FUMIGATION APPLICABILTY AND Air Quality …2019/01/17 · PRESENTATION OVERVIEW • What is...

DIVISION OF AIR QUALITYAIR QUALITY, ENERGY, AND SUSTAINABILITY

Air Quality

Energy

SustainabilityJ A N U A R Y 1 7 , 2 0 1 9

FUMIGATION APPLICABILTY AND ADDITIONAL REQUIREMENTS

Presented by Mubin Kathrada & Anjuli Ramos-Busot

PRESENTATION OVERVIEW

• What is fumigation?• Why is fumigation necessary?• Where are fumigation facilities located in NJ?• Typical fumigants and their toxicity.• Fumigants & equipment used in fumigation.• Rule changes under consideration.

Slide 21/17/2019 |Division of Air Quality | NJDEP | Presented by: Mubin Kathrada & Anjuli Ramos-Busot

WHAT IS FUMIGATION?

• Fumigation• Fumigation is a method of pest control that completely fills an

area with gaseous pesticides—or fumigants—to suffocate or poison the pests within. It is used to control pests in buildings, soil, grain, and produce, and is also used during processing of goods to be imported or exported to prevent transfer of exotic organisms.

• Commodity Fumigation• Commodities fumigated in NJ include, but not limited to - grains,

seeds, plants, bulbs, timber, flowers, vegetables, cocoa beans, coffee beans, fruits, cars and clothing.


WHY IS FUMIGATION NECESSARY?

• Fumigation is now a legal requirement in many countries. A fumigation certificate must be issued by the fumigator. Most countries will not import goods without a fumigation certificate, if fumigation is mandated for the goods in question.

Slide 41/17/2019 Division of Air Quality | NJDEP | Presented by: Mubin Kathrada & Anjuli Ramos-Busot add your name here

LOCATION OF FUMIGATION FACILITIES IN NJ


TYPICAL FUMIGANTS & THEIR TOXICITY

Methyl bromide

Phosphine- HAP- VOC- Colorless and Odorless- Ozone Depleting

Substance- High Toxicity- Limiting Ban - 2005

- HAP- NOT a VOC- Colorless and Garlic/Fish

like Odor- High Toxicity

Sulfuryl fluoride

- NOT a HAP- NOT a VOC- Colorless and Odorless- Greenhouse Gas - High Toxicity - Proposed to be banned

in 2014 – never finalized

1/17/2019 |Division of Air Quality | NJDEP | Presented by: Mubin Kathrada & Anjuli Ramos-Busot Slide 6

SULFURYL FLUORIDE (SF)

• Commercial names: Vikane® (+ chloropicrin, odor agent) and ProFume®

• Regulated by USDA (Agriculture) and US FDA• Uses:

- Insecticide and rodenticide fumigant• Residential structures• Processed-food and pet food facilities• Warehouses• Shipping containers

- Synthesis of organic drugs and dyes • Registered in the US as a pesticide since 1959• Sold/used as a liquefied gas in pressurized steel cylinders


• Stratospheric ozone-depleter

• Regulated by the Montreal Protocol in 1986

• U.S. production and import is banned since 2005, except for:• "quarantine and pre-shipment" purposes commodity fumigation• "critical use exemption" of agriculture applications

• Currently regulated as a HAP by USEPA and NJDEP• Reporting Threshold – 230 lb/yr• Toxicology data by IRIS and CalEPA

• Less toxic than sulfuryl fluoride and phosphine

METHYL BROMIDE (MB)


• Acute (short-term) inhalation exposure:• Irritating to the eyes, skin, and mucous membranes of the upper respiratory

tract • Headaches, dizziness, fainting, apathy, weakness, confusion, speech

impairment, visual effects, numbness, twitching, and tremors• Frequently leads to neurological effects in humans • Kidney damage has been observed in humans who have inhaled high levels

of MB

• Chronic (long-term) inhalation exposure:• Mild functional neurological impairment may results in humans/workers• Neurological effects, including lethargy, forelimb twitching, tremors, and

paralysis have also been observed in animal studies

MB TOXICITY


PHOSPHINE (Phos)

• Commercial name: ECO2FUME™• Regulated by USDA (Agriculture) and US FDA• Used as an insecticide for the fumigation of grains, animal feed,

and leaf-stored tobacco, and as a rodenticide• Restricted Use Pesticide (RUP) because of its acute inhalation

toxicity• Currently regulated as a HAP by USEPA and NJDEP

• Reporting Threshold – 14 lb/yr• Toxicology data by IRIS and CalEPA

• Registered in the US as a pesticide since 1999 • More toxic than sulfuryl fluoride and methyl bromide


• Acute (short-term) inhalation exposure:Headaches, dizziness, fatigue, drowsiness, burning substernal pain, nausea, vomiting, cough, labored breathing, chest tightness, pulmonary irritation, pulmonary edema, and tremors in humans

• Chronic (long-term) inhalation exposure of workers may cause:Inflammation of the nasal cavity and throat, weakness, dizziness, nausea, gastrointestinal, cardiorespiratory, central nervous system symptomology, jaundice, liver effects, and increased bone density

Phos Toxicity


Toxicity Values

Methyl bromide (ppm) Sulfuryl fluoride (ppm) Phosphine (ppm)

10 min 30 min 60 min 4 hr 8 hr 10 min 30 min 60 min 4 hr 8 hr 10 min 30 min 60 min 4 hr 8 hr

AEGL 1 NR NR NR NR NR NR NR NR NR NR NR NR NR NR NR

AEGL 2 940 380 210 67 67 27 27 21 13 6.7 4 4 2 0.5 0.25

AEGL 3 3300 1300 740 230 130 81 81 64 40 20 7.2 7.2 3.6 0.9 0.45

AEGL = Acute Exposure Guideline LevelsNR = Not recommended due to insufficient data.

Methyl bromide (µg/m3)

Sulfuryl fluoride (µg/m3)

Phosphine (µg/m3)

RfC Long-Term 5 60 0.3RfC Short-Term 3,900* 1,700** 70**

RfC = Reference Concentration* Averaging time of 1 hour.** Averaging time of 24 hours.


1/17/2019 |Division of Air Quality | NJDEP | Presented by: Mubin Kathrada & Anjuli Ramos-Busot

0.0048

0.019

0.039

0.063

0.094

0.0064

0.026

0.058

0.10

0.15

0.0

0.1

0.2

10 20 30 40 50 100 150 200

Emiss

ion

Rate

(lb/

hr)

Distance to Property Line (ft)

Emission Rate (lb/hr) presenting Negligible Risk for Ground-Level Discharge as a function of Distance to Property Line (Zoomed In)

Sulfuryl fluorideMethyl bromidePhosphine

Slide 13

FUMIGANTS & EQUIPMENT USED IN THE FUMIGATION PROCESS

• Methyl bromide, sulfuryl fluoride and phosphine are the most commonly used fumigants.

• The fumigation enclosures can be sealed trailer transport trucks, purpose built fumigation chambers or “tarped” areas in warehouses.

• At the end of the fumigation process, the enclosure is evacuated.

• In most instances the fumigant is released to the atmosphere at ground level.


A BASIC FUMIGATION CHAMBER

Slide 1511/17/2017 |Division of Air Quality | NJDEP | Presented by: Presented by: Mubin Kathrada & Anjuli Ramos-Busot

RULE CHANGES UNDER CONSIDERATION

• At minimum, the rule will require a fumigation operation to be vented through a stack that meets the following conditions:

• The stack is a Good Engineering Practice (GEP) stack.• The stack is designed for “worst case” emissions.• The stack achieves negligible RISK levels.

NOTE: The proposed rule will not specifically dictate add-on controls. However, controls may be necessary to mitigate health RISK concerns or comply with an applicable state or federal regulation.


GOOD ENGINEERING PRACTICE (GEP) STACK HEIGHT

A GEP stack height analysis shall be conducted in accordance with the USEPA stack height regulation (40 CFR 51) and the Guideline for Determination of Good Engineering Practice Stack Height (USEPA, 1985).

The formula for the GEP stack height, is:HGEP = Hb + 1.5 L

where: HGEP is formula GEP stack height;Hb is the height of adjacent or nearby building; and L is the lesser of the height and the maximum projected width of adjacent or nearby building.

A stack is considered close enough to a building to be affected by downwash if it is located within 5L, or five times the lesser dimension of the building in any wind direction.

See https://www.state.nj.us/dep/aqpp/downloads/techman/1002.PDFsection 6.3 for a detailed discussion of GEP stack height.


https://www.state.nj.us/dep/aqpp/downloads/techman/1002.PDF

WHAT ARE “WORST CASE” EMISSIONS?

• “Worst Case” must include:• The maximum tons per year of each fumigant emitted.• The maximum pounds per hour of each fumigant emitted

during the first hour of the evacuation step.


WHAT IS NEGLIGIBLE RISK?

• Hazard quotient (for non-carcinogenic risk) must be <= 1 for both long-term (annual) and short-term effects (24 hours).

• Incremental risk (for carcinogen) must be <= 1 in a million.


METHYL BROMIDE HAZARD QUOTIENT VS STACK HEIGHT

0

0.5

1

1.5

2

2.5

3

3.5

4

4.5

0 10 20 30 40 50 60

Series 2HA

ZARD

QUO

TIEN

T (Fi

rst L

evel

)


5 TPY / 25 lb/hour / 250 ft to Prop LineSeries 1 = Hazard Quotient (Annual)

Series 2 = Hazard Quotient (Short Term 24 hr)

Stack Height (ft)

Series 1

SULFURYL FLUORIDE HAZARD QUOTIENT VS STACK HEIGHT

0

1

2

3

4

5

6

0 20 40 60 80 100 120

Series 2

HA

ZARD

QUO

TIEN

T (Fi

rst L

evel

)


3 TPY / 25 lb/hour / 250 ft to Prop LineSeries 1 = Hazard Quotient (annual)

Series 2 = Hazard Quotient (Short Term 24 hr)

Stack Height (ft)

Series 1

PHOSPHINE HAZARD QUOTIENT VS STACK HEIGHT


0

5

10

15

20

25

0 20 40 60 80 100 120 140 160 180 200

HAZA

RD Q

UOTIE

NT (

Firs

t Lev

el)

Stack Height (ft)

3 TPY / 350 ft. to Property lineSeries 1 = Hazard Quotient (annual)

Series 1

QUESTIONS???

• Mubin Kathrada: 609-633-1134 • [email protected]

• Anjuli Ramos-Busot: 609-633-1113• [email protected]

• Quddus Qayyum: 609-633-8221• [email protected]

Slide 232/14/2019 |Division of Air Quality | NJDEP | Mubin Kathrada & Anjuli Ramos-Busot

mailto:[email protected]



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FUMIGATION APPLICABILTY AND Air Quality …2019/01/17 · PRESENTATION OVERVIEW • What is...

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