Preview Newsletter
ACC PM 9/23/16
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Sen. Boxer: EPA Should Include Asbestos in Top Priorities
Sep 23, 2016 | Asbestos.com
By Beth Swantek
Selecting the 10 most dangerous chemicals in the U.S. is the first order of business under the recently strengthened arm of the Environmental Protection Agency. -
(ACC Blog) Carcinogen or Not a Carcinogen? A Tale of Two WHO Agencies, and the Importance of Evaluating Study Quality and Human Relevance
Sep 23, 2016 | American Chemistry Matters
By Nancy Beck, Ph.D., D.A.B.T.
How is it possible that two World Health Organization (WHO) agencies could evaluate the same chemical’s potential to cause cancer and come to seemingly opposite conclusions? -
(ACC Mentioned) Prop. 65 Conference Focuses on Compliance With New Warning and Settlement Regulations
Sep 23, 2016 | Lexology
By Bryan Cave
The Prop. 65 Clearinghouse held its annual conference in San Francisco recently, and the speakers and panelists had a number of recommendations for both retailers and manufacturers following the adoption of Proposition 65’s new warning regulations. -
(ACC Mentioned) EU Considers Adding Six Substances to Restricted Chemicals List
Sep 23, 2016 | Environmental Leader
By Jessica Lyons Hardcastle
The primary chemical law in the European Union, the Registration, Evaluation, Authorization and Restriction of Chemicals or REACH, has proposed adding six new substances of very high concern to its restricted substances list, according to Assent Compliance, an environmental compliance software as a service provider. -
Company Urges EPA To Re-Evaluate 2010 Chloroprene IRIS Assessment
Sep 23, 2016 | Inside EPA
By Maria Hegstad
Representatives of a company that owns a Louisiana plant at the center of an ongoing investigation into a modeled high potential cancer risk from emissions of chloroprene are urging EPA to update its 2010 assessment of the human health risks of chloroprene, which identified the chemical as a likely carcinogen. -
US EPA Extends Consultation for Proposed Snur Rule
Sep 23, 2016 | Chemical Watch
The US EPA has extended the consultation period for its proposed rule to update significant new use rule (Snur) regulations. -
Consultants 'Exploiting Gaps' in REACH Data-Sharing Regulation
Sep 23, 2016 | Chemical Watch
Some consultants are exploiting gaps in the EU Regulation on the joint submission of data and data sharing for REACH registrations, according to law firm Mayer Brown. -
The Seven Questions That Will Determine the Fate of EPA's Carbon Rules
Sep 23, 2016 | Politico Pro
By Alex Guillén
When the Clean Power Plan has its day in court Tuesday, lawyers for the states and businesses aiming to overturn the rule will focus on questions they hope EPA can't answer. -
Appeals Court Decision on Clean Power Plan Will Affect Businesses
Sep 23, 2016 | The Hill - Congress Blog
By David Levine
Later this month, the U.S. Court of Appeals for the D.C. Circuit will hear a case on the legality of the Clean Power Plan, the single most significant climate change policy we have. -
Calif. Court Rejects Challenge to Injection Wells
Sep 23, 2016 | E&E Energywire
By Ellen M. Gilmer
A California court this week rejected environmentalists' challenge to the state's oversight of oil and gas wastewater. -
Emissions Won't Go Down Without Reining in Industrial Users — Report
Sep 23, 2016 | E&E Energywire
By Kristi E. Swartz and Emily Holden
Large manufacturers and other industries can help states reduce greenhouse gas emissions by increasing energy efficiency, clean energy experts said yesterday. -
How Big Data Changes the Economics of Renewable Energy
Sep 23, 2016 | Wall Street Journal - Blog
By Jason Bordoff
Thanks to the exponential growth of information commonly known as “big data” and our increasingly sophisticated methods to analyze it, the machine learning revolution is increasingly disrupting old industries from advertising and transportation to fashion and the legal profession. -
(ACC Mentioned) ‘Erin Brockovich Chemical’ Found in PA Water Systems, Study Says
Sep 23, 2016 | State Impact
By Jon Hurdle
More than 160 public water systems in Pennsylvania contained the carcinogenic chemical chromium 6 during recent tests at levels that were above a health limit recommended by scientists in California, according to a new analysis of data from the U.S. Environmental Protection Agency. -
East Coast States, Midwestern Utilities Divided Over CSAPR 'Update' Rule
Sep 23, 2016 | Inside EPA
By Stuart Parker
East Coast states and Midwestern power plant operators are divided over the merits of EPA's “update” for its Cross-State Air Pollution Rule (CSAPR) emissions trading program, with the states suggesting the rule falls short of the scope and emissions caps necessary while utilities are criticizing the agency's data and calling the rule unnecessary. -
Kerry Calls for HFC Phaseout, Says Paris Alone Won't 'Get the Job Done'
Sep 23, 2016 | E&E Climatewire
By Jean Chemnick
The United States and other countries proclaimed yesterday that an upcoming effort to amend an international ozone treaty to curb refrigerants that contribute to global warming would be a test of the post-Paris Agreement era. -
Calif. Cap and Trade Faces New Hurdles
Sep 23, 2016 | E&E Climatewire
By Debra Kahn
California regulators are running into opposition as they make a bid to extend their economywide greenhouse gas program to 2030 and mesh it with federal regulations.
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Sen. Boxer: EPA Should Include Asbestos in Top Priorities
Sep 23, 2016 | Asbestos.com
By Beth Swantek
Selecting the 10 most dangerous chemicals in the U.S. is the first order of business under the recently strengthened arm of the Environmental Protection Agency.
“EPA must consider all forms of asbestos in this initial list of chemicals it acts on,” U.S. Sen. Barbara Boxer, D-Calif., wrote in an Aug. 26 letter to EPA administrator Gina McCarthy.
President Barack Obama signed the Frank R. Lautenberg Chemical Safety for the 21st Century Act into law in June, updating the antiquated Toxic Substances Control Act and granting the EPA more power to regulate toxic chemicals.
Boxer, a ranking member of the Environment and Public Works Committee, declared the top 10 list will dictate the agency’s agenda for the next several decades, making it crucial that asbestos lead the list.
Asbestos is the leading cause of mesothelioma. The incurable cancer claims the lives of nearly 3,000 people in the U.S. annually.
Boxer Sends EPA Asbestos Consumption & Deaths in U.S.
According to Boxer’s letter, she said it’s necessary “to build confidence in the agency’s ability to deliver meaningful results for our children and families.”
She cited several statistics from the Asbestos Disease Awareness Organization and the Environmental Working Group for her recommendation:
15,000 annual asbestos-related deaths in U.S.
11,000 deaths from lung cancer
Since 2006, a total of 23 U.S. ports received more than 8.2 million pounds of raw asbestos
In 2015, the annual report of the United States Geological Service showed asbestos consumption in the U.S. weighed an estimated 400 tons. The chloralkali industry, which produces the chlorine used to disinfect water, was listed as the primary consumer of the asbestos, but it also was used for coatings, compounds, plastics and roofing products.
“The combination of well-documented, widespread and serious health effects and ongoing exposure provides a strong basis for EPA to act quickly on asbestos,” Boxer said.
McCarthy’s office did not return calls for comment to Asbestos.com.
More Nations Are Banning Asbestos
The World Health Organization in 2006 called for a global end to asbestos, which is known to cause the incurable cancer mesothelioma and numerous other health-related issues.
Fifty-six nations already heeded the warning and banned the toxic substance, including the European Union and Japan. Canada is currently considering a moratorium on the mineral.
Boxer reminded McCarthy the Occupational Safety and Health Administration shares this national concern: “OSHA has similarly said it is ‘aware of no instance in which exposure to a toxic substance has more clearly demonstrated detrimental health effects on humans that has asbestos exposure.’”
New Law Bolsters EPA’s Power to Regulate Asbestos
While the original TSCA law, passed in 1989, was too weak to allow the EPA to make any major headway in the regulation of lethal chemicals, this new reform beefs up the agency’s authority, allowing them to:Decisively evaluate existing chemicals with clear and enforceable deadlines as mandated by the law.Create a new risk-based safety standard.Increase public transparency for chemical information.Provide ongoing funding to execute its responsibilities under the new law.
The bipartisan measure received overwhelming support in the U.S. House and U.S. Senate, and supporters are hopeful it will put an end to asbestos importation, as well as increase regulation of other dangerous chemicals.
https://www.asbestos.com/news/2016/09/23/senator-barbara-boxer-asbestos-epa-priority/
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Sep 23, 2016 | American Chemistry Matters
By Nancy Beck, Ph.D., D.A.B.T.
How is it possible that two World Health Organization (WHO) agencies could evaluate the same chemical’s potential to cause cancer and come to seemingly opposite conclusions?
Dr. David Eastmond explored this question in a presentation at the Summer Toxicology Forum meetingcomparing the approaches taken by the International Agency for Research on Cancer (IARC) and the Joint Meeting on Pesticide Residues (JMPR), in their evaluations of the herbicide glyphosate. You can view the slides from his presentation here.
IARC: Glyphosate is “Probably Carcinogenic to Humans”
The objective of IARC, the cancer agency of the WHO, is to promote international collaboration in cancer research. The IARC Monographs on the Evaluation of Carcinogenic Risks to Humans identify environmental factors that have the potential to cause cancer in humans. Since 1971, more than 900 agents have been evaluated.
In March 2015, IARC published a final evaluation and rationale relating to the carcinogenicity of glyphosate.IARC classified glyphosate as probably carcinogenic to humans (Group 2A). This was based on IARC’s finding of limited evidence of carcinogenicity in humans for non-Hodgkin lymphoma. In addition, IARC noted that there is also convincing evidence that glyphosate can cause cancer in laboratory animals, and that glyphosate caused DNA and chromosomal damage in human cells.
JMPR: Glyphosate is Unlikely to Pose a Carcinogenic Risk to Humans Exposed via Diet
JMPR is an expert ad hoc body administered jointly by the Food and Agriculture Organization of the United Nations and WHO for the purpose of harmonizing the requirement and the risk assessment on the pesticide residues. JMPR provides advice on the acceptable levels of pesticide residues in food moving in international trade. In May 2016, JMPR re-evaluated the risk posed to human health of consuming residues of glyphosate in food. JMPR determined that glyphosate is unlikely to pose a carcinogenic risk to humans exposed via the diet.
Study Quality and Human Relevance
While the findings by IARC and JMPR may seem contradictory, they actually are not. As stated by JMPR: “IARC reviews published studies to identify potential cancer hazards. It does not estimate the level of ‘risk’ to the population associated with exposure to the hazard. In contrast, JMPR reviews both published and unpublished studies to assess the level of health risk to consumers associated with dietary exposure to pesticide residues in food.”
The JMPR finding of an unlikely risk results from the fact that JMPR gave greater weight to the studies most relevant to humans and to oral exposure. JMPR gave less weight to studies on species far removed from humans, like plants, earthworms, fish and caiman, and routes other than oral exposures. This review led to the conclusion that glyphosate is unlikely to be genotoxic at anticipated dietary exposures.
Dr. Eastmond was on the JMPR panel and at the Toxicology Forum meeting and provided insights into why IARC and JMPR reached these differing conclusions, including:
While IARC focuses only on the published studies, the JMPR evaluation was able to include many guideline studies, which are not published. JMPR evaluated just over 246 studies, compared to IARC’s evaluation of ~113.
JMPR gives more weight to higher quality studies, in vivo studies over in vitro studies, and more weight to mammals than other species. JMPR also gave higher weight to relevant exposure routes, in this case the oral route. While these seem like minor points, Dr. Eastmond’s presentation shows the importance of digging into the study details and looking at more than results. The JMPR group looked at the methods and the quality of the studies. They articulated their weighting criteria in advance of the evaluation and benchmarked each of the studies to these clear criteria.
When it came to genotoxicity, JMPR gave more weight to serious endpoints like mutations and chromosome alterations than they did to less serious or transient endpoints (e.g., single strand breaks).
While IARC did not have original reports for some animal studies and often worked with re-evaluations of the data, JMPR looked at the data in original reports.
The differences in some cases were striking. While IARC found 80 percent of the human biomonitoring studies to be positive, JPRM considered 0 percent to be positive with most being evaluated as equivocal. For studies that looked at bacteria, where IARC found 67 percent to be positive, JMPR found only 13 percent to be positive. The findings were similarly dissimilar for other types of studies. When looking at studies that IARC said were highly significant, JMPR found inconsistencies and concerns with the studies, leading the results to be deemed only equivocal.
Dr. Eastmond acknowledged that the JMPR review required considerable expertise and scientific judgment. For the glyphosate review, JMPR was able to conclude that the overall weight of evidence, for oral exposure, did not support genotoxicity in mammals, despite IARC’s finding of strong evidence of genotoxicity.
The differences in outcomes were largely due to the information available for evaluation, the rigor and weights applied to the different types of studies, and the criteria used to incorporate the important issue of human relevance. The JMPR report is not yet final so it is difficult to evaluate the full extent of the differences. However, it is easy to see that the strength of the evidence matters: having clear criteria and giving more weight to data that are most relevant to exposure routes in humans, is going to create differing results.
This example with two agencies with two different reviews reaching different conclusions about the same chemical is not just confusing for chemical specialists and toxicologists like Dr. Eastmond. Confusing results – especially when it comes to whether or not a substance causes cancer in people – creates confusion for the public.
IARC and JMPR aren’t the only agencies to look at the same chemical and publish seemingly contradictory results. Varying standards in evaluating quality of evidence have led government bodies such as the National Toxicology Program, the U.S. Environmental Protection Agency’s (EPA) IRIS program, EPA’s pesticides program, the U.S. Food and Drug Administration, and California’s Proposition 65 agency to come to different conclusions regarding a chemical’s health effects.
Examples like these emphasize why the new requirements in the Lautenberg Chemical Safety Act (LCSA) calling for weight of the scientific evidence evaluations will truly help to increase the quality of chemical assessments done by EPA – and give consumers greater confidence about the safety of chemicals in their products.
https://blog.americanchemistry.com/2016/09/carcinogen-or-not-a-carcinogen-a-tale-of-two-who-agencies-and-the-importance-of-evaluating-study-quality-and-human-relevance/
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Sep 23, 2016 | Lexology
By Bryan Cave
The Prop. 65 Clearinghouse held its annual conference in San Francisco recently, and the speakers and panelists had a number of recommendations for both retailers and manufacturers following the adoption of Proposition 65’s new warning regulations.
The New Warning Regulations
As we reported on September 7th, the Office of Environmental Health Hazard Assessment (OEHHA) has adopted new warning regulations which take effect in two years on August 30, 2018. Businesses can choose to comply with either the current or new regulations in the interim, but all retailers and manufacturers who sell products in California should review their Prop. 65 compliance protocols to ensure that they will continue to comply.
The new regulations seek to put the primary responsibility for providing warnings on product manufacturers or suppliers, who must either label their products with any required warnings or provide notice and warning materials to retailers.
The regulations expressly provide, however, that parties can continue to contractually allocate who has responsibility for providing warnings. Retailers should therefore analyze and consider revising their terms and conditions to clarify who is responsible for providing warnings and in what manner, whether retailers will accept and post shelf warnings provided by vendors, and to whom the notice and warning materials should be sent.
Complying With New Warning Regulations
The first panel – which included the chief counsel of OEHHA, the presidents of two enforcement groups, an industry lobbyist, and a defense attorney — focused on some of the challenges that the new regulations will impose on retailers and manufacturers, and how they envision the new warning requirements being implemented.
The panelists predicted that many retailers will refuse to post shelf warnings provided by vendors, and will instead contractually require vendors to put any required warnings on product labels or packaging. The consensus among all of the panelists was that this process of contractual allocation of the compliance obligations will be an important part of how these new regulations are actually implemented.
Some panelists also expressed concern that there will be disagreement between retailers and their suppliers as to whether to comply with the current or amended regulations prior to the effective date, and recommended that this issue also be resolved contractually.
One of the biggest changes under the new regulations is that each warning must specify one or more chemicals for which the warning is being given. Carol Monahan-Cummings, chief counsel for OEHHA, emphasized that although the warning must list at least one chemical, it does not necessarily have to include all listed chemicals included in the product.
The panelists also discussed whether a manufacturer can be liable for unauthorized third-party sales into California. Ms. Monahan-Cummings indicated that this is a problem that OEHHA has considered since Proposition 65 was first enacted, but that ultimately, the law applies to everyone in the chain of commerce. The question turns on whether the sale into California is “knowing,” and the panelist had different opinions on that point. One enforcement group felt that every business should assume that their products will be sold in California, and should always provide warnings. Another argued that no liability would attach to a manufacturer who did not know about the sale in California. This important question remains open, and will depend significantly on the facts of each case.
Complying With Settlement Regulations
The California Attorney General has amended the regulations concerning settlement terms, penalty amounts, and attorney’s fees in Prop. 65 enforcement actions brought by private parties, and a second panel spoke on complying with these amended regulations, which take effect on October 1.
The amended regulations require that private settlements resolving a notice of violation without the filing of a complaint or court approval of the settlement must be submitted to the Attorney General’s office within five days of reaching the settlement.
Current regulations allow attorneys’ fees to be paid to the plaintiff where a “significant benefit” has been conferred on the public, and provide that a settlement requiring a product to be sold with a warning or reformulated confers such a benefit. The amended regulations require documentation that at least some of the products at issue contained chemicals in levels that exceeded the agreed-upon reformulation standard.
The regulations continue to require that at least 75 percent of any penalty be paid to OEHHA. Importantly, the amended regulations impose limits and requirements on “additional settlement payments” – payments that are not penalties paid to OEHHA, reimbursement of costs, or attorneys’ fees. Where a settlement provides for such a payment to the plaintiff or a third party, the plaintiff must demonstrate to the court that it is in the best interest of the public. Therefore, such payments should not be included in any settlement that is not subject to court approval.
The amended regulations require plaintiffs to clearly specify the activities that will be funded by additional settlement payments, and such activities must have a “clear and substantial nexus” to the alleged violation. Plaintiffs must disclose any relationship between the plaintiff or plaintiff’s counsel and entities or individuals receiving payments. Finally, plaintiffs must document how the money was spent, and provide such records to the Attorney General within 30 days of request. Some panelists expressed concern that plaintiffs will raise their overall settlement demands in order to cover the additional documentation and accounting costs.
OEHHA’s New Website Concerning Warnings
Another panel discussed the requirement in the new Prop. 65 regulations that all safe harbor warnings include a link to OEHHA’s warnings website. As we reported on June 23rd, the website is intended to provide more information to consumers about Prop. 65 warnings, listed chemicals that may be present in products, and how to reduce potential exposure.
The industry representatives raised concerns that the information on the website might legitimize prophylactic warnings (e.g. warnings where there may not be a chemical present) based on the additional information available on the website. To address that issue, a spokeswoman for the American Chemistry Council advocated for business to be able to provide some factual context to the warnings. That context could include a description of where the chemical is located and how a consumer might be exposed to it, references to other agencies’ determinations about the safety of the product or chemical, or other factual information that the manufacturer or retailer thinks is relevant. The new warning regulations only allow information on the source of the chemical and how to reduce exposure to be added to the safe harbor warning, and the enforcement groups had serious concerns that these “context” statements would be used to detract from the effectiveness of the warnings.
Overall the consensus was that the website simply needs more content in order to be effective, but that when it does, it will provide a useful tool for consumers.
http://www.lexology.com/library/detail.aspx?g=761c7e26-3893-41c6-aca7-3ece7712ff12
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(ACC Mentioned) EU Considers Adding Six Substances to Restricted Chemicals List
Sep 23, 2016 | Environmental Leader
By Jessica Lyons Hardcastle
The primary chemical law in the European Union, the Registration, Evaluation, Authorization and Restriction of Chemicals or REACH, has proposed adding six new substances of very high concern to its restricted substances list, according to Assent Compliance, an environmental compliance software as a service provider.
The six substances are:
4,4’-Isopropylidenediphenol
4-Heptylphenol
4-tert-butylphenol
Benzene-1,2,4-tricarboxylic acid 1,2-anhydride (trimellitic anhydride)
Nonadecafluorodecanoic acid (PFDA) and its sodium and ammonium salts
p-(1,1-dimethylpropyl)phenol
Although REACH applies only to products sold in the EU, US and other global businesses are affected, because REACH compliance throughout the supply chain is required to do business in Europe.
“Since REACH has the potential to affect all chemicals and chemical products produced or imported into the EU, any company that wants a chemical on the market in the EU should pay close attention to REACH chemical rules and regulations,” the American Chemistry Council’s Greg Skelton told Environmental Leader in an earlier interview. “Regardless of where a company is based — US or otherwise — companies are required to comply with applicable REACH requirements in order to export to the EU.”
The REACH news comes as the US has banned exports of five mercury compounds, effective Jan. 1, 2020, under the reformedToxic Substances Control Act.
An EPA notice published in the Federal Register lists the five mercury compounds: mercury (I) chloride or calomel; mercury (II) oxide; mercury (II) sulfate; mercury (II) nitrate; and cinnabar or mercury sulphide.
https://www.environmentalleader.com/2016/09/23/eu-considers-adding-six-substances-to-restricted-chemicals-list/
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Company Urges EPA To Re-Evaluate 2010 Chloroprene IRIS Assessment
Sep 23, 2016 | Inside EPA
By Maria Hegstad
Representatives of a company that owns a Louisiana plant at the center of an ongoing investigation into a modeled high potential cancer risk from emissions of chloroprene are urging EPA to update its 2010 assessment of the human health risks of chloroprene, which identified the chemical as a likely carcinogen.
Consultants to Denka Performance Elastomer (DPE) met with managers and staff of EPA's Integrated Risk Information System (IRIS) program last month to discuss concerns that the consultants have with the 2010 IRIS assessment of chloroprene, which they argue is overly stringent and should be updated. Released in September 2010, the chloroprene assessment classifies the chemical as a likely human carcinogen and sets a risk estimate for cancer potency when chloroprene is inhaled daily over a lifetime of 5x10^-4 per microgram per cubic meter of air (ug/m^3)^-1.
The consultants, with the firm Ramboll-Environ, Inc., argued that the assessment should be updated because they say that "[e]pidemiological evidence may have been misinterpreted."
Specifically, they say the data is "insufficient to conclude that chloroprene causes cancer in humans" and "inadequate for determining risk estimates." They also argue that the cancer risk factor, known as an inhalation unit risk estimate (IUR), "included influential adjustments and multiple upward rounding" and "[r]eliance on animal evidence for risk estimates requires fuller consideration of evidence of profound interspecies differences,"according to a copy of their presentation posted on EPA's website.
EPA and Louisiana Department of Environmental Quality (LDEQ) regulators have been performing air monitoring for chloroprene emissions around the DPE elastomer plant in LaPlace, LA, after EPA last December released the most recent set of National Air Toxics Assessment (NATA) data, dating from 2011. There appear to be no other potential sources of the air toxic chloroprene anywhere else in the region, leading to the focus on the DPE plant -- a rare if not unheard of use of NATA data.
An LDEQ spokesman told Inside EPA last July that when regulators examined the NATA maps, "There was a large area of red, which indicates a cancer risk, in LaPlace" that spurred them to contact EPA and DPE's management. To get a better understanding of the situation, EPA and LDEQ began six months of monitoring air emissions around the plant. DPE is stepping up its modeling of air releases and investigating new control technologies including improved leak detection that could reduce risk to neighbors.
Greg Langley, the LDEQ press secretary, says staff are in voluntary discussions with DPE to reduce chloroprene emissions at the site. Langley said in July that state regulators have limited options to require those controls if modeling and monitoring efforts bear out the NATA data because EPA has promulgated only a health advisory level of 0.2 ug/m^3. "There is not an enforceable standard . . . We don't have a cudgel to hold over them," he said.
IRIS Assessment
Meanwhile, DPE is seeking revisions to the 2010 IRIS assessment that classified chloroprene as a likely carcinogen, which if successful could negate or reduce the NATA warnings of cancer risk from the LaPlace facility's air emissions. The last page of the consultants' presentation indicates that their next steps include providing additional information, seeking an additional meeting with EPA, and possibly, a "[f]ormal request for updating the IRIS review and risk numbers."
A source with the company says that "at this time, no final decisions have been made regarding follow-up." The source adds that one other option under consideration is the possibility of filing a request for correction with EPA under the Data Quality Act. "The Data Quality Act seems to be the proper channel to help us make the agency aware of the most up to date scientific information," the source says.
DPE's consultants argue that in addition to their concerns about the bases for EPA's IRIS assessment, newer studies result in a significantly less risky analysis. In its presentation, the Ramboll points to a 2014 study by Allen et al. that uses a physiologically based pharmacokinetic (PBPK) model to adjust for differences between humans and lab mice in a study of mouse lung tumors -- EPA used mouse lung tumors as the basis for its quantitative risk estimate, but not the model.
The result in the Allen paper is an IUR of 1.86x10^-6 (ug/m^3)^-1, about a "100 fold decrease" in risk from the IRIS assessment.
The Allen paper, published in the journal Regulatory Toxicology and Pharmacology, explains that "[c]hronic inhalation studies have demonstrated that [chloroprene] is carcinogenic in B6C3F1 mice and Fischer 344 rats. However, epidemiological studies do not provide compelling evidence for an increased risk of mortality from total cancers of the lung. Differences between the responses observed in animals and humans may be related to differences in toxicokinetics, the metabolism and detoxification of potentially active metabolites, as well as species differences in sensitivity."
Allen is an independent consultant, and the paper's other authors include other consultants, researchers at the University of Pittsburgh, and a scientist with DuPont, which operated the DPE plant before two Japanese companies, Denka and Mitsui, acquired it in 2014, according to a Dec. 11, 2014, press release from Denka.
The Allen paper says it seeks to "develop and apply a novel method that combines the results from available [PBPK] models for chloroprene with a statistical maximum likelihood approach to test commonality of low-dose risk across species. . . . The method applied to mouse and human [chloroprene] data supports the hypothesis that a [PBPK]-based metric reconciles the differences in mouse and human low-dose risk estimates and further suggests that, after PBPK metric exposure adjustment, humans are equally or less sensitive than mice to low levels of [chloroprene] exposure."
Multi-Year Agenda
An EPA source says that chloroprene is not on the multi-year agenda for the IRIS program that EPA released last December. The plan is intended to guide the program's assessment activities for the next five years or more. "No, chloroprene is not part of our plan, but we'll listen to anyone," the source adds.
Langley, the LDEQ spokesman, says that state staff listened to Ramboll's Aug. 9 meeting with EPA, but has no comment on the consultants' presentation. He added that LDEQ will not participate in any request by DPE to update the chloroprene assessment.
Ramboll also raised concerns about EPA's use of epidemiology data, a key to the cancer classification, as well. The consultants argue that recommendations from the National Academy of Sciences to the IRIS program -- including directions on increasing transparency on decision-making and strengthening methods of evaluating an overall body of evidence -- call for reassessing the IRIS document. Consultants argued that EPA should have focused on one epidemiology study published in 2007 by Gary Marsh et al. of American and European workers and excluded what they consider flawed studies of Armenian, Chinese and Russian cohorts.
The "Marsh et al. . . . study demonstrates no lung or liver cancer excess risk and no clear exposure-response," their presentation states. "Integration of the evidence strongly suggests that the responses relied on for the IUR are unique to the mouse. Absent strong, affirmative epidemiological evidence of cancer risk, employing an approach that quantitatively addresses differences between the mouse and human is critical."
But DPE may have an additional challenge in its request for an IRIS update, in that chloroprene emissions do not appear to be widespread. IRIS assessments are intended to address environmental contaminants of large scale, often requested by other EPA offices. The latest Toxics Release Inventory data, from 2014, indicates that there are only 12 facilities emitting chloroprene in the U.S. Of those, the DPE plant emitted by far the most, at 265,488 pounds of the total 267,095, or 99 percent, emitted that year.
http://insideepa.com/daily-news/company-urges-epa-re-evaluate-2010-chloroprene-iris-assessment
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US EPA Extends Consultation for Proposed Snur Rule
Sep 23, 2016 | Chemical Watch
The US EPA has extended the consultation period for its proposed rule to update significant new use rule (Snur) regulations.
Kathleen Roberts of B&C Consortia Management – an affiliate of Bergeson & Campbell – filed an extension request.
The law firm flagged up that the proposal raises "significant and complex" issues earlier this summer.
Comments on the proposed rule will be accepted until 26 October.
https://chemicalwatch.com/49854/us-epa-extends-consultation-for-proposed-snur-rule
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Consultants 'Exploiting Gaps' in REACH Data-Sharing Regulation
Sep 23, 2016 | Chemical Watch
Some consultants are exploiting gaps in the EU Regulation on the joint submission of data and data sharing for REACH registrations, according to law firm Mayer Brown.
Writing in this month’s Global Business Briefing, the firm's Jean-Philippe Montfort and Thomas Delille warn that some consultants, seeking to sell low cost access to EU registration to their clients, are challenging "essential elements" of the implementing Regulation.
In particular, these consultants are taking advantage of lead registrants' obligation to share available data and respond to a request for it, they say.
"Potential registrants or their consultants," say the lawyers, "are using their right to request an itemisation and justification of the data, as a means to contest [registration] costs and push lead registrants into a corner."
Because of this, discussions between registrants are "getting more difficult".
The Regulation requires Echa to ensure the "one substance, one registration" principle is upheld, even when a new registrant fully opts out of the joint submission of data.
"This is causing problems, with some companies and consultants not only refusing to pay their share of the costs (normally achieved by obtaining a letter of access), but also requesting the key to the registration dossier, known as a token," they say.
Companies justify their request on the basis they will otherwise opt out from all endpoints, where information has been jointly submitted by existing registrants, and have the pretext of a disagreement on the information and/or its cost.
If Echa receives a complaint, this can turn into a joint submission dispute. In such cases, the agency asks the parties to show they have made every effort to reach an agreement on access to the joint submission. If the potential registrant has done this, the agency will probably grant them the access the lead registrant is refusing.
The lawyers say this is a "very dangerous development". It is particularly so when the prospective registrant lacks legitimate rights to refer to full study reports. There is no guarantee for the lead registrant that Echa will verify the new registration. In these situations the lead registrant would need to appeal or pursue "lengthy and uncertain national proceedings".
Cases where new registrants "copy and paste already submitted information and refer only to published studies through a full opt-out registration, without contributing to the assessment costs, naturally appear unfair to existing registrants," they say.
"This is because those free riders cherry pick the data served to them on a silver plate."
https://chemicalwatch.com/49833/consultants-exploiting-gaps-in-reach-data-sharing-regulation
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The Seven Questions That Will Determine the Fate of EPA's Carbon Rules
Sep 23, 2016 | Politico Pro
By Alex Guillén
When the Clean Power Plan has its day in court Tuesday, lawyers for the states and businesses aiming to overturn the rule will focus on questions they hope EPA can't answer.
Oral arguments before the D.C. Circuit Court of Appeals will cover essentially every claim the challengers throw against EPA's landmark rule to limit carbon emissions from the nation's fleet of power plants, and the judges hearing the case will ultimately have to weigh in on all those issues. While the case is widely expected to be appealed to the Supreme Court, which enjoys the latitude to define the scope of its cases, the winner at the D.C. Circuit will likely enter that proceeding with some advantage. And uncertainty over whether the Senate fills the Supreme Court vacancy before the case can make its way to the high court has some speculating whether the high court will actually take the case.
Here’s a look at arguments the D.C. Circuit judges will hear on Tuesday, some of which could kill the Clean Power Plan or force EPA back to the drawing board, while others may simply force changes on the rule's structure or targets. And check POLITICO’s guide to the Clean Power Plan legal challenge for more information on some of these terms and cases.
Can EPA regulate carbon dioxide from power plants under Section 111(d) of the Clean Air Act?
This is the first of two “kill shot” questions, known as the “112 Exclusion” argument. It asks whether EPA can use its preferred approach to regulate carbon emissions, and if the challengers win on this point, the court would be forced to throw out the Clean Power Plan in its entirety and the rest of their arguments essentially would be moot.
The arcane dispute goes back to an unusual legislative glitch when the 1990 Clean Air Act amendments were signed into law. The final text did not resolve a disagreement between the House and Senate over the wording of section 111 of the act, under which the Clean Power Plan was written, and both versions made it into the final law. But challengers argue EPA should be held to the House language, which they say would prohibit the agency from using section 111(d) to regulate power plants' carbon emissions because it already regulates those sources with its Mercury and Air Toxics Standard, written under section 112 of the law.
EPA says the challengers are misreading the statute, and that in any case it should be given deference to interpret the competing provisions. States supporting EPA note that the agency has long regulated certain sources, such as landfills and fertilizer plants, for different pollutants under both sections of the law.
A loss in this category doesn’t necessarily mean EPA can never regulate greenhouse gases. However, a path forward outside of Section 111(d) is unclear. Legal scholars have considered other options — include Section 112, the National Ambient Air Quality Standards program, and a never-before-used section meant to tackle international pollutants — but generally agree that those would prove either prohibitively costly or exceedingly ineffective.
Should EPA get Chevron deference?
The 112 Exclusion argument will give the court another opportunity to revisit the longstanding doctrine known as Chevron deference, in which judges give federal agencies wide latitude to interpret unclear wording in laws.
Applying the doctrine to two competing provisions of the same statute inadvertently both signed into law may be a novel application of Chevron deference, an issue on which there is disagreement among D.C. Circuit judges.
"This is a Chevron case, and when Congress passes conflicting statutes we let the agency decide,” Judge Thomas B. Griffith, a George W. Bush appointee, said during a hearing last year on the proposed version of the Clean Power Plan. He cited a 2014 Supreme Court decision in Scialabba v. Cuellar de Osorio.
On the other hand, Judge Brett Kavanaugh, another Bush appointee on the panel, indicated at the time that he was not necessarily on the same wavelength. Kavanaugh pointed to Chief Justice John Roberts' concurrence in Scialabba, which declared that Chevron deference is "not a license for an agency to repair a statute that does not make sense."
Is the Clean Power Plan unconstitutional?
Laurence Tribe, the liberal legal icon and former Obama mentor now working for coal producer Peabody Energy, has compared EPA's regulation to "burning the Constitution.” Challengers hope the constitutional arguments he helped to hone deliver a "kill shot" for the rule, although it remains to be seen how seriously the judges take them.
EPA says that the Clean Power Plan is a “textbook” case of cooperative federalism that has been used in numerous environmental regulations before, and that the constitutional claims “attempt to put a thumb on the scales of this court’s statutory analysis.” The rule directs states to write their own plans to meet carbon reduction targets but warns EPA will impose a federal plan in any states that do not act.
States and industry groups challenging the rule say it violates the Tenth Amendment because the agency could force coal plants to shut down or direct utilities to use more renewable power, regardless of the states' responsibilities to ensure electric reliability. That would leave "states to bear the brunt of citizen complaints about the increased costs and lost jobs,” the challengers argued.
Can EPA go 'beyond the fence line' to require generation shifting and other measures beyond individual coal plants?
This argument wouldn't kill the Clean Power Plan outright, but it would severely limit EPA’s ability to secure reductions in greenhouse gas emissions.
Most of the rule's anticipated reductions are expected to result from efficiency programs, coal-to-gas switching and the growth of renewable power — things that fall well outside the typical approach to environmental regulation in which power plant operators are required to install pollution controls. But whether EPA can require states to take those types of actions is a question that remained unresolved when the Supreme Court established the agency's authority to regulate greenhouse gases in the 2007 Massachusetts v. EPA decision.
As a potential sign that the court views this issue as the most complex or most important, the first and longest segment of Tuesday’s oral arguments are dedicated to this question. Many legal experts think this is the most treacherous area of the case for EPA, given ambiguities in the Clean Air Act's requirement that EPA set standards based on a “best system of emission reduction."
EPA says its approach is a valid because of the unique characteristics of the electricity sector, in which power suppliers frequently shift among different generation sources, such as coal, nuclear or renewable power plants, to match supply to demand in real time (and sometimes to comply with other environmental regulations).
The challengers argue that EPA's authority to regulate applies only "within the fence line" of actual coal-fired power plants, barring generation shifting to new gas or renewables. But there’s a limit to the gains EPA can make with such constraints. On-site efficiency improvements will net only a small chunk of emissions reductions gained via the Clean Power Plan, and it is difficult if not impossible to retrofit technology like carbon capture onto existing plants.
Are the rule’s requirements 'adequately demonstrated' and 'achievable'?
The Clean Air Act says EPA can only set standards based on technology that has been “adequately demonstrated,” meaning it is reliable, efficient, not “exorbitantly” expensive and shown to be feasible in the real world.
Arguments on this point dovetail with the fence-line argument.
The challengers say the carbon rule falls short of that requirement because EPA is not requiring individual power plants to install pollution controls or switch fuels, as it traditionally has with other environmental rules, and cannot demonstrate the viability of its industry-wide approach of "shifting generation from existing coal units to gas units and new renewable resources.”
EPA points to programs like the Regional Greenhouse Gas Initiative and California’s cap and trade program to prove that such generation-shifting strategies already are working.
Did EPA make too many significant changes between the proposed and final rules?
This is a procedural issue that argues EPA made so many changes in between the proposed and final rules that “no one could have divined the rule EPA finalized — an emission reduction program based on separate, uniform performance rates for coal- and gas-fired units applied nationwide.”
Among the highlighted changes are EPA's decision to drop projected energy efficiency improvements and recalculate state emission targets, and its increased emphasis on potential emissions trading programs. A number of states challenging the rule saw their targets rise sharply between the proposed and final versions of the rule.
EPA replies that those criticisms are both vague and incorrect, and that final rule's changes are “logical outgrowths” of the proposal and subsequent input from the public. “EPA’s modifications to the Rule were foreseeable and the subject of extensive comment, including by Petitioners, so there is no procedural error,” the agency wrote.
Are EPA’s state-specific goals reasonable?
The challengers argue that EPA created an ill-fitting, one-size-fits-all approach for each state when bespoke strategies are called for.
Though there wasn’t time or space to litigate each and every state’s complaint, they cite experiences in six specific states — Arizona, New Jersey, North Carolina, Utah, Wisconsin and Wyoming — to make their case. They say EPA ignored factors such as the 2013 decommissioning of a Wisconsin nuclear plant, the potential for sage grouse habitat to limit renewable energy development in Wyoming and the effect of a 2002 North Carolina law that the state says has already delivered all of the carbon reductions that can “reasonably be achieved.”
EPA said the Wisconsin plant closed too late to be considered because 2012 was the most recent year for which complete data was available when it developed the proposed rule. In Wyoming, EPA said sage-grouse was a nonfactor because the bird is not listed under the Endangered Species Act. And it said the North Carolina law puts the state "in a better position to comply with the rule’s requirements."
https://www.politicopro.com/energy/story/2016/09/the-seven-questions-that-will-determine-the-fate-of-epas-carbon-rules-130833
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Appeals Court Decision on Clean Power Plan Will Affect Businesses
Sep 23, 2016 | The Hill - Congress Blog
By David Levine
Later this month, the U.S. Court of Appeals for the D.C. Circuit will hear a case on the legality of the Clean Power Plan, the single most significant climate change policy we have.
There are legal issues at stake here; for example, whether the Obama administration acted within its authority by using executive action, or whether the Clean Air Act gives the EPA the power to regulate greenhouse gas emissions (a power the Supreme Court has already said it has). Those are important issues, and we expect the Circuit Court to look closely at them.
But the rule faces another kind of counterargument: the idea that the Clean Power Plan, or any climate-related action, will hurt the economy.
This is not true. It never has been true, and increasing numbers of business leaders are realizing is that the opposite is true: that the longer we wait to act on climate change, the worse off we all will be.
Our organizations, the American Sustainable Business Council (ASBC) and the U.S. Black Chambers, Inc. along with two dozen other business organizations across the country, released an amicus brief (PDF) earlier this year noting the myriad economic benefits that policies like the Clean Power Plan can create. On this, the evidence is clear: we can shift our energy mix away from fossil fuels and also help businesses and the economy grow.
In fact, the pair go hand in hand.
As our brief to the court noted, employment in the solar industry rose 123% from 2010 to 2015, giving us over 115,000 new living-wage jobs -- many of them in rural communities, and predominantly local. After all, coal and oil may have to be transported from one state to another, but the sun or wind don’t have that issue.
Renewable energy costs are stable and do not spike when the air temperature is very hot or very cold. This means more predictability for businesses, letting them make smarter decisions about how or whether to invest.
What’s more, we’ve already seen how states can work together to tackle climate change. Take the Regional Greenhouse Gas Initiative, or RGGI -- a collaboration of northeastern states setting up a cap-and-trade system to lower emissions.
The brief covered that, too: From 2009 to 2011, its first three years of operation, RGGI produced $1.6 billion in economic value and led to over 16,000 additional jobs. For the three years after that, RGGI added an additional $1.3 billion in economic value and 14,200 more jobs.
But you don’t have to take our word for it. Take it from small business owners --Republicans, Democrats, and Independents -- who worry about how climate change will affect them. According to national, scientific polling conducted by ASBC, nearly one in five business owners say severe weather events caused by climate change have already harmed their businesses.
So when you hear someone stand up before the DC Circuit Court and say that the Clean Power Plan is harmful to business, keep in mind that the opposite is true. Remember that numerous business owners do know what’s at stake if we don’t act on climate change.
Then, whether the Clean Power Plan survives its court challenges or not, plan to keep on talking about it. The real voice of aware business owners may be what it takes to get policymakers to finally take useful action against this very real threat.
David Levine is CEO of the American Sustainable Business Council, which represents the policy interests of over 200,000 responsible businesses across the country.
http://www.thehill.com/blogs/congress-blog/energy-environment/297351-appeals-court-decision-on-clean-power-plan-will-affect
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Calif. Court Rejects Challenge to Injection Wells
Sep 23, 2016 | E&E Energywire
By Ellen M. Gilmer
A California court this week rejected environmentalists' challenge to the state's oversight of oil and gas wastewater.
The Alameda County Superior Court on Wednesday denied all claims brought by the Center for Biological Diversity and Sierra Club in a May 2015 lawsuit.
The groups had asked the court to halt oil and gas wastewater injection at thousands of disposal wells.
The suit came after California regulators came under fire for allowing injection in more than 2,500 wells in formations with drinkable groundwater, due to a misclassification. According to environmentalists, the state's emergency regulations to protect aquifers fall far short.
"The true emergency is the ongoing contamination of California's underground supply of water," the CBD and Sierra Club said in the suit (EnergyWire, May 7, 2015).
A group of oil and gas companies joined the suit on the state's side, represented by Gibson, Dunn & Crutcher LLP.
The court tossed the environmental groups' claims. Its ruling, which finalizes a tentative decision issued in August, finds that state regulators at the Division of Oil, Gas, & Geothermal Resources (DOGGR) were reasonable and within their discretion in crafting the emergency plan.
"DOGGR has discretion to select the appropriate corrective action to remedy non-compliance with its [underground injection control] program," the decision says.
http://www.eenews.net/energywire/2016/09/23/stories/1060043322
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Emissions Won't Go Down Without Reining in Industrial Users — Report
Sep 23, 2016 | E&E Energywire
By Kristi E. Swartz and Emily Holden
Large manufacturers and other industries can help states reduce greenhouse gas emissions by increasing energy efficiency, clean energy experts said yesterday.
U.S. industries are the single largest energy users in the nation, representing one-third of the nation's electricity use, said Jennifer Kefer, executive director for the Alliance for Industrial Efficiency. This means policymakers should include large manufacturers when developing energy policy, she said.
"If we're looking to tackle climate change, it's impossible to do so without taking into account the emissions from the industrial sector," Kefer said during a conference call on industrial electric bills, energy efficiency and energy policies.
Industrial emissions are projected to increase 18 percent by 2025, Kefer said. With that projection, it's almost impossible to address climate change without including industry reduction goals, she said.
"Industry has a huge opportunity to help utilities meet those targets," she said.
The Georgia Institute of Technology and the Alliance for Industrial Efficiency released reports yesterday on industrial energy efficiency investments being driven by federal climate and state utility policies. They are the third in a series of reports funded by Georgia Tech that looked at the Clean Power Plan and energy efficiency.
The first two focused on households and the commercial and business sector.
"We must keep energy bills affordable as we transition into a low-carbon economy," said Marilyn Brown, a Georgia Tech professor and the studies' co-author.
The reports come just before legal battles will play out next week over the carbon rule, which aims for a 32 percent reduction in power-sector emissions between 2005 and 2030. The U.S. Court of Appeals for the District of Columbia Circuit will hear oral arguments Tuesday but will not determine whether the rule is legal for at least several months.
Georgia Tech modeled low-cost compliance options for the Clean Power Plan that focus on energy efficiency and renewable policies. If industries were to adopt these models, they could save roughly $39.6 billion annually in 2030, the study said.
While forecasts often show energy efficiency to be a cost-effective carbon-cutting strategy, experts have found that savings can be difficult to project and count and that some programs overpromise and underdeliver. Because savings can be unpredictable, it's unclear how many states might use energy efficiency as a way to comply with the Clean Power Plan.
Doug Lewin, vice president of regulatory affairs and market development for the energy efficiency implementation company CLEAResult, said energy efficiency can "meet a very large part of the requirements under the Clean Power Plan, even for utilities whose requirements to reduce are not as stringent as some of the others."
CLEAResult manages energy efficiency programs for 250 utility clients around the country.
Lewin explained utilities may want to invest in energy savings to acquire carbon credits or allowances that would be available in a compliance trading system under the Clean Power Plan. They could bank carbon credits in case they exceed their individual emissions goals later on, or they could sell those credits to other utilities.
The Southeast, in particular, has the most room for energy efficiency to grow, Lewin said. Programs there haven't developed as quickly as in other areas of the country, in part because the region built out power plans in the 1970s through 1990s and didn't need to worry about shortages. Power prices there have also been historically cheaper, he said, removing some incentive for efficiency.
Most power providers in the Southeast are vertically integrated and regulated by the state, meaning they must produce integrated resource plans and measure how building new power sources compares with implementing efficiency programs.
"Energy efficiency almost always comes out as the lowest-cost or one of the lowest-cost resources available," Lewin said. "In an environment where there's a cost associated with emitting carbon, that value proposition only goes up."
http://www.eenews.net/energywire/2016/09/23/stories/1060043293
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How Big Data Changes the Economics of Renewable Energy
Sep 23, 2016 | Wall Street Journal - Blog
By Jason Bordoff
Thanks to the exponential growth of information commonly known as “big data” and our increasingly sophisticated methods to analyze it, the machine learning revolution is increasingly disrupting old industries from advertising and transportation to fashion and the legal profession.
The energy industry is no exception. Big data analytics are optimizing oil-field production and estimating oil storage levels via satellite images and remote sensing methods. But perhaps nowhere in the energy sector is the impact of big data more revolutionary than in the operations of the electricity system, where it will play an increasingly pivotal role integrating more and more renewables into the power mix.
Renewable costs are falling rapidly, leading to a sharp rise in renewable-energy deployment. According to a new report from the International Energy Agency, renewables—mainly wind and solar—accounted for 70% of global investment in new power generation projects last year.
But renewables have their limits. The sun is not always shining and the wind is not always blowing. During such periods, generators must quickly be able to call on conventional power sources, like fast-ramping natural-gas generation. This requires costly investments in backup – but less utilized – conventional generation capacity, and becomes increasingly challenging for utilities to manage as the share of renewables increases.
Big data is disrupting this traditional approach, however. In fact, according to the International Energy Agency’s Chief Economist, Laszlo Varro, renewables combined with big data could crowd out conventional fuel sources, putting natural gas – the fuel most often used to balance intermittency in power markets – increasingly “in competition with Silicon Valley.”
Utilities and engineers are testing how big data and machine learning can mitigate the intermittency problems of solar and wind to put more renewable energy into the system. For example, sensors on solar and wind facilities gather data in real time about wind speeds and sunlight intensity. New technologies then transmit these in real time to advanced computers that combine them with data from weather stations, radar and satellites to more accurately predict power generation needs in advance.
More precise estimates of how much renewable energy will be generated bring many benefits. First, wind farms can more efficiently control the number and capacity of turbines in operation to meet electricity demand. This could increase power generation by at least 10% and potentially up to 16%, according to a recent commentary in Nature, allowing a higher concentration of renewables in the energy mix even without electricity storage capability.
Second, more accurate predictions allow system operators to make better use of existing backup capacities. Electricity systems can thus substantially reduce their safety margins, which are largely comprised of poorly utilized and often costly conventional fossil fuel plants.
Third, they allow grid operators to more accurately schedule not only backup generation, but also manage consumer demand. With the proliferation of smart devices and bi-directional electricity flows, big-data technologies can facilitate increased use of demand response by allowing system operators to reduce power demand during peak hours. Under such schemes, power utilities can incentivize consumers to reduce electricity consumption or even switch off nonessential devices like air conditioners and water heaters remotely during times of peak demand.
Using big-data analytics in these ways can lower carbon emissions and save consumers money by reducing the need for fossil-fuel-based backup generation and by shaving demand peaks and lowering electricity prices.
The big-data revolution will transform the energy industry in the coming years and decades. It has already made operation of utilities more efficient. Over time, further machine-learning advances have the potential to increase the amount of intermittent renewable energy the power grid can handle, allowing solar and wind investment to rise even further.
Jason Bordoff (@JasonBordoff), a former energy adviser to President Obama, is a professor of professional practice in international and public affairs and founding director of the Center on Global Energy Policy at Columbia University.
http://blogs.wsj.com/experts/2016/09/23/how-big-data-changes-the-economics-of-renewable-energy/
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(ACC Mentioned) ‘Erin Brockovich Chemical’ Found in PA Water Systems, Study Says
Sep 23, 2016 | State Impact
By Jon Hurdle
More than 160 public water systems in Pennsylvania contained the carcinogenic chemical chromium 6 during recent tests at levels that were above a health limit recommended by scientists in California, according to a new analysis of data from the U.S. Environmental Protection Agency.
The study from the Environmental Working Group, a research and advocacy nonprofit, combined previously published EPA data with the health limit proposed by the California Office of Health Hazard Assessment to calculate that 218 million people nationwide, or some two-thirds of the population, are exposed to drinking water containing chromium 6 at concentrations above the recommended California limit.
Chromium 6, better known as the “Erin Brockovich chemical” – after the environmental campaigner who first exposed its damaging effects on human health in the 1990s – was tested for by the EPA using 60,000 samples across the U.S. between 2013 and 2015. The agency found the chemical in 75 percent of the systems, the EWG report said.
The tests found 22 cities with water systems serving more than 1 million people where chromium 6 was at or above a 0.02 parts per billion (ppb) limit recommended by the California panel. The cities included Philadelphia where all 24 samples taken contained the chemical at an average of 0.388 ppb, the sixth-highest of the major water systems, and almost 20 times the proposed California level, the EWG report said.
Other Pennsylvania locations where the chemical was found include the PA American Water Co. system in Norristown, Montgomery County, with an average level of 1.9 ppb, and in PA American Water’s Pocono District in Monroe County which had an average of 0.24 ppb, according to the EPA data used by EWG.
Nationwide, the presence of chromium 6, also known as hexavalent chromium, in drinking water at the levels detected will cause an extra 12,000 cases of cancer by the end of the century, the study said.
Chromium 6, which is used in steel making, chrome plating and, as in the Brockovich case, lowering water temperature in the cooling towers of power plants, has been linked to lung cancer, liver damage, and reproductive and developmental problems.
While the chemical’s levels in Pennsylvania systems, and hundreds of others around the country, topped the level recommended by California scientists, they were below a much higher legal limit of 10 ppb established by that state, the only one to regulate chromium 6 so far.
EWG said the looser legal limit reflected pressure on lawmakers from industry at state and national levels.
“Federal regulations are stalled by a chemical industry challenge that could mean no national regulation of a chemical [that] state scientists in California and elsewhere say causes cancer even when ingested at extraordinarily low levels,” the report said.
The study, published on Sept. 20, also focused on New Jersey where more than 150 water systems were found to contain the chemical at or above the limit recommended – but not adopted — in California. New Jersey follows an EPA guidance limit for “total chromium” – a combination of chromium 6 and chromium 3 – of 100 ppb.
Bryan Goodman, director of product communications for the American Chemistry Council, said the EWG report contained no new data on chromium 6 in the water supply.
Goodman said that when the chemical is found in ground water, it is present at low levels that are well below the EPA’s national drinking water standard. He said there is limited scientific data on how human health could be affected by low, naturally occurring levels of the chemical, and so the Council has supported third-party research into the issue.
“This is a positive example of industry supporting independent, peer-reviewed research to inform regulatory decisions about hexavalent chromium and drinking water,” Goodman wrote in an email.
Bill Walker, who wrote the report with EWG’s Senior Scientist David Andrews, said the group was publishing its analysis as the latest stage of a campaign in which it conducted its own tests for chromium 6 in 35 cities in 2010 and found the chemical in 25 systems at levels exceeding California’s proposed health standard.
“We want people to be aware that the EPA is dragging its feet on setting a national drinking water standard; that the chemical industry and the electrical power industry have delayed that process, and that as a result of industry influence, the EPA might eventually decide to do nothing,” Walker said.
Delaware Riverkeeper Network, an environmental group that advocates for clean water, urged Pennsylvania authorities to adopt their own standard for chromium 6 in drinking water rather than following the federal guidance level.
“Because Pennsylvania does not have an adopted safe drinking water standard for chromium 6 or chromium 3, they follow the EPA guidance, which is unjustly exposing people to the risk of developing disease,” said Tracy Carluccio, DRN’s deputy director. “We need action by government to adopt a mandatory requirement for all water suppliers to remove chromium 6 from our water and for companies responsible for the pollution to clean it up.”
A spokesman for the Pennsylvania DEP says the state does not have a separate chromium-6 standard, instead the DEP follows the EPA 100 ppb total chromium limit.
https://stateimpact.npr.org/pennsylvania/2016/09/23/erin-brockovich-chemical-found-in-pa-water-systems-study-says/
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East Coast States, Midwestern Utilities Divided Over CSAPR 'Update' Rule
Sep 23, 2016 | Inside EPA
By Stuart Parker
East Coast states and Midwestern power plant operators are divided over the merits of EPA's “update” for its Cross-State Air Pollution Rule (CSAPR) emissions trading program, with the states suggesting the rule falls short of the scope and emissions caps necessary while utilities are criticizing the agency's data and calling the rule unnecessary.
At a Sept. 20 meeting of the Ozone Transport Commission (OTC) in Washington, D.C., both sides said they have lingering concerns with EPA's update rule issued earlier this month. The rule revised states' emissions caps, or “budgets,” for ozone-forming nitrogen oxides (NOx) in order to drive down ozone levels and help states attain the 2008 ozone national ambient air quality standard (NAAQS) of 75 parts per billion (ppb).
The final update rule, released Sept. 7, covers 22 states compared to the 28 states covered by the original CSAPR issued in 2011. The cap-and-trade program was first launched to control ozone-forming NOx emissions, and also sulfur dioxide that leads to fine particulate matter formation (PM2.5), in order to help states attain EPA's ozone and PM2.5 NAAQS -- though the update rule does not affect the SO2 caps.
Instead, the update only applies to states' NOx budgets, excluding the Carolinas, Georgia and Florida, among other states, from the new NOx trading program. Georgia is unique among CSAPR-region states because it still has obligations under the old NOx trading regime, and EPA has said it can also join the updated plan.
The rule and its update aim to help states satisfy a Clean Air Act “good neighbor” mandate that their interstate transport of air pollution not hinder downwind states from attaining EPA's NAAQS.
The revised rule also responds in part to a July 2015 remand from the U.S. Court of Appeals for the District of Columbia Circuit in EME Homer City Generation L.P., v. EPA (Homer City II), in which the court remanded to EPA the NOx and SO2 emissions budgets of several states. The court found EPA had “overcontrolled” several upwind states by setting NOx caps more stringent than necessary for other states to attain the ozone standard.
At the meeting of OTC -- representing 12 Mid-Atlantic and Northeastern states -- representatives from states and industry reiterated long-running claims that CSAPR is either too limited or too broad.
Members of the OTC questioned EPA's technical analysis that excluded some Southeastern states from the new NOx trading system, and EPA's use of relatively “cool” years to project future ozone levels.
Cooler, rainier conditions during the summertime ozone season, when high ozone is typically seen in the East, are less conducive to ozone formation, some state regulators and environmentalists note. Using these years as a baseline may underestimate future ozone, given a trend toward progressively hotter summers, they say.
But power sector officials claim that decreasing NOx levels mean the new rule is entirely unnecessary. Industry groups are faulting not just EPA's technical analysis, but the legal foundations of the rule.
Utilities' Concerns
The Midwest Ozone Group (MOG), a coalition of Midwestern electric utilities, in comments at the meeting outlined its concerns with the CSAPR update: “While we will have much to say on other occasions about the legal and technical deficiencies of this rule, we find it remarkable that EPA itself now predicts a dramatic improvement in ozone air quality in 2017 (as compared with the projections that supported the proposed rule.)”
MOG notes that EPA predicts very few air quality monitors in downwind areas will show NAAQS nonattainment for the 2008 standard in 2017, which it says means there is no basis for the CSAPR rules.
“EPA's base case modeling shows that without anything more than the existing regulatory programs it considered, ozone air quality will have improved enough by 2017 that one of the three non-attainment monitors in Connecticut will be brought into attainment with the 2008 ozone NAAQS and that the other three non-attainment monitors (two in Connecticut and one in Wisconsin) will be very nearly in attainment with that standard,” MOG says.
MOG doubts EPA took into account all regulatory programs that will reduce ozone in 2017, saying, “We are convinced that had EPA given full consideration to all of the emission reduction programs that are currently mandated to be in effect in 2017, all monitors in the East would indeed be in attainment with that standard by 2017.”
A MOG source tells Inside EPA that the remaining air quality monitors predicted to show nonattainment are “right on the ragged edge” of attainment, and would be modeled to attain the 2008 NAAQS if additional factors, such as Connecticut state regulations, were taken into account. Connecticut will by 2017 have its own regulation in place for reasonably available control technology -- a level of emissions control required within the OTC area.
The source says, “We see ozone air quality continuing to improve year after year,” regardless of any warming trend, and denies that EPA's use of 2011 -- a relatively low-ozone, cool year -- skews projections toward attainment. The period of 2009-2013 that EPA considered for the CSAPR update is the “dark ages” in terms of NOx levels, which have fallen dramatically since then, thanks to regulations and shifts in power plant fuel use, the source says.
MOG further questions EPA's modeling assumptions involving monitors, such as those at issue in Wisconsin and Connecticut that are very close to water, a concern that OTC-area regulators share.
Also, the group believes EPA has wrongly excluded consideration of international emissions and says that otherwise the East would not face nonattainment issues and would not require CSAPR at all, the group says.
One industry attorney concurs with MOG's analysis that if all relevant regulatory programs were taken into account, all areas would attain the 2008 NAAQS and the CSAPR update rule would lack any basis. “There remain issues about whether EPA has properly credited the air quality impacts of several programs that are scheduled to take effect by 2017,” the source says, predicting that “there will be litigation” over the update rule.
The attorney adds that there is not enough time for industry to comply by a May 2017 deadline, which is “just around the corner and many units need to be making major upgrades.” EPA pitched the rule, however, as requiring units to run existing pollution controls, and did not foresee many major upgrades as necessary.
'More Reasonable'
The industry source concedes, however, that the final rule is “more reasonable than the proposal,” largely due to the change of the NOx emissions rate EPA assumed for electric generating units using selective catalytic reduction (SCR), a highly-effective NOx control technology.
EPA in the final rule assumes a less efficient removal rate, of 0.10 pounds of NOx per million British Thermal Units (lb NOx/mmbtu), than it did in the proposal (0.075 lb NOx/mmbtu). This lowers the expectations on states to curb NOx and produces higher emissions caps. According to EPA, the final rule's emissions reductions are some five percent lower than proposed, meaning its projected benefits are also lower than the proposal.
OTC regulators at the meeting said they are working on a technical fix to overestimation at the water's edge by computer models used to project future NAAQS attainment -- and therefore as a basis for EPA's rules.
Models consistently overestimate ozone levels over water, and current EPA guidance requires that states include the area around a monitor in their projections of future NAAQS attainment, including over-water areas. OTC is nonetheless working on a method of screening out the over-water areas, to give a more accurate projection, OTC officials said.
OTC's actual ozone monitoring results from 2015 and 2016 appear to conflict with MOG's projections. Ozone monitoring for 2014-2016, used to calculate “design values” at monitors that determine NAAQS attainment, show monitors in Connecticut, New Jersey, New York and Pennsylvania reading above 75 ppb.
States will in October 2017 issue final attainment designations for the tougher 2015 NAAQS of 70 ppb that EPA issued on Oct. 1, triggering the need for state planning, and possibly another CSAPR-type rule, to meet the good neighbor obligations. Good neighbor obligations are determined by “significant contribution” to another state's NAAQS attainment problem, where significant contribution is defined as one percent of the NAAQS.
CSAPR's Scope
OTC regulators at the meeting greeted the absence of some Southeastern states from the update rule with some skepticism. They noted that in the years used to develop the update rule, transport of pollution from the Southeast to the Northeast along the “noctural jet” of air was sharply reduced, lowering ozone levels in the OTC area. With different whether conditions, the southerly component of ozone pollution in the region will return, pumping ozone levels higher and possibly undermining EPA's projections, some OTC regulators fear.
This feeds into a broader fear among some that EPA is underestimating the effect of a warming climate on ozone levels. Many expect higher temperatures to counteract NOx reductions, tempering the ozone reductions that would otherwise follow NOx cuts. One environmentalist says EPA in the update rule is following a “pray for rain” strategy, and has not properly accounted for the effect of higher temperatures in the future.
One OTC-area regulator says that the adequacy of state emissions budgets -- and hence the impact on industry -- “will vary based on perspective obviously but suffice it to say that the revised framework continues to try to solve a short term NAAQS problem with a seasonal program which does not protect against peak day emissions.”
OTC regulators are now focusing on encouraging power plants with emissions controls installed to run them, mitigating ozone production on hot summer days with peak electricity demand. The regulator notes that emissions trading appears the wrong mechanism to address this issue.
http://insideepa.com/daily-news/east-coast-states-midwestern-utilities-divided-over-csapr-update-rule
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Kerry Calls for HFC Phaseout, Says Paris Alone Won't 'Get the Job Done'
Sep 23, 2016 | E&E Climatewire
By Jean Chemnick
The United States and other countries proclaimed yesterday that an upcoming effort to amend an international ozone treaty to curb refrigerants that contribute to global warming would be a test of the post-Paris Agreement era.
Speaking in a posh Midtown hotel conference room blocks away from the United Nations, where the landmark global warming deal struck in the French capital sailed past its first ratification hurdle Wednesday, Secretary of State John Kerry said a hydrofluorocarbon phasedown under the Montreal Protocol would be a "huge step" toward making good on the promise of Paris.
"We know that the Paris Agreement itself won't, in and of itself, get the job done," said Kerry, who spent much of that summit in the suburb of Le Bourget working to deliver the deal.
"So we need to do more," he said. "And one of the single most important actions that the global community can take is to amend the Montreal Protocol to include an ambitious amendment that phases down the use of hydrofluorocarbons, HFCs."
Kerry was joined onstage by foreign ministers from developed and developing countries representing the 100 nations that signed on to a declaration calling for next month's summit in Rwanda to produce an "ambitious amendment" that would freeze the production and use of HFCs "early" in poor countries, cut them in rich ones and introduce "an ambitious phasedown schedule for all parties."
The statement was accompanied by pledges of a combined $80 million by 16 countries and a variety of private philanthropists aimed at helping poor countries make a swift transition away from HFCs, and by a statement of support by the coolants industry.
The so-called New York Declaration of the Coalition to Secure an Ambitious HFC Amendment was signed by more than half the world's countries two weeks before negotiators gather in the Rwandan capital of Kigali with hopes of ironing out continuing areas of disagreement about how the world should phase out these climate superpollutants.
HFCs are used in cooling and refrigeration and can be thousands of times more climate-forcing that carbon dioxide, though they stay in the atmosphere a shorter time.
The amendment has been a long-term priority for President Obama, and securing it is perhaps the most important item still on his climate diplomacy to-do list besides seeing the Paris deal take effect. That agreement moved closer to entry into force Wednesday when a requirement that at least 55 countries join was met. Paris will take effect when countries responsible for 55 percent of greenhouse gas emissions join, which will almost certainly be later this year.
So Kigali is seen as the next opportunity to make a serious impact on warming, but the road to an amendment has been long and bumpy. Countries including China, India and Arab nations have historically objected to amending the ozone treaty to address HFCs, often insisting that climate issues fell under the purview of the U.N. Framework Convention on Climate Change (UNFCCC).
That opposition began to crumble when Obama and Chinese President Xi Jinping agreed to work together on an amendment during a summit at Sunnylands, Calif., in 2013. Now virtually every country in the world agrees on the need for an HFC phasedown, though they don't all see eye to eye on how it should be constructed.
Speaking at yesterday's event, Chinese Ambassador Liu Xiaoming touted Xi and Obama's agreement earlier this month to collaborate on an "ambitious" HFC amendment, which came the same day the world's two largest emitters ratified Paris.
But he also made a plug for the continuation of "common but differentiated responsibilities" between wealthy and poor nations — a convention of the UNFCCC that was all but sidelined during last year's carbon deal but that still holds sway under the Montreal Protocol, where developed and developing countries phase out emissions at different rates and assistance is provided to poor nations.
And while he made a pitch for developing countries to "have their needs met," Liu pledged that China would "continue to work with all other parties toward an ambitious and comprehensive HFC amendment to the Montreal Protocol this year."
Negotiators and advocates who follow the HFC debate say they are optimistic that next month's summit will produce the looked-for amendment, which they hope will help save the world a half-degree Celsius in warming by the close of this century. The long-term goal was to contain postindustrial warming to well below 2 degrees, which would make the Montreal Protocol amendment a hefty down payment on Paris.
Ambition and money
But there are still many questions to be settled as the days count down to Kigali. These divide generally into questions about how ambitious the deal will be and about the resources that will be available to poor countries to help them transition to less climate-forcing coolants.
The ambition of any amendment will be determined by how quickly poor countries' emissions are capped, how quickly rich nations cut their emissions and ultimately when the chemicals are phased down completely. Also important is the baseline that is used to measure those reductions — the higher the baseline, the more leeway a nation has to keep producing and using HFCs.
During a preliminary meeting in Vienna in July, there were eight proposals, though negotiators say some of those differences have narrowed since and predict that parties will eventually coalesce around a common model in Kigali.
The world's developed countries proposed that developing nations begin cutting their emissions in 2019 from a baseline average of 2011 to 2013 levels. But China, Argentina and the Persian Gulf states put forward slightly different models that capped HFC growth in the middle of the next decade, while India held fast to a freeze date of 2031.
Poor countries note that they are responsible for emitting far less HFCs than developed nations. They also are still gaining access to refrigeration and air conditioning, making it harder to stem HFC growth. Advocates, meanwhile, argue that the rapid proliferation of air conditioning in the developing world is exactly why an early freeze date is important.
Observers say China and Argentina — both signatories to yesterday's New York Declaration — have shown considerable flexibility in negotiations since Vienna.
Argentina Foreign Minister Susana Malcorra, who is also a top-tier contender for U.N. secretary-general, said at yesterday's event that while developing countries' needs for time and support must be addressed, the work of phasing down HFCs belongs to everyone.
"I am convinced that we will be able to sort this out, and as proud as I was yesterday when my president presented to the secretary-general our confirmation of joining the Paris Agreement, I'm sure we will be proud to in Kigali share this common and shared responsibility," she said.
India has shown little movement coming out of Vienna and is not a party to the declaration. But a senior State Department official said that is likely a negotiating tactic. Progress was made during a work session earlier this week in Beijing, and there may be more progress in the days leading up to the summit in Rwanda.
Developing countries have also expressed concern about the cost of transitioning to non-HFC coolants, particularly as some of those alternatives are still under patent.
The State Department source said the issues of ambition and finance are "linked" for developing countries, which might have more confidence in embracing an earlier phasedown if resources are assured.
Sixteen developed countries including the United States responded yesterday with a combined $27 million pledge toward the Montreal Protocol Multilateral Fund to help poor nations transition away from HFCs and improve energy efficiency. Nineteen private donors, including Microsoft founder Bill Gates and billionaire financier Tom Steyer, supplemented that with $52 million for efficiency. The money is contingent on an "ambitious" agreement. The public-sector resources would only be provided for action taken next year, and are earmarked to help poor countries comply with an amendment with "a sufficient early freeze date," to be adopted this year.
Paris leaders see a link to a 'sister' agreement
The protagonists of Paris implementation say a Montreal Protocol amendment is crucial to the success of last year's deal. HFCs drive so much warming in the short term that taking them out of the atmosphere will have a near-immediate benefit, they say, buying time for the more comprehensive agreement to go into effect.
"This is the fastest way to cool the Earth, you know? And the most easy one," Morocco's environment ambassador, Hakima El Haite, told ClimateWire.
In New York to represent the upcoming Moroccan presidency of the next round of UNFCCC talks, El Haite recalled how fraught the negotiations in Paris were over where to set the long-term temperature target to guide future ambition.
"We made many, many, many nights to discuss and to struggle against other parties to say in the Paris Agreement one word — 'well below 2 degrees C,'" she said. "That was a struggle."
But if curbing HFCs can contribute half a degree's worth of warming avoidance, she said, "we don't need to struggle."
U.N. climate chief Patricia Espinosa wrote in an op-ed published earlier this month by Project Syndicate that Paris' long-term targets would eventually demand a universal HFC phasedown.
"Ultimately, all countries will have to find a way forward on reducing HFCs and climate change generally, through national action plans and emissions reductions agreed to under the 2015 Paris agreement," she wrote in the column, co-authored by Nobel Prize-winning chemist Mario Molina. "Frameworks established by sister agreements like the Montreal Protocol can help to do this."
Durwood Zaelke of the Institute for Governance & Sustainable Development said that because manufacturers improve efficiency at the same time as they transition from HFCs, the true benefit of an amendment could be to avoid a full degree of warming, rather than a half. The efficiency gains would save consumers money, further offsetting the cost of transitioning to less climate-forcing sources, he said.
Zaelke, who follows these negotiations closely, said India's apparent opposition will not prove a significant stumbling block to hopes of securing a deal in Kigali.
"There's a tremendous amount of bilateral initiative going on around the world, and India is the No. 1 country that this broad coalition for an ambitious amendment know they have to deal with," he said. The July session in Vienna showed enough progress from all players that an amendment should be possible next month, he said.
'We cannot afford to fail'
But participants in yesterday's HFC events in New York said if Kigali fails to deliver, it will deal a blow to international confidence since Paris.
"Kigali gives us an opportunity to demonstrate action on Paris," said Vidar Helgesen, minister of climate and the environment for Norway, which was one of the donor countries. "Just imagine if we're not successful in Kigali. What signal would that send about Paris? It would be disastrous. So we know our responsibilities."
Kate Hampton, CEO of the Children's Investment Fund Foundation, which contributed to the private-sector fund, said donors were buoyed by the success of Paris and the sense that governments are committed to a low-carbon transition.
"If Kigali is in some sense a failure, there will be a massive retreat of interest and capital," she said at a briefing at U.N. headquarters. She said a consistent government message would encourage private donors to offer help with other aspects of climate response.
"Politicians particularly have a real opportunity here to send a very, very strong signal that this transition is inevitable, and that will mobilize resources that you can't imagine," she said.
Vincent Biruta, the Rwandan environment minister, who is preparing to host next month's summit, noted that Africa stands to suffer more from climate change than most continents. All 54 African countries signed yesterday's declaration, and Africa and small island states have pushed for tougher reductions for developed countries than the developed world has proposed for itself.
"We cannot afford to fail," he said.
http://www.eenews.net/climatewire/2016/09/23/stories/1060043335
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Calif. Cap and Trade Faces New Hurdles
Sep 23, 2016 | E&E Climatewire
By Debra Kahn
California regulators are running into opposition as they make a bid to extend their economywide greenhouse gas program to 2030 and mesh it with federal regulations.
At a hearing yesterday to consider extending their cap-and-trade market past 2020, the California Air Resources Board (ARB) heard from opponents of the program who argued that it has allowed businesses to buy their way to compliance with the state's carbon cap without actually reducing "co-pollutants" of particulate matter and other substances in disadvantaged communities where industrial facilities are more likely to be located.
The opposition of the environmental justice movement has added an obstacle to California's efforts to continue its emissions cuts through 2030, as a new law signed earlier this month, S.B. 32, mandates.
Accompanying S.B. 32 was another law, A.B. 197, that specifies ARB must "prioritize" regulations that reduce direct emissions from stationary and mobile sources. The practical effect of that provision is unclear, but it is viewed at the least as a new restriction on board's authority to implement cap and trade (ClimateWire, Sept. 20).
Environmental justice groups demonstrated outside yesterday's hearing against cap and trade and also against its inclusion in California's compliance plan for U.S. EPA's Clean Power Plan for existing power plants. ARB is planning to use the cap-and-trade program to demonstrate that it meets its federal emissions rate target of 13.2 percent below the 2012 level by 2030.
"We do not want this hoax of a system to be ossified in federal law," said Shana Lazerow, staff attorney with Communities for a Better Environment.
In addition to extending the market through 2030, amendments under consideration would link California to Ontario's market that is scheduled to begin next year. They would also potentially set up a way for Washington state businesses to buy allowances from California for use in their own climate program, which Democratic Gov. Jay Inslee's Ecology Department adopted last week (ClimateWire, Sept. 16).
ARB will not be voting on the changes until at least next spring. That could leave enough time to pick another method of getting to the 2030 target, one board member suggested.
"I wonder if you've thought about that," said Diane Takvorian, director of the Environmental Health Coalition. "As the world changes, as the legislation has come forward, it seems we need to jump into that as much as we can."
Another board member pointed out there are other ways to reduce conventional air pollution. "Whether or not cap and trade goes forward, the separate issue is what are those regulations that are needed, state and locally, to improve health in local communities," said ARB board member John Gioia, a member of the Bay Area Air Quality Management District. "It doesn't mean cap and trade itself goes away; it means how is it designed and what in addition to cap and trade achieves health improvements in local communities?"
http://www.eenews.net/climatewire/2016/09/23/stories/1060043332
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