Questions and Answer Forum

Calgon Carbon, DeQuincy

The wastes from the thermal reactivation process that is planned for the DeQuincy area were first going to be discharged into the Sabine River, then they were going to be disposed of in an injection will. Currently, the proposal is to treat the off-gases with a dry scrubber. What is a dry scrubber?

A dry scrubber is a process that injects either dry solids that absorb potential contaminants or a slurry of water and salt that reacts with the contaminants. The resulting product is a damp to dry powder that is then removed by an electrostatic precipitator or a baghouse. Calgon Carbon Corp. has selected a baghouse to remove the remaining powder.

Has the Department of Environmental Quality considered the possibility that the 20+ tons of particulates released into the atmosphere from the proposed Calgon Carbon facility at DeQuincy could be carrying halogenated dioxins?

Yes. Prior to full authorization for operations, the facility must conduct trial burn tests. One series of tests will be done to determine the operating limits of the unit. A second set of tests will be done to estimate emissions for an indirect risk assessment that may be conducted by the United States Environmental Protection Agency in Region 6. The results of the indirect risk assessment have been put into combustion unit permits to minimize the projected thirty-year impact of site emissions.

Given the concerns that prompted the study of blood dioxin levels in Calcasieu Parish by the Agency for Toxic Substances and Disease Registry (ATSDR) would it be prudent to test the soot at Calgon’s other facilities for dioxin before granting a permit for the new facility in DeQuincy?

Dioxin/Furan emissions will be included in the emissions testing during the trial burns. The dioxin/furan data is also used in the indirect risk assessment. The question of soot releases into ambient air has already been questioned in the Technical Notice of Deficiencies (NODs) that will be released to the facility as part of the permit application review.

Calgon Carbon wants to put 3 seventy-foot rotating kiln incinerators near the DeQuincy Middle School and feed 500 different RCRA codes hazardous materials into the burners. With the nearest state-operated air monitoring station perhaps 20 miles away in Westlake, how can citizens be assured of the safety of school children?

First, the 500 chemicals listed by the facility are standard practice to “cover their backsides” in case a chemical is found in the spent carbon that they did not expect. The methodology of the trial burn will use a chemical that is harder to destroy than any chemical in the list of 500. Failure of the trial burn to demonstrate compliance will fail the facility. Also, the indirect risk assessment conditions that will be in the permit are based upon a conservative model that limits average emissions to normally one-tenth peak emissions or less.

When emissions are released into the atmosphere from a stack that is 100-feet high, characteristically how far can the emissions travel from the point of release?

The distances emissions can travel from any given stack are dependent on particle size, distribution and density, wind speed and direction, stack height, gas velocity, and temperature. The indirect risk assessment model uses an air dispersion model to take emissions data and determine the dispersion pattern on a five-year average. This five-year average analysis then feeds the thirty-year indirect risk assessment model. More information would be available from the United States Environmental Protection Agency, Region 6 where the models are run.

If the Calgon Carbon facility near DeQuincy becomes a reality, would the Lake Area Industry Alliance, United States Environmental Protection Agency, and the Louisiana Department of Environmental Quality commit jointly to establish an air monitoring station down wind from the facility?

If the permit(s) are granted for the facility, air monitoring will be required for the operation.

Newspaper articles have appeared describing the funding and potential ethical problems being experienced by the Louisiana Department of Environmental Quality. In the light of these problems in the agency, why should we have confidence in the permitting and regulatory capability of the agency as they relate to the Calgon Carbon project?

The Louisiana Legislature recently approved fee increases and additional State General Fund monies, which will provide this agency with funds necessary to continue operation of department programs. These funds will also allow the agency to continue staffing levels in the area of enforcement as well as other regulatory responsibilities. Additionally, the Department is committed to having an ethically responsible workforce, and we have committed to train all employees on the requirements of the Code of Governmental Ethics. With help from the Board of Ethics, we have trained the vast majority of our employees, and we are in the process of scheduling training for all remaining employees. If there are ethical concerns regarding LDEQ employees and the Calgon Carbon project, the Department and the Board of Ethics are available to investigate alleged violations of the Ethics Code.

Can the citizens of DeQuincy be assured that the operation of the proposed Calgon Carbon project in that town will not harm rare and endangered bird species found in the forests around that community? For example, are the red-cockaded woodpeckers in the area likely to be damaged?

No assurances can be given. However, with the review of the technical design of the facility and the demonstration of regulatory compliance with a trial burn, the confidence level of compliance increases. With periodic monitoring and documentation review the confidence in facility compliance with the statutes and regulations continues to increase. There are no guarantees.

As with so many endangered species, it is suspected that loss of habitat will cause more risk to the red-cockaded woodpecker than this facility. Loss of habitat can be associated with companies expanding operations in suburban and rural areas as wells as citizens seeking country retreats in the wilderness. Unfortunately, the Department cannot control all factors that could impact the red-cockaded woodpecker.

Air Permit issues

Calgon Carbon is seeking an air permit to add about 90 tons of air pollutants into the air of Calcasieu Parish; Citgo plans to add over 1,000 tons per year of new air pollutants into the atmosphere with a plant expansion. How can the Louisiana Department of Environmental Quality and the United States Environmental Protection Agency keep allowing more air pollution in Calcasieu Parish?

There are programs, such as New Source Review (NSR) and Prevention of Significant Deterioration (PSD) that were designed to minimize any impact of new construction on air quality. These programs are designed to evaluate the emissions change and compare to ambient air quality differences expected from the change. The regulations specify the limitations that have to be met. If these limitations are exceeded, actions have to be taken by the facility in the design and permitting phase to reduce the emissions and the projected impact to below the specified limits.

What can citizens do to impact the system that should be protecting the citizens instead of allowing greater pollution?

The environmental laws that EPA and the states administer do not prohibit pollution outright; rather, they treat some level of pollution as "acceptable" when pollution sources are regulated under individual, facility-specific, permits recognizing society's demand for such things as power plants, waste treatment systems, and manufacturing facilities. In effect, Congress—and, by extension, society—has made a judgment that some level of pollution and possible associated risk should be tolerated for the good of all, in order for Americans to enjoy the benefits of a modern society—to have heat in our homes, and the products we use to clean dishes or manufacture our wares. The expectation and belief of the regulators is that, assuming the facilities comply with their permit limits and terms, the allowed pollution levels are acceptable and low enough to be protective of the environment and human health. Any proposed major project will require public notice in the local newspaper. This notice will afford citizens the opportunity to submit written comments on the proposed project. In addition, the department may conduct a Public Hearing for some proposed major projects. The public will be able to make oral comments and/or submit written comments associated with any such hearing. All such relevant comments are considered prior to making a final permit decision.


A comment period is now open for a proposed permit for a Citgo project that will add seven tons per day of additional pollutants into the local atmosphere. What is the point of having a program called Prevention of Significant Deterioration if all the program does is allow for more pollution to be added on top of what we already have?

The provisions of the Prevention of Significant Deterioration program apply to the construction of any new major stationary source or to any major modification at a major stationary source at a location where all pollutants are in attainment (i.e., Calcasieu Parish). The main purpose of Prevention of Significant Deterioration review is to require the company to apply Best Available Control Technology (BACT) to new or modified sources. The CITGO Petroleum Corporation Cat Gasoline Hydrotreater permit was signed October 1, 2002. The new air emission sources from the proposed project include three furnaces and three reboilers, a storage tank, a flare and fugitives. The BACT requirements are as follows. Ultra low-NOX burners (ULNB) will be used to limit NOX emissions from the furnaces and reboilers to 0.04 lbs/MM BTU. These burners, used in combination with good combustion practices, using NSPS Subpart J fuel gas with H2S concentration of equal to or less than 0.10 grains/dscf are BACT for SO2, NOX, and VOC emissions from the furnaces and reboilers. The storage tank will be equipped with an internal floating roof and submerged fill pipe, which will limit VOC emissions from the tanks. The new flare will comply with NSPS Subpart A requirements for control devices and will handle emergency releases. A streamlined equipment leak-monitoring program will be applied to limit fugitive emissions from process equipment. With all these control measures, the adverse environmental impact will be minimized or avoided.

Regulatory agency issues DEQ

The Secretary of the Louisiana Department of Environmental Quality in 2001 said that the agency does not have the resources to conduct annual inspections of industrial facilities and requested that the agency be relieved of that responsibility. Has anything happened in this area?

No. There have been no changes to the Environmental Quality Act related to inspection responsibilities of the Department. The Department does perform many inspections of industrial facilities each year, but does not have adequate staffing to inspect all permitted facilities once per year as required by the Act. For fiscal year ’93, the Department has 14 fewer inspections than in the prior fiscal year.

Are companies given advanced notice of major inspections by the Louisiana Department of Environmental Quality?

That depends on the type and intent of the inspection. In some cases where specific technical expertise is needed, coordination of the inspection is done to ensure that expertise is available. During these scheduled inspections historical records, strip chart recordings and dated records are reviewed. The falsification of historical documents, strip chart recordings and dated records are not easily falsified. Discrepancies are examined.

Most field inspections are surprise inspections with checks on the operations staff to ensure the workers know what they are doing and that the facility is in compliance at that moment. These inspections also review the paperwork specified above.

Since there are no legal requirements for an operator of a hazardous waste incinerator to keep records of how many times the automatic waste feed cutoff system of an incinerator is activated, how can the Louisiana Department of Environmental Quality and the general public have any idea of the number and magnitude of incinerator upsets?

The Louisiana Hazardous Waste Regulations do contain specific requirements pertaining to the automatic waste feed cutoff system of an incinerator. The Louisiana Administrative Code (LAC) 33:V. 3119, Monitoring and Inspections, contains specific provisions addressing the waste feed cutoff system. The LAC also specifies that this monitoring and inspection data must be recorded and the records must be placed in the facility’s operating log as required by LAC 33:V.1523.

Additionally, the hazardous waste permit governing the operation of the incinerator sets forth provisions pertaining to the waste feed cutoff system and the submittal of correspondence to DEQ identifying excessive waste feed cutoffs (i.e., those which exceed a limit indicated in the permit). The specific waste feed cutoff language also requires that the correspondence from the facility indicate what triggered the cutoff and what steps were taken to resolve and prevent a similar cutoff from occurring in the future.

Cancer Issues in Calcasieu Parish

What is a soft tissue sarcoma?

Sarcomas are cancers of connective (mesenchymal) tissues. Soft tissue sarcomas include cancers of sites such as muscle, fat, and blood vessels, and are distinguished from sarcomas of bone. Soft tissue sarcomas comprise a small portion of cancers - less than five percent. The majority of cancers are carcinomas, derived from epithelial cells (i.e., cells that line surfaces of the body such as skin, the gut, the lungs, and the bladder).

Does the recent Department of Health and Hospitals cancer study show that Calcasieu Parish has the highest cancer rate for soft tissue sarcoma cancer in Louisiana and also higher than national numbers?

The Department of Health & Hospitals (DHH) cancer statistics review found soft tissue tumor incidence elevated in Calcasieu Parish compared to statewide rates in 3 of 4 demographic groups (black females, white females, and white males). The cancer review did not assess whether soft tissue tumor incidence in Calcasieu Parish was higher than every other parish in Louisiana. Calcasieu Parish soft tissue tumor rates that were elevated compared to the state were also higher than national averages.

Does the rate for soft tissue sarcoma in Calcasieu Parish mean that we in the parish have the highest rate of this type of tumor in the United States?

Such comparisons were not done. Soft tissue tumor incidence in Calcasieu Parish was higher than national averages, but the DHH reviewers did not compare to every county in the United States.

Do we know for a fact that soft tissue sarcoma is not caused by chemicals in the air that we breathe in Calcasieu Parish?

The cancer review did not address causation, only relative cancer incidence. We cannot say specifically what caused the soft tissue sarcoma cases in Calcasieu Parish. We do know from published studies that exposure to certain chemicals is among the risk factors for soft tissue sarcomas. Our cancer incidence review is designed to evaluate whether current incidence (risk) of this cancer is higher, lower, or the same magnitude as risk in other areas. The causes of the excess that was found for this type of cancer in Calcasieu would require data on individual exposures to many factors over several decades and such data are not available.

Do chemicals like vinyl chloride cause soft tissue cancers?

Vinyl chloride exposure has been associated with increased risk of angiosarcoma of the liver, a very rare form of soft tissue cancer. There were no cases of angiosarcoma in Calcasieu Parish during the period reviewed.

What is the health effect when multiple chemicals are breathed into the body, even in very small amounts?

The Agency for Toxic Substances & Disease Registry (ATSDR) has recently released a draft Toxicological Profile addressing this fundamental, complex issue. Generally speaking, health effects can be additive, synergistic (greater than the sum of individual effects), or antagonistic (less than the sum of individual effects). Specifically, however, very little is known in this area.

Soft tissue sarcomas constitute what percentage of the total tumor inventory in Calcasieu Parish over the past 10 years?

Soft tissue sarcomas comprised roughly one percent of all cancers during the study period.

Is exposure to dioxin a risk factor in the development of soft tissue sarcoma?

Several studies have associated dioxin exposure with soft tissue sarcoma. Small numbers of cases in these studies make the association less than certain, but it appears likely.

The public explanation of cancer statistics from Calcasieu Parish indicate that the rates in the parish are comparable to rates in other parts of the state; however, the rates of rare soft tissue sarcoma appear from the written reports to be significantly elevated. Can you comment on these statistics?

The cancer review compared incidence of all cancers combined and cancers of 22 specific anatomic sites. Overall cancer incidence for black females, white females and white males in Calcasieu Parish was comparable to statewide rates. Overall cancer incidence for black males was significantly lower than the state rate. Black females had significantly lower incidence of cervical cancer and multiple myeloma in Calcasieu Parish than statewide, but had significantly higher incidence of colorectal cancer, lung cancer and soft tissue tumors than statewide. Site-specific cancer incidence for black males in Calcasieu Parish did not differ significantly from black males statewide. White females had significantly lower ovarian cancer incidence in Calcasieu Parish than statewide while they had significantly higher rates of melanoma skin cancer, cervical cancer, bladder cancer, soft tissue tumors and lung cancer. White males in Calcasieu Parish had a significantly lower incidence of oral cavity and pharyngeal cancers than statewide and significantly higher incidence of skin cancer and soft tissue tumors.

Why does the Cancer Registry operated for the state fail to collect data on the lifestyle and environmental factors associated with tumor patients?

The Louisiana Tumor Registry (LTR) is for surveillance of disease, in this case cancer. The LTR performs functions according to federal and state registry laws and federal registry guidelines. The LTR is mandated to collect information on cancer diagnosis and treatment from medical records, where information on lifestyle and environmental exposure is not available. The function and role of the LTR is consistent with all cancer surveillance programs in the nation and in all states. Information on lifestyle and other exposures on people with and without cancer can only be obtained by special studies that require grant funds. Surveillance of the environment is the role of the United States Environmental Protection Agency (EPA), the state Department of Environmental Quality, and other agencies.

Regulator and trustee agencies are scheduled to release data on dioxin contamination of seafood from the Calcasieu system. What level of contamination will trigger dioxin advisories concerning the consumption of seafood?

A public health risk analysis of fish-tissue data for the Calcasieu Estuary will be conducted following the guidelines set forth in Protocol for Issuing Health Advisories and Bans on Chemical Contamination of Fish/Shellfish in Louisiana published by DHH in January 1997. The protocol does not establish action levels for chemicals of concern. Instead, data are evaluated on a case-by-case basis using current toxicity values and, if available, site-specific exposure assumptions.

What is the status of various public advisories concerning the consumption of seafood taken from the Calcasieu Estuary because of contamination of fish and shellfish with such pollutants as hexachlorobenzene [(HCB)], hexachlorobutadiene [(HCBD)], polychlorinated biphenyls [(PCBs)] and mercury?

The following table presents a summary of the fish-consumption advisories issued for water bodies along the Calcasieu Estuary.
 

The above advisories may be further reviewed (or new advisories may be issued for the Calcasieu Estuary) as new data become available.

What is the status of the proposed medical facility in the Mossville area and how long will it take for the medical facility to open?

To DHH’s knowledge, there are no plans to establish a new medical facility in the Mossville area. However, through its Office of Public Health, the agency has undertaken the following measures to improve the health of the residents of Mossville and Calcasieu Parish:

• Worked at the federal level with EPA and the United States Department of Health & Human Services to contract the services of environmental health experts to provide continuing education to local health providers to address environmental health concerns of patients in the parish.

• Offered to assist qualifying residents in obtaining medical coverage through different state and federal resources:

1. Grants from the Office of Rural Health Policy of the Health Resources & Services Administration (through the DHH Office of Rural Health);
2. Medicare;
3. Medicaid;
4. Louisiana Children’s Health Insurance Program;
5. Care for the uninsured by the Louisiana State University Health Sciences Center (through the Dr. Walter O. Moss Regional Medical Center in Lake Charles); and
6. Support of ATSDR efforts to prepare healthcare professionals at the federally Qualified Health Center in Lake Charles to provide care to area patients.
 

Citizen Participation

Would McNeese consider assigning environmental science or American government students to attend the Calgon Carbon permit hearings and report to the public on the proceedings?

The faculty at McNeese State University cannot “assign” students to engage in activities outside of the classroom unless that activity is clearly related to the educational mission of some course and is listed in the class syllabus for that course. We can encourage, advocate, beg, implore, plead, or promote, but not assign. Getting students into activities off campus is especially difficult.

Questions Concerning CONOCO

On February 20, 2002, when the air monitoring stations were up-wind from Conoco and Lake Charles was down-wind, Conoco had a six-hour release of over 7,000 pounds of air pollutants including benzene, other hydrocarbons, and catalyst that may have contained asbestos. No shelter-in-place was called even though strong odors were detected as far away as Highway 14. Conoco did not notify the Office of Emergency Planning of the hydrocarbons during the event. This event raises several questions:

There are some factual errors in the background paragraph leading up to the three questions.
The release that occurred on February 20, 2002 consisted of a mixture of Fluidized Catalytic Cracking (FCC) catalyst, gas oil feed, and reaction products (including an estimated 5.9 pounds of benzene). FCC catalyst does not contain asbestos. The catalyst is a clay-like, inert, nonhazardous material.
The release resulted from a scheduled maintenance activity on the FCC. Because of the potential for a release from this activity, the local Office of Emergency Planning and the Louisiana Department of Environmental Quality (LDEQ) were notified ahead of time at 8:37 A.M. The release began at 9:45 A.M. Notification of the actual release was made to the LDEQ, Local Emergency Planning Committee (LEPC) and HazMat between 9:55 A.M. and 10:07 A.M. In addition, both local TV stations and an FM radio station were provided with advisories at 10:15 A.M.

Why was a shelter-in-place not called during the event?

A shelter-in-place was called for the south side of I-10 (Zones 3 and 6 for LEPC purposes).

What penalty will Conoco face because of the long release time and the amount of material released during the event?

Conoco complied with all regulatory notification requirements and provided all available release information at the time notifications were made. In addition, a formal written follow-up report was submitted as required, on February 27, 2002. No penalties have been assessed at this time.

Questions Concerning PPG Releases

At least some of the high readings of air toxics detected by the enhanced air monitoring stations during the first phase of the effort were related to an event at PPG involving the loss of material through a cooling tower. Will you please explain the nature of this event.

A process cooler sustained a tube failure that resulted in a process chemical leaking into the cooling tower water and ultimately out of the cooling tower stack.

Was PPG aware of the leak in the cooling tower before the material was detected by the off-site monitoring station?

Yes, PPG’s onsite monitoring systems detected a leak.

How did the release go undetected by PPG employees?

PPG employees detected the leak in response to unit monitoring system alarms.

If the leak went undetected by the monitoring system in place at PPG, did any employees note the leak by smell or some other detection device.

The monitoring system detected the leak. There were no other sensory or visual indications of the release.

If the leak went undetected by monitors or employees at PPG, what does this tell the public about the leak detection and management system in place at PPG?

The monitoring system detected the leak.

Has anything been changed in the leak detection and management system at PPG as a result of this episode?

PPG was and is in compliance with the approved Leak Detection and Elimination Plan under Federal regulations as well as Louisiana statutes. However, enhancements to the existing system include the installation of additional monitoring devices in the area.

Questions Concerning Units

If a part per billion (ppb) is one second in 32 years, isn’t one femtogram one second in 32 million years?

Yes. One billion seconds is to one second as follows:
One billion seconds divided by 3600 sec/hour divided by 24 hours/day divided by 365 days/year = 31.7 years/one second.

If a part per billion is a hundred times as much as a part per quadrillion, is it not correct that some toxins such as 2,3,7,8-tetrachlorodibenzo-para-dioxin (TCDD) have negative effects on living things at the part per quadrillion range?

The first part of the question is wrong; 1 ppb = 1 in 109 and 1 part per quadrillion is 1 in 1015, or one million time smaller, not 100 times smaller. Reversing the explanation, 100 times as much as a quadrillion = 100 times 1 x 1015, which equals 1 x 1013 not 1 x 109 (the latter being a ppb).

As far as the toxicity is concerned, the available evidence does not support the statement.

Questions for the USEPA

Why is yearly averaging of chemicals in the atmosphere used as a parameter when there is no scientific health basis to support the use of this measure?

Levels of air pollutants in the atmosphere are usually described in terms of concentration over a given period of time. The period of time employed can depend on several things such as: the method of measurement, the purpose of the monitoring, the type of value the measured air concentrations will be compared against (such as a state ambient standard), or whether short-term (acute) or long-term (chronic) health risks are to be evaluated based on the measured or estimated air concentrations.

Yearly averaging of the concentrations of chemicals in the atmosphere does make sense if chronic (long-term) potential health risks (both cancer and non-cancer risks) are being evaluated. Such risk evaluations typically look at impacts of chemicals over a lifetime (70 years). Consequently, obtaining an annual average that is assumed to exist each year of the lifetime risk evaluation period is practical and appropriate.

If the lifetime potential health risks are being evaluated, the idea is to get a representative value on which to estimate long-term risks to citizens being exposed. Annual averaging has the benefit of more appropriately taking into account the varying amounts of the chemical that might be released at different times during the year as well as the impact of seasonal weather conditions on the concentration of the chemical in the air.

When will meaningful hourly averaging be implemented as a parameter with which to measure human exposure to toxicants?

As mentioned in the answer to the previous question, the period of time over which an air concentration is averaged depends on several factors. Hourly averaging can be, and in some cases is, used as a parameter to measure human exposure to air contaminants.
Hourly averaging is more appropriate for evaluation of short-term exposures, and such data is collected and used on a case-by-case basis employing available guidance. However, there is currently no Federal Clean Air Act requirement for hourly averaging of ambient air toxics to be implemented as a parameter with which to measure human exposed to toxicants.

When will standards for the exposure of humans to chemical toxicants be established for use in protecting human health?

From a federal regulatory point of view, the Federal Clean Air Act does not require the US EPA to develop ambient air standards for air toxics. The Act takes an approach of primarily using technology-based controls at the emissions source. To change the current approach, Congress would need to change the Clean Air Act to require federal ambient air standards for air toxics to be developed.
Fortunately for the citizens of Calcasieu Parish and all of Louisiana, the State of Louisiana is one of the few states in the country that have developed ambient air standards for air toxics. These state ambient standards go above and beyond what is required by the Federal Clear Air Act for air toxics.