
contribute to urban sources affecting sediment quality (EPA, 1999). Emissions from commercial
and residential fuel-burning furnaces and vehicle emissions are additional urban sources
associated with PAHs in contaminated sediment. Waterways with heavy diesel traffic have been
reported to contain high levels of PAH-contaminated sediment (ATSDR, 1999).
        Tier 1 sites are those where associated adverse effects are probable. Tier 2 sites are those where
associated adverse effects are possible, but expected infrequently.

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3.5    DATA SOURCES FOR THE GREAT LAKES STATES

       As discussed in Section 3.0, an inventory of B(a)P emissions has been compiled for the
Great Lakes. The states of Illinois, Indiana, Michigan, Minnesota, and Wisconsin conducted
statewide air toxic emissions inventories for the Great Lakes Air Toxic Emissions Inventory
Project for the calendar year 1993.  Data from these state inventories were used to compile the
1993 B(a)P emissions inventory for the Great Lakes (Great Lakes Regional Air Toxics Emissions
Inventory Report EPA, 1998).

       In addition, ambient air and precipitation monitoring is conducted at several sites in the
Great Lakes Basin through the Integrated Atmospheric Deposition Network (IADN) and
Environment Canada ambient air monitoring.

       B(a)P water releases are reported under EPA's Permit Compliance System (PCS). B(a)P
releases are not reported individually to either EPA's  Toxic Chemical Release Inventory (TRI) or
RCRA's Biennial Reporting System (BRS) but may be reported within the category of polycyclic
aromatic compounds.

       Information from each  of these sources is summarized below, and included in detail in
Appendix A. Appendix A provides a summary of the number of facilities that report B(a)P
releases under these programs. The number of facilities reporting releases varies by reporting
program as a result of differing reporting requirements.

Integrated Atmospheric Deposition Network

       The Integrated Atmospheric Deposition Network (IADN) was established by the U.S. and
Canada for conducting air and  precipitation monitoring in the Great Lakes Basin.  IADN was
created as part of the 1987 amendments to the Great Lakes Water Quality Agreement.  Currently,
the network consists of five Master Stations and  14 Satellite Stations in both Canada and the U.S.
which measure wet deposition  and air concentrations  of gas phase and particulate phase organics
and trace elements. Data comparing the wet and dry deposition,  gas absorption, and gas
volatilization for B(a)P showed that wet and dry  deposition from the atmosphere largely defined
the loading of B(a)P to Lake Ontario in 1994 (IADN,  1998). Wet and dry deposition decrease
from the lower to upper lakes, being the greatest for Lake Erie. This may be enhanced by large
urban sources along Lake Erie. Appendix A includes precipitation, particle phase, and gas phase
concentration data from IADN Master Stations for B(a)P from 1992-1994.

Environment Canada

       The Analysis and Air Quality Division of Environment Canada conducts ambient air
monitoring of over 300 contaminants, including B(a)P, at locations around the country. In a
1997 unpublished report entitled "Monitoring of Persistent Toxic Substances in Ontario-Great
Lakes Basin", a large gradient in ambient air concentrations between urban and rural sites was
demonstrated for B(a)P, indicating a substantial influence from local sources of release. A
maximum concentration of 16  ng/m3 was measured at the Hamilton, Ontario, site (Dann, 1997).
                                          10

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RCRA Biennial Report Data
       The RCRA Biennial Report System (BRS) tracks information on hazardous waste
generated and managed by large quantity generators and permitted Treatment, Storage, and
Disposal (TSD) facilities.  There are no waste codes that specifically characterize B(a)P in
hazardous waste. However, there are many waste codes characterizing the wastes resulting from
industry-specific processes for source categories of B(a)P.  For example, waste code "F037"
defines petroleum refinery primary oil/water/solids separation sludge.

Permit Compliance System (PCS) Data

       EPA's Permit Compliance System (PCS) data for water discharges approximates point
source loads from municipal and industrial dischargers.  The information is based on monitoring
data supplied by regulated facilities. EPA uses PCS data as the basis for its National Pollutant
Discharge Elimination System (NPDES) permit enforcement program.  Table 1 presents PCS
data by industrial sector for regulated facilities in EPA Region 5 issued permits between January
1, 1995 and August 31, 1999. These are facilities that were issued permits to discharge B(a)P.
Table 1 does not imply release of B(a)P; data on actual discharges of B(a)P could not be
obtained. Appendix A lists the number of facilities in Great Lakes states  holding NPDES
permits to discharge B(a)P from EPA's Permit Compliance System.

Table 1.   Facilities in EPA Region 5 Issued NPDES Permits between  1995 and 1999 to
          Release B(a)P
Industrial Sector
Plastic Materials, Synthetic Resins, and Nonvulcanizable
Elastomers
Petroleum Bulk Stations and Terminals
Railroads, Line-Haul Operating
Gasoline Service Stations
Nonclassifiable Establishments
Electric Services
Refined Petroleum
Wood Preserving
Steel Works, Blast Furnaces (Including Coke Ovens), and
Rolling Mills
Cyclic Crudes and Intermediates
Industrial Organic Chemicals, nee
Sewerage Systems
Other
SIC Code
2821
5171
4011
5541
9999
4911
4613
2491
3312
2865
2869
4952
-
Number of
Permits Issued
10
9
8
7
6
5
4
3
3
2
2
2
23
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Toxic Chemical Release Inventory (TRI)

       The Toxic Chemical Release Inventory (TRI) contains chemical release and transfer
information from manufacturing facilities (SIC codes 20-39) which have ten or more employees
and that manufacture or process 25,000 pounds of a listed chemical or otherwise use 10,000
pounds of a listed chemical.  TRI reporting of B(a)P releases is not required under the Emergency
Planning and Community Right to Know Act (EPCRA) (see Section 4.0). However, TRI does
report for the larger chemical category of polycyclic aromatic compounds. No TRI releases of
poly cyclic aromatic compounds were reported in EPA Region 5 for 1997.
4.0    REGULATIONS AFFECTING B(A)P SOURCES

       Table 2 provides an overview of B(a)P regulations under the Clean Air Act (CAA), the
Clean Water Act (CWA), the Safe Drinking Water Act (SDWA), the Resource Conservation and
Recovery Act (RCRA), and the Comprehensive Environmental Response, Compensation, and
Liability Act (CERLA). These are described in greater detail below.

Clean Air Act

       In the U.S., the Clean Air Act (CAA) establishes requirements for airborne emissions
from a variety of sources. USEPA, state, and regional air quality agencies are all likely to be
involved in CAA implementation. Under the CAA, the major regulatory requirements include
National Emissions Standards for Hazardous Air Pollutants (NESHAPS) and maximum
achievable control technology (or MACT standards) for a specific list of hazardous air pollutant
source categories and subcategories. Included on this list is polycyclic organic matter, which
encompasses B(a)P as a PAH.  The CAA also establishes the national ambient air quality
standards, which although they have no direct regulatory impact,  serve as baseline for judging the
effectiveness of release regulations.  Currently, there is no federal ambient air standard
established under the CAA  for B(a)P.

       To control particulate matter (PM) emissions from residential wood combustion, the
largest source of B(a)P emissions in the Great Lakes, a 1988 New Source Performance Standard
(NSPS) requires EPA certification for residential wood-fired heaters manufactured after 1990.
The certification is based on a PM emission rate limit of 7.5 grams per hour and is expected to
reduce B(a)P and PM emissions from new wood-stoves. The NSPS does not apply to fireplaces
and other wood-burning devices such as masonry heaters that do not meet the definition of
"affected facility" in the NSPS.
                                          12

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Table 2. B(a)P Regulatory Overview
B(a)P Regulatory Overview





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CAA
§112(b): POM
(which includes
B(a)P) is a
designated
HAP; Major
source
categories
identified under
§112(c)(6);
MACT
standards
promulgated or
scheduled










CWA
CWA Priority:
Listed priority
pollutant
(40CFR 423);
subject to
NPDES
effluent
limitations
under §304(b)
(40CFR 122)
and general
pretreatment
(40CFR 403)










SDWA
NPDWR /
MCL: 0.0002
mg/L

MCL goal is
zero

















RCRA
Subtitle C:
B(a)P-
containing
substances are
listed as
hazardous
toxic wastes
(40CFR
261.33);
subject to
hazardous
waste
regulations
(40CFR 302.4)

Universal
treatment
standards for
B(a)P levels in
waste (40CFR
268.48)


SARA/EPCRA
§313: Releases
of PAHs,
including B(a)P,
(by facilities with
10 or more
employees and
that process
25,000 Ibs., or
otherwise use
10,000 Ibs.) must
be reported to
TRI (40CFR
372.65)

Jan. 5, 1999
Federal Register
proposed
reduction of TRI
reporting
threshold for
PAHs to 10
Ibs/year (64FR
687)
CERCLA
§103: Spills of
B(a)P >1 Ib.
must be
reported to the
National
Response
Center
















CM: Clean Air Act NPDWR: National Primary Drinking Water Regulations
CERCLA: Comprehensive Environmental Response, Compensation, and PAH: Polycyclic Aromatic Hydrocarbons
Liability Act POM: Polycyclic Organic Matter
CWA: Clean Water Act RCRA: Resource Conservation and Recovery Act
HAP: Hazardous Air Pollutant SARA/EPCRA: Superfund Amendment Reauthorization Act /
MCL: Maximum Contaminant Level. (Drinking water standard) Emergency Planning and Community Right-to-know Act
NESHAPS: National Emissions Standards for Hazardous Air Pollutants SDWA: Safe Drinking Water Act
(HAPs) TRI: Toxic Release Inventory
NPDES: National Pollutant Discharge Elimination System
       For the second largest source of B(a)P emission in the Great Lakes, petroleum refining, a
maximum achievable control technology (MACT) standard has been proposed for refinery
catalytic cracking units, catalytic reforming units, and sulfur recovery units. The MACT will
require complete combustion with demonstrated compliance for petroleum refining catalytic
cracking units. Complete combustion can be expected to reduce B(a)P emissions. However,
complete combustion is already required under a New Source Performance Standard (NSPS) for
the industry, and refineries complying with the NSPS are considered in compliance with the
proposed MACT. Under the proposed MACT, only partial combustion units and complete
combustion units not currently meeting the full combustion requirements would be expected to
reduce B(a)P emissions further (Coburn, 1999).

       Blast furnaces and steel mills, the third largest source of B(a)P emissions in the Great
Lakes, are the subject of several EPA air controls. Under the Clean Air Act (CAA), a 1993
National Emissions Standard for Hazardous Air Pollutants (NESHAP) for coke oven charging,
                                          13

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topside, and door leaks, is projected to decrease B(a)P emissions for coke plants operating in
Great Lakes states in 1998-1999 to 597 pounds per year (Melton, 1999). A MACT standard for
coke ovens, which applies to pushing, quenching, and battery stacks, is scheduled for
promulgation on December 31, 1999 and is expected to reduce B(a)P emissions to 0.1-0.2
pounds per year. In addition, residual risk standards (remaining risk to the public after
implementation of the MACT standard) for the entire coke oven operation are being developed
under the MACT program to address remaining risks from coke ovens. The scheduled date of
promulgation for residual risk standards for the coke oven industry is 2001.

       MACT standards are also planned for primary aluminum production and industrial,
commercial, and institutional boilers.  Although B(a)P emissions are not targeted specifically by
these MACT standards, lower emissions of poly cyclic organic matter resulting from the MACT
standards can be expected to reduce B(a)P emissions.

Clean Water Act

       The Clean Water Act (CWA) regulates discharges to surface waters with the overall goal
to restore and maintain the chemical, physical, and biological integrity of the nation's surface
waters.  To control  point source discharges, the CWA established the National Pollution
Discharge Elimination System (NPDES) permit program, which defines the conditions and
effluent limitations under which a facility may make a discharge. The NPDES permit is the
regulatory tool translating the general standards (CWA, Subchapter III) into effluent limitations
and monitoring requirements applicable to specific point source polluters.  Indirect discharges via
municipal wastewater treatment plants or sewage treatment plants must meet pre-treatment
requirements, including categorical standards developed by the EPA that apply to each industry
and local standards developed by each publicly owned treatment work (POTW).  Effluent
guidelines regulations for both direct discharges and pre-treatment standards are generally sector
specific. PAHs are regulated under the Clean Water Effluent Guidelines as a group of chemicals
controlled as Total  Toxic Organic for the point source categories of electroplating and metal
molding and casting. Specific regulatory limitations have been defined for the point source
categories of organic chemicals, plastics, and synthetic fibers; iron and steel manufacturing; and
nonferrous metals manufacturing (ATSDR, 1999).

       The effluent limitations guidelines for the Iron and Steel Manufacturing Point Source
Category are currently under reassessment.  EPA is in the process of gathering data for this rule
reassessment, which is scheduled to be proposed in October 2000 (Jett, 1999).

       To address the risk of contaminated runoff, NPDES storm water permits are required for
any storm water discharge associated with industrial activity, a large or medium municipal  storm
sewer system, or a discharge which EPA or the State determines to contribute to a violation of a
water quality standard or is a significant contributor of pollutants to waters of the United States.
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Safe Drinking Water Act

       The Safe Drinking Water Act (SDWA) was established by Congress in 1974 to protect
human health from contaminants in drinking water, and to prevent contamination of existing
groundwater supplies.  The SDWA National Primary Drinking Water Standards define
enforceable maximum  contaminant levels (MCLs), in addition to non-enforceable maximum
contaminant level goals (MCLGs).  The maximum contaminant level for B(a)P is 0.0002 mg/L
(0.2 ppb), and the maximum contaminant level goal is 0 mg/L.

RCRA Requirements

       The Resource Conservation and Recovery Act (RCRA) establishes a regulatory structure
for the handling,  storage, treatment, and disposal of solid and hazardous wastes. Subtitle C of
RCRA addresses "cradle-to-grave" requirements for hazardous waste from the point of
generation to  disposal.  A solid waste containing B(a)P may be characterized as hazardous waste
when subjected toxicity testing as stipulated in 40 CFR 261.24. If the waste is so characterized,
it must be managed as a hazardous waste. As stipulated in 40 CFR 261.33, when B(a)P, as a
commercial chemical product or manufacturing chemical intermediate or an off-specification
commercial chemical product or a manufacturing chemical intermediate, becomes a waste, it
must be managed according to Federal and/or State hazardous waste regulations. Also defined as
a hazardous waste is any residue, contaminated soil, water,  or other debris resulting from the
cleanup of a spill, into water or on dry land, of this waste. Generators of small quantities of this
waste may qualify for partial exclusion from hazardous waste regulations (40 CFR 261.5).

CERCLA Reportable  Quantities

       The Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA), or Superfund, establishes a list of hazardous substances which  are subject to release
reporting regulations. Releases  of CERCLA listed hazardous substances, if occurring in
amounts exceeding a predefined "reportable quantity" (RQ), must immediately be reported to the
National Response Center.  Persons in charge of vessels or facilities are required to notify the
National Response Center (NRC) immediately when there is a release of this designated
hazardous substance in an amount equal to or greater than its reportable quantity of 10 Ib (4.54
kg).

Superfund Amendment and Reauthorization Act
(Emergency Planning and Community Right-to-Know Act)

       The Superfund  Amendment and Reauthorization Act, known as SARA Title III, or the
Emergency Planning and Community Right to Know Act (EPCRA), also requires notification
and reporting of hazardous  substances. The key regulatory requirements of EPCRA include
emergency planning and release notification, Community Right-to-Know reporting, and Toxic
Release Inventory (TRI) reporting.  Toxic release reporting requirements, which allow for the
compilation of the national  Toxic Release Inventory (TRI) database, apply to specific
manufacturing facilities, which have ten or more employees, and which manufacture, process, or

                                          15

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use specified chemicals in amounts greater than threshold quantities. Emergency planning is
required when substances on the Extremely Hazardous Substances list are present in quantities
exceeding the Threshold Planning Quantities (TPQs).

       Principal provisions of SARA Title III that affect B(a)P reporting are the following. All
facilities in the manufacturing sector (SIC codes 20 - 39) that manufacture or process 25,000
pounds of a listed chemical or otherwise use 10,000 pounds of a listed chemical must report air,
water, and land releases to TRI.  TRI thresholds are based on the quantity of each substance used,
processed, manufactured, or imported at any of these facilities. Beginning with the 2000
reporting year, the threshold for reporting polycyclic aromatic compounds is expected to be
lowered to 10 pounds per year. The purpose of the proposed lowering of the reporting threshold
is to capture a vast majority of sources that are not required to report under the current reporting
threshold. The proposed rule was announced January 5,  1999 (64FR687), and a final rule is
expected by the end of 1999. Reporting would begin in 2000, and the first public release of data
obtained through the new TRI rule would be available in 2001.

OSHA

       The Occupational Safety and Health Administration (OSHA) regulates the benzene
soluble fraction of coal-tar pitch volatiles (29 CFR 1910.1002). Employers must maintain a
Permissible Exposure Limit for B(a)P of 0.2 mg/m3 (8-hour time weighted average).

Transport Methods and Regulations

       No person may transport, offer, or accept a hazardous material for transportation in
commerce unless that person is registered and the hazardous material is properly classed,
described, packaged, marked, labeled, and in condition for shipment as required or authorized by
the hazardous materials regulations (49 CFR 171.2 (7/1/96)).

State Laws

       In addition to federal  clean water requirements, every state also regulates water pollution
within their territory. This sometimes results in a dual system of permitting, whereby each
facility must obtain both a federal NPDES permit and a state discharge permit. States can gain
EPA approval of the state permitting system so that the state itself administers the NPDES
program. In such cases, one permit issued by the state government meets both the federal and
state requirements.  States have the explicit right to enact any water quality standard or limitation
that is more stringent than those  required by federal statute (33 U.S.C. sec. 1370). Minnesota has
set drinking water quality standards for PAHs.  New York, Ohio and Wisconsin have set water
quality standards for B(a)P (ATSDR, 1999).

       The states of Indiana, Michigan, New York, and Pennsylvania have set average annual
acceptable ambient air concentrations for B(a)P of 0.0006 |ig/m3, 0.0003 |ig/m3, 0.00 |ig/m3, and
0.0007 |ig/m3, respectively. Open trash burning may be regulated by state (e.g., Michigan,
Minnesota) and local laws. The  open burning of scrap tires is banned in nearly all states.  Laws

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regulating the storage, processing, hauling, and disposal of scrap tires vary by state.  For
example, Illinois, Minnesota, Ohio, and Wisconsin ban whole tires in landfills, and several states
impose a tax per vehicle title or per new tire for scrap tire disposal.
5.0    CURRENT PROGRAMS FOR B(A)P REDUCTION

       Since B(a)P occurs in a mixture of other PAHs, monitoring and reduction efforts are
typically aimed at a broader group of PAHs. B(a)P has been targeted independently, however, as
a Level 1 substance in the Binational Toxics Strategy and as a priority pollutant in EPA's PBT
Strategy. B(a)P has also been named, along with other PAHs, in international Long-Range
Transboundary Air Pollution (LRTAP) negotiations.  Table 3 lists these and other current
domestic and international data collection and toxic reduction efforts targeting B(a)P.

       Other efforts that affect B(a)P emissions include campaigns at state and local levels, and
voluntary industry initiatives.  For example, 35 states have developed measures to address the
problem of scrap tire fires. In Illinois, EPA has held "Tire Cleanup Days" for the public to
recycle old tires at no charge.  The tires are shredded at the collection site for use in tire-derived
fuel. Minnesota and Wisconsin offer grants for tire processors recycling scrap tires. One
commercial meat charbroiling fast-food restaurant chain is currently installing catalytic
converters on charbroilers at selected chain locations.  The catalytic converters decrease
particulate emissions by about 88 percent and thus can be expected to reduce B(a)P emissions as
well.  An integrated steelmaking and processing complex in Hamilton, Ontario, has undertaken
refurbishment  of several coke oven batteries that will help eliminate leaks and decrease
particulate emissions from coking operations.

Table 3. Current Domestic and International Efforts Targeting B(a)P
Current Domestic and International Efforts Targeting B(a)P
Program
Description
National and Regional Strategies
Binational Toxics Strategy
(BNS)
The BNS challenges the U.S. to seek reductions in B(a)P releases from
sources resulting from human activity by 2006. The BNS provides an
established process for engaging stakeholders and seeking voluntary
reduction efforts through a B(a)P Workgroup. The workgroup offers an
opportunity for EPA to solicit and recognize efforts toward the virtual
elimination of B(a)P in the Great Lakes. An additional challenge of the
BNS is to assess atmospheric inputs of strategy substances to the Great
Lakes and, if long-range sources are confirmed, to work within
international frameworks to reduce releases of such substances.
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Table 3. Current Domestic and International Efforts Targeting B(a)P (Continued)
              Current Domestic and International Efforts Targeting B(a)P
         Program
                           Description
 EPA's Agency-wide
 Multimedia Strategy for
 Priority Persistent,
 Bioaccumulative, and
 Toxic (PBT) Pollutants
Building on the BNS, the PBT Strategy seeks to reduce risks from
persistent toxic substances at a national level.  The PBT Strategy targets
B(a)P as a Level 1 pollutant. The aim of the PBT Strategy is to respond to
the cross-media issues associated with PBT pollutants by going beyond
the traditional single-statute approaches in order to reduce risks to human
health and the environment from existing and future exposure to PBT
pollutants. The PBT national action plan for B(a)P will seek to coordinate
efforts among all EPA national and regional programs as well as to
collaborate with international organizations to reduce  risks from current
and future exposure to B(a)P.	
 EPA's Integrated Urban
 Air Toxics Strategy
EPA's Integrated Urban Air Toxics Strategy identifies polycyclic organic
matter, including B(a)P, as one of 33 air toxics that present the greatest
threat to public health in the largest number of urban areas.  Building on
its existing air toxics regulatory program, key components of the Strategy
are 1) regulations addressing sources at both the national and local level,
2) initiatives to identify and address specific community risks (e.g., though
pilot projects), 3) air toxics assessments (including expanded air toxics
monitoring and modeling) to identify areas of concern, to prioritize efforts
to reduce risks, and to track progress, and 4) education and outreach
efforts to inform stakeholders about the strategy and to seek input for
program design and implementation.	
 EPA's Contaminated
 Sediment Management
 Strategy
EPA's Contaminated Sediment Management Strategy utilizes a cross-
program policy framework to promote consideration and reduction of
ecological and human health risks posed by sediment contamination. The
strategy advocates cross-program coordination, as well as a watershed
approach, to prevent and remediate existing sediment contamination and
to prevent future contamination. Actions required to manage legacy
contaminated sediment sites as well as sites with existing discharges,
include source control, pollution prevention, and remediation.	
 Lakewide Management
 Plans (LaMPs)
The U.S. and Canadian governments agreed to develop Lakewide
Management Plans (LaMPs) for each of the five Great Lakes under Annex
2 of the 1987 Great Lakes Water Quality Agreement.  The purpose of the
LaMPs is to assess critical pollutants as they relate to the impairment of
beneficial uses of the Great Lakes and to develop measures to restore
beneficial uses where they have been impaired.  B(a)P has been
identified as a critical pollutant in the Lake Erie LaMP.	
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Table 3. Current Domestic and International Efforts Targeting B(a)P (Continued)
              Current Domestic and International Efforts Targeting B(a)P
         Program
                           Description
 Great Lakes Regional Air
 Toxic Emissions
 Inventory Project
The Great Lakes Regional Air Toxic Emissions Inventory Project presents
a compilation of best available data for emissions from point and area
sources of 49 air toxics pollutants in the Great Lakes Basin. The project
began with an initial inventory report in August 1998 compiled using 1993
data. The project is a long-term U.S. federal/state and provincial effort to
provide basinwide data and improve decision-making capabilities by
promoting consistency in data collection and analysis, establishing
standard procedures and protocols, and developing an automated
emission estimation and inventory system. In the initial August 1998
report, data for B(a)P were available from five Great Lakes states.	
 Remedial Action Plans
 (RAPs)
The Great Lakes Remedial Action Plan (RAP) program originated from a
1985 recommendation made by the International Joint Commission's
Great Lakes Water Quality Board and was formalized in the 1987
amendments to the GLWQA.  The aim of RAPs is to restore beneficial
uses in 43 Areas of Concern (AOCs) identified in the Great Lakes Basin
where beneficial uses or the area's ability to support aquatic life have
been impaired. Through the RAP program, Canada and the U.S. are
committed to cooperating with state and provincial governments to
incorporate a systematic and comprehensive ecosystem approach to
address critical pollutants, to restore beneficial uses, and to ensure that
the public is consulted in all actions undertaken to develop and implement
RAPs for designated AOCs.  PAHs contribute to impaired uses in several
AOCs.
 Scrap Tire Management
EPA has studied the open burning of scrap tires and reported its findings
in Air Emissions from Scrap Tire Combustion (EPA, 1997a).  In its report,
EPA presents recommendations for storage site design, civilian
evacuation, and fire suppression tactics to minimize potential health risks
from open tire fires. The Scrap Tire Management Council (STMC) is an
independent advocacy organization created by the North American tire
industry that offers a seminar and guidelines for the prevention and
management of scrap tire fires. The Council also provides assistance in
developing and promoting the utilization of scrap tires as a resource
opportunity.	
 Wildland Fire
 Prevention/Education
Teams of specialists throughout the U.S. promote local wildland fire
prevention efforts by raising public awareness about fire dangers and
educating thousands of citizens on how they can prevent unwanted
wildland fires.
                                             19

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Table 3. Current Domestic and International Efforts Targeting B(a)P (Continued)
Current Domestic and International Efforts Targeting B(a)P
Program
Wood-stove Changeout
Programs and
Workshops
Description
Organized by the Hearth Products Association in cooperation with
manufacturers, distributers, and retailers of wood-burning stoves, wood-
stove changeout programs offer substantial trade-in rebates on purchases
of advanced technology stoves and fireplaces. Wood-burning workshops
are also organized as part of changeout programs for those interested in
learning how to make their wood-burning systems more effective and
cleaner burning. A wood-stove changeout program was held in Ontario,
and EPA and the Hearth Association are planning to sponsor two
additional programs in Green Bay, Wisconsin, and Traverse City,
Michigan.
International Programs
UN ECE Convention on
Long-Range
Transboundary Air
Pollution (LRTAP)
protocol
In February 1998, under the United Nations' Economic Commission for
Europe Long Range Transboundary Air Pollution (LRTAP) Convention, 43
countries completed negotiations on a regional Persistent Organic
Pollutants (POPs) protocol. The LRTAP Protocol sets a framework for
controlling, reducing, and eliminating discharges, emissions, and losses of
persistent organic pollutants, including B(a)P. The agreement does not
outline numerical emission limits, but instead member countries have
agreed to control emission levels above a specified baseline year selected
by each country. New stationary sources will have 2 years to reach
identified emission levels and existing point sources will have 8 years to
reach identified emission levels once the Convention is ratified.
Monitoring Efforts
Integrated Atmospheric
Deposition Network
(IADN)
IADN is a joint monitoring network established by the U.S. and Canada in
response to the Great Lakes Water Quality Agreement to address issues
concerning airborne contaminants in the shared Great Lakes basin. IADN
is designed to assess the magnitude and trends of atmospheric deposition
of toxic substances to the Great Lakes and, where possible, to determine
sources of atmospheric pollutants. Among other toxic chemicals, IADN
currently monitors the atmospheric deposition of B(a)P.
                                        20

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Table 3. Current Domestic and International Efforts Targeting B(a)P (Continued)
              Current Domestic and International Efforts Targeting B(a)P
         Program
                           Description
 CAA§112(m) program,
 Atmospheric Deposition
 to Great Lakes and
 Coastal Waters (Great
 Waters Program)
The 1990 Amendments to the CAA include Section 112(m), Atmospheric
Deposition to Great Lakes and Coastal Waters, to establish research,
reporting, and potential regulatory requirements related to atmospheric
deposition of hazardous air pollutants (HAPs) to the "Great Waters".
EPA's Great Waters Program coordinates activities to address the
requirements of Section 112(m).  Polycyclic organic matter, which
includes PAHs, is a Great Waters pollutant of concern. The "Great
Waters" referred to in this program are the Great Lakes, Lake Champlain,
Chesapeake Bay, and specific coastal waters designated through the
National Estuary Program and the National Estuarine Research Reserve
System. EPA provides biennial Great Waters Reports to Congress
discussing the current scientific understanding of atmospheric deposition
and the health and environmental effects of toxic pollution, as well as EPA
programs to protect human health and the environment.	
 USEPA National Study of
 Chemical Residues in
 Fish
Study design and peer review of EPA's National Study of Chemical
Residues in Fish have been completed.  EPA will statistically evaluate the
incidence and severity of B(a)P and other chemical residues in fish, both
downstream from suspected problem areas and in background areas.
EPA will work with State Departments of Health and Environmental
Protection and will coordinate with state fish advisory programs.
Sampling will begin in fiscal year 1999 (FY99) and conclude in Summer
FY01. Study results will be available in FY02.	
 Children's Total Exposure
 to Persistent Pesticides
 and Other Persistent
 Organic Pollutants
 (CTEPP)
As young children are hypothesized to have greater exposures, as well as
greater sensitivities, to persistent organic pollutants than older children or
adults, the National Exposure Research Laboratory of EPA's Office of
Research and Development (ORD) plans to conduct a three-year study
investigating the exposures and risks to young children from these
pollutants, including PAHs. The data, collection of which are expected to
begin in late 1999 or early 2000, will be used to characterize children's
exposure, understand pathways, and refine exposure models.
Information on how and to what extent children are exposed to PAHs and
other PBTs will be used to guide exposure reduction and environmental
remediation activities and to determine  what additional steps may be
needed to protect young children.	
 National Oceanic and
 Atmospheric
 Administration (NOAA)
 Mussel Watch Program
The National Oceanic and Atmospheric Administration's (NOAA) Mussel
Watch Project has been using measurements of contaminants in mussel
and oyster tissues since 1986 to evaluate the status and trends in
contaminant levels in the nation's Great Lakes, estuarine, and marine
waters.  Sites are visited approximately biennially for collection of animals
to be analyzed for a suite of over 70 contaminants, including PAHs.	
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6.0    CONCLUSIONS

Status of Knowledge Concerning Sources

       Data collected from the Great Lakes states of Illinois, Indiana, Michigan, Minnesota, and
Wisconsin indicate that almost 90 percent of B(a)P emissions in the Great Lakes Basin originate
from two source categories: 46 percent from residential wood combustion and 42 percent from
petroleum refining. Coke ovens are reported to comprise approximately 8 percent; other
unnamed sources are reported to account for 5 percent of B(a)P emissions in the Great Lakes
Basin (EPA, 1998).

       The national emissions inventory for the 7-PAH chemical category, which includes B(a)P
and similar compounds, reports 21 major source categories of 7 PAHs, as well as other, smaller
source categories (EPA, 1998a). Like the Great Lakes B(a)P inventory, the national inventory for
7 PAHs is dominated by two  source categories. For the national inventory, however, these are
wildfires and prescribed burning (48 percent) and residential wood combustion (29 percent).

       The exclusion of several source categories from the Great Lakes inventory of B(a)P
emissions is likely due to a lack of available emissions data from those source categories, rather
than from the absence of those sources in the Great Lakes Basin.  In Ohio, for example, a scrap
tire fire raged for days in August 1999 before it could be extinguished, sending large plumes of
black smoke into the air. Source categories not listed in the Great Lakes inventory but which
may be contributing to B(a)P emissions in the basin include primary aluminum production, open
burning of scrap tires, coal combustion, and on- and off-road vehicles and equipment.
Commercial meat charbroiling and open trash burning are additional emission sources not listed
in either the Great Lakes inventory or the national 7-PAH emissions inventory but which are
reported in the literature (Rogge, 1991; EPA, 1997). Emissions estimates for commercial meat
charbroiling and open trash burning have not been developed.

       The Great Lakes inventory estimates that airborne emissions of B(a)P to the Great Lakes
Basin are approximately 122,000 pounds (61 tons), and PAHs have been identified in the wastes
of several industrial processes. Atmospheric deposition of B(a)P released to air is the main
source of B(a)P to surface waters and may be a primary contributor to sediments in aquatic
systems.  B(a)P in the atmosphere is also capable of long-range transport. To the extent that air
emissions and the generation  of wastes can be controlled, surface water contamination,
deposition to sediment,  and long-range transport might also be reduced.

Regulations and Regulatory Gaps

       While regulations will provide significant control over most industrial point sources of
B(a)P emissions, control of many  area sources is limited. Petroleum refineries,  coke ovens,
primary aluminum plants, and commercial and industrial boilers will be affected by MACT
standards that may be expected to lower B(a)P emissions.  Enforcement and  compliance of
regulations  to control emissions from residential wood-burning, wildfires, scrap tire fires, open
                                           22

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trash burning, and residential coal and oil combustion are not as easily accomplished and may
require innovative approaches, including education, incentives, and voluntary actions.

       As of 1990, newly manufactured wood-fired heaters are required to meet an EPA
certification for particulate matter (PM) emissions. Although this standard has been in effect for
nearly ten years, only about 11 percent of wood-stoves in the U.S. are EPA-certified. The phase-
out of older wood-fired heaters that do not meet EPA's PM limit is slow to take effect. Industry
associations, such as the Hearth Products Association, are taking measures to accelerate the
replacement of older wood-stoves, as well as to provide education on clean burning techniques
that result in lower PM emissions.

       There are many issues associated with wildfire control and prevention. Education and
awareness may be keys to preventing unwanted fires caused by a lack of understanding about fire
conditions and fire causes. The maintenance of qualified and adequate resources to fight fires
and the cooperation  of federal, state, and local organizations are needed to ensure the success of
firefighting efforts in controlling emissions from wildfires.

       Although several states have implemented scrap tire management programs in recent
years, scrap tire fires continue to occur as a result of lighting strikes and vandalism.  In addition,
scrap tires in some landfills and stockpiles have not been cleaned up  or appropriately managed to
prevent or minimize fires.  The development of opportunities to recycle old tires and permits to
combust products derived from used tires also reduce the number of scrap tire piles and therefore
lessen the chance of unwanted fires.

       Regulations  concerning open trash burning vary by state and locality, as does
enforcement. Although the extent of open trash burning in the Great Lakes is not known, the
practice may be more prevalent in rural areas and tribal communities where trash collection and
recycling opportunities may not be as readily available as in urban areas.

       In conclusion, three source categories of B(a)P air emissions in the Great Lakes Basin
have been identified from an inventory compiled with data from five of the eight Great Lakes
states.  Additional source categories have been identified in a national emissions inventory for 7
PAHs. Whereas regulations may adequately control known industrial point sources  of B(a)P
emissions, sources of area emissions prove more difficult to control.
                                           23

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7.0    REFERENCES

Agency for Toxic Substances and Disease Registry, U.S. Public Health Service, (1999)
ATSDR's Toxicological Profiles on CD-ROM, CRCnetBase.

Coburn, Jeff (1999) Research Triangle Institute, personal communication.

Cummings, Anita (1999) OSW, EPA, personal communication.

Dann, T.  (1997) Monitoring of Persistent Toxic Substances in Ontario-Great Lakes Basin,
Environment Canada Technology Development Directorate, Environmental Technology Centre,
October.

Houck, I.E., Tiegs, P.E., McCrillis, R.C., Keithley, C., and Crouch, J. (1999) Air Emissions from
Residential Heating: The Wood Heating Option Put into Environmental Perspective, Proceedings
of Emission Inventory: Living in a Global Environment. New Orleans, Dec. 8-10, 1998, Air and
Waste Management and EPA Specialty Conference, Vol. 1: 373-384.

IADN Scientific Steering Committee, (1998) Technical Summary of Progress under the
Integrated Atmospheric Deposition Program 1990-1996, U.S./Canada IADN Scientific Steering
Committee, January 1998.

Jett, George (1999) OW, EPA,  personal communication.

Martin, Glen (1999) "Despite end to direct piping of sewage, pollution worse now than 30 years
ago," San Francisco Chronicle, August 2, 1999.

Melton, Lula (1999) U.S. Environmental Protection Agency, Metals Group, ESD/OAQPS,
personal communication.

Rogge,W.F., Hildemann, L.M., Mazurek, M.A., Cass, G.R. and Simonelt, B.R. (1991) Sources of
Fine Organic Aerosol. 1. Charbroilers and Meat Cooking Operations, Environ. Sci. Technol.
25:1112-1125.

United States Environmental Protection Agency (1999) http://www.epa.gov/OST/cs/
congress.html.

United States Environmental Protection Agency, "Great Lakes Regional Air Toxic Emission
Inventory Report: Initial Inventory Using 1993 Data," Region 5, U.S. Environmental Protection
Agency, August 1998.

United States Environmental Protection Agency, "1990 Emissions Inventory of Section 112(c)(6)
Pollutants: Polycyclic Organic Matter (POM), 2,3,7,8-Tetrachlorodibenzo-p-dioxin
(TCDD)/2,3,7,8-Tetrachlorodibenzofuran (TCDF), Polychlorinated Biphenyl Compounds
(PCBs), Hexachlorobenzene, Mercury, and Alkylated Lead," Emission Factor and Inventory

                                          24

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Group and Visibility and Ecosystem Protection Group, U.S. Environmental Protection Agency,
April 1998a.

United States Environmental Protection Agency, "Evaluation of Emissions from the Open
Burning Of Household Waste in Barrels," Office of Research and Development, U.S.
Environmental Protection Agency. EPA 600-R-97-134b, November 1997.

United States Environmental Protection Agency, "Air Emissions from Scrap Tire Combustion,"
Office of Research and Development, U.S. Environmental Protection Agency. EPA 600-R-97-
115, October 1997a.

U.S. National Library of Medicine, Hazardous Substances Data Bank (HSDB).  Issue: 99-2, May,
1999.

Van Buren, Michael (1999) Hearth Association, personal communication.
                                         25

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APPENDIX A
       Appendix A contains information on B(a)P releases available from several federal and
state reporting systems.  Federal and state agencies collect information on B(a)P releases as part
of broader programs designed to meet reporting requirements for multiple substances. It is
important to keep in mind that each data set must be interpreted separately due to differences in
reporting requirements and the types of information collected. Table Al presents B(a)P
concentration data from Integrated Atmospheric Deposition Network (IADN) master stations for
1992-1994. Table A2 presents the number of facilities in Great Lakes states holding National
Pollutant Discharge Elimination System (NPDES) permits to discharge B(a)P, from EPA's
Permit Compliance System (PCS).  Table A3 lists the 1990 7-PAH Clean Air Act (CAA) Section
112(c)(6) emissions estimates by source category. Table A4 lists the sites in EPA Region 5
currently on the Final National Priority List (NPL) with B(a)P as a contaminant of concern.

Table A1.  B(a)P Concentration Data from  IADN Master Stations 1992-1994 Annual
           Averages
Year
1992
1993
1994
Superior
Precip
(ng/L)
2.90
1.45
2.90
Particle
(pg/m3)
11.0
2.38
11.0
Gas
(pg/m3)
9.30
8.90
9.30
Michigan
Precip
(ng/L)
3.80
1.81
3.80
Particle
(pg/m3)
21.0
8.88
21.0
Gas
(pg/m3)
10.4
9.10
10.4
Huron
Precip
(ng/L)
NA
NA
NA
Particle
(pg/m3)
NA
28.1
14.3
Gas
(pg/m3)
NA
NA
NA
Erie
Precip
(ng/L)
5.10
5.04
5.10
Particle
(pg/m3)
44.0
35.9
44.0
Gas
(pg/m3)
13.0
9.20
13.0
Ontario
Precip
(ng/L)
3.00
NA
NA
Particle
(pg/m3)
45.0
54.2
36.0
Gas
(pg/m3
3.00
NA
NA
Table A2.  Number of Facilities in Great Lakes States Holding NPDES Permits to
           Discharge B(a)P, from PCS
Number of Facilities Reporting
IL
59
IN
5
Ml
8
MN
2
NY
-
OH
7
PA
-
Wl
3
Total
84
Data is the most current available: 1995-1999.
                                          A-1

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Table A3. 1990 7 PAH CAA Section 112(c)(6) Emissions Estimates by Source Category

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22

Source Category
Wildfires and prescribed burning
Residential wood combustion
Primary aluminum production
Coke ovens: charging, topside & door leaks
Open burning of scrap tires
Commercial coal combustion
Onroad vehicles
Residential coal combustion
Coke ovens: pushing, quenching & battery stacks
Non-road vehicles & equipment - other(1 )
Petroleum refining: all processes
Pulp & paper manufacturing - Kraft recovery furnaces
Industrial coal combustion
Portland cement manufacture: non-hazardous waste
kilns
Other sources(2)
Portland cement manufacture: hazardous waste kilns
Residential oil combustion
Asphalt roofing production
Industrial waste oil combustion
Industrial wood/wood residue combustion
Industrial stationary 1C engines - natural gas
Commercial wood/wood residue combustion
TOTAL
Percent of Total
7-PAH Emissions
48.30%
28.66%
7.06%
3.60%
2.63%
1.80%
1.73%
1.60%
1.58%
1.20%
0.82%
0.19%
0.15%
0.13%
0.11%
0.10%
0.09%
0.08%
0.07%
0.06%
0.05%
0.05%

7-PAH Emissions
(Ibs/yr)
1,928,000
1,144,000
282,000
143,600
105,000
72,000
68,800
63,800
60,200
48,000
32,800
7,480
6,180
5,200
4,391
4,160
3,400
3,360
2,680
2,420
2,060
2,020
3,991 ,600 Ibs/yr
(1 ) Includes 74 different equipment types, such as agricultural, construction, and industrial equipment and
vehicles.
(2) "Other sources" includes: Asphalt hot-mix production, carbon black production, cigarette smoke,
commercial oil combustion, crematories, drum and barrel reclamation, ferroalloy manufacture, hazardous
waste incineration, industrial oil combustion, industrial stationary engines - diesel, iron foundries, landfill
(gas) flares, pulp & paper manufacturing - lime kilns, residential natural gas combustion, scrap tire
incineration, secondary lead smelting, sewage sludge incineration, and utility oil combustion.
(3) These refer to EPA air programs that target the emissions source category listed. They may or may not
directly affect PAH emissions.
                                     A-2

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Table A4.  Sites Within EPA Region 5 Currently on the Final NPL (Superfund) with B(a)P
          Detected as One Contaminant of Concern

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
Site Name
Allied Chemical & Ironton Coke
Continental Steel Corp.
Douglass Road/Uniroyal, Inc., Landfill
Electro voice
Feed Materials Production Center (USDOE)
H. Brown Co., Inc.
Lower Ecorse Creek Dump
Mound Plant (USDOE)
Ormet Corp.
Parsons Casket Hardware Co.
Reilly Tar & Chemical (Indianapolis Plant)
Rockwell International Corp. (Allegan)
Sanitary Landfill Co. (Industrial Waste)
Skinner Landfill
Sturgis Municipal Wells
Van Dale Junkyard
Wright-Patterson Air Force Base
Yeoman Creek Landfill
City
Ironton
Kokomo
Mishawaka
Buchanan
Fernald
Grand Rapids
Wyandotte
Miamisburg
Hannibal
Belvidere
Indianapolis
Allegan
Dayton
West Chester
Sturgis
Marietta
Dayton
Waukegan
State
Ohio
Indiana
Indiana
Michigan
Ohio
Michigan
Michigan
Ohio
Ohio
Illinois
Indiana
Michigan
Ohio
Ohio
Michigan
Ohio
Ohio
Illinois
                                      A-3

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