"Summary of Air Quality Issues and Identification of Information Needed to Address Community Health Concerns "

"PORT TOWNSEND PAPER CORPORATION JEFFERSON COUNTY, WASHINGTON. DECEMBER 24, 2008

U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES 

Public Health Service 

 Agency for Toxic Substances and Disease Registry 

Division of Health Assessment and Consultation 

Atlanta, Georgia 30333

"The Washington State Department of Health (DOH) has prepared this health consultation in cooperation with the Agency for Toxic Substances and Disease Registry (ATSDR).

ATSDR is part of the U.S. Department of Health and Human Services and is the principal federal public health agency responsible for health issues related to hazardous waste. This health consultation was prepared in accordance with methodologies and guidelines developed by ATSDR. "

"Local air monitoring In Port Townsend, monitoring for air pollution occurs at Blue Heron Middle School, 3339 San Juan Avenue in Jefferson County. This monitor only collects information on particulate matter (PM2.5).6 Additionally, it may not be sited in a place that is relevant (i.e., does not consistently capture emissions from PTP mill). Indeed, this monitoring station was sited to represent air quality conditions representing the overall air shed. It was never intended to capture emissions directly from the mill but many other sources such as woodstoves, motor vehicle emissions, and other combustion sources in Port Townsend.

According to the EPA, air quality samples are generally collected for several reasons: (1) to
judge compliance [of an air shed] with and/or progress made towards meeting ambient air quality standards, (2) to activate emergency control procedures that prevent or alleviate air pollution episodes, (3) to observe pollution trends throughout the region, including non-urban areas, and (4) to provide a data base for research evaluation of effects: urban, land-use, and transportation planning; development and evaluation of abatement strategies; and development and validation of diffusion models.

Potential air pollution sources at PTP mill 

There are many potential emission sources at the pulp mill including combustion units, chemical manufacturing operations, and effluent treatment processes.

According to EPA’s Toxics Release Inventory (TRI), industries in the Port Townsend industrial area release toxic substances into the air. Estimates of the annual air emissions of many chemicals can be found at http://www.epa.gov/triexplorer/. TRI data provide DOH staff with a general overview of the potential chemicals in an area.

However, the TRI regulations only require facilities in certain industries to disclose releases for specific hazardous chemicals. The regulations do not require that all facilities report and do not address all chemicals.

In addition, information in the TRI database does not represent measured concentrations; rather, it represents industry-reported estimates of emissions.

The accuracy of these estimates of emissions is not known. Furthermore, while TRI data typically capture large stationary sources of emission releases, smaller stationary sources are not captured.

These smaller stationary sources could include offices and residences, gasoline stations, and dry cleaners. Additionally, TRI data do not capture mobile sources, like automobiles, trucks, buses, and motorcycles.

These mobile sources may be a significant source of outdoor air pollution, including such chemicals as acetaldehyde, propionaldehyde, and formaldehyde. TRI data shows self-reported estimates of pollutants emitted from PTP in the past.

Tables 1 and 2 show TRI emissions (tons per year) from 2002, 2005 and 2006. Additional
limitations of the data collected in the TRI inventory include the following.

 TRI requires the reporting of chemical releases only when a facility manufactures,
processes, or otherwise uses an amount greater than the TRI reporting threshold [e.g.,
more than 0.1 grams/year of dioxin and dioxin-like compounds, more than 100
pounds/year of polycyclic aromatic hydrocarbons (PAHs)].

 Per TRI guidance, release reports may be based on estimates, not measurements. As a
result, facilities may overstate releases because they can be penalized for under-reporting
releases.

 Certain chemicals (PAHs, dioxin and dioxin-like compounds, metal compounds) are
reported as a class, not as individual chemical compounds. Because the individual
compounds in the class have widely varying toxic effects, the potential toxicity of
chemical releases can be inaccurately estimated.

 Year-to-year comparisons are nearly impossible given that the TRI rules and definitions
for reporting change year-to-year. "

Source and Full Document
http://www.atsdr.cdc.gov/hac/pha/PortTownsendPaper/PortTownsendPaperHC12-24-2008.pdf