MCIC

Acceptable Ambient Acceptable Ambient LevelLevel Hydrogen Sulfide Hydrogen Sulfide

EMC Air Quality EMC Air Quality Committee Committee

12 February 12 February 20032003

byby

Preston Howard, Preston Howard, PresidentPresident

Manufacturers & Chemical Manufacturers & Chemical IndustryIndustry

Council of North Council of North Carolina Carolina

MCICMCIC

MCIC

6 Affected MCIC Members 6 Affected MCIC Members Sites - All in Economically Sites - All in Economically Depressed RegionsDepressed Regions

Blue Ridge Paper - CantonBlue Ridge Paper - Canton International Paper International Paper

• Riegelwood Riegelwood • Roanoke RapidsRoanoke Rapids

PCS Phosphate - AuroraPCS Phosphate - Aurora WeyerhaeuserWeyerhaeuser

• New BernNew Bern• PlymouthPlymouth

MCIC

All are Major Economic All are Major Economic HubsHubs

Directly employ from 500 to 1200 Directly employ from 500 to 1200 on-siteon-site

Statewide 9000 total jobsStatewide 9000 total jobs Thousands of “spin-off” jobsThousands of “spin-off” jobs Annual payroll $494 MillonAnnual payroll $494 Millon $750 Million in purchases from NC $750 Million in purchases from NC

vendorsvendors

MCIC

ResponsibilitiesResponsibilities

SAB - Risk AssessmentSAB - Risk Assessment• No considerations other than No considerations other than

sciencescience

EMC - Risk ManagementEMC - Risk Management• Practical considerationsPractical considerations• Technical feasibilityTechnical feasibility• Economic impactEconomic impact

MCIC

Regulated SourcesRegulated Sources

Six sites owned by MCIC member Six sites owned by MCIC member companies = 14% of all Hcompanies = 14% of all H22S S emissions in NCemissions in NC

86% of H86% of H22S emissions would not be S emissions would not be subject to the new AALsubject to the new AAL

Is it prudent to spend $500 Million Is it prudent to spend $500 Million to control 14% of the emissions?to control 14% of the emissions?

MCIC

HH22S Emissions in North S Emissions in North CarolinaCarolina

Targeted Industry6,412,620 lb/yr

16.16%

Asphalt Industry204,913 lb/yr

0.52%

Municipal WWTP(not a targeted industry),

17,660 lb/yr0.04%

Animal Husbandry(not a targeted industry)

33,046,201 lb/yr83.28%

Figure 1 Hydrogen Sulfide Emissions in North Carolina

MCIC

Jappinen et al. 1990Jappinen et al. 1990

““to assess the possible effects of to assess the possible effects of low concentrations of Hlow concentrations of H22S on S on respiratory function”respiratory function”

Exposed 10 Exposed 10 asthmaticsasthmatics to 2 ppm to 2 ppm for 30 min.for 30 min.

2 ppm = 2700 ug/m32 ppm = 2700 ug/m3 current AAL is 2100 ug/m3current AAL is 2100 ug/m3

MCIC

Conflicting interpretations Conflicting interpretations of Jappinen’s resultsof Jappinen’s results

SABSAB Concluded that the Concluded that the

bronchial bronchial obstruction obstruction experienced by 2 of experienced by 2 of the 10 asthmatics the 10 asthmatics constituted an constituted an asthmatic responseasthmatic response

JappinenJappinen noted that the noted that the

“increase [in “increase [in bronchial bronchial obstruction] was obstruction] was not statistically not statistically significant and did significant and did not result in not result in clinical symptoms”clinical symptoms”

MCIC

Bruce Dalton, MD, Bruce Dalton, MD, FACOEMFACOEM

““Jappinen study findings are Jappinen study findings are consistent with population studies consistent with population studies of residents living near industrial of residents living near industrial sources of hydrogen sulfide”sources of hydrogen sulfide”

““the SAB’s recommendations are the SAB’s recommendations are based on interpretations of the based on interpretations of the Jappinen study that are inconsistent Jappinen study that are inconsistent with the data as published”with the data as published”

MCIC

Vickie L. Tatum, Ph.D.Vickie L. Tatum, Ph.D.

““The SAB implies ...that exposure to The SAB implies ...that exposure to low levels of hydrogen sulfide trigger low levels of hydrogen sulfide trigger asthma attacks . Such conclusions asthma attacks . Such conclusions are not supported by the scientific are not supported by the scientific and medical literature, nor are they and medical literature, nor are they shared by other bodies.”shared by other bodies.”

Michigan Environmental Science Michigan Environmental Science Board interpreted Jappinen - Board interpreted Jappinen - “asthmatic subjects [are] not more “asthmatic subjects [are] not more susceptible to [the] effects of Hsusceptible to [the] effects of H22S S

MCIC

OthersOthers

1997 American Conference of 1997 American Conference of Governmental Industrial Hygienists Governmental Industrial Hygienists - “studies on respiratory function - “studies on respiratory function of pulp mill workers and of pulp mill workers and asthmatics at 2 ppm hydrogen asthmatics at 2 ppm hydrogen sulfide failed to find a statistically sulfide failed to find a statistically significant change produced by the significant change produced by the hydrogen sulfide”hydrogen sulfide”

MCIC

““Real world” studies…Real world” studies…

11 different studies on respiratory health 11 different studies on respiratory health of residents near pulp mills and refineriesof residents near pulp mills and refineries

10 studies found 10 studies found nono evidence of evidence of significantly increased incidence of significantly increased incidence of asthma or asthma-like symptomsasthma or asthma-like symptoms

1 study found increased incidence of 1 study found increased incidence of asthma, but authors noted that other asthma, but authors noted that other factors, such as mold in homes and factors, such as mold in homes and pollen, appeared to play a rolepollen, appeared to play a role

MCIC

The 1 hr AAL derived from The 1 hr AAL derived from Jappinen should be Jappinen should be discounteddiscounted

Is not supported by Jappinen (the author)Is not supported by Jappinen (the author) Is not supported by scientific and medical Is not supported by scientific and medical

literatureliterature Is not supported by interpretations by other Is not supported by interpretations by other

government agencies (Michigan ESB)government agencies (Michigan ESB) Is not supported by American Conference of Is not supported by American Conference of

Government Industrial HygienistsGovernment Industrial Hygienists Is not supported by population studies of Is not supported by population studies of

residents living near industrial sources of Hresidents living near industrial sources of H22SS

MCIC

Vanhoorne et al. 1995Vanhoorne et al. 1995

Basis for SAB’s 24 hr AAL of 33 Basis for SAB’s 24 hr AAL of 33 ug/m3ug/m3

Study of eye irritation complaints Study of eye irritation complaints among workers at a viscose rayon among workers at a viscose rayon plantplant

Workers were exposed to both Workers were exposed to both hydrogen sulfide and carbon hydrogen sulfide and carbon disulfidedisulfide

MCIC

Quotes from Quotes from Vanhoorne. . .Vanhoorne. . .

““the prevalence of eye complaints… is the prevalence of eye complaints… is clearly associated with exposure. clearly associated with exposure. However, deciding which of the two However, deciding which of the two suspected agents, Hsuspected agents, H22S or CSS or CS22, was , was responsible proved impossible in this responsible proved impossible in this study.”study.”

Last year EPA judged studies like Last year EPA judged studies like Vanhoorne to be “unsuitable” due to the Vanhoorne to be “unsuitable” due to the “co-exposure to other chemicals like CS“co-exposure to other chemicals like CS22””

MCIC

Vanhoorne . . .Vanhoorne . . .

Since Vanhoorne involved the co-Since Vanhoorne involved the co-exposure of Hexposure of H22S and CSS and CS22, and since , and since EPA has indicated that the use of EPA has indicated that the use of studies involving such co-exposure is studies involving such co-exposure is inappropriate, MCIC believes that the inappropriate, MCIC believes that the EMC should disregard the Vanhoorne EMC should disregard the Vanhoorne study and the proposed AAL of 33 study and the proposed AAL of 33 ug/m3 that was derived from itug/m3 that was derived from it

MCIC

MCIC Position MCIC Position

The SAB offered a 24 hr AAL of 120 ug/m3, The SAB offered a 24 hr AAL of 120 ug/m3, based on Brenneman studybased on Brenneman study

MCIC’s experts have reviewed this derivationMCIC’s experts have reviewed this derivation Scientific disagreement over the Brenneman Scientific disagreement over the Brenneman

study is not extensivestudy is not extensive MCIC believes that compliance with this 24 hour MCIC believes that compliance with this 24 hour

AAL is achievable at reasonable cost, if AAL is achievable at reasonable cost, if accompanied by an exemption for WWTPaccompanied by an exemption for WWTP

MCIC has no objection to adoption of 120 ug/m3 MCIC has no objection to adoption of 120 ug/m3 (24 hr), with WWTP exemption and compliance 5 (24 hr), with WWTP exemption and compliance 5 years following permit renewalyears following permit renewal

MCIC

What should the EMC do?What should the EMC do?

We know from staff about the severe economic We know from staff about the severe economic hardship associated with 56 ug/m3 (1 hr)hardship associated with 56 ug/m3 (1 hr)

We know there is considerable disagreement in the We know there is considerable disagreement in the scientific and medical communitiesscientific and medical communities

Scientific complexity/disagreement causes confusion Scientific complexity/disagreement causes confusion Confusion breeds a tendency to “defer” the decision to Confusion breeds a tendency to “defer” the decision to

the science experts - the risk assessors the science experts - the risk assessors Urge youUrge you not not to shirk your risk MANAGEMENT to shirk your risk MANAGEMENT

responsibility by deferring a management decision to responsibility by deferring a management decision to risk ASSESSORSrisk ASSESSORS

This decision is rightfully made by the EMC - you are the This decision is rightfully made by the EMC - you are the risk MANAGERS - you should decide the appropriate AALrisk MANAGERS - you should decide the appropriate AAL

MCIC

High regard for SABHigh regard for SAB

DR. Lucier and his colleagues on the DR. Lucier and his colleagues on the SAB are well respectedSAB are well respected

Our purpose here today is not to Our purpose here today is not to criticize the SABcriticize the SAB

To the contrary, our purpose is to note To the contrary, our purpose is to note for you that knowledgeable scientists for you that knowledgeable scientists and medical professionals disagree on and medical professionals disagree on the health effects of low level Hthe health effects of low level H22S S exposureexposure

MCIC

EMC’s Role as RISK EMC’s Role as RISK MANAGERMANAGER

Weigh the merits of the scientific Weigh the merits of the scientific arguments and assess the scientific arguments and assess the scientific uncertainty and disagreementuncertainty and disagreement

Consider the significant economic Consider the significant economic implications for the 4 companies as well as implications for the 4 companies as well as for entire regions of North Carolinafor entire regions of North Carolina

Assign an AAL that affords adequate Assign an AAL that affords adequate protection for the public health without protection for the public health without unnecessarily jeopardizing the jobs of unnecessarily jeopardizing the jobs of working families working families