EPA-450/3-33-011b
Inorganic Arsenic Emissions from
  Glass Manufacturing Plants —

   Background Information for
      Promulgated Standards
        Emission Standards and Engineering Division
       U.S. ENVIRONMENTAL PROTECTION AGENCY
            Office of Air and Radiation
       Office of Air Quality Planning and Standards
       Research Triangle Park, North Carolina 27711

                May 1986

-------


-------
                      ENVIRONMENTAL PROTECTION AGENCY

                          Background Information
                    Final Environmental  Impact Statement
       for Inorganic Arsenic Emissions from Glass Manufacturing Plants
i  fi2
                               Prepared by:
jack R.  Farmer
Director, Emission Standards and Engineering  Division
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina  27711

1.   The promulgated standards will limit emissions of inorganic arsenic
     from existing and new glass manufacturing  plants.  The promulgated
     standards implement Section 112 of the Clean Air Act and are based on
     the Administrator's determination of June  5, 1980 (48 FR 37886)  that
     arsenic  presents a significant risk to human health as a result  of air
     emissions from one or more stationary:source categories, and is
     therefore a hazardous air pollutant.

2.   Copies of this document have been sent to  the following Federal
     Departments:  Office of Management and Budget; Labor, Health and Human
     Services, Defense, Transportation, Agriculture, Commerce, Interior, and
     Energy;  the National Science Foundation; the Council on Environmental
     Quality;  members of the State and Territorial Air Pollution Program
     Administrators; the Association of Local Air Pollution Control
     Officials; EPA Regional Administrators;  and other interested parties.

3.   For additional information contact:

     Mr. Robert L. Ajax
     Standards Development Branch (MD-13)
     U.S. Environmental Protection Agency
     Research  Triangle Park, North Carolina   27711
     Telephone:  (919) 541-5624

4.   Copies of this document may be obtained  from:

     U.S. EPA  Library (MD-35)
     Research  Triangle Park, North Carolina   27711

     National  Technical Information Service
     5285 Port Royal Road
     Springfield, Virginia  22161
                                   m

-------

-------
                              TABLE OF CONTENTS
                                                               Page

Chapter 1 - Summary	 1-1

     1.1  Summary of Changes Since Proposal  	 1-1
     1.2  Summary of Impacts of Promulgated  Action 	 1-3

Chapter 2 - Summary of Public Comments	 2-1

     2.1  Affected Facilities 	 2-1
     2.2  Stringency of the Proposed Emission Limit 	 2-11
     2.3  Selection of Control Technology 	 2-17
     2.4  Cost Effectiveness of the Proposed Standard 	 2-22
     2.5  Economic Impact	 2-22
     2.6  Exemptions and Allowances 	 2-25
     2.7  Monitoring and Measurement Methods 	 2-29
     2.8  Determination of Compliance	 2-37
     2.9  Reporting Requirements	 2-41
     2.10 Arsenic Emissions from Soda-Lime Furnaces 	 2-42
     2.11 Zero Production Offsets 	 2-48
     2.12 Risk Assessement and Risk Management	 2-49

Appendix A - Summary of Results of Emission  Testing
             Performed After Proposal	 A-l

Appendix B - Updated Cost and Economic Analysis 	 B-l

Appendix C - Available Arsenic Emissions Data for
             Existing Arsenic-Using Glass Plants 	 C-l

Appendix D - Inorganic Arsenic Risk Assessment for
             Glass Manufacturing Plants	 D-l

-------

-------
                                  1.0  SUMMARY

     On July 20, 1983, the Environmental Protection Agency (EPA) proposed
standards for inorganic arsenic (48 FR 33112) pursuant to Section 112 of the
Clean Air Act which requires national emission standards for hazardous air
pollutants (NESHAP).  The proposed standard covered the following categories
of sources of inorganic arsenic: high-arsenic primary copper smelters,
low-arsenic primary copper smelters, and glass manufacturing plants.  EPA
also identified six additional source categories, but determined that
standards are not warranted at this time.
     Public comments were requested on the proposal in the Federal Register.
This document addresses the comments pertaining to glass manufacturing
plants.  After proposal, the public comment period for the proposed
standards for glass manufacturing plants was reopened on March 20, 1984
(49 FR 10278).  Additional comments were solicited for one month concerning
inorganic arsenic emissions from soda-lime glass manufacturing and
concerning zero production rate offsets.
     There were 24 comment letters submitted concerning the standards for
glass manufacturing.  Eleven letters were from industry,, seven from state
agencies, four from environmental groups, one from the Office of Management
and Budget, and one from two private individuals.  In addition, two industry
and one environmental group spokesman testified about the arsenic NESHAP for
glass manufacturing plants at the public hearing.
     The comments submitted, along with responses to these comments, are
summarized in this document.  The summary of comments and responses serves
as the basis for the revisions made to the standard between proposal and
promulgation.

1.1  SUMMARY OF CHANGES SINCE PROPOSAL
     In response to public comments received on the proposed rulemaking and
as a result of EPA re-evaluation, five major changes were made to the
proposed standard.  These changes involve (1) revising the cutoff for
existing furnaces, (2) revising the format of the emission limits,
                                     1-1

-------
(3) allowing the control device to be by-passed for periods of maintenance,
(4) eliminating the exemption to 40 CFR Part 60, Subpart CC for sources that
comply with the NESHAP, and (5) establishing a provision to exempt certain
sources from testing procedures.
Existing Furnace Cutoff
     Further examination of risks associated with arsenic emissions from
specific existing glass manufacturing plants led the Agency to change the
regulation by establishing the cutoff on uncontrolled arsenic emissions for
existing glass melting furnaces at 2.5 Mg (2.75 tons) per year.  The
proposed cutoff on uncontrolled arsenic emissions of 0.4 Mg (0.44 ton) per
year is retained for new or modified furnaces.
Format of the Standard
     The second major change in the regulation since proposal involves a
change in the format of the emission limits.  The promulgated standard
requires owners or operators of existing glass furnaces to ensure either
that uncontrolled total arsenic emissions are less than 2.5 Mg (2.75 tons)
per year or that arsenic emissions are reduced by 85 percent.
By-pass of the Control Device
     The third major change in the regulation allows glass furnace owners or
operators to petition the Administrator for permission to by-pass the
control device for a limited period for control device maintenance purposes.
After receiving a comment requesting this provision, the Agency investigated
the cost and environmental impacts associated with performing routine
maintenance on emission control devices installed on affected glass
furnaces.  EPA concluded that control devices could be by-passed during
maintenance because the cost of requiring a temporary shutdown during
maintenance would be excessive without offsetting environmental benefits and
because the use of well maintained control devices is essential in
effectively controlling arsenic emissions on a continuing basis.  However,
the Agency has included provisions to requie plants to minimize arsenic
emissions during maintenance periods and will allow it only upon
demonstration of its necessity.
                                     1-2

-------
Elimination of Exemption from NSPS        ' ;
     In the proposed standard, participate emission limits were identical  to
those in the glass manufacturing NSPS (40 CFR Part 60, Subpart CC) and no
furnace was allowed to operate with uncontrolled arsenic emissions in excess
of 0.4 Mg (0.44 ton) per year.  The promulgated standard has been revised
such that the emission limits are no longer identical and the exemption from
the NSPS is no longer appropriate.
Compliance Testing
     In the final major change, EPA created a provision to exempt certain
sources from performing emission tests to demonstrate compliance.  Existing
sources that add less than 8.0 Mg arsenic per year to the batch and new or
modified sources that add less than 1.0 Mg arsenic per year to the batch
will be exempted from performing emission tests.  Analysis has shown that  if
an existing or new source adds less arsenic than these amounts to the raw
materials, it would emit less than 2.5 Mg (2.75 tons) or 0.4 Mg (0.44 ton),
respectively.  In these cases, the Administrator has concluded that emission
testing is not necessary.

1.2  SUMMARY OF IMPACTS OF PROMULGATED ACTION
1.2.1     Alternatives to Promulgated Action
     Regulatory alternatives considered during development of the standard
are discussed in Chapter 4 of "Inorganic Arsenic Emissions from Glass
Manufacturing Plants - Background Information for Proposed Standards",
EPA-450/3-83-011a, April 1983.  This document is also referred to as the
Background Information Document (BID).  These regulatory alternatives
reflect the different levels of emission control.  After proposal, the
Agency revised the emission limits as discussed in Section 1.1.  These
revisions made it necessary to recalculate1 environmental, energy, and
economic impacts because fewer furnaces are affected by the revised emission
limits.
                                          i
1.2.2     Environmental Impacts of Promulgated Action
     Under the promulgated standard, eight existing glass melting furnaces
are subject to the control requirement and are required 10 reduce emissions
                                     1-3

-------
of arsenic by 85  percent.  Six of these furnaces are presently equipped with
controls and will not be required to install any additional controls as a
result of this standard.  The reduction in arsenic emissions currently
achieved on these six furnaces totals 30.4 Mg (33.4 tons) per year.  The
remaining two furnaces are presently uncontrolled and are required to
install control devices capable of reducing arsenic emissions by at least
85 percent.  However, one of these furnaces is expected to change production
to a non-arsenic containing glass type while the other will install a
control device.  The total reduction in arsenic emissions expected to be
achieved from these two furnaces is 14.6 Mg (16.1 tons) per year.
     Because only one furnace is anticipated to install controls as a result
of this standard, the total water and solid waste impact associated with the
standard are those arising from this furnace.  Application of controls to
this furnace will not result in any emissions to water.  The solid waste
collected in the control device would amount to about 20 Mg (22 tons) per
year.  However, because reuse of this waste would result in cost savings for
raw materials and because of the high costs of disposing of this waste, it
is anticipated that- about 90 percent of the total waste will be recycled to
the melting furnace.  Therefore, the total solid waste impact of the final
standard is estimated to amount to about 2 Mg (2.2 tons) per year.
     The analysis of environmental impacts presented in Volume I of this
document, as modified by the changes described above, is the final
environmental impact statement for this action.
1.2.3     Energy and Economic Impacts of Promulgated Action
     Revisions in the emission limits since proposal have resulted in
changes in the energy and economic impacts presented in the BID for the
proposed standard.
     Because only one presently uncontrolled furnace is anticipated to
install controls as a result of the promulgated  standard, the total energy
impact of the standard is that associated with controlling this furnace.  It
is estimated that the application of controls will  increase energy use at
the plant by about 185 MW-hr per year.   This represents about 0.1 percent of
the total energy use at the plant.
                                     1-4

-------
     The revised economic impacts are summarized and compared to  the  impacts
of the proposed standard in Appendix B of this BID.   Although at  proposal
information was available on the financial  characteristics of the affected
glass companies, sufficient data were not available  to estimate the cost
impacts of controlling all arsenic-using glass furnaces operated  by those
companies.  Detailed information gathered after proposal  was used to
reassess economic impacts of control options.   The revised analysis in
Appendix B indicates moderate profit declines  for most potentially affected
furnaces with severe profit declines for a  few furnaces.   However, no
adverse economic impacts are estimated for the single plant anticipated to
install controls as a result of this action.   There  was little impact on
capital availability.
1.2.4     Other Considerations            :
     1.2.4.1   Irreversible and Irretrievable  Committment of Resources.
     Other than the fuels required for power  generation and the materials
required for the construction of the control  system, there is no  apparent
irreversible or irretrievable commitment of resources associated  with this
regulation.
     1.2.4.2   Environmental and Energy Impacts of Delayed Standards.
     Delay in implementing the standard would  result in a delay in emission
reduction of arsenic from affected furnaces and delay in  realization  of
other estimated impacts.
     1.2.4.3   Urban and Community Impacts.
     Neither plant closures nor impacts on  small  business are forecasted.
The issue of plant closure is discussed in  more detail  in Section 2.5.
                                     1-5

-------

-------
                       2.0 SUMMARY OF PUBLIC COMMENTS

     A total of 24 letters commenting on the proposed standard for the glass
industry were received.  In addition, three speakers commented on the
proposed standard at the public hearing.  The transcript from the public
hearing, comments made at the public hearing, and the 24 letters have been
recorded and placed in the docket.  The list of commenters, their
affiliation, and the docket number assigned to each comment by the
Environmental Protection Agency (EPA) are shown in Table 2-1.  The docket
reference number is indicated in parentheses in each comment summary.  All
docket references are part of Docket Number A-83-08, Category IV.  The
comments have been summarized according to the following 11 categories:

     2.1  Affected Facility
     2.2  Stringency of the Proposed Emission Limit
     2.3  Selection of Control Technology
     2.4  Cost Effectiveness of the Proposed Standard
     2.5  Economic Impact
     2.6  Exemptions and Allowances
     2.7  Monitoring and Measurement Methods
     2.8  Determination of Compliance     '
     2.9  Reporting Requirements          ;
     2.10 Arsenic Emissions from Soda-lime Furnaces
     2.11 Zero Production Offsets
     2.12 Risk Assessment and Risk Management

2.1  AFFECTED FACILITIES
                                          j
     2.1.1  Comment:  Three commenters (F-l, D-5, D-10)  addressed the issue
of whether the presence of arsenic as an impurity in the raw materials used
to manufacture glass should be considered in determining the applicability
of the standard.   Each of these commenters expressed concern that it would
be burdensome and costly to require facilities which do  not use arsenic as
                                     2-1

-------
    TABLE 2-1.  LIST OF COMMENTERS ON THE PROPOSED STANDARDS FOR ARSENIC
                  EMISSIONS FROM GLASS MANUFACTURING PLANTS
                          Docket Number A-83-08, IV
                               Public Hearing
Commenter

Dr. Robert A. Drake
Vice President, Technical
Glass Packaging Institute
6845 Elm St., Suite 209
McLean, Virginia  22101

Mr. H. Neal Troy
Manager of Environmental Control
Owens-Illinois, Incorporated
One Seagate
Toledo, Ohio  43666

Mr. David D. Doniger
Senior Staff Attorney
Natural Resources Defense Council, Inc.
1725 I St., N.W. '
Suite 600
Washington, D.C.  20006

                                   Letters

Mr. Thomas J. Koralewski
Senior Environmental Engineer
Libbey-Owens-Ford Company
1701 East Broadway
Toledo, Ohio  43605

Dr. George and Adriana Hess
4437 West Grandview Place
Tacoma, Washington  96466

Mr. Ben A. Brodovicz, Chief
Division of Technical Services  and Monitoring
Bureau of Air Quality Control
Department of Environmental Resources
Post Office Box 2063
Harrisburg, Pennsylvania  17120
Docket Reference

      F-l
      F-2
      F-3
      D-l
      D-2
      D-3
                                    2-2

-------
                             TABLE 2-1 CONTINUED
Commenter

Mr. John T. Barr
Regulatory Response
Air Products and Chemical, Inc.
Box 538
Allentown, Pennsylvania  18105

Mr. F. P. Partee                         !
Principal Staff Engineer                 ;
Stationary Source Environmental Control Office
Ford Motor Company
One Parklane Blvd.
Dearborn, Michigan  48126                :

Mr. Paul F. Munn
Chief Engineer
Department of Public Utilities
Environmental Services Agency
26 Main Street
Toledo, Ohio  43605

Mr. Bill Stewart
Executive Director
Texas Air Control Board
6330 Hwy 290 East
Austin, Texas  78723

Anita Fries
A-95 Coordinator
State Clearinghouse
30 East Broad Street
Colombus, Ohio  43215                    :

Mr. Michael Gregory
Grand Canyon Chapter, Arizona
Sierra Club
Rt. 1, Box 25A
McNeal, Arizona  85617                   '

Mr. Lowell D. Turnbull
Leva, Hayes, Symington & Martin
8l5 Connecticut Ave., N.W.
Washington, D.C.  20006                  ;

Executive Office of the President
Office of Management and Budget
Washington, D.C.  20503
Docket Reference

      D-4
      D-5
      D-6
      D-7
      D-8
      D-9
      D-10
      D-ll
                                   2-3

-------
                             TABLE 2-1 CONTINUED
Commenter

Mr. David F. Zoll
Vice President and General Counsel
Chemical Manufacturers Association
2501 M Street, N.W.
Washington, D.C.  20037

Mr. John L. Cherill
Energy and Environmental Control
Corning Glass Works
Corning, New York  14830

Mr. Richard A. Kamp
Smelter Crisis Eduction Project
Post Office Box 5
Naco, Arizona  85620

Mr. H. M. Howe
Chief Siting Engineer
Pacific Gas and Electric Company
77 Beale Street
San Francisco, California  64160

Robert Abrams
Attorney General of the State of New York

Mary Lyndon
Assistant Attorney General of the State of New York
Two World Trade Center
New York, New York  10047

David D. Doniger
Senior Staff Attorney
Natural Resources Defense Council
1725 I Street, N.W.
Suite 600
Washington, D.C.  20006

Mr. H. Neal Troy
Manager of Environmental Control
Owens-Illinois, Incorporated
One Seagate
Toledo, Ohio  43666

David D. Doniger
Senior Staff Attorney
Natural Resources Defense Council
1725 I Street, N.W.
Suite 600
Washington, D.C.  20006
                                    2-4
Docket Reference

      D-12
      D-13
      D-14
      D-15
      D-16


      D-17




      D-18
     D-23
     D-24

-------
                               TABLE 2-1 CONTINUED
Commenter
Mr. John L. Cherill
Energy and Environmental Control
Corning Glass Works
Corning, N.Y.  14830

Steven 6. Kuhrtz
Director
New Jersey Department of Environmental Protection
Division of Environmental Quality
Trenton, N.J.  08625

Mr. Herbert Engel
Decor, Incorporated
60 Cedar Lane
Englewood, N.J.  07631

Mr. John L. Cherill
Energy and Environmental Control
Corning Glass Works
Corning, N.Y.  14830
Docket Reference

     0-25
     D-26
     D-27
     D-28
Docket entries D-19, D-20, D-21, and D-22 are not included in this list
because they did not include comments pertaining to the proposed standard.
                                     1-5

-------
a raw material to demonstrate that emissions arising from trace arsenic
contamination of other raw materials would not result in exceedance of the
proposed emissions cutoff.  The commenters requested that EPA explicitly
exclude from the promulgated regulation all furnaces that do not
intentionally use arsenic as a raw material.  One commenter (D-10) noted
that the arsenic content of raw materials is not routinely specified by
purchasers since arsenic is not known to impair glass quality.  However, the
commenter indicated that in a telephone survey of glass manufacturers and
raw material suppliers, no evidence was found that arsenic exists in
significant quantities as an impurity of raw material components.  The only
detectable quantity of arsenic was found in Green River soda-ash at
concentrations ranging from 0.03 to 0.05 parts per million (ppm).  These
concentrations would result in maximum uncontrolled arsenic emissions of
about 1.1 kg (2.5 pounds) per year from a typical 227 Mg/day (250 tons/day)
glass container furnace.  This commenter concluded that EPA should give no
consideration to the arsenic content of raw materials since there is no
reason to believe that the arsenic content of raw materials used for glass
manufacture is any higher than it is in raw materials used in other process
industries.  Another commenter (D-5) pointed out that for the size of
furnace typically used to produce flat glass (500 to 600 tons/day), trace
amounts of arsenic in the raw materials on the order of 2 to 3 ppm by weight
could result in uncontrolled arsenic emissions approaching the proposed
emission cutoff of 0.4 Mg/year (0.44 ton/year).  The commenter is aware of
only one conventional raw material that contains arsenic as an impurity.
That one exception, an additive used in small  amounts in producing
body-colored glass, would result in arsenic emissions of less than one pound
per year.
     2.1.1  Response:  EPA has examined the problems posed by the presence
of arsenic as an impurity in various raw materials used in the production of
glass, and has concluded, based on available information, that this source
of arsenic is not expected to affect significantly the emissions of arsenic
from glass manufacturing furnaces.  The specific comment which appears to
indicate that the presence of arsenic impurities may result in emissions
                                     2-6

-------
 approaching 0.4 Mg (0.44 ton)  per year was  closely  examined.   It was
 determined that the calculations  present  an unrealistic  situation  in
 presuming that all of the raw  materials entering  the  furnace contain 2 to 3
 ppm arsenic by weight,  and that all  of the  arsenic  entering the furnace  is
 emitted.   Because  it would be  uncommon for  all  raw  materials to contain
 arsenic at that level,  and because most of  the  arsenic is  known to be
 retained  in the product,  EPA has  concluded  that the emissions  calculated in
 the example given  in the  comment  are substantially  overstated  and not
 indicative of  an actual  condition that might occur.
      EPA  has also  independently investigated the  concentration of arsenic
 found in  the bulk  raw materials commQnly  used in  the  glass industry.
 (Docket reference  IV-B-12).  During  an  emissions  test of an arsenic-using
 furnace,  samples of the bulk raw  materials  were taken and analyzed for
 arsenic content.   With  the single exception of  barium carbonate, the
 concentrations  of  arsenic  in the  raw materials  from this plant were below
 the detection  limits of the analytical  method used.   The measured
 concentration of arsenic  in the barium  carbonate  sample was 2.32 ppm.
 However,  barium carbonate  is not  widely used in large quantities within :he
 glass  industry.  Even assuming that  the concentration of arsenic in bulk raw
 materials  is equal  to the  detection  limit of the analytical methods used on
 the  test  samples,  the maximum uncontrolled emissions of arsenic arising from
 raw material impurities would be  about 0.19 Mg/year (0.21 ton/year) from a
 furnace producing  500 Mg/day (550 tons/day) of glass.
      Based on all  of the information available to the Agency,  glass melting
 furnaces which do  not use commercial  arsenic as  an ingredient  of their batch
 composition would  not emit enough arsenic to be  affected  by the promulgated
 cutoff of 0.4 Mg (0.44 ton) per year for new and modified furnaces  and
 2.5 Mg (2.75 tons) per year for existing furnaces.  EPA agrees  it would be
 unreasonable to require demonstration of this and, therefore,  the
applicability section of the regulation has  been revised  to exclude from the
promulgated standard all furnaces  which do not use commercial  arsenic as  a
 raw material.  Commercial arsenic  is  any variety of arsenic or  arsenic
compounds  which is produced by  extracting  arsenic  from minerals.
                                     2-7

-------
      2.1.2  Comment:   Two commenters  (D-13;  F-2)  stated  that  the  proposed
 regulation should be  applicable  only  to  furnaces  that are  at  present
 uncontrolled.   One commenter (D-13) added  that  all  existing glass melting
 furnaces  equipped with fabric filters or electrostatic precipitators  should
 be  excluded from further  regulation under  this  NESHAP.   The commenter stated
 that  although  uncontrolled furnaces are  relatively  few in  number, the
 largest reductions in arsenic emissions  could be  obtained  from  these
 furnaces.
      2.1.2 Response:   Under the  promulgated  cutoff  on arsenic emissions for
 existing  sources,  six currently  controlled furnaces would  be affected  by the
 emission  limits.   However, all six of the  furnaces  are at  present achieving
 the required reduction in  arsenic emissions  and no  additional controls are
 required  on these  furnaces.   The Agency  wants to  ensure  that existing
 control devices will  be properly operated  and maintained because the  health
 risks associated with emissions  above the  cutoff  could be  significantly
 reduced at reasonable cost.   Therefore,  it would  not be  in keeping with
 Section 112 of the Clean Air Act to exempt existing furnaces and to fail to
 ensure that control systems  on these  furnaces remain effective  in reducing
 emissions.
     2.1.3  Comment:   One  commenter (D-26) stated that EPA has  relied
 totally on cost and economic  factors  in  establishing 0.4 Mg (0.44 ton) per
year as the cut-off between  affected  and unaffected furnaces in the proposed
 standard,  and  that no  analysis of the  impact of this cutoff on exposure or
 risk has been  presented.   The commenter  urged that the data on exposure and
 risk should  be presented so  that the  impact of the cutoff can be fully
evaluated.
     Another commenter  (F-2) stated that the proposed emission cutoff of 0.4
Mg  (0.44 ton) arsenic  per year is overly stringent given the insignificant
environmental benefits that would be gained from controlling emissions at
this level.  According to  the commenter1s calculations,  the emissions from
one of the commenter's plants, which emits more than the proposed cutoff,
would contribute only 0.17 micrograms/cubic meter to the ambient
concentration over an 8 hour period.   This is only 2 percent of the  OSHA
                                     2-8

-------
standard of 10 micrograms/cubic meter.  The commenter also referred to the
previous testimony of Dr. Lamm (November 8, 1983 public hearing transcript,
Docket No. A-83-08-IV-F), that ambient concentrations of 300
micrograms/cubic meter over a lifetime would be necessary to cause
significant health impacts.  If the furnace were controlled to the proposed
emission limit of 0.2 Ib particulate/ton of glass produced, the
corresponding reduction in the ambient concentration of arsenic would be
0.13 micrograms/cubic meter.  The commenter concluded that such a reduction
is not justified given the costs required to achieve it and that the
proposed emission cutoff should be increased by a factor of two or three and
apply only to uncontrolled furnaces.     i
     2.1.3  Response:  At the time of proposal, the Agency's standard
setting approach involved first selecting a standard that was achievable
through the application of best available.technology (BAT).  Determination
of BAT was based on the capability of existing technologies to reduce
emissions, as well as on the costs of emission controls and on the economic
impact of applying the controls at specific facilities.  The residual risks
remaining after application of BAT to furnaces which would have been
affected by the proposed cutoff (0.4 Mg/year of arsenic prior to control)
were then considered to determine if a more stringent standard would be
necessary to protect public health.  However, Agency policy has since
evolved to place greater emphasis on risk and risk reduction in determining
which specific sources within a source category shall be subject to an
emission limit under Section 112.  Costs and economic impact are still
considered in relation to the reductions in risk achievable through the use
of selected control technologies.
     Because of various site-specific factors, the degree of risk associated
with emissions of inorganic arsenic from glass manufacturing plants does
not, in all cases, directly correlate with the absolute magnitude of those
emissions.  Moreover, risks to the population in the vicinity of a plant
must be assessed in terms of emissions of arsenic from the entire plant,
rather than emissions from individual furnaces within the plant.  Therefore,
in establishing an emission cutoff, the emphasis has shifted from
                                     2-9

-------
consideration  of  the magnitude of the emissions arising from individual
furnaces and the  costs of controlling those emissions, to consideration of
the magnitude  of  the risks associated with specific plants and the degree to
which  those risks can be reduced at a reasonable cost.
     The Agency estimated the risks associated with arsenic emissions from
existing glass manufacturing plants and determined that most of the
emissions and  risks were associated with 11 uncontrolled furnaces emitting
more than 0.4 Mg  per year each.  These furnaces are located at five
different plants.  A sixth plant, having nine furnaces, all of which emitted
arsenic at a level below the proposed cutoff of 0.4 Mg per year, also had
relatively high aggregate risks.  Because of the proposed cutoff of
0.4 Mg/yr, however, none of these furnaces would have been subject to the
proposed control  requirements.  Nevertheless, EPA considered whether the
cutoff should be  changed to require control of the emissions from these nine
furnaces by estimating and analyzing the emission and risk reductions
achievable and the associated costs and economic impacts.  The analysis
indicated that the cost of controlling emissions would be disproportionately
high at this plant compared to the reduction of risk achievable.
     Of the other five plants, three posed relatively high risks.  The
analysis indicated that the reduction in risk achievable from the first two
plants is about three to four times greater than the reduction in risk that
could be achieved from the third plant.  Also, the costs of controlling
emissions from the third plant are disproportionately high when compared to
the reduction in risk which would be gained.  For these reasons, the
promulgated standard establishes an emission cutoff for existing glass
melting furnaces that would require add-on control  of emissions for only the
first two plants.  Emissions from both of these plants arise from arsenic-
using glass furnaces which individually emit more than 2.5 Mg/yr (2.75
tons/year) of uncontrolled arsenic.   Therefore, the cutoff on uncontrolled
emissions of inorganic arsenic for existing glass melting furnaces is
established at 2.5 Mg/yr (2.75 tons/yr).   A more detailed discussion of the
information on which this decision is based is included in Appendix D.
Agency estimates indicate that there will  be eight existing furnaces subject
to the NESHAP.
                                     2-10

-------
     The Agency does not evaluate risks to the general public based on OSHA
occupational standards.  The OSHA standards are set based on exposure to
healthy workers during the 40 hour work week.  The general public includes
individuals at a greater risk than healthy workers (e.g., children, the
elderly) and may be exposed continuously for a very long period of time.
     Dr. Lamm testified at the public hearing concerning risks from arsenic
emissions from the copper smelter in Ajo, Arizona.  A response to this
comment is found in the background information document for promulgated
standards on primary copper smelters (EPA 450/3-83-010b).

2.2  STRINGENCY OF THE PROPOSED EMISSION LIMIT

     2.2.1  Comment;  One commenter (D-13) expressed support for EPA's
                   '"•!!'
emissions control proposal and emissions reduction targets, given that EPA
concludes that arsenic emissions from the glass industry must be reduced.
     2.2.1  Response:  .No response necessary.
     2.2.2  Comment:  One commenter (D-18) stated that the standards for
emissions of arsenic from glass manufacturing plants should be more
stringent than the 90 percent reduction on which the proposed standards are
based.  The commenter referred to data in the Background Information
Document on the  performance of electrostatic precipitators and fabric
filters in  controlling particulate matter emissions.  These data, the
commenter asserted/show that with only one exception fabric filters and
electrostatic  precipitators have control efficiencies greater than
90 percent. Setting the level of emissions reductions achievable by these
technologies at  the level of the least effective system does not satisfy the
requirements of.Section 112 of the Clean Air Act.
      2.2.2   Response:   It is the intent of the Agency to require the most
effective  possible control of arsenic emissions where these emissions may
 reasonably  be  expecfed to endanger public health.  The proposed standards
were not  based ori  the achievability of 90 percent reduction of arsenic
 emissions  from glass melting furnaces.  Rather, the proposed standards
 required  particulaty emission from affected furnaces to be controlled to the
                                     2-11

-------
established  under the  new  source  performance  standards  (NSPS) for glass
manufacturing  plants.  These  standards  represent the level of control
achievable through the application of the best demonstrated technology (BDT)
for  controlling  particulate emissions from glass melting furnaces.  Because
the  data  available to  the  Agency  at the time  of proposal indicated that at
least  90  percent of the arsenic emitted from  glass melting furnaces would be
emitted as particulate matter, it was believed that in meeting the NSPS
particulate  emission limits at least 90 percent of the emitted arsenic would
be collected as  well.  As  a result, the best  available technology (BAT) for
controlling  arsenic emissions was determined  to be identical to BDT for
control of total  particulate emissions.  Therefore, the proposed standards
were not  based on  the  reduction of arsenic emissions achievable by the least
effective system,  but  on the reductions in arsenic emissions achieved by the
application  of the best available technology.  The 90 percent reduction
cited  in  the background information document  (BID) only reflects the minimum
level  of  control  for arsenic that was expected to be achieved through the
application  of BAT.
     Data gathered by  EPA  after proposal, however, have indicated that in
some instances significantly less than  90 percent of the arsenic emitted
from glass melting furnaces is in particulate form.  No correlations were
identified between  the proportion of arsenic emitted as particulate matter
and the type of arsenic used as a raw material, the type of glass produced,
or other  process parameters.
     In addition,  EPA found that  some furnaces, including the largest
emitting  furnace,  could meet the  proposed emission limits by reducing
particulate emissions by as little as 45 percent.   In this case, the
corresponding reduction achieved  in arsenic emissions would be no greater
than 45 percent.   For these reasons, it was concluded that the proposed
emission  limits would not guarantee that the most effective control  of
arsenic emissions would be achieved on all  affected furnaces.   In
considering all of the available data, the  Agency determined that a  standard
requiring arsenic emissions to be reduced by a specific percentage would  be
                                     2-12

-------
necessary to ensure that emissions control devices are installed and
operated in a manner which best reflects their effectiveness in controlling
arsenic emissions.
      In setting the level of the final standard, consideration was given to
the performance of existing control devices in reducing arsenic emissions,
to the factors affecting control device performance, to the level of control
achievable from uncontrolled furnaces, and to the costs of control.  The
data  obtained on arsenic-using furnaces with existing controls indicated
that  the efficiency of these devices is variable, ranging from 92 percent to
99 percent.  The data further indicate that the variability observed in
control device performance does not correlate to the design or operating
characteristics of either the glass melting furnace or the control device.
Rather, the efficiency of these systems in reducing arsenic emissions is
primarily a function of the amount of arsenic emitted as particulate matter.
Although the available data do indicate that exhaust gas cooling may be
effective in increasing the proportion of arsenic emitted as particulate
matter, sufficient data are not available to predict quantitatively the
extent to which cooling will increase the effectiveness of control.
      As a result of these uncertainties, no technical basis exists for
concluding that the efficiency of any existing control device could be
improved by modifying either the design or the operation of the existing
control system.  In addition, the costs of modifying any existing control
device would be disproportionate to the incremental  reduction in arsenic
emissions that might be achieved, even if there were reason to believe that
these modifications would increase the effectiveness of control.   Therefore,
the Agency concluded that the standard should be set at a level which would
not require any additional  control  of furnaces equipped with existing
control devices.
     Because of the variability observed in control  device performance, and
because no correlations exist between control  device performance and process
or operating characteristics, the efficiency of existing control  devices in
reducing arsenic emissions  could not be generalized  to furnaces that are not
presently controlled.   Therefore, emission testing was performed on the
                                     2-13

-------
uncontrolled furnace that will be required to install  controls under the
promulgated standard.  These tests (summarized in Appendix A)  indicated that
a maximum reduction in arsenic emissions of 85 percent could be achieved
within the range of anticipated furnace production rates if the exhaust gas
was first cooled to less than 121°C (250°F) prior to entering the control
device.  Because no methods for reducing uncontrolled emissions from this
furnace by more than 85 percent (including further cooling) could be
identified, and because all affected furnaces with existing controls have
demonstrated removal efficiencies of 85 percent or more, the level  of the
final standard was established at a 85 percent reduction of uncontrolled
arsenic emissions.
     2.2.3  Comment:  One commenter (D-18) stated that there is a
discrepancy between the data concerning arsenic trioxide removal and the
theoretical considerations relied on by EPA in setting the proposed
standards.  This commenter asserted that EPA found much more arsenic is
removed from glass furnace flue gas by electrostatic precipitators than
would be predicted by theory.  Since the data support more stringent control
requirements, EPA should not develop an emission standard that relies on
this current theory.
     2.2.3  Response:  The standards were developed based on data collected
by EPA which reflect the level of arsenic emissions reductions achieved by
particulate matter control devices.  The standards were not developed based
on theoretical calculations of the anticipated emissions of arsenic.
Indeed, if theory were relied upon, it would have been concluded that
particulate matter control devices are ineffective in reducing arsenic
emissions.
     2.2.4  Comment:  One commenter (D-17) stated that EPA has not proposed
standards which address arsenic in the vapor phase or in fine particulate
form.  The commenter points out that arsenic trioxide is appreciably
volatile at temperatures of 100°C (212°F), a temperature common to many
industrial processes.  Because arsenic trioxide sublimes from the solid to
the vapor phase more rapidly than it condenses from vapor to liquid phase,
flue gas may become supersaturated by arsenic trioxide, resulting in more
vapor-phase arsenic trioxide than expected.  Also, condensation of the
                                     2-14

-------
 vapor-phase  arsenic will  not  occur  as expected.  Unless the process vapor  is
 substantially  saturated with  arsenic trioxide,  lowering the temperature will
 not force  the  vapor to condense.  Therefore, control methods based on the
 condensation of arsenic trioxide will not be effective.  Further, the
 commenter  points out that arsenic trioxide adsorbs most readily onto small
 particulates,  and that the removal  efficiencies of particulate matter
 control devices are lower on  fine particulates  than on total particulates.
 The commenter  concludes that  fabric filters are the most effective
 technology in  removing particulate  matter emissions over a range of flue gas
 temperatures and particle sizes. Therefore, the proposed standards should be
 based on the performance  of a well  designed and maintained fabric filter
 system.
     2.2.4  Response:  Arsenic emissions from most glass manufacturing have
 been shown to  be predominantly in the solid phase.  Although this apparently
 contradicts theoretical considerations which predict that all of the arsenic
 would be emitted in the vapor phase, theoretical considerations do not take
 into account the presence of other  chemical species in the stack gases.
 Therefore, EPA has not relied on theoretical data in developing this NESHAP.
 Rather, EPA has conducted a series  of tests on glass furnaces to provide an
 indication of the physical form in which arsenic emissions occur, and to
 assess the effect of temperature on the proportion of arsenic found in the
 solid phase.   In most tests, more than 90 percent of the arsenic has been
 shown to exist in the solid phase at typical stack gas temperatures of 288'°C
 (550°F).
     One test conducted on a furnace melting soda-lime glass indicated that
 a relatively small  percentage (-x-40%) of total  arsenic exists in the solid
 phase at 288°C (550°F).  When the filtered gases were cooled to 121°C
 (250°F), however, up to 80 percent of the total  arsenic was found in the
solid phase.   In this instance, condensation did appear to occur even though
the vapor-phase concentration at 288°C (550°F)  was less than 1.0 x 10"6 of
the theoretical vapor-phase concentration at saturation at that temperature.
The results of this test were inconclusive, however.   Although the amount of
solid-phase arsenic increased as the filtered  gas temperature in the
sampling train was  cooled from 288°C (550°F)  to  121°C (250°F), the amount of
                                     2-15

-------
 vapor-phase  arsenic  did  not  decrease  proportionally.  Therefore,  it  is not
 certain  that the  increase  observed  in the amount of solid-phase arsenic
 captured in  the sampling train  occurred as a  result of condensation  of
 vapor-phase  arsenic.  Another emission test performed by EPA on a soda-lime
 glass furnace showed that  all of the  arsenic  emitted from the furnace was in
 the  solid phase regardless of temperature.
      In  another test on  a  glass melting furnace, additional information was
 obtained by  EPA on the factors  affecting condensation of gaseous arsenic.
 Both Reference Method 108  samples at  121°C (250°F) and single-point  samples
 at elevated  temperatures (204°C and 288°C) were collected during this test.
 In addition,  backup  filters  maintained at 121°C (250°F) were placed  prior to
 the  impingers in  some high temperature sampling trains.  The fraction of
 arsenic  detected  in  the  Reference Method 108  sampling trains averaged
 39 percent.   The  fraction  of arsenic  detected on the filters at 204°C
 (400°F)  averaged  34  percent  and an average of 36 percent of the total
 arsenic  was  collected on the filters  at 288°C (550°F).  These data indicated
 that condensation of  gaseous arsenic  was not occurring, even though the
 concentration of  gaseous arsenic was  relatively high.  However, substantial
 amounts  of arsenic were  collected on  the backup filters maintained at 121°C
 (250°F)  in the high temperature sampling trains, which indicated that
 condensation  did occur between the high temperature filters and the low
 temperature backup filters.  These data suggest that the rate of
 condensation  in the sampling train may be sensitive to residence time,
 temperature gradient, and/or probe location.
     Although EPA agrees that the removal  efficiencies of particulate matter
 control  devices are lower for the smallest particle sizes,  EPA is not aware
 of any data to support the contention that fabric filters are universally
more effective in controlling arsenic emissions from glass  melting furnaces
than electrostatic precipitators (ESP).  EPA has conducted  three separate
tests on controlled arsenic glass furnaces.   Two of these were equipped with
 ESPs and the third  with a fabric filter.   The average control  efficiency of
the fabric filter in removing particulate  arsenic was 99.7  percent.   One of
the ESPs demonstrated an average control efficiency of 99.6 percent,  and the
                                     2-16

-------
 other achieved an average participate arsenic removal  efficiency  of
 99.0 percent.   Therefore, the EPA has concluded  that  ESPs  are  as  effective
 as fabric filters in controlling emissions  of arsenic  from glass  manufacturing
 plants.

 2.3  SELECTION OF CONTROL TECHNOLOGY

      2.3.1  Comment:   One commenter (D-12)  stated  that EPA should not assume
 that because a particular control  device has  been  adequately demonstrated on
 one type  of source,  that  it  should be considered BAT for a different source
 category.   EPA should consider only those control  technologies that have
 been demonstrated at  a commercial  scale on  a  plant of  the  same type for
 which the  control  requirement is  to be imposed.  The commenter also stated
 that the definition  of BAT should  also vary among  existing sources within
 the same general  source category on the basis  of the age and remaining
 useful life of the facilities.  While a particular technology may be
 considered BAT for new plants, it  may not necessarily  represent BAT for
 older plants.   The commenter  endorsed EPA's approach of not regulating
 facilities where  a level  of control equivalent to  BAT  is already  in place.
 Finally, the commenter stated that controls corresponding  to BAT should not
 be  imposed if  they are not needed  to  eliminate a significant health risk,
 particularly in cases  where a less  costly technology will  effectively
 eliminate  all  risks of mortality or serious illnesses.
      2.3.1  Response:   The selection  of ESPs and fabric filters as the
 basis for  the  standard  for the control of arsenic emissions from glass
 manufacturing  furnaces  is not based, on assumptions, but on the actual
 experience  of  the  glass industry in using these technologies to control
 arsenic emissions.  The promulgated standard is set at a level  that will
 require installation of emission control  devices on only those existing
 glass furnaces where emissions of  inorganic arsenic have been determined  to
 present a  significant  risk to public health.
     2.3.2  Comment:   One commenter (D-18)  objected to the EPA's reliance on
 compliance with OSHA standards for fugitive emissions  of arsenic in the
workplace  in deciding not to propose standards for these emissions.   The
                                     2-17

-------
 commenter stated that (1) this reliance was based solely on statements made
 by company representatives and had not been independently verified by the
 Agency; (2) although OSHA standards, if implemented, may provide protection
 to workers in glass manufacturing plants, they do not give persons living
 around the plants the enforcement power to compel compliance with the
 standards that would be available under the Clean Air Act; (3)  the Agency
 should, at the least, incorporate into a Section 112 standard the equipment
 and work practice requirements needed to comply with the OSHA standards.
      2.3.2  Response:  The Administrator believes that where standards
 established under separate authorities are effective in reducing emissions,
 redundant standards need not-be established by EPA.   The Agency establishes
 separate standards when there is evidence that either the control  measures
 are not likely to remain in place or are unlikely to be properly operated
 and maintained.   EPA has again reviewed the emission sources at glass
 manufacturing plants to determine any need for controls beyond  those
 required by OSHA.
      Information  gathered after proposal  during visits  to glass plants  that
 use arsenic indicated that fugitive  emissions  from some plants  may  not  be
 controlled.   As a  result of this  finding,  EPA  has  estimated  the magnitude of
 the emissions of  arsenic which could arise from fugitive  sources within
 glass  manufacturing plants.  (Docket  reference  IV-B-11)  These estimates were
 based  on  published fugitive  emissions factors  for  various material  handling
 operations,  as well  as on  data gathered  during  visits to  glass  plants which
 use arsenic.   To be conservative,  "worst  case"  conditions were  assumed  in
 estimating  potential  fugitive  arsenic emissions.   For example,  in this
 analysis  it  was assumed  that the  plant uses unusually high concentrations of
 arsenic  (14  Ib/ton)  in the batch  raw materials.  The major potential source
 of  fugitive  particulate  emissions  at  glass manufacturing  plants are the
materials handling  operations  associated with the unloading, storage and
weighing of the bulk  raw materials.   However, arsenic is not present during
 these operations.  Arsenic is  added  later, just prior to mixing  of the
batch.  Fugitive emissions of  arsenic could occur during mixing  of the batch
materials, during the transfer of these materials to the furnaces, when the
                                     2-18

-------
materials are  charged  into the furnace, and when control devices (if used)
are emptied and the waste products removed for disposal or recycled back
into  the melting furnace.  In considering all of the possible sources of
fugitive emissions from glass manufacturing plants, and employing the best
information currently  available to the Agency, EPA estimated that the
maximum,fugitive emissions of arsenic from a large, 545 Mg/year (600 tons
per day) plant would amount to 0.21 Mg/year (0.23 ton/year) if emission
control devices were not used.  For a plant of this size, uncontrolled stack
emissions would be about 145 Mg/year (160 tons/year).  The same plant, if
controlled, would emit about 7 Mg/year (8 tons/year) out of the stack(s);
fugitive arsenic emissions from a 545 Mg/day (600 tons/day) controlled plant
were  estimated to be 0.33 Mg/year (0.36 ton/year) under worst case
conditions.  Because all of the plants known to use arsenic have capacities
less  than 545  Mg/day (600 tons/day), and because the estimates
summarized above are based on "worst case" assumptions, EPA has concluded
that  fugitive  emissions of arsenic from glass manufacturing plants are
negligible and do not endanger public health.  Therefore, the promulgated
standard does  not require controls for fugitive arsenic emissions at glass
manufacturing  plants nor have OSHA requirements been incorporated into the
promulgated standard as suggested by the commenter,,
      2.3.3  Comment:  Four commenters (F-l, F-2, D-10, D-18)  discussed the
elimination of arsenic as a raw material  in the manufacture of glass.   Two
commenters (F-l, D-10) stated that the use of arsenic in the  manufacture of
glass containers has been completely eliminated, and that there is no
technical  reason to use arsenic in the manufacture of glass container
products.   These two commenters posed no objection to a requirement that
arsenic be eliminated from glass container manufacturing, as  long as no
additional  administrative burdens were placed upon container  glass
manufacturers.   One commenter (F-2)  stated that the  use of arsenic in  the
manufacture of pressed and blown glassware is essential and that no
acceptable substitutes are currently available.   Without arsenic,  tableware
glass tends to  have an objectionable green tint.   Another commenter (D-18)
objected to the contention that the  elimination of arsenic in  pressed  and
                                     2-19

-------
 blown glass manufacturing would have serious consequences for this  sector of
 the glass manufacturing industry.  This commenter stated that the only
 benefit to the glass industry stemming from the use of arsenic is that it
 improves the cosmetic qualities of the glass by making it clearer.   This
 commenter asserted that cosmetic benefits are insufficient to justify  public
 exposure to arsenic emissions and urged that the standards be amended  to
 eliminate arsenic from the manufacture of pressed and blown glass.   The
 commenter also stated that if there are specialized, non-substitutable uses
 for arsenic which rise above the level of cosmetics, then EPA should set  a
 standard requiring extremely stringent controls for a small  number  of
 furnaces dedicated to such uses.
      2.3.3  Response:  Based on the public comments received  and  the
 information available before and after proposal  of the standards, EPA  has
 concluded that the container glass, flat glass,  and wool  fiberglass  segments
 of the  glass manufacturing industry do not use  arsenic as  a raw material  in
 the manufacturing process.   Because the promulgated standard  applies only to
 furnaces that use arsenic  as a  raw  material,  no  furnaces  in the container,
 flat, or wool  fiberglass segments of the glass  industry would be affected.
 Owners  or operators  of furnaces that do not melt  a  glass  in which arsenic is
 added as a raw material are  not subject to  the requirements of this NESHAP,
 including those for  reporting and recordkeeping.   If an owner or operator of
 a  furnace in  any  of  these  segments  of  the  industry were to begin using
 arsenic,  the  furnace  would be subject  to the standard.
     Arsenic  is used  in the  manufacture of some products in the pressed and
 blown segment  of  the  glass industry, however.  A case-by-case assessment of
 the potential  to  eliminate arsenic  use was conducted by contacting all  six
major manufacturers of pressed  and  blown soda-lime glassware, (docket
 reference  IV-B-13)  Although some companies have been successful  in  removing
arsenic entirely from their  raw batch materials, other companies  producing
similar types of glass have been unable to obtain a product of acceptable
quality when arsenic is removed.  The qualities achieved by the inclusion  of
arsenic  (clarity,  elimination of unwanted color, etc.) are not just
"cosmetic" in the  sense that they have no economic value, but reflect
                                     2-20

-------
certain  physical attributes of the final product which are required by the
consumer.  Demand for these products is inherently connected to their
physical appearance which, therefore, has a tangible economic value.  The
EPA expects that producers of pressed and blown glasswares will continue to
try to eliminate arsenic from their batch recipes to avoid being subject to
the requirements of this NESHAP.  It is not clear, however, when (and if)
these efforts will be successful.  Because a requirement to eliminate the
use of arsenic in the pressed and blown glass noncontainer segment of the
industry could have severe economic impacts for some producers, it is not
included in the final standard but will be evaluated as part of the 5-year
review of the standard.
     EPA considered banning the use of arsenic in those segments of the
glass industry where arsenic is known to be no longer used by establishing a
zero emission limit for certain segments of the glass industry.  However,
the promulgated standard does not ban the use of arsenic within any segment
of the glass manufacturing industry.  The decision not to ban the use of
arsenic  in the flat, container and wool fiberglass industry segments was
made for two main reasons.  First, the only available system for
differentiating among the various segments of the glass industry are the
Standard Industrial  Classifications (SIC)  devised and administered by the
Department of Commerce.  EPA has no assurance that all  plants at which
arsenic is used at present have been classified within the pressed and blown
glass segment of the industry (SIC 3229).   Therefore, placing a ban on the
use of arsenic according to SIC categories might place an unfair and
unintended burden on some individual  plants.
     Second, the decision to establish an  arsenic NESHAP for glass
manufacturing plants was made on the basis of the finding that atmospheric
emissions of arsenic pose a potentially significant risk to human  health.
The health risks arising from individual glass  plants were carefully
evaluated in establishing the promulgated  standard.   Emissions of  arsenic
from plants producing container,  flat,  or  wool  fiberglass would pose the
same risks as  those  from plants  in the pressed  and  blown glass segment of
the industry.   Therefore, EPA sees no reason  to establish a separate
                                     2-21

-------
emission limit for plants producing container, flat, or wool fiberglass that
is any different than that for pressed and blown glass.
     Glass melting furnaces which do not at present use arsenic, but which
will use arsenic in the future, would be considered to be modified furnaces
under the general provisions of 40 CFR Part 61.  These furnaces would then
be required under the promulgated standard to install a control device if
emissions of arsenic exceed 0.4 Mg/year (0.44 ton/year).

2.4  COST EFFECTIVENESS OF THE PROPOSED STANDARD

     2.4.1  Comment:  One commenter (F-2) stated that the costs of applying
add-on control technology to furnaces producing tableware glasses are
disproportionate to the resulting reductions in emissions.
     2.4.1  Response:  The EPA's analysis of the costs of applying the
promulgated standards to the production of tableware glass indicates that
the costs of the final standard do not have significant adverse impacts on
the industry and are reasonable in light of the reductions in arsenic
emissions and health risks achieved.
     2.4.2  Comment;  One commenter (D-13) stated that only glass furnaces
which are at present uncontrolled should be subject to the proposed
regulations because the most cost-effective emissions reductions can occur
from these furnaces.
     2.4.2  Response;  The response to comment 2.1.2 explains why the Agency
decided to establish emission cut-offs based on emissions prior to any
control device for existing and new or modified furnaces rather than making
the NESHAP applicable only to uncontrolled furnaces as the commenter
suggests.

2.5  ECONOMIC IMPACT

     2.5.1  Comment:  One commenter (F-2) stated that the monetary costs
required to comply with the standard would severely affect an already
depressed market which is facing significant and increasing competition from
                                     2-22

-------
foreign producers of glass tableware.  Between 1979 and 1982, the compound
growth in imports has been 6.8 percent, while growth in the domestic share
of the market has declined by 0.4 percent.  In addition, over the past ten
years there has been a decline in real total dollar market value for the
U.S. tableware industry.  Two tableware manufacturers have recently closed
plants.  The strong U.S. dollar will continue to favor imports of glass
tableware.  The commenter stated that reducing emissions to the level
proposed by the standard is estimated to cost $14.20/ton of glass.  These
costs would increase operating costs by over 2 million dollars/year.  This
represents an increase of 2.1 percent in production costs over 1982 levels,
which would have decreased 1982 profits by! 25 percent.
     2.5.1  Response:  The EPA recognizes that machine-made glass tableware
manufacturers are facing competition from foreign producers of glass
tableware; and in the economic analysis conducted after proposal, it was
assumed that prices cannot be raised and that companies must absorb the
control costs as decreased profits (See Appendix B).  The costs cited by the
commenter were for a specific plant owned and operated by the commenter.
The cost and economic impacts of the promulgated standard were analyzed for
this plant, and EPA concluded that they would be disproportionately high
compared to the risk reduction that would be achieved through application of
control technology.  Therefore, the plant is one of several that would have
been required to install controls under the proposed standard but, due to
the revised emission cutoff for existing furnaces, would not be required to
install emissions control devices under the promulgated standard.
     The economic analysis indicated a potential closure for only one
furnace currently using arsenic and emitting arsenic at a rate above the
revised cutoff.  Company representatives have informed EPA, however, that
they plan to eliminate the use of arsenic at this furnace (Docket reference
IV-E-58); therefore, it would not be affected by the standard.  The EPA's
analysis indicates that no other furnace closures would result from this
NESHAP.
     2.5.2  Comment:  One commenter (D-13) stated the belief that some
plants would close down if the proposed standard were promulgated.
                                     2-23

-------
      2.5.2  Response;  As mentioned above, EPA has reanalyzed the economic
 impacts and has raised the uncontrolled emissions cutoff for existing
 furnaces.  Within the narrowed range of affected furnaces, EPA believes that
 there will be no furnace closures due to the promulgated regulation.
      2.5.3  Comment:  One commenter (D-18) stated that the "worst case"
 economic analysis conducted by EPA has been grossly exaggerated in reaching
 a conclusion that under certain conditions the proposed regulations could
 cause some furnaces to close.  Further, the commenter stated that the
 assertion that the elimination of arsenic from pressed and blown glass  would
 make U.S. manufactured glassware uncompetitive with glassware imported  from
 countries which do not restrict arsenic use has not been supported by hard
 data or analysis.   The commenter stated that if the regulations do impose a
 competitive disadvantage on U.S.  glass manufacturers,  other steps should  be
 taken to protect their position,  such  as the imposition of duties on  imports
 of arsenic containing glass.
      2.5.3  Response:   The  revised economic analysis  (Appendix  B)  of  the
 promulgated standard explains that cost absorption  (profit reduction) by
 producers, rather  than cost pass-through to consumers,  is  more  likely to
 result  because  of  the  competitive  role  of imports.  Using  this  assumption,
 all  control  costs  were analyzed as additions  to baseline operating expenses.
 No  closures  are  anticipated as a result of  the  promulgated standard.
      The EPA's assertion  that U.S.  manufacturers of pressed and blown glass
 would be at  a competetive disadvantage  with foreign manufacturers if arsenic
 were  eliminated  is based on the fact that the properties that arsenic
 provides  in  the  glass  products have an  economic value.  Such properties as
 clarity  and  sparkle are desired by  the  consumer and, thus, are considered
 necessary  for certain  products to be competitive in the market.  The
 economic value of these properties has  not been quantified but is,
 nevertheless, real.  The commenter's suggestion that duties be imposed on
 imports of pressed and blown glass that contain arsenic cannot be
 implemented because EPA does not have legislative authority to impose such
duties or to take any similar measure to reduce possible competition to  U.S.
glassware manufacturers by foreign glass.
                                     2-24

-------
2.6  EXEMPTIONS AND ALLOWANCES

     2.6.1  Comment:  One commenter (D-13) requested that EPA include
provisions for conducting normal  maintenance on control  devices.   Most glass
furnaces operate continuously for a period of years, while emission control
devices require frequent maintenance.   The commenter stated that  the
maintenance requirement on an electrostatic precipitator is about 144
hours/year and that a provision should be made for by-pass of the control
device while maintenance is being conducted.
     2.6.1  Response:  EPA has investigated the cost and environmental
impacts associated with performing routine maintenance on emission control
devices installed on affected glass furnaces. (Docket reference IV-B-10)
Two alternatives were considered.  The first alternative would be to require
the glass furnace to be shut down during these maintenance periods in order
to avoid uncontrolled emissions of arsenic.  The second alternative would
allow furnace operators to by-pass the control device for a limited period
of time for maintenance purposes.  Emissions of arsenic during these periods
would not be controlled.  EPA analysis compared the increase in the costs
incurred by a model manufacturing plant which would result from the first
alternative to the increase in emissions which would follow from the by-pass
alternative.  In this analysis both large and small furnaces and  high and
low glass production costs were considered.  In total, the cost and
environmental impacts associated with  the alternative requirements were
evaluated for eight different cases.
     In the first four cases the impacts were calculated for two furnace
sizes (50 tons/day and 150 tons/day) and for two levels of specific arsenic
emissions (0.05 Ib arsenic/ton of glass produced and 1.00 Ib arsenic/ton of
glass).  In the first four cases, relatively low glass production costs were
assumed, on the order of $0.34/lb of product.  The second four cases assumed
the same furnace sizes and specific arsenic emission rates, but were based
on the assumption of a glass with higher production costs of $1.90/lb.
These values represent the low and high end of the ranges for actual glass
furnaces which use arsenic.  In all cases, it was assumed that the time
required for maintenance of control devices is 144 hours/year.
                                     2-25

-------
      The results of this analysis showed that a large furnace with a high
 arsenic emission rate could emit up to 0.41 Mg (0.45 ton) of arsenic during
 the 144 hours that the control device is by-passed.  Small furnaces with low
 arsenic emission rates would emit 0.01 Mg (0.01 ton) of arsenic during this
 maintenance period.  The costs of furnace shutdown were estimated to range
 from a low of $63,000 for a small furnace producing a low cost glass, to a
 high of $1,000,000 for a large furnace producing a high cost glass.  Thus,
 the cost effectiveness of requiring all  arsenic-using furnaces to be
 shut down while maintenance is carried out on emissions control  devices
 would range from about $420,000 per ton  of arsenic removed to over
 $47,000,000 per ton of arsenic removed.
      Because the impacts of requiring furnaces to  be temporarily shut down
 while maintenance is performed on emissions  control  devices  would be
 excessive in some cases, and because the use of well  maintained  control
 devices is  essential  in effectively controlling arsenic emissions on a
 continuing  basis, the promulgated standard allows  emission control  devices
 installed on furnaces affected by the standard to  be  by-passed for purposes
 of conducting necessary maintenance.   EPA has  also determined, however,  that
 arsenic emissions from glass melting  furnaces  can  be  reduced  by  implementing
 certain work practices during maintenance periods.  Therefore, the
 regulation  requires  owners  or operators  of affected furnaces  to minimize
 arsenic emissions to  the maximum  extent  practicable during periods when  the
 control  device  is shut down  for maintenance  purposes.   Each owner or
 operator of an  affected furnace that wishes  to  by-pass  the control device
 for maintenance  purposes is  required to  submit  a plan to the Administrator
 which details  (1) the  length  of time  it will be necessary to by-pass the
 control  device,  (2) the emissions of arsenic which would occur during
 maintenance  periods if no steps were taken to reduce them, (3) the
 procedures and work practices which will be  implemented to minimize arsenic
 emissions during maintenance periods, and  (4) the expected reduction in
 emissions of arsenic achieved by the implementation of these procedures and
work practices.  Only after approval by the Administrator of this plan will
 the by-pass of an emission control device be allowed.
                                     2-26

-------
       In some cases, emissions of arsenic can be prevented entirely while
 control devices are undergoing maintenance.  For example, control device
 maintenance could be scheduled during periods of normal furnace shutdown
 whenever possible.  For some plants, it may be feasible to switch production
 temporarily during periods of control device maintenance to glasses which do
 not contain arsenic.  All facilities affected by the regulation should make
 maximum use of control devices which are divided into two or more
 independently operated sections.  Use of so called "sectionalized" control
 devices enables maintenance to be performed on one section of the device
 without affecting the operation of the other(s).   Other steps that can be
 taken to minimize emissions of arsenic during maintenance of control  devices
 are the maximum use of oil let, the temporary reduction in arsenic feed, or
 the temporary reduction of furnace output.
      2.6.2   Comment:   One commenter (D-13)  requested that furnaces melting
 arsenic-containing glasses  over limited time periods (1 to 10 weeks)  for
 research and development purposes  not be subject to  the standard.   Only
 after a glass  is  commercially  proven  and melted for  production purposes
 should the  glass/furnace become  subject to  the regulation.
      2.6.2   Response:   New  or  modified  glass  manufacturing  furnaces emitting
 more  than 0.4 Mg  (0.44  ton)  of arsenic  per year or existing furnaces
 emitting more than 2.5  Mg  (2.75  tons) per year are subject  to  regulation
 without regard  to  the purposes of the particular glass  production.  It  is
 not anticipated that research  and development furnaces will exceed the
 cutoffs.  However, should emissions from a research and development furnace
 exceed  these levels, the furnace would be subject to the standard.  Whether
 the glass is produced as a research project or for sale, the arsenic
 emissions pose the same hazard and may be controlled through the application
 of the  same control devices.  Therefore, no exemption is provided in the
 final standard for research and development glass production.
     2.6.3  Comment:  One commenter (D-13) requested that, in those cases
where production is shifted from a controlled furnace to an uncontrolled
furnace, sufficient time (24 months) be allowed for installation of a
control device.   The commenter considered it unrealistic for the industry to
                                     2-27

-------
 anticipate  the  need  to  switch  furnaces  2 years  in advance in order to have a
 control  device  installed  at  start-up.
      2.6.3   Response:   The promulgated  standards do not provide for an
 interim  period  following  the switching  of an existing furnace to the
 production  of arsenic-containing glass  to allow for the installation of
 control  equipment.   Basically, the switching of a furnace is viewed as
 similar  to  the  construction  of a new furnace and the same degree of planning
 prior to the change  should be  undertaken.  Section 112 provides for the
 possibility of  a 2-year waiver period only for  existing sources of arsenic
 emissions.
      2.6.4   Comment:  One commenter (D-13) stated that because the grain
 loading  from electrically boosted furnaces is on the order of 0.05
 grains/dscf, an add-on  control device may not be able to meet the standard
 for these furnaces at all times.  It was noted  that there are no add-on
 emissions control devices currently in  use on electrically boosted glass
 furnaces.   The commenter  suggested that EPA may need to establish a separate
 category to reflect  this.
      2.6.4   Response:   The comment is assumed to imply that the efficiency
 of particulate matter control  devices will be adversely affected by low
 concentrations of particulates in the stack gases.  As the commentor noted,
 there are no electrically boosted furnaces currently in operation which are
 equipped with an add-on control device.  Therefore, EPA has no means to
 determine whether an electrically boosted furnace would be able to meet the
 proposed particulate limit at all times.  No information has been submitted
 to EPA,  however, that would  indicate that electrically boosted furnaces
would be unable to do so  if equipped with an appropriate control  device.
 EPA did  test one electrically boosted furnace in the development of this
NESHAP.  The average particulate grain loading from this furnace was
0.11 gr/dscf, more than double the concentration cited by the commenter.
Although electric boosting decreases the amount of particulate matter
emitted, it also decreases the flow rate of the furnace exhaust.   As a
result, electric boosting is expected to have only a minor impact, if any,
on the concentration of particulate matter at the inlet of the control
device or on the emissions reduction efficiency of the control  device.
                                     2-28

-------
      Results of tests conducted by EPA in the development of this  NESHAP
 have demonstrated that ESPs and fabric filters can achieve high  arsenic
 collection efficiencies even when the concentration of arsenic in  the flue
 gas is low.  Average particulate arsenic removal  efficiencies of 97.8, 99.7,
 and 99.7 percent were achieved by control devices on particulate arsenic
 inlet concentrations of 0.024, 0.006, and 0.01 gr/dscf, respectively.
 Because no data have been presented which Indicate that emissions  from
 electrically boosted furnaces cannot be controlled as efficiently  as
 emissions from conventional furnaces and because  ESPs and fabric filters are
 capable of high pollutant removal  efficiencies even at low pollutant  inlet
 concentrations, EPA sees no reason to establish a separate category for
 electrically boosted glass melting furnaces.
      2.6.5  Comment:   One commenter (D-13)  recommended that the  non-arsenic
,portion of the particulate emissions reduced  in complying with the proposed
 standard should be  available for future bubbling  purposes allowed by  State
 regulations.   For example, the commenter stated that for  a furnace emitting
 7  Ib/hour of total  particulate,  including 1 Ib/hour of arsenic,  that  is
 required to reduce  its  arsenic emission to 0.1  Ib/hour, the corresponding
 reduction in total  particulates  of 5.4  Ib/hour  should  remain  available  for
 future  bubbling purposes.   The commenter stated that the  state agencies
 should  have this  option.                   ',
      2.6.5  Response:   The availability of particulate matter emission
 reductions achieved under  the  NESHAP for "bubbling"  is an  issue outside the
 scope of this  rulemaking,  and  is therefore,not  being addressed here.

 2.7   MONITORING AND MEASUREMENT METHODS

      2.7.1  Comment:  One  commenter  (D-6) supported  the EPA's position that
a material  balance or other  non-stack test data be used to establish whether
a facility is affected by  the  proposed  regulation and to monitor compliance.
However,  the commenter requested clarification on two points.  First,  what
confidence  level does EPA  have in the estimates of arsenic retention in
glass?  Specifically, should the low end of the estimate, 70 percent
                                     2-29

-------
 retention, be used  in estimating uncontrolled arsenic emissions?  Second,
 how should the arsenic content of the cullet be determined?  Is it accurate
 to assume that all  of the arsenic entering with the cullet remains in the
 glass, and thus has no impact on arsenic emissions?
      2.7.1  Response:  The estimates of the amount of arsenic retained in
 the glass product were provided by the glass industry.  Data obtained from
 tests conducted by  EPA have been found to be reasonably consistent with data
 supplied by industry representatives.  It should be noted, however, that the
 amount of arsenic retained in the glass can vary significantly according to
 the specific recipe used in making the glass.
      The 70 percent retention value published  in the proposal  BID
 (EPA-450/3-83-011a) was supplied by industry representatives as a typical
 retention rate for lead silicate type glass.   Data gathered by the EPA after
 proposal  have demonstrated that at least 70 percent of the arsenic is
 retained in  the  glass  product regardless of its  composition.   However, the
 amount  of arsenic retained in the glass  product  is not strictly a function
 of the  type  of glass produced.   For any  given  type of glass,  the percentage
 of arsenic retained in  the product can vary widely.   For  example,  data
 collected by  EPA  show  that the  percent of arsenic  retained in  soda-lime
 glass can range from about 70 percent to about 90  percent.  Therefore, in
 estimating uncontrolled arsenic  emissions,  the arsenic retention  value
 should  be based on  actual  laboratory  analysis of the  glass  produced in a
 specific  melting furnace.   If analytical  data are  not  available, an assumed
 retention value of  70 percent would provide an estiamte of  the maximum rate
 of uncontrolled arsenic emissions from a  glass melting furnace.   In
 developing a material balance for monitoring compliance,  it is the
 responsibility of the furnace owner or operator to provide a theoretical
 emission  factor which accurately takes into account the amount of arsenic
 retained  in the glass.  Retention values should be based on actual
 analytical data for the specific type(s) of glass produced by the furnace.
     The amount of arsenic entering the furnace in the cullet should be
explicitly accounted for.   Some furnaces may add mixed cullet that is not
exactly similar in chemical composition to the  type of glass being melted.
                                     2-30

-------
 When  the  cullet  added  is  identical to the glass being produced, the
 percentage  of  arsenic  in  the cullet can be assumed to be identical to the
 percentage  retained  in the glass.  Thus, the arsenic entering with the
 cullet would not have any impact on arsenic emissions.  When this assumption
 is  made,  however, care must be taken to calculate the amount of arsenic
 retained  in the  glass on  the basis of the percent of product weight that is
 derived from fresh raw materials rather than on the basis of the total
 product weight.
      For  example, consider a hypothetical furnace which produces 2000 pounds
 of  glass  per hour.   Each  2000 pounds of product is made from a batch
 composition which consists of 1700 pounds of fresh batch materials,
 including 0.3  pound  of arsenic, and 500 pounds of cullet.  The Gullet is
 identical in composition  to the product and contains 0.012 percent arsenic.
 Thus, the total  amount of arsenic entering the furnace per hour is 0.36
 pound (0.3 lb/hr + [0.00012 x 500 Ib/hr]).  The amount of arsenic retained
 in  the product per hour is 0.24 pound (2000 Ib/hr x 0.00012).  On this basis
 the expected emissions of arsenic from the furnace would be 0.12 Ib/hour
 (0.36 lb/hr -  0.24 lb/hr).  However, if the amount of arsenic entering with
 the cullet is  ignored, then the portion of the total  product that is derived
 from the  cullet  must also be ignored in determining the expected emission
 rate.  Thus, if  the total arsenic input is assumed to be 0.30 Ib/hr (the
 amount of arsenic added in the fresh batch) then the  amount of arsenic
 retained  in the  product per hour would be 0.18 Ib/hour ([2000 Ib/hour - 500
 lb/hr] x  0.00012).  This  procedure yields the same expected emission rate as
 that obtained when the cullet arsenic is explicitly accounted for.   It would
 be  erroneous, on the other hand,  to assume that of the 0.30 Ib/hour of
 arsenic added to the fresh batch, 0.24 Ib/hour is retained  in the glass.
     2.7.2  Comment:   Two commenters (F-2, D-13) stated that the proposed
 requirement for opacity monitoring is unnecessary and inconsistent  with the
 NSPS for glass  manufacturing,  which does not require  opacity monitoring.
 One commenter (F-2)  indicated that opacity monitoring would represent an
 unjustifiable cost burden.  The other commenter (D-13)  stated that  opacity
monitoring is administratively burdensome, and  readings cannut  be correlated
                                     2-31

-------
with emissions of either arsenic or participates, especially when multiple
furnaces are exhausted to a common stack.  The commenter noted that
excessive stack opacity occurs in one of the commenter's furnaces as a
result of gaseous fluoride emissions from melting one type of glass, and
that this opacity is unrelated to arsenic or total particulate emissions.
     2.7.2  Response:  The requirement for opacity monitoring was proposed
as a means to ensure that emissions control devices installed on arsenic-
using glass furnaces are continuously operated and maintained in a manner
consistent with the procedures followed to comply with the standard
initially.  These requirements have been retained in the promulgated
standard.  The fact that opacity monitoring is not required as part of the
NSPS for glass manufacturing plants has no bearing on this action because
the intent of this regulation is to control a hazardous air pollutant which
is not specifically regulated under the NSPS.  With respect to the costs of
opacity monitoring, EPA has determined that the costs involved are
reasonable in light of the improved effectiveness in enforcement that will
be gained as a result of this requirement.  No information has been
presented to the Agency which indicates that continuous monitoring of
opacity represents an unjustifiable cost burden.
     The promulgated standard does not set any specific limit on stack gas
opacity based on correlations between opacity and emissions of either
particulate matter or of arsenic.  Rather, the promulgated standard requires
that a 6-minute average opacity value for a given furnace be determined
during compliance testing.  Any subsequent exceedance of the average opacity
value demonstrated in a compliance test must be reported semiannually.  If
excess opacity occurs as a result of a change in the composition of the
glass being melted in a furnace, this cause should be cited in the report.
Alternatively, if multiple types of glass are typically melted in a single
furnace, and stack gas opacity is expected to be significantly higher for
one type of glass, the initial  compliance test may be performed while this
glass is being melted.  Finally, paragraph 61.163(i) of the promulgated
standard allows owners or operators of affected furnaces to petition the
                                     2-32

-------
 Administrator for approval  of any alternative continuous  monitoring  system
 that can be demonstrated to provide accurate and representative monitoring
 of a properly operating control  device.
      2.7.3  Comment:   Two commenters (D-l,  D-3)  stated  that  the inclusion of
 a procedure for measuring sulfur dioxide in the  flue  gases from glass
 manufacturing is unnecessary.  One commenter (D-l)  further indicated that
 the procedure specified for sampling sulfur dioxide may give inaccurate
 results  when applied  to glass  melting furnaces because  of the formation of
 nitric oxide and sulfur trioxide in the  manufacture of  glass.  The nitric
 oxide will  be measured as sulfur dioxide because the  analytical procedure is
 non-specific; it is a  general  test for all  acidic species formed by  passage
 through  the hydrogen  peroxide  impingers.  In  conclusion,  the commenter
 recommended that all  references  to the measurement  of sulfur dioxide be
 eliminated  in the description  of EPA Method 108  procedures.   The other
 commenter (D-3)  indicated that the use of three  hydrogen  peroxide impingers
 is  unnecessary,  and that  much  of the currently available  source sampling
 equipment cannot accommodate a six impinger sampling  train.   The commenter
 recommended that sulfur dioxide  sampling  be eliminated  from  the testing
 procedure for glass manufacturing  plants.
      2.7.3   Response:   The  three  hydrogen peroxide  impingers  at the back of
 the  sampling  train were included  only  to  protect the metering system from
 corrosion when sampling gas streams with  high  sulfur dioxide concentrations.
 The  analysis  steps for measuring  sulfur dioxide were  included to allow the
 tester to determine the approximate  sulfur  dioxide concentration so that the
 final sample  volume could be corrected for  the sulfur dioxide collected by
 the  sampling  train.  However, neither of these steps would be necessary in
 collecting  samples from glass furnaces so all  references to sulfur dioxide
 collection  and analysis have been deleted from the method.
     2.7.4  Comment:  One commenter (D-3) recommended that EPA establish
greater consistency in specifying sampling probe  and filter temperatures
for EPA Reference Method 5 particularly for source categories that do not
emit significant concentrations of sulfur dioxide.  The  commenter  pointed
out that  a probe and filter temperature of 320°F  was recommended for  boilers
                                     2-33

-------
 (NSPS), while a probe and filter temperature of 350°F was specified for
 glass melting furnaces (NESHAP).  The commenter saw no reason to
 differentiate between sources firing more than, or less than, 0.5 percent by
 weight sulfur content.  The commenter recommended that a set probe
 temperature be specified rather than a range, since the ratio of the
 front-half to back-half catch can vary significantly according to sample
 collection temperature.  Finally, the commenter stated that comments
 previously made in response to Document No.  A-81-19 relating to proposed
 Quality Assurance revisions to Methods 6 and 7 of 40 CFR, Part 60, Appendix
 A,  as published in the Federal Register on March 30, 1983, are applicable
 here as well, and should be considered.
      2.7.4  Response:   Because the proposed  particulate matter emission
 limits have not been  retained in the promulgated standard, EPA Reference
 Method 5 sampling procedures are no longer applicable.   Therefore, the
 temperature requirements referred to by  the  commenter are no longer relevant
 to  this action.   The  Agency agrees that  there is no reason to  differentiate
 between sources  firing fuel  with greater than 0.5 percent by weight sulfur
 and those with  less than 0.5 percent,  and has revised the standard
 accordingly.
      The commenter referred  to comments  made  on  the quality  assurance and
 quality control  revisions' proposed for Reference Methods  6 and  7  in  the
 March 30,  1983 Federal  Register (48 FR 13388).   He  felt comments made on  the
 proposed revisions to  Reference Methods  6 and 7  were  applicable to the
 requirement for  an audit  sample in  Reference  Method  108.   The EPA
 promulgated the  quality assurance  and  quality control revisions to  Reference
 Methods  6  and 7  (49 FR 26522)  on June  27,  1984.   Comments  and Agency
 responses  are summarized  in  the  promulgation  notice.
      This  commenter (D-3) referred  to  the  comments on Reference Methods 6
and 7, applying  them to Reference Method  108,  noting  that an audit per set
of compliance samples is over-regulation.  The proposed quarterly  (Reference
Method 6 and 7) exemption covers repetitive testing at a given source only.
Most control agencies will have a central  laboratory and will use different
personnel and analytical systems.  The arsenic analyses are very time
                                     2-34

-------
 consuming,  and  a  team of chemists may  be  routinely assigned to analyze the
 samples  so  they can  be completed in  a  timely manner.  The requirement that
 only  one person analyze arsenic samples (paragraph 4.4) could delay the
 preparation of  the compliance  test report past deadlines now set by the
 States and  EPA.   The proposal  should be amended to allow more than one
 person to analyze the samples.  Any  analytical variations would be checked
 by quality  control procedures  currently incorporated in EPA methods (e.g.,
 equipment calibrations, duplicate testing and analysis, and inter-
 laboratory  testing).   Furthermore, since  the "oneness" rationale is not and
 should not  apply  to  the sample collection phase, it should not be mandated
 for the  analyst and  analytical equipment  phase.
      The comments on  Reference Method  6 and 7 went on to say that the
 rulemaking  ignores the  logistical problems that will be created with a
 one-on-one  audit  requirement, especially  for control agencies conducting
 numerous  tests.
      1.   How will EPA guarantee delivery  of the audit samples?
      2.   Will EPA ensure that the concentrations are within the analytical
 range of the samples?
      3.   Can it ensure  a different audit  concentration for each request?
     4.   Can EPA  guarantee fast delivery  of audit samples?  Our regulations
 require  analysis within 48 hours of sample Collection.
      In  response to these comments on Reference Method 6 and 7 and their
 applicability to Reference Method 108, the quarterly auditing allowance for
 analyses  performed on a frequent basis has been changed.   The revised
 requirement (Reference Method 6, 7 and 108) is to analyze audit samples at
 least once per month.  This discourages the use of 3 month-old analytical
 reagents as allowed in the quarterly audit and also eliminates the need to
 perform an audit with each set of compliance samples if samples are analyzed
on a frequent basis.
     The  intention of the rule is not to restrict the analysis to une
person but rather to  ensure that all  parties involved in  the analysis  of the
compliance samples likewise take part in the analysis of  audits.   The names
of all persons participating in the audit  analysis  are to be included  in the
report that is submitted to the appropriate enforcement agency.
                                     2-35

-------
      EPA will be able to respond if notified soon after a decision has been
 made to perform a compliance test.  The quality assurance revisions will
 have instructions to notify the EPA Quality Assurance Management Office
 30 days prior to the actual test.
      Since all sample concentrations must be diluted to fall within the
 calibration range of the standards for Method 108, the audit sample
 concentrations will be within these analytical  ranges.  Coordination within
 the auditing program will ensure that sources receive different audits on
 different requests.
      2.7.5  Comment:  One commenter (D-7) stated that the acid digestion
 bombs required by the Method 108 protocols are  a potential  explosion hazard,
 and recommends that alternative methods be developed.  The commenter also
 noted that since a five hour digestion period is specified by the  methods,
 it would be desirable to have multiple-bombs in order to digest several
 samples simultaneously.   However,  since these bombs  are expensive,  small  air
 pollution laboratories  could incur significant  expense in obtaining multiple
 bombs.
      2.7.5  Response:   A review of data collected  at glass  furnaces shows
 that  there is  little or  no  arsenic  in  the  insoluble  paniculate matter which
 must  be digested  by  the  bomb digestion procedure.  Although  significant
 amounts of arsenic  can be found in  the insoluble particulate  from copper
 smelters,  the  digestion  procedure will  be  eliminated  from Method 108 when it
 is  applied  to  glass  furnaces.
      2.7.6   Comment:  One commenter (D-13) stated  that  the time allowances
 for testing  under the proposed  Section  61.163 were inflexible and
 inadequate,  and that the specified  testing procedures were inflexible and
 unnecessary.   In support of  this view,  the commenter provided data  showing
 that  other analytical methods can provide similar results to those obtained
when  using the specified EPA Method 108 procedures.
      The major difference between the procedure proposed by the commenter
and the EPA Method 108 procedure was in the method used in determining
arsenic concentration of the samples.  The procedure proposed by the
commenter employed the colorimetric molybdenum blue method instead of atomic
                                     2-36

-------
 absorption.  There were also slight differences in the types of reagents
 employed, and the procedures followed, in leaching the materials collected
 by the probe, filter, and impingers.  In the example provided, the amount of
 arsenic detected when using the molybdenum blue method was 21 mg, 5 mg, and
 0.2 mg in the filter, probe, and impingers, respectively.   These results
 compared to detected arsenic levels when using EPA Method  108 procedures of
 21 mg in the filter, 1 mg in the probe,  and 0.4 mg in the  impingers.
      2.7.6  Response:  Under Section 40  CFR 61.14 in Subpart A - General
 Provisions, the Administrator may allow  the use of any alternative method
 which he has determined to be adequate for indicating whether a  source  is in
 compliance.   Anyone wishing to have a  method approved as an  alternative may
 submit comparative data between the candidate method and the reference
 method for evaluation by the Administrator.   EPA has notified the commenter
 of these provisions (docket reference).

 2.8  DETERMINATION OF COMPLIANCE

      2.8.1  Comment:   One  commenter (D-13)  stated  that  not all furnaces that
 are at present  controlled  can be assumed  to  meet the  proposed  standard.   For
 example,  a controlled furnace at one of the  commenter's plants is  in
 compliance with  the proposed emission  limits  at low and medium production
 rates.   The  furnace has  not been  tested at high rates of production,
 however,  and  it  is not  known if  the furnace would achieve compliance at high
 rates  of  production.  The commenter stated that it would be costly and
 burdensome to test this  furnace at artificially high production rates, and
 unnecessary in light of  the fact that the control device installed on this
 furnace represents the best system available at present.
     2.8.1  Response:  Under the promulgated standards, it  would not be
 necessary to test glass manufacturing furnaces at artificially high
 production rates.  Rather, for purposes of, demonstrating compliance, testing
will be performed at the typical expected production rate of a given
furnace.  Because the proposed limits on  particulate emissions have not been
retained in the promulgation standards, determinations of compliance for
                                     2-37

-------
 furnaces which are required to install control devices will  not be affected
 by the production rate of the furnace.  These furnaces must  only demonstrate
 that emissions of arsenic are being reduced by the percentages specified  in
 Section,61.162.
      2.8.2  Comment:   One commenter (D-13) provided an example of the
 difficulties that may arise in demonstrating compliance with the proposed
 emission limits for furnaces that are already equipped with  control  devices.
 The commenter provided a hypothetical  situation in which a baghouse  controls
 emissions from two furnaces which melt four different types  of glasses, and
 three of these glass  compositions contain  arsenic.  Each module of the
 baghouse has its own  "goose neck" exhaust  stack.   The commenter states that
 these goose neck stacks cannot be tested using EPA Method 5  procedures, and
 cannot be equipped with opacity monitors.   The commenter suggested that EPA
 should consider accepting the efficiency rating of the control  device as
 specified by the manufacturer, in lieu of  requiring emissions  testing.
      2.8.2  Response:   Method 108 has  replaced Method 5 as the  required test
 method in the promulgated standard,  but the sampling procedures  in
 Method 108 would not  be appropriate  for testing the specific source  cited by
 the  commenter either.   However,  there  is another test method, Method  5D,
 whcih  was developed specifically for testing  baghouses and whose  sampling
 procedures would be applicable to this  source.  For sources equipped with
 positive  pressure fabric filters,  Section  4 of Method 5D  should be used in
 conjunction with Method 108  to determine a  suitable sampling location and
 procedure.  Although  it would  be  possible  to  equip a  source such as this
 with opacity  monitoring equipment, it would not be very cost effective since
 multiple  opacity monitors would  be required.   A source could request an
 alternative procedure such as  the one allowed  at electric arc furnaces where
 daily  observation  of visible emissions  (in  accordance with Method 9) by a
 certified  visible  emissions observer is  used  to monitor opacity.
     2.8.3  Comment:  One commenter  (D-13)   raised  the question of the
 applicability of  the standard  in cases where multiple furnaces are exhausted
 to a common stack.  An  example was given of a group of five furnaces which
melt more than 30 different glass compositions, 9 of which contain arsenic.
                                     2-38

-------
 These furnaces  are  controlled by  two  electrostatic  precipitators which
 exhaust to  a  common stack.   The commenter stated  that more  than  100,000
 combinations  of furnaces/glasses  could  occur  on any given day.   For  this
 reason, it  would be virtually impossible  to determine if each combination  is
 in  compliance with  the  applicable proposed emission limit.   Finally, the
 commenter indicated that  the control  devices  installed on these  furnaces
 reflect the best technology  currently available, yet do not always comply
 with  the proposed standards.   The commenter provided another example in
 which a furnace melting fluoride  opal glass is known not to meet the
 proposed emission limits  at  all times even through  the furnace is controlled
 with  the Best Available Technology (BAT).  The commenter stated that this
 situation is  attributable to EPA's classification of fluoride opal glass in
 the "all other"  category  during NSPS  development.   In conclusion, the
 commenter indicated that  furnaces  that  are;already  equipped with BAT should
 not be subject  to further regulation  under the proposed standard.
      2.8.3  Response:   EPA has investigate^ the problems associated with
 demonstrating compliance  with the  proposed;emission  limits on total
 particulates  in  cases where multiple furnaces, producing different types of
 glass,  are  exhausted to a common  stack.  Because the proposed particulate
 emission limits  varied  according  to glass  type, the emission limit
 applicable  to a  given furnace would change with a corresponding change in
 the type of glass produced.  No satisfactory approach could be developed for
 determining compliance with a particulate emission limit under these
 circumstances, or for prorating emissions from multiple furnaces which
 exhaust to a common stack when these furnaces melt various types of glass.
 Partly for this  reason, the proposed emission limits on total particulates
 have been abandoned and replaced by a requirement that arsenic emissions be
 reduced by a specified percentage.  (See response to comment 2.2.2.)
     EPA also investigated the issue raised by the commenter in  regard to
 the compliance status of furnaces  which are equipped with  existing control
devices.  In reviewing all available data on  controlled  arsenic-using
glass  furnace, the Agency has found that many of these control devices
achieve more than 95 percent reduction of total  arsenic  emissions,  although
                                     2-39

-------
some of  them  are  not  capable of  reducing emissions of total participates to
the levels  prescribed by  the proposed standard.  The cost of upgrading these
control  devices to meet the proposed particulate emission limits was
investigated  and  found to be excessive given the minimal incremental
reduction in  arsenic  emissions that would be achieved.  Therefore, basing
the control requirement on the NSPS emission limits originally proposed
would  result  in the failure of some furnaces with existing control devices
to achieve  the standard,  even though these control devices represent an
effective control for emissions  of arsenic.  For this reason also, the
proposed emission limits  have not been retained in the promulgated standard.
Data made available to EPA from  industry representatives indicate that all
existing controlled furnaces with uncontrolled arsenic emissions of more
than 2.5 Mg/year  (2.75 tons/year) will be able to demonstrate compliance
with the promulgated  emission limits without additional control.
     The EPA  has  investigated the emission reductions currently achieved
from the furnace  producing a fluoride-opal glass composition referred to by
the commenter.  The control device installed on this furnace was found to
reduce arsenic emissions by more than 98 percent, although particulate
emissions from the furnace exceed the applicable NSPS emission limits.  As
discussed above,  the  proposed emissions limits were not adopted in the final
regulation, and no additional control is required on this furnace under the
promulgated standard.
     2.8.4  Comment:  One commenter (D-26) stated that the provision in the
proposed standards requiring emissions to be monitored only at the stack
outlet and reported every 6 months is unenforceable.  The commenter
suggested that an efficiency standard for arsenic removal, which would
require  the measurement of arsenic levels at both the inlet and the outlet
to the control device, or a standard limiting the amount of arsenic in each
batch would be enforceable and would reduce arsenic emissions to the
atmosphere.
     2.8.4  Response:   Although the commenter provided no information to
support the contention that the proposed standard would have been
unenforceable, the proposed emission limits on total  particulates have been
replaced in the promulgated standard by a requirement that emissions of
                                     2-40

-------
 arsenic be  reduced by a specified percentage.   In analyzing data made
 available after proposal,  EPA found that particulate emission rates from
 some uncontrolled arsenic-using furnaces are significantly less than would
 normally be expected.  Thus, these furnaces could conceivably meet the
 proposed limit dVi particulate emissions by reducing particulate emissions by
 as little as 45 percent.   In this case, the corresponding reduction achieved
 in arsenic emissions would be only 40 to 45 percent even if all of the
 arsenic were emitted as particulate matter.  In considering these data, EPA
 has found that emission control equipment that would meet the proposed
 particulate emission limits may not, in all instances, represent the most
 effective control technology for arsenic emissions.  Therefore, the
 promulgated standard requires emissions of arsenic to be reduced by a
 specified percentage which reflects the level of control achievable by the
 most effective control technologies.
     Setting a limit on the amount of arsenic added to the raw materials
 would constitute a work practice standard as defined in Section 112 of the
 Clean Air Act.  Section 112 allows work practice standards to be set only in
 those instances in which it is not feasible to prescribe or enhance an
 emission standard.  Because emission standards for arsenic from glass
 manufacturing plants can be established and enforced, EPA has no authority
 to establish a work practice standard.  In any case, the amount of arsenic
 added to the raw materials varies widely within the industry as a function
 of the type of glass being produced and the market for the final product.
 Therefore, it would be impossible to set any specific limit on arsenic usage
 which could be applied to all glass melting furnaces, or to categories of
 glass melting furnaces, that would not fundamentally interfere with process
 operations.

 2.9  REPORTING REQUIREMENTS

     2.9.1  Comment:   One commenter (F-2)  stated that it is unreasonable and
 irrational  to require 12-month projections of arsenic emissions from glass
 plants.   A semiannual reporting of past emissions should be sufficient for
enforcement purposes.
                                     2-41

-------
      2.9.1  Response:  The requirement that arsenic emissions be projected
 over a 12-month period is necessary in order for the operator of the glass
 manufacturing furnace to anticipate the level of control  that will  be
 required for each facility.  Only in this way can possible instances of
 noncompliance with the proposed standards be prevented.   The calculation of
 past emissions may reveal actual instances of noncompliance, but only after
 unacceptable levels of arsenic have been emitted to the  atmosphere.   This
 result would be inconsistent with the objectives of Section 112 of  the Clean
 Air Act.
      2.9.2  Comment:   One commenter (D-13) stated that many administrative
 problems  could result with EPA's semiannual  reporting requirements  under the
 proposed  Section 61.163.
      2.9.2  Response:  The administrative problems referred to  in this
 comment have not been specified.  However, it is the EPA's  conclusion  that
 the reporting, recordkeeping,  and other requirements contained  in the
 standards are both necessary to the implementation of the  regulation and
 reasonable in their impact on  the glass manufacturing industry  and
 individual  furnace owners and  operators.

 2.10 ARSENIC EMISSIONS FROM SODA-LIME  FURNACES

      2.10.1   Comment:  Three commenters  (D-23, D-24,  D-25)  addressed the
 issue of  whether the  temperature of the  gas exhausted from  furnaces melting
 soda-lime glass  affects the  percentage  of  arsenic  emitted in the solid
 phase, and the three  options proposed by EPA  for controlling arsenic
 emissions from soda-lime  glass  furnaces.
     One  commenter  (D-25) stated  that data from one of the commenter's
 soda-lime furnaces indicate that  the percentage of arsenic in the solid
 phase increases with  increasing  stack gas temperature.  He noted that the
 proportion of arsenic found in particulate from this furnace varied  widely
 from a low of about 50 percent to a high of 99 percent.  The commenter
 offered no explanation of why these data conflicted with  the data gathered
by EPA, but felt that there may be some complex chemical  reactions taking
                                     2-42

-------
 place  in  the  melting  furnaces which  are  not at present understood.  Data
 obtained  from another of the commenter's plants  (melting an "all other"
 glass  type) have  also shown a trend  of increasing solid-phase arsenic with
 increasing stack  gas  temperature.  For 23 representative samples collected
 on  this furnace,  from 30 to 100 percent  of the total arsenic was emitted as
 particulate.   The commenter concluded that temperature alone is not the only
 factor affecting  the  level of arsenic control achievable from glass melting
 furnaces.
     The  commenter (D-25) also responded to the  options proposed by EPA for
 controlling arsenic emissions from soda-lime glass manufacturing furnaces.
 According to  the  commenter, a stack  gas  temperature of 250°F is at, or
 below, the acid dew point for most exhaust streams and would lead to severe
 corrosion of  control  equipment.  Corrosion; problems would decrease the
 on-line availability  of  control devices  leading  to higher emissions of
 particulate arsenic than would occur if  the temperature of the exhaust gas
 was maintained at  a higher temperature.   The commenter stated that dry
 scrubbing is  not,  in  practice, a reliable  technology.  In the commenter's
 opinion,  EPA  should not  require cooling  of exhaust gas to 250°F at the
 present time  without  at  least first demonstrating the technology on a pilot
 scale.  The commenter also noted that the dew point of exhaust gases from
 glass  furnaces is  constantly changing, and cannot be accurately monitored on
 a continuing  basis.   Also, temperatures  profiles across an emission control
 device are not uniform.  Therefore, maintaining the temperature of the
 exhaust gases at the  inlet of the control device at 10° to 20°C above the
 dew point is  not practical, and would not ensure that the temperatures
within the control devices would not fall below the dew point.   According to
 the commenter, a control option based on maintaining exhaust gas
 temperatures  at 10° to 20°C above the acid dew point demands more from
 technology than current technology can provide.   The commenter concluded
 that the reduction in arsenic emissions from soda-lime furnaces achievable
with ESPs or  fabric filters would, in practice,  be much better than theory
would suggest, and recommended that EPA test this hypothesis on a pilot
scale before selecting any other regulatory option.
                                     2-43

-------
      Another commenter (D-23)  challenged the validity  of  the  data  presented
 by EPA in support of the options  being considered  for  control of inorganic
 arsenic emissions from soda-lime  glass furnaces.   The  commenter noted that,
 based on a concern over the  data  and  information presented  in the  March 20,
 1984 Federal  Register notice,  additional  information was  requested from, and
 provided by EPA.   After receiving and thoroughly reviewing  this additional
 information,  the  commenter concluded  that the test data used  by EPA were
 faulty,  and also  misrepresented in the March 20, 1984  notice  in the Federal
 Register.   Specifically,  the commenter stated that Figure 1 was not a graph
 showing  the percentage of arsenic in  the  solid-phase,  but rather a graph
 showing  normalized data produced  from inaccurate test  data.   The commenter
 also noted that a meeting was  held with EPA  on April 12,  1984 to review the
 information provided by EPA.   On  the  basis of that meeting, it was concluded
 by the commenter  that the data were sufficiently flawed such  that  the
 conclusions presented by  EPA could not be drawn.   The  commenter stated that
 the total  measurements of arsenic emissions  in each of the three tests
 showed a  decreasing  amount of  total particulate, and that this could only be
 the case  only if  the sampling  train failed to collect  material.  [The
 Administrator assumes  that this commenter meant to  refer  to "total  arsenic"
 rather than "total particulate".]   The  commenter found this position
 difficult  to accept  based  on EPA's  contention that the sampling train is 99
 percent efficient in  capturing gaseous  and particulate emissions.
     The commenter stated  that if an arsenic emission  limitation is to be
 placed on  soda-lime  glass  melting operations, then it  should be based on the
 effects of emissions on ambient air quality and on risks to public  health.
 The method for meeting  an  established emission limitation should be left up
 to glass manufacturers.   In conclusion  the commenter urged EPA to  review its
 earlier position  that  at least 90 percent control  of arsenic emissions can
 be achieved by control equipment,  a position that the commenter believes to
 be correct.  The  commenter also contended that sufficient time and  resources
 have already been committed to the study of soda-lime glass  melting
operations and that further activities are unnecessary.
                                     2-44

-------
     A third commenter (D-24) stated that the data presented by EPA
demonstrate that emissions of participate arsenic increase sharply as  the
temperature of the furnace exhaust gases decreases.  This shows that
substantial additional control of arsenic emissions can be achieved by
cooling the gas stream prior to the particulate control device.  Therefore,
in reviewing the three options considered by EPA for controlling arsenic
emissions from soda-lime glass furnaces, the commenter stated the belief
that the option of not requiring any cooling should be rejected.  The
commenter noted that the drawback to the second option (require cooling to
10° to 20°C above the dew point of the furnace exhaust gases) is that  the
cooling requirement would need to be tailored to each facility which would
increase the task of implementation and enforcement.  This option is still
preferable to requiring no cooling, however.  The commenter expressed  the
belief that the best option is to require cooling of the furnace exhaust
gases to 121°C, or to an even lower temperature.  However, the commenter
challenged EPA's conclusion that cooling to this temperature would mean that
"most" operators would need to install dry scrubbers upstream of the
particulate control device.  The commenter noted that EPA neither presented
nor referred to, any data to substantiate this claim and that the Background
Information Documents (BIDs) for smelters suggested that temperatures  of
121°C or lower are tolerable.  Nonetheless, the commenter supported the
option of requiring operators to reduce exhaust temperatures to 121°C, even
if scrubbers are necessary, because of the substantial reductions in
emissions of arsenic achievable through gas cooling.
     2.10.1  Response:  Since the three options proposed by EPA for
controlling arsenic emissions from soda-lime glass melting furnaces were
published in the Federal Register (49 FR 10278), the Agency has performed
two additional emission tests and has reviewed additional data provided by
industry representatives.  In considering all of the available data, EPA
concludes that there is insufficient evidence to support a requirement that
the exhaust gas from soda-lime glass furnaces, or from furnaces producing
any other type of glass, be cooled to any specific temperature prior to
entering a particulate control device.
                                     2-45

-------
     The available data do indicate that arsenic emissions from some glass
melting furnace may occur less predominantly as particulate matter than was
previously believed, and that cooling can be effective in increasing the
proportion of total arsenic emitted as particualte matter.  However, no
correlations have been identified between the proportion of arsenic emitted
as particulate matter and the type of glass produced, the type of melting
furnace used, the type of arsenic added to the raw materials, or any other
source characteristics.  In addition, EPA does not have sufficient data to
conclude that cooling of furnace exhaust gases would be effective in
increasing the efficiency of a control device in all cases.  Therefore, a
requirement that the exhaust gas from all affected furnaces be cooled to
some specific level prior to entering a cotnrol device could result in
increased costs with no guarantee that additional control would be achieved.
The Agency does believe, nonetheless, that both the format and the level of
the final standard are sufficient to ensure that furnace exhaust gases are
cooled in those instances where the effectiveness of control is dependent on
the operating temperature of the control device.
     The results of the first test on a furnace melting soda-lime glass
showed that less of the total arsenic emitted from the furnace was in
particulate form compared to the previous tests (about 74 percent compared
to more than 90 percent) at the standard EPA Method 108 sampling temperature
of 121°C (250°F).  In addition, samples taken simultaneously at three
different temperatures (121°C, 204°C, and 288°C) showed that the amount of
arsenic in the particulate matter generally increased as the filtered gas
was cooled from 288°C (550°F) to 121°C (250°F).  However, the amount of
vapor-phase arsenic detected in these samples did not decrease in proportion
to the increase observed in particulate arsenic, and the total amount of
arsenic collected at 288°C (550°F) was uniformly less than the total amount
collected at a filtered gas temperature of 121°C (250°F).  The results of
this test were also complicated by the fact that some of the filters used
during the test were later found to be torn.  Because there was not a
decrease in vapor-phase arsenic emissions in proportion to the apparent
increase in particulate arsenic, no basis exists for concluding that cooling
                                     2-46

-------
of the exhaust gases caused vapor-phase arsenic to condense and form
particulate arsenic.  The Agency agrees with the commenter that the data
obtained from the first test on a soda-lime furnace are inconclusive, and
are insufficient to support a limit on the temperature of the gases at the
inlet of particulate control devices.
     After publication of the notice in the Federal Register on March 20,
1984, a second arsenic emission test was performed on a soda-lime glass
melting furnace.  No significant amounts of vapor-phase arsenic were found
in the emissions from this furnace regardless of the temperature of the
filtered gas.  In all test runs, more than 99 percent of the total arsenic
was captured as particulate matter.  Therefore, even if the results of the
first test on a soda-lime furnace had demonstrated a relationship between
temperature and the amount of arsenic emitted as particulate matter, this
relationship could not be generalized to all furnaces producing soda-lime
glass.
     The EPA also performed emission tests on a glass melting furnace
producing an alumino-silicate glass.  Although the furnace is not presently
equipped with a permanent control device, a pilot-scale fabric filter system
had been recently installed on the furnace.  The test program included both
EPA Reference Method 108 and single-point sampling, as well as a series of
performance tests on the pilot-scale fabric filter.  The results of these
tests did conclusively demonstrate that cooling of the furnace exhaust gases
caused gaseous arsenic to condense, and thereby increased the effectiveness
of the fabric filter in reducing arsenic emissions.  When the temperature of
the exhaust gas was cooled to below 121°C (250°F), control efficiencies
ranged from about 75 percent to 97 percent and averaged about 87 percent.
When the temperature of the exhaust gas was maintained above 121°C (250°F),
control efficiencies ranged from about 58 percent to 82 percent and averaged
about 71 percent.  The data also indicated that the effectiveness of cooling
is sensitive to the concentration of gaseous arsenic in the exhaust gas and
to the residence time of the gas stream at lower temperatures.  However, the
data collected during these tests are not sufficient to correlate specific
temperatures to specific removal efficiencies.
                                     2-47

-------
     Although the promulgated standard does not require exhaust gas cooling,
EPA does believe that dry scrubbing is a demonstrated technology for control
of emissions from glass melting furnaces.  At least two manufacturers offer
dry scrubbing systems for glass furnaces and eight dry scrubbing systems are
known to be installed on glass melting furnaces.  Both manufacturers and all
eight plants were contacted for information on the performance, reliability,
and costs of these systems.  The information obtained from these contacts
(Docket reference IV-B-14) indicates that dry scrubbing systems are a
demonstrated technology for removing potentially corrosive pollutants from
the exhaust gases of glass melting furnaces, and would enable cooling of the
exhaust gases to a temperature of 121°C (250°F).

2.11  ZERO PRODUCTION OFFSETS

     2.11.1  Comment:  Two commenters (D-24, D-25) responded to EPA's
proposal for revising the method of applying zero production offsets in
determining compliance with the proposed particulate emission limits.  One
commenter (D-24) discouraged EPA from developing either tighter offsets,
which would place existing control equipment in jeopardy of being out of
compliance, or more complex offsets which would make it more difficult to
obtain a meaningful  guarantee from vendors of new control equipment.  The
commenter expressed the belief that the existing offset provisions are
sufficient to adequately protect the environment, and that reducing or
changing them will only result in miniscule reductions in emissions.  At
worst, changing the zero production offset provisions will result in trivial
non-compliance situations, and uncertainty in engineering new control
devices.  The commenter concluded that EPA should have more important
matters to pursue than worrying about a few tenths of a pound per hour of
particulate emissions from small glass melting furnaces with an existing, or
new, ESP or fabric filter control  device.
     One commenter (D-24) expressed support for EPA's analysis of the zero
production offset issue.  The commenter stated that these offsets were
developed in an unrelated proceeding to suit a purpose which is neither
                                     2-48

-------
controlling nor relevant to the development of a NESHAP for glass
manufacturing plants.  According to the commenter, retention of the offsets
would allow higher emissions from some facilities than would occur if the
offset provisions were dropped.  Therefore, the commenter stated support for
dropping the use of zero production offsets.
     2.11.1  Response:  The issue of zero production offsets would apply
only to a standard which set a limit on emissions from glass melting
furnaces specific to the amount of glass produced in the furnaces,  however,
the format of the standard has been revised to require affected furnaces to
reduce arsenic emissions by a certain percentage.  Therefore, the zero
production offset provisions of the NSPS for glass manufacturing plants are
not applicable to the requirements set forth in the final NESHAP.

2.12  RISK ASSESSMENT AND RISK MANAGEMENT

     2.12.1  Comment:  One commenter agreed with EPA's judgment that an
arsenic emission standard is needed for glass manufacturing plants.  The
commenter characterized glass plants as sources of substantial arsenic
emissions.  They opposed the idea that glass manufacturing plants emit less
than smelters EPA has proposed to exempt and should therefore not be
regulated.  The commenter offered three reasons for not exempting glass
manufacturing plants from the regulation:  (1) the commenter believed that
the proposed smelter exemptions were unlawful and unwise; (2) the commenter
contended that section 112 of the Clean Air Act requires EPA to set
standards for all arsenic source categories; and (3) the commenter saw the
opportunity to reduce or eliminate 37 Mg/yr of arsenic as substantial and
not to be ignored.
     A contrary view was offered by two other commenters.  They called
arsenic emissions from the entire glass manufacturing industry insignificant
because glass manufacturing contributed only 3 percent of the total arsenic
emissions.  One commenter asked how EPA could conclude that 37 Mg/yr from
the entire glass industry represents an "unreasonable risk" while
                                     2-49

-------
simultaneously finding that emission rates of 627, 172 and 140 Mg/yr from
individual copper smelters after control by the proposed standards are
reflective of an ample margin of safety.
     2.12.1  Response:  The Agency noted that the above commenters focused
their reasoning to regulate or not regulate glass manufacturing plants on
the arsenic emissions from the various plants and source categories.  In an
approach that is sometimes used by the Agency, the commenters are using
emissions estimates as a surrogate for ambient concentrations and public
exposure on which risk assessment is based.  However, surrogates must be
carefully applied and the underlying assumptions that make the use of
surrogates reasonable techniques must be carefully considered.  For example,
when comparing emissions from different sources as a surrogate or substitute
to comparing public exposure, the commenter is assuming that similar
emissions cause similar ambient concentrations, that is, emission parameters
for and population distributions near each source or source category are
similar.  The commenters' comparison of the arsenic emissions from copper
smelters to glass manufacturing plant emissions is a case of where the
surrogate approach breaks down.  In this case, primary copper smelters emit
a large portion of their emissions from tall stacks and thereby create
relatively small concentrations around the plant.  Unlike the smelting
industry, glass manufacturing plant emissions are coming from relatively low
stacks and are causing larger ambient concentrations per ton of emissions
than the primary copper smelters.  And, indeed, EPA air dispersion modeling
has borne this out.  So, EPA cannot determine the need to regulate or not
regulate the glass manufacturing plants by comparing glass plant emissions
to the primary copper smelters emissions; EPA analysis has shown that this
approach would lead to faulty decisions when protecting public health.
     2.12.2  Comment:  One commenter estimated that one of his glass plants
                                     •3
(at Shreveport) contributes 0.16 ug/m  arsenic averaged over 8 hours, and he
called this an insignificant environmental impact.
     2.12.2  Response:  Based on the Agency's calculations, the maximum
                                                                       o
concentration to which people near this plant are exposed is 0.018 ug/m
averaged over several years.  Although EPA has not calculated an 8-hour
                                     2-50

-------
average concentration, it appears that the two estimates  are  reasonably
consistent when considering the difference in averaging times.   The
Administrator believes that the risk associated with  Shreveport  plant's
arsenic emissions is low.
                                     2-51

-------

-------
                                 APPENDIX A

       SUMMARY OF  RESULTS OF  EMISSIONS TESTING  PERFORMED AFTER PROPOSAL

A.I  SUMMARY OF EMISSION TESTING ON A SODA-LIME FURNACE

A.1.1   Introduction
     Emission tests were conducted on a soda-lime glass melting furnace in
July 1983.  Arsenic was being added to the batch raw materials in the form
of powdered arsenic trioxide.  Emissions from  the furnace were not
controlled.  Two  different types of emission tests were performed.  First,
in order to evaluate whether the temperature of the furnace exhaust gases
has an  effect on  the proportion of arsenic emitted in the solid phase, a
series  of three single point tests were conducted.  In the single point
testing, three sampling trains were operated simultaneously.  In each train,
the filtered gas  was maintained at a different temperature: one at 121°C
(250°F), one at 204°C (400°F), and one at 288°C (550°F).  Second, four
modified EPA Method 108 tests were performed.  The results of these tests
are presented below.
A.1.2   Summary of Single Point Tests
     Table A-l summarizes the results of the single point sampling.  The
values  given for  the S-l-A and S-2-A results are suspect because small  tears
were identified in the filters used when these samples were taken.
Nonetheless, the proportion of solid-phase arsenic appears to increase as
the filtered gas temperature is cooled from 288°C (550°F) to 121°C (250°F).
In run  S-3, a three-fold increase in solid-phase arsenic occurred as a
result  of cooling the gas stream.  The amount of vapor-phase arsenic present
did not, however, decrease in proportion to the increase in solid-phase
arsenic.  In run S-3, vapor-phase emissions decreased by about half when the
filtered gas temperature was reduced from 288°C (550°F) to 121°C (250°F).
In runs S-l and S-2, the amount of vapor-phase arsenic detected remained
roughly constant at all  temperature levels.   Because the amount of
                                     A-l

-------
TABLE A-l.  SUMMARY OF SINGLE POINT TESTS ON A SODA-LIME FURNACE

Run ID
S-l-A
S-l-B
S-l-C
S-2-A
S-2-B
S-2-C
S-3-A
S-3-B
S-3-C
MEAN (S-A
MEAN (S-B
MEAN (S-C
Sample
Temp (°F)
250
400
550
250
400
550
250
400
550.

Arsenic
Solid
(gr/dscf)
0.00141
0.00144
0.00097
0.00217
0.00161
0.00069
0.00343
0.00230
0.00102
0.00234
0.00178
• 0.00089
Emissions
Vapor
(gr/dscf)
0.00153
0.00133
0.00155
0.00109
0.00090
0.00123
0.00074
0.00085
- 0.00155
0.00112
0.00103
0.00144
Total
(gr/dscf)
0.00294
0.00277
0.00252
0.00326
0.00251
0.00192
0.00417
0.00315
0.00257
0.00346
0.00281
0.00234
Solid
(%)
47.96
51.99
38.49
66.56
64.14
35.94
82.25
73.02
39.69
65.59
63.05
38.04
                             A-;

-------
 vapor-phase  arsenic  detected  did  not  decrease  proportionally to  the  increase
 in  the  amount of solid-phase  arsenic  detected  as  the filtered gas
 temperature  was  decreased  from 288°C  (550°F) to 121°C  (250°F), the total
 amount  of  arsenic detected in the high  temperature  samples was uniformly
 less  than  the total  amount detected in  the  low temperature samples.
      The percentage  of  the arsenic detected in the  solid phase at a  filtered
 gas temperature  of 121°C (250°F)  ranged from a low  of  48 percent to  a high
 of  about 82  percent.  The  validity of the S-l-A and S-2-A values is
 questionable,  however,  because of the tears identified in these filters.  At
 a filtered gas temperature of 288°C (550°F), from about 36 to 40 percent of
 the total  arsenic catch was collected in the front  half of the sampling
 train as particulate arsenic.   Once again, the validity of these results is
 questionable  because the total  amount of arsenic  detected declined with
 increasing filtered gas temperature.
      Because  of  the inconsistencies in the data,  and because the measured
 concentrations of arsenic  were  so uniformly low,  it is difficult to draw any
 general conclusions from the  results  of this test.  The data did appear to
 indicate that a  relationship  exists between the temperature of the filtered
 gas and the amount of arsenic captured in the  probe and filter (particulate
 arsenic).  However, the data  did not  consistently indicate that the increase
 in  the amount of  particulate  arsenic  captured as  the temperature of the
 filtered gas was  cooled resulted from condensation of vapor-phase arsenic.
 Therefore, other  explanations for the trends observed  in the data cannot be
 completely discounted.  For example, the collection efficiency of the entire
 sampling train may have been  somehow  impaired during these tests when the
 filtered gas was maintained at elevated temperatures.
A.1.3  Summary of EPA Method  108 Tests
     Table A-2 gives  the results obtained from the four EPA Method  108 tests
on the soda-lime furnace.   The amount of total  arsenic detected  in  the
solid-phase ranged from 66.9 percent to 83.6 percent.   On  the average, about
74 percent of total arsenic was captured in  the front  half of the sampling
trains.   This was considerably less  than the percentage of solid-phase
arsenic found in other tests.   The other tests  had indicated  that more than
                                     A-3

-------
           TABLE A-2.  SUMMARY OF EPA METHOD 108 TESTS ON A SODA-LIME FURNACE
Run ID
  Vapor
(gr/dscf)
Arsenic Emissions
   Solid            Total
 (gr/dscf)        (gr/dscf)
                                                                          Solid
p-1
P-2
P-3
P-4
0.00064
0.00105
0.00045
0.00116
0.00249
0.00218
0.00230
0.00234
0.00313
0.00323
0.00275
0.00350
79.55
67.49
83.64
66.86
MEAN
 0.00083
  0.00233
0.00315
74.38
                                         A-4

-------
90 percent of the arsenic emitted from glass melting furnaces is in the
solid phase and collected by conventional participate control devices.

A. 2  SUMMARY OF EMISSION TESTING AT FOSTORIA GLASS COMPANY

A.2.1  Introduction
     Emission tests were conducted at Fostoria Glass Company from
October 11-13, 1983, and from November 1-3, 1983.  During the October tests,
arsenic was being added to the batch raw materials in the form of powdered
arsenic trioxide.  For the November tests, liquid arsenic acid was
substituted.  Both EPA Method 5 (particulate emissions) and EPA Method 108
(arsenic emissions) were employed.  In addition, three single point samples
were taken during both the October and November tests.  During each single
point run, two sampling trains were used simultaneously.  The temperature of
the filtered gas was maintained at 121°C (250°F) in one, and at 288°C
(550°F) in the other.  The objective of the single point tests was to test
the effect that temperature has on the phase composition of the emitted
arsenic.
     Fostoria Glass Company produces a lead-crystal glass in a single
melting furnace.  Arsenic is added to the batch as a refining agent in the
form of powdered arsenic trioxide under normal operating conditions.
Emissions from the furnace are controlled by an electrostatic precipitator
(ESP).

A.2.2  Summary of Single Point Tests
     Table A-3 provides a summary of the results from the single point
tests.  Runs S-l, S-2, and S-3 were performed in October when arsenic
trioxide was being used; runs S-4, S-5, and S-6 were conducted while arsenic
acid was being used during November.
     In each run, at both 121°C (250°F) and 288°C (550°F), over 99 percent
of the arsenic collected was in the solid phase.  The highest concentration
of vapor-phase arsenic detected was 0.00023 gr/dscf in run S-3 at 121°C
                                     A-5

-------
TABLE A-3.  SUMMARY OF SINGLE POINT TESTS AT FOSTORIA GLASS COMPANY
Run ID
S-l-A
S-l-B
S-2-A
S-2-B
S-3-A
S-3-B
MEAN (S-A)
MEAN (S-B)
S-4-A
S-4-B
S-5-A
S-5-B
S-6-A
S-6-B
MEAN (S-A)
MEAN (S-B)
Sample
Temp (°F)
550
250
550
250
550
250

550'
250
550
250
550
250

Arsenic
Solid
(gr/dscf)
0.01890
0.02490
0.02580
0.02610
0.02090
0.02610
0.02187
0.02570
0.02620
0.02150
0.01930
0.01840
0.01510
0.01640
0.02020
0.01877
Emissions
Vapor
(gr/dscf)
0.00006
0.00004
0.00007
0.00008
0.00006
0.00023
0.00007
0.00012
0.00015
0.00010
0.00008
0.00007
0.00009
0.00007
0.00011
0.00008
Total
(gr/dscf)
0.01896
0.02494
0.02587
0.02618
0.02096
0.02633
0.02193
0.02582
0.02635
0.02160
0.01938
0.01847
0.01519
0.01647
0.02031
0.01885
Solid
(%)
99.67
99.86
99.72
99.68
99.72
99.12
99.70
99.55
99.43
99.52
99.59
99.65
99.39
99.56
99.47
99.58
                              A-6

-------
(250°F).  This corresponds to 0.9 percent of the total  arsenic detected  in
this run.  On average, 99.6 percent of the total arsenic catch was  in the
participates.
     Little or no difference was apparent in the total  amount of arsenic
captured in the sampling train as a function of temperature.   In runs S-l
and S-3 the total amount of arsenic detected was about  20 percent less at  a
filtered gas temperature of 288°C (550°F) than it was at 121°C (250°F).
However, this difference is probably not significant given the small
concentrations of arsenic present.  Similarly, the data did not indicate
that the temperature of the filtered gas had any significant effect on the
proportion of arsenic captured in the particulate matter.  In all runs,  more
than 99 percent of the arsenic was found in the solid phase regardless of
temperature.
     There was no significant difference between the overall results
obtained when arsenic acid was used and when arsenic trioxide was used.

A.2.3   Summary EPA Method 108 Tests
     Table A-4 summarizes the results of the EPA Method 108 tests.   On
average, 0.021 gr/dscf of arsenic were emitted from the furnace and about
0.00025 gr/dscf were finally emitted to the atmosphere.
     The overall efficiency of the ESP in controlling emissions of arsenic
ranged  from  97.5 percent to 99 percent.  An average efficiency of
98.7 percent was demonstrated.  Control levels for solid-phase arsenic
ranged  from  a low of 97.5 percent in run P-l, to a high of 99.2 percent in
run P-4.  The data also suggest that vapor-phase emissions were reduced
across  the control device.  For example, in run P-2 vapor-phase emissions
decreased by about 86 percent.  However, because the outlet samples were
collected at the stack rather than at the outlet duct from the control
device, some condensation of arsenic could  have occurred  in the ducting or
in  the  heat  exchanger which  immediately preceded the stack.
     As in the  results from the  single point  sampling,  there were no
indications  that the  form  in which arsenic  is added to  the batch materials
has any effect  on either controlled or uncontrolled arsenic emissions.
                                      A-7

-------
          TABLE A-4.   SUMMARY OF ARSENIC EMISSIONS DATA FROM FOSTORIA GLASS COMPANY
Run ID
P-l
P-2
P-3
MEAN
P-4
P-5
P-6
Uncontrolled Emissions
Solid Vapor Total
(gr/dscf) (gr/dscf) (gr/dscf)
0.018
0.022
0.022
0.021
0.017
0.024
0.024
0.000010
0.000036
0.000054
0.000033
0.000016
0.000068
0.000080
0.0175
0.0224
0.0218
0.0206
0.0165
0.0236
0.0245
Controlled Emissions
Solid Vapor Total
(gr/dscf) (gr/dscf) (gr/dscf)
0.0004
0.0003
0.0002
0.0003
0.0001
0.0003
0.0002
0.000001
0.000005
0.000025
0.000011
0.000004
0.000012
0.000015
0.0004
0.0003
0.0002
0.0003
0.0001
0.0003
0.0002
Control
Efficiency
(%)
97.50
98.53
98.95
98.33
99.24
98.88
99.02
MEAN
0.021
0.000055    0.0215
0.0002
0.000010
0.0002    99.05
                                            A-8

-------
 A.3.   SUMMARY OF EMISSION TESTING AT INDIANA GLASS COMPANY

 A.3.1   Introduction
     Emission tests  for inorganic arsenic were conducted  at  Indiana  Glass
 Company over  the period May  14  to 19,  1984.   The furnace  on  which  the  tests
 were performed produces a crystal  glass  from a soda-lime  recipe.   Arsenic
 trioxide powder is added to  the recipe to improve the  clarity  of the glass
 and to  eliminate undesirable coloration.   Emissions  from  the furnace are not
 controlled.
     The purpose of  the test was two-fold.   One purpose was  to gather
 further data  on the  proportion  of arsenic emitted from soda-lime furnaces as
 particulate matter.  As reported in  Section  A.I,  an  earlier  test on  a
 soda-lime furnace indicated  that emissions from furnaces  producing soda-lime
 glass might consist  of  relatively  greater amounts of vapor-phase emissions
 compared to those from  furnaces  melting other  types  of glass.  In addition,
 there were some indications  from this  test that cooling of the furnace
 exhaust gases  might  be  effective in  increasing  the amount of arsenic emitted
 as particulate matter,  and thereby increase  the efficiency of  conventional
 control  devices  i'n reducing  arsenic  emissions  from soda-lime glass melting
 furnaces.  However,  the results  from the  previous test were difficult to
 interpret because some  of the filters  used during this test had torn while
 sampling was  in  progress.
     The second  purpose  of the test  was to determine the precision of the
 proposed EPA Reference  Method 108  in measuring  emissions of inorganic
 arsenic  from glass melting furnaces.   The precision of the method was
 estimated by calculating the relative  standard deviations (the standard
 deviation expressed as a percentage  of the mean value) of samples collected
 in a four-train  (quad)  sampling apparatus.  This system allows four trains
 to sample simultaneously at essentially a single point in the stack which
 reduces the effect of variations in the velocity and particulate  profiles on
 the sampling results.   It also permits a  statistically significant  number of
 samples to be collected  in a short amount of time.  A total  of nine quad
 train runs, representing 36 individual  samples, were performed using EPA
Method   108 sampling and analytical procedures.
                                     A-9

-------
      The effect of temperature on the proportion of arsenic emitted as
 participate matter was evaluated by maintaining the temperature of the
 filtered gas in the single-point quad sampling train at temperatures of
 204°C (400°F) and 288°C (550°F).  Altogether, four test runs were conducted
 at elevated sampling temperatures.  In each run, the temperature of the
 filtered gas in two of the sampling trains was maintained at 204°C (400°F)
 and at 288°C (550°F) in the other two trains.  During each run, a single
 Method 108 sampling train was operated at a filtered gas temperature of
 121°C (250°F) for reference purposes.   At the completion of the single-point
 sampling, three multi-point EPA Method 108 runs were conducted with a
 standard sampling train.   The results  of these tests are presented below.
 A.3.2  Summary of Single  Point Tests
      The results of the single-point sampling at elevated filtered gas
 temperatures are given in Table A-5.  During runs 11D,  12C,  and 12D the
 filter supports ruptured  as a result of thermal  decomposition  of the silica
 rubber gaskets.  These ruptures allowed particulate  matter to  pass directly
 into the impingers.   However, in run 12C the rupture occurred  in the final
 minute of the 70 minute test run.   Run 12D was  terminated immediately after
 the rupture  occurred.   Sampling continued after the  gasket failed  in run 11D
 which invalidated the  results from this  run.
      In  every run,  virtually all  of the  arsenic was  emitted  from the furnace
 as  particulate  matter.  The temperature  of the  filtered  gas  had  no  effect on
 the proportion  of arsenic  captured as  particulate.   In each  test  run, less
 than  0.05 mg of arsenic was detected in  the  back-half of  the sampling train.
 Because  up to 0.05 mg  of arsenic was detected in  unused  samples  of  the NaOH
 rinse and HgO impinger solutions,  after-sampling  values of 0.05 mg  or less
 are considered  insignificant.   Therefore,  no significant amounts of  arsenic
 were  emitted from the  Indiana Glass  furnace  in the vapor phase.
 A.3.3 Summary  of EPA  Method  108 Tests
      The results of the standard EPA Method  108 tests are presented  in
 Table A-6.   As was evident  from the  results of the single-point sampling, no
 significant  amounts of vapor-phase arsenic were detected in the emissions.
The total arsenic concentrations measured while traversing the stack were
equivalent to the concentrations measured during single-point sampling.
                                     A-10

-------
                 TABLE A-5.  SUMMARY OF SINGLE POINT TESTS AT INDIANA GLASS
Run ID
10A
10B
11A
11B
12A
12B
13A
13B
MEAN
IOC
10D
11C
11D
12C
120
13C
13D
MEAN
10-RT
11-RT
12-RT
13-RT
Sample
Temp (°F)
400
400
400
400
400
400
400
400
400
550
550
550
550
550
550
550
550
550
250
250
250
250
Arsenic Emissions
Solid Vapor
(gr/dscf) (gr/dscf)
0.00343
0.00384
0.00359
0.00384
0.00354
0.00383
0.00358
0.00388
0.00369
0.00378
0.00412
0.00367
0.00372
0.00418
0.00341
0.00400
0.00384
0.00383
0.00387
0.00313
0.00379
0.00001
0.00001
0.00001
0.00002
0.00000
0.00001
0.00001
0.00001
0.00001
0.00001
0.00001
0.00000
0.00000
0.00001
0.00002
0.00002
0.00001
0.00000
0.00001
0.00000
0.00002
Total
(gr/dscf)
0.00344
0.00385
0.00360
0.00386
0.00354
0.00384
0.00359
0.00389
0.00389
0.00379
0.00413
0.00367
0.00372
0.00419
0.00343
0.00402
0.00385 '
0.00383
0.00388
0.00313
0.00381
Solid
99.7
99.7
99.7
99.5
100.0
99.7
99.7
99.7
99.7
99.7
99.8 .
100.0
100.0
99.8
99.4
99.5
99.7
100.0
99.7
100.0
99.5
MEAN
250
0.00366
0.00001
0.00366
99.8
                                           A-ll

-------
                TABLE A-6.  SUMMARY OF EPA METHOD 108 TESTS AT INDIANA GLASS
Run ID
               Arsenic Emissions
  Vapor            Solid             Total
(gr/dscf)         (gr/dscf)          (gr/dscf)
                                                                               Solid
CD-I
CD-2
CD-3
MEAN
 0.00001
 0.00001
 0.00001
 0.00001
0.00374
0.00359
0.00324
0.00352
0.00375
0.00360
0.00325
0.00353
99.73
99.72
99.69
99.72
                                           A-12

-------
 A.4   SUMMARY  OF  EMISSION  TESTING AT  CORNING GLASS WORKS  IN MARTINSBURG, WEST
      VIRGINIA                                           ."...'

 A.4.1  Introduction
      Emission tests for inorganic arsenic were conducted by EPA at Corning
 Glass Works in October 1984.  The furnace on which the tests were performed
 produces a pyro-ceramic composition  which is derived from an aluminosilicate
 batch recipe.  Liquid arsenic acid (H2As04) is added to the recipe as a
 fining  agent.  Emissions  from the furnace were not controlled.
      The purpose of the test was two-fold.  One purpose was to gather
 further data  on the proportion of solid phase arsenic emitted from the
 aluminosilicate glass furnace.  Previous tests conducted by Corning
 demonstrated  that the proportion of  arsenic emitted as particulate matter
 varied  significantly from test to test and this variability was apparently
 independent of process parameters.   The second purpose was to determine the
 effect  of sampling train  filter temperature on the collection of particulate
 arsenic.
      The emission tests consisted of five separate single point runs using a
 four  train (quad) sampling system, and a single standard EPA Method 108
 sampling train.  Single point testing consists of simultaneous operation of
 the four sampling trains  at a single point in the offgas stream.  During the
 tests,  the temperature of the filters in two of the single point sampling
 trains  was maintained at  204°C (400°F) and at 288°C (550°F) in the other two
 trains.  In addition, each of the two higher temperature sampling trains
 (204°C  and 288°C) had a back-up filter before the impingers.   These back-up
 filters were maintained at 121°C (250°F).
     A  standard EPA Method 108 sampling train with a filter temperature of
 121°C (250°F), was also operated during each of the test runs for reference
 purposes.  Except for the third run,  the standard reference tests and the
 single  point tests were conducted simultaneously.
     During the same period, tests were also conducted by Corning Glass
 Works on a pilot scale fabric filter system.   The efficiency  of the pilot
 system  in controlling arsenic emissions at varying operating  temperatures
was determined.
                                    A-13

-------
A.4.2  Summary of EPA Method 108 Tests
     Table A-7 summarizes the results of the EPA Method 108 tests.   Total
arsenic emissions ranged from 0.0325 to 0.0536 gr/dscf.  On the average,
0.0436 gr/dscf of arsenic were emitted from the furnace.   The proportion  of
solid phase arsenic ranged from 29 to 45 percent.  On the average,  the solid
phase arsenic was approximately 39 percent.

A.4.3  Summary of EPA Single Point Tests
     The results of the single-point sampling at elevated filtered  gas
temperatures are given in Table A-8.  The percentage of the arsenic detected
in the solid phase ranged from a low of 26 percent to a high of about
51 percent.  Ten samples were collected at a filtered gas temperature of
204°C (400°F) and 9 samples were collected at 288°C (550°F).  The average
solid phase arsenic collection using the 204°C (400°F) sample trains was
34 percent, while the average of the 288°C (550°F) trains was 36 percent.
This average was not statistically different from the average (39 percent)
of the Method 108 reference train.
     However, while this indicates no effect of temperature on the
proportion of solid phase arsenic emitted from this furnace, substantial
amounts of arsenic were collected in the back-up filters maintained at 121°C
(250°F).  As can be seen from Table A-9, the sampling trains with back-up
filters show a significant degree of condensation of arsenic between the
higher temperature filters and the 121°C filters.  This discrepancy may
result due to the fact that condensation may be occurring in the sampling
train as a function of residence time in the sampling system, temperature
gradient of the sampling train, and/or the probe location.  Therefore, in
instances where the concentration of vapor-phase arsenic is sufficiently
high to be sensitive to condensation effects, the sampling train may not
provide a reliable indication of the actual proportion of solid phase
arsenic in the furnace exhaust or the effectiveness of a control device in
reducing total arsenic emissions.
                                    A-14

-------
     TABLE A-7.  SUMMARY OF EPA METHOD 108 TESTS ON CORNING/MARTINSBURG
                 ALUMINOSILICATE FURNACE
Run ID
  Solid
(gr/dscf)
  Vapor
(gr/dscf)
  Total
(gr/dscf)
                                                                        Solid
 RT-1

 RT-2

 RT-3

 RT-4

 RT-5
 0.01140

 0.01043

 0.02178

 0.02081

 0.02116
 0.02108

 0.02609

 0.03181
 » ;

 0.02587

 0.02737
 0.03247

 0.03652

 0.05359

 0.04664

 0.04853
35.09

28.55

40.64

44.62

43.61
MEAN
 0.01712
 0.02644
 0.04355
38.50
                                         A-15

-------
            TABLE A-8.   SUMMARY OF SINGLE POINT TESTS  ON  CORNING/MARTINSBURG
                        ALUMINOSILICATE FURNACE

Arsenic Emissions
Run ID
S-l-A
S-l-B.
S-l-Ca
S-l-D
S-2-A
S-2-B
S-2-C
S-2-D
S-3-A
S-3-B
S-3-C
S-3-D
S-4-A
S-4-B
S-4-C
S-4-D
S-5-A
S-5-B
S-5-C
S-5-D
Filter
Temp (°F)
361
352
511
351
349
504
518
356
352
514
527
351
347
505
518
358
356
516
527
Solid
(gr/dscf)
0.01250
0.01571
0.01443
0.01632
0.01522
0.01500
0.01228
0.01456
0.01619
0.01390
0.01703
0.01967
0.01654
0.01654
0.01311
0.01518
0.01465
0.01241
0.01421
Vapor
(gr/dscf)
0.02719
0.03806
0.02358
0.01553
0.02825
0.02350
0.01492
0.03802
0.03934
0.03080
0.03159
0.02891
0.02948
0.02666
0.01958
0.03590
0.03560
0.03454
0.03287
Total
(gr/dscf)
0.03964
0.05377
0.03802
0.03190
0.04347
0.03850
0.02719
0.05258
0.05557
0.04074
0.04858
0.04853
0.04598
0.04321
0.03269
0.05108
0.05025
0.04695
0.04721
Solid
(%)
31.52
29.21
37.96
51.17
35.02
38.97
45.15
27.70
29.14
34.13
35.05
40.53
35.98
38.29
40.11
29.72
29.16
26.43
30.10

MEAN S-A
MEAN S-B
MEAN S-C
MEAN S-D
355
351
510
520
0.01565
0.01566
0.01446
0.01421
0.02911
0.03415
0.02889
0.02451
0.04475
0.04981
0.04235
0.03874
36.13
31.70
34.46
37.67
Run S-l-C is void due to excessive post-test leak rate.
                                          A-16

-------
TABLE A-9.  PERCENTAGE OF TOTAL ARSENIC COLLECTED ON  FRONT  HALF,  GLASS
      CONNECTOR AND BACKUP FILTER AT CORNING/MARTINSBURG FURNACE
           Run ID
  Filter
Temp (°F)
Solid (%)
           S-l-A
           S-l-D
   361
   511
   75%
   86%
           S-2-A
           S-2-D
   351
   518
   88%
   89%
           S-3-A
           S-3-D
   356
   527
   91%
   91%
           S-4-A
           S-4-D
   351
   518
   94%
   73%
          S-5-A
          S-5-D
   358
   527
   95%
   93%
                               A-17

-------
 A.4.4 Summary of Pilot Scale Fabric Filter Performance Tests
      The purpose of the pilot test was to investigate the effect of offgas
 temperature and cooling techniques on the arsenic reduction performance of
 the pilot scale fabric filter system.  Furnace offgases were tapped from the
 process stream prior to the main stack control damper.  The hot exhaust
 gases at 272°C to 318°C (522 to 605°F) were cooled by a liquid spray tower
 or by air dilution prior to the fabric filter.  Water and a mixture of
 sodium hydroxide and water were the liquids used during the spray tower
 cooling tests.  Thermocouples located at the inlets and outlets of the spray
 tower and the fabric filter provided gas stream temperature measurements
 during the test runs.  A total  of 33 test runs were conducted by
 simultaneously collecting samples upstream and downstream of the pilot scale
 fabric filter system.  All  samples were collected using EPA Method 108
 sampling procedures.   Nine  test runs were performed with baghouse inlet
 temperatures  between  129°C  and  139°C (265 and  283°F).   These nine tests are
 referred to as high  temperature runs.   Twenty-four test runs were conducted
 with baghouse inlet  temperatures ranging from  92 to 111°C (198 to 232°F) and
 these are referred to as  low temperature runs.
      The performance  of the fabric filter was  tested under 4 sets of
 conditions.   These are (1)  water cooling with  high  temperature baghouse, (2)
 water cooling with low temperature baghouse, (3)  water and  sodium hydroxide
 cooling  with  low  temperature baghouse,  and  (4)  cooling  by  air  dilution with
 low  temperature baghouse.

 A.4.5  Summary of Fabric Filter  Performance Data
     The  results of the pilot scale  fabric filter performance  tests also
 indicate  that  the stack gas  sampling protocols may  not  provide a  reliable
 indication of  the proportion of arsenic emitted as  particulate matter when
this proportion is sensitive to gas stream temperature.  Table A-10 shows
the fraction of solid phase arsenic detected prior to the fabric filter.
These data were collected with EPA Method 108 sampling trains  (filter
temperature of 121°C) and flue gas temperatures similar to those for EPA
tests.  An average of 77 percent of the arsenic was found to be in the solid
                                    A-18

-------








1—
o
LU
••3 =3:
0 H-
o^ ^^
Q. CD.

1— 00
CD z:
_1 CD
Q- OO
OO
CI5 I-H
rv* y
rD LU
CO
OO CJ
2: t— 1
HH ^-^
t— LU
o; oo
ec o;
;y ^^
-*^
OO Q
CO LU
-
i-H C£
1 <=C
•< ^.
LU ^3
_l CO
CD
i^C
1—



















CU
i— re ti-
re r- u
•4-> 3 CO
o o -a
*~ T> "tT
s- en
D-^

o
"O 'f-
•r- E 	 »
i — CU &^
O tO- — •
oo i-



^_^
0 t-
1— •!- O
re E co
OO 4-> CU T3
S O !/J • — .
CD I— i- S_
I-H  S- S-
CD «a; en
fV- 	 .
t—
O '-T
C_3 O 4-
z: -o -r- o
ZD T- E to
t— tu ~o
O to *^>,
oo s- s-
•=C en
^_^








E
O
•1—
+J
Q-
•r™
J^
O

O
O





co
CO







to
LO
o
•
CD






J^,
0
o

CD





cr>
'^f'
0

O







^-^
CU
1—
E en
i — i E
•r—
LU i—
Lu 0
O
O.O
E
CU S-
1— CU
•*->

0 3

CM
»— i
1
^"


^^
1*^*
O
CD





CM
OO







«-H
LO
O

CD






CTl
CD
CD

CD





CM
^H^
O
•
CD





en
E
-|J -i—
CU i—
t— O
E O
I-H O

Lu S-
Lu CU
4_>
Q. re
E 2

|— ~[^
O
3 re
0 2=
LO
r— 1
1
CO
i-H


CO

O
CD





*5J~
co







CM
to
CD
•
O






o
i-H
CD

CD





CM
LO
O
•
O







+J
a>
p«.
c
I-H C
o
LL. -r-
LL_ 4->
23
Q.C—

CU Q
1—
S-
S *r™
o
3
.Q.1—
E *>^
CU O
1—

jg •!—•
o <:
t— i
CM
, i
cr>
r- 1


LO
LO
O
CD





CO
to







f^^
CO
CD

CD






CM
i-H
CD

CD





LO
CM
CD
•
CD







•4^
CU
r—
E
I-H E
O
Lu -i-
Lu •}->
3

E *r""
CU ' — *
I—

S ••-
0«=t

CM
1
CM
CM


i— 1
^J-
O
CD





CO
to







[*^
CM
O

CD






O
t-H
O
*
o





r--.
i— i
CD
•
O






•4-3
cu
^— •
c**
i— i co
c-
U_ -r-
LU r—
0
Q. O
E 0

(^ s_
CU
^= 4->
en to
^

CM
1
to
CM


CO
^J-
o
CD





i-H
r-^.







(-H
CO
o
m
O






o^
CD
O

CD





CM
CM
CD
*
O







+-*
O)
1— "
E en
I-H E
•r-
LU i—
Lu 0
O
Q.O
E
CU i-
f— CU

S re
0 3
0
CO
i
CO
CM



^^
"%-
^





1^^
co







0
CO
o

CD






•=*•
CD
O

CD





to
CM
O

CD







4-3
CO

E
I-H E
O
Lu T-
1 1 ) ^
3
CLr—

CU O
t—

s ••-
—1
CO
CO
1
r—4
CO


CO
to
o
CD




f-^»
f"«*v








co

CD

O






^^
1—4
CD

CD





^«
co
0

CD
























"Z-
f^
UJ
s:
A-19

-------
phase compared to only about 39 percent for the EPA reference Method 108
sampling trains and about 87.5 percent for the EPA single-point tests with
back-up filters.
     Table A-ll presents a summary of the fabric filter performance data.
The initial six test runs were conducted while the temperature of the
control device was maintained at a temperature of about 138°C (280°F).
Control efficiencies for total arsenic during these runs ranged from about
58 percent to 82 percent, and averaged about 71 percent.  Significantly
higher removal efficiencies were obtained during the following 15 test runs
(runs 7 through 21) after the operating temperature of the fabric filter was
lowered to about 104°C (220°F).  The control efficiencies for total arsenic
emissions averaged about 90 percent during these 12 test runs.  Although the
efficiency of the control device decreased during the next three test runs,
these were performed after the production rate of the furnace had been
decreased by about 20 percent.
     For test runs 25, 26, and 27, the operating temperature of the control
device was increased to about 138°C (280°F).  The data from these runs
indicated that the average amount of arsenic exiting the fabric, filters was
only slightly less than the amount measured at the inlet.  The increase in
temperature may have caused the evaporation and subsequent entrainment of
some of the arsenic previously collected in the filters.
     The results obtained from the final six test runs (all at low
temperatures) showed wide variability in arsenic removal efficiencies,
possibly as a result of further declines in the production rate of the
furnace.
     Table A-12 shows the average control efficiencies achieved under
various operating conditions of both the control device and the melting
furnace.  Significantly higher removal efficiencies were obtained when the
temperature of the fabric filter was maintained below 121°C (250°F)
regardless of furnace production rate or cooling method.  In considering the
data obtained at low control device temperatures only, the production rate
of the furnace appeared to exert the greatest influence on arsenic removal
efficiencies.  During the tests conducted with water spray cooling, average
                                    A-20

-------



















co
i—
co
LU
H-

LU
O
2: o
or uj
o --3
U- O
or or
uj a.
o_
i—

UJ _l
I— 1-1
__ i a.
i — t
U. CD
fv"
O ^3
I-H CO
or co
ca :z
- CD
or z:
•a: .-I
2: 2:
2: or
=3 O
oo o


•
r—l
t
•=c

LU
on
«=c
1—






















O)
IT}
'(0 'rJ
&^ +•* O
O '1-
E h- +J
O S-
| » O
O
3
-o
 S- -r-
•=t o c-~ -
O. CL> S«
(TS t/J 	
> s_
•*



3)
4_>
03 U
I— T—
^5 d •""""•*
O 
o.

E!
o
(/I
(U
Q



d •
3 0
or z


co cn CM r-.
n • # •
O oo CO *d-
co cn cn cn








LO LO CM O
• • • •
O CM CM O
t*^ cn cn cn





co LO co cn
• • • •
i^» co cn CM
CM CO LO >5j-







r»~ CM co co
• • • •
cn LO p-^ co
r**« cn cn cn

















co LO o r-.
1 — r— 1 CO CM
CM CM CM CM







cn
0) -4-> +J •!- +J
r— OJ O) t— 
E r— r— O r—
l-H CO E CO CO E
E I— I E I— I O I — IE
U_ •!— •!— O
LUr— Ll_t— LUS- Ll_^i-
O U- O U_ Cl) U_ 4-»
Q. O O •»-> 3
E 0 0.0 Q. (0 Q.I—
r o
CO CO





o «*
• •
r-) O
LO CO







CO «H-
• •
•3jt" I ' S
cn cn

















«>J- LO
CM CM
CM CM








-M -!->
CD  U_ 4->
3 3
Q.I— Q.r-

0) C^ QJ O
h- 1—
S- S-
S -I- 3S -r-
O ^C O ^C
_1 _l

CM CM
1 1
cn CM
i-H CM


CM
•
CO
IO








LO
•
LO






CD
•
CM
oo







CM
•
^J-
i-H
1
















CO
CO
CM








CD
^—
E
l-H CO
E
U_ -r-
U. r—
0
Q. O
E 0

H^ S-
O)

CO as
•r- 3

CM
1
LO
CM


CM «=C
• ""-"x^
co z:
cn








CM CM
• •
CO CO
i^ cn





O CM
• •
cn CM
co t — .







r*^- o
• •
CM IO
cn cn

















cn et:
* — i °^^»
CM z:








+J +J
(U CD

"E co "E
I-H E >— i E
•r- O
U_ r— U_ •!—
i 1 Q i t ^J
O 3
0.0 Q-r—


-------
TABLE A-12.  ARSENIC CONTROL EFFICIENCY OF CORNING/MARTINSBURG
       PILOT FABRIC FILTER UNDER VARIOUS TEST CONDITIONS
Fabric Filter
Temperature

High
High
Low
Low
Low
Low
Low
Low
Furnace
Production Rate

High
All
High
Low
All
High
Low
All
Method of
Cooling

Water Spray
Water Spray
Water Spray
Water Spray
Water Spray
Air Dilution
Air Dilution
Air Dilution
No. of
Data Points

4
7
9
3
12
6
5
11
Average
Arsenic
Reduction
(*)
70.5
42.6
92.1
78.2
88.6
87.4
80.8
86.5
                          A-22

-------
removal efficiencies of about 92 percent were achieved at high furnace
production rates, compared to an average of about 78 percent at lower
production rates.  Similarly, when cooling was achieved by air dilution the
average percent reduction obtained at high production rates was higher than
those obtained at low production rates.  As can be seen in the data provided
in Table A-10, the concentration of particulate arsenic entering the control
device decreased with decreasing production rate while the concentration of
gaseous arsenic remained relatively constant.  Therefore, at lower
production rates proportionally less arsenic entered the control system in
particulate form and was captured in the fabric filters.  The concentration
of total arsenic in the gas leaving the control device remained constant at
all production rates.  Cooling by air dilution also decreased the
concentration of arsenic at the inlet of the control  device, although it did
not appear to affect significantly the proportion of particulate arsenic.
As a result, the results obtained during cooling by dilution air are not
significantly different from those obtained during water cooling.
                                   A-23

-------
 A.5  SUMMARY OF EMISSIONS DATA SUPPLIED BY INDUSTRY REPRESENTATIVES

 A.5.1  Introduction
      In response to requests from EPA, industry representatives  supplied
 additional  data on arsenic emissions from glass melting furnaces.   These
 data are summarized in the following sections.   Because EPA was  not present
 during these tests, and because in some cases  the test methods employed do
 not fully conform to EPA reference test methods, the results of  the tests
 cannot be fully evaluated.
      For each test, the average temperature  of  the stack gas is  given.
 However, the temperature of the filtered gas in the sampling train  was
 maintained  at about 121°C (250°F)  in each of these tests.   Therefore,
 arsenic present in the stack gas as  vapor-phase arsenic might condense into
 particulate arsenic as the  gas  is  cooled within the sampling train,  and
 thereby obscure any relationship between stack  gas temperature and  the
 proportion  of arsenic  emitted as particulate matter.

 A.5.2   Summary of  Arsenic Emissions  Testing  on  the Corning  Soda-Lime Furnace
        in Charleroi, Pennsylvania
     A soda-lime glass  recipe is melted  in a furnace located at Corning
 Glass  Works'  facility  in Charleroi,  PA.   Emissions  from  the  furnace are
 uncontrolled  and exhausted  to two  separate stacks.  Each stack has been
 tested  five times  for  emissions  of both  solid-  (probe and filter catch) and
 vapor-phase  (impinger  catch)  arsenic.  Prior to  1976, powdered arsenic
 trioxide was added  to the batch.  After  1976, the  plant switched to liquid
 arsenic acid.
     The results of these five tests are shown  in Table A-13.  In most
 tests, more than 99 percent of the emitted arsenic was found to be in
particulate matter.  However, in the April 1983 test only 50 to 60 percent
of the arsenic emitted from the main stack was  detected in the solid phase.

-------










'
LU
t— «
	 1
1



CO
1— 1
o
1 1 1
—I
Sg
<_>

CD

>— 1
z:
O
o
o

13
z:
i—
co
UJ
r—
CO
o
co
CO
t— 4
sc
UU
u

•^f
LU
CO
err
.
0£
j|
—i
CO


•
CO
T-H
1
•a:

LU
i
CO
•a:
h-T




















•o
v— ' — *
^ ^^
o ^-^
CO
i — O J=
ro a.-.—
+•> ro X)


•r- .C
"o XI
CO i —

'!— *— *
r— (3-5
o —
co

, "^"
0 -C
ro ja
.*• ^d-
u
ro

CO -O 1-
•r- -C
i?~o xT
ro CO r—
•r— , — -^
•r-ro
X <1)
3 S-
< 3
W ••— •
S- U-
Ol 0
Q.- 	
f—
^.

«^
o
fl3 **" "H
4-> XJ S-
CO •!- J=
sr 'o xi
•i- CO i —
(O •---
z:
ro
(U

3

 cn cn
cn cn cr»
A A A


r-H ' — I 1 — 1
O O O
0 3 O
V V V



o o --vi
r-H r-H "^
O O O





IO LO i-l
I— « CO T-H






cn en CP>

A A A





o o o
0 O 0
V V V




T-H CM T-H
«*'*«*
O O O








•— I •* O
r-.r-.vo
LO LO LO









J3 -Q -O
ll* ^i* ^^
CO OO 00
**^» **^^ ^1*11*
IO tQ f*«^
"x*»x*^\
oo ro oo
000
CO CO VO
cn cn co


VO VO ^"
O O T-H
o o o


co co cn
o O o


r»» LO co
oo cn cn



CO li-H 1— I
o o o
3 O O




O O r-.
CM CM <^-
O O O





. CM CO O
LO VO O
LO LO IO





VO CO O
en en co






co uo co
O O T-H
0 O O





t-- UO CM
vo vo un
000








o*> *~H r^»>
CO UO CO










.Q t~^ ft
CO OO OO
co oo oo
"""^ "V^ **»•»,, '
CO OO CO
"-N. 'S^. '^^.
r*^ r^* f^^
o o o
r-. co
uft vo
A A

2S
o o
J V

r— r*.
T-H T-H
0 O


vo vo
CO CO
A A


i-H r—4
O O
O O
v



vo vo
o o
0 0





vo O
CM O
CO CO





O r-H
un vo






T-H O
0 0





r-H T-H
r-H i-H
0 0








UO CM
O O
LO un









-O XI
CO CO
CO OO
*^^ "X^
CO OO
CVJ Cvj
*^ *^t*
o o
cn cn cn
cn cn en
A A A

CM CM CM
O 0 O
O O O
V V V
•a "a ~a
r-. co vo
co co co
o o o


cn cn cn
cn cn cn
A A A


T-H r— 1 T— 4
O O O
O O O
V V V


•y x) ~a
cn o o
r-H CM CM
000





CO r-H CO
•* CO -=f
un un in





CTI cn cn
cn cn cn
A A A





000
o o o
V V V



-o -o -o
co cn r-.
vo vo vo
000








un co vo
in un cn
o o o
T-H T-H T-H








u u u

("*•» p"^ I*1^
^•x. "**^ *"""•'*
co •* un
o o o
VO VO VO
o o o
r-» co r^
cn cn cn
A A A

CM CM CM
O O O
O O O
V V V
"X3 T3 "O
CO t~- CO
VO !"-» VO
O O O


cn c^ cn
cn cn cn
A A A


t— 1 r-H r—4
O O O
O O O
V V


-o -o -a •
vo co en
CM CM T-H
o o o





r^ cn cn
^d" CO CM
un un un





cn cn cn
cn cn cn
A A A





o o o .
o o o :
V V V



•a -a -o
CM *a- cn
^f un •*
000>








r-. T-H un
CO CO CO
cn cn cn






F


u u u
i^f »qj» 1^-
r^ i^*» r^«
^^ ^*^» "^^
vo ^o r^
CSJ CXJ Csl
^~ ^" v^*
o o o











































o
•r—
C
 e:
in
e^
 0) O
ro ~O 1-
$- -r- Q-
O) X
Q.T3 O ••>
S(l_ *_• ^Ifc.
• |_ if.. ^|^
 C:
o
CO O O
Cn-r- -r- i-
03 C C 
-------
 During  the  same  test, more  than 86 percent of the arsenic in the auxiliary
 stack was emitted  as particulate matter.  In the test conducted in July,
 1983, the proportion of arsenic collected as particulate matter ranged from
 80  percent  to  96 percent  in the main stack, and from 87 to 98 percent in the
 auxiliary stack.   No explanation could be found for the variations in the
 solid/vapor split  during  tests conducted at different times.
 A.5.3   Summary of  Arsenic Emission Testing on the Corning Aluminosilicate
        Furnace in  Charleroi, Pennsylvania
     The results of an emissions test on Coming's aluminosilicate glass
 melting furnace  in Charleroi, PA are given in Table A-14.  This furnace is
 also equipped  with two separate stacks.  Liquid arsenic acid is used as a
 raw material in  this furnace.  Arsenic emissions from the main stack were
 sampled on  April 21, 1983; the auxiliary stack was tested the following day.
 Tests on the main  stack showed that 95 percent of the arsenic is emitted in
 the solid phase.   A somewhat smaller fraction (about 90 percent) of the
 total arsenic  was  found in the solid phase in the emission from the
 auxiliary stack.
 A.5.4   Summary of  Arsenic Emission Testing on the Corning Aluminosilicate
        Furnace in  Martinsburg, West Virginia
     An aluminosilicate glass composition is produced in the Corning/
 Martinsburg furnace and arsenic is added to the batch raw materials as a
 liquid  acid.   This furnace has been tested numerous times since 1978 for
 emissions of arsenic.  Table A-15 summarizes the results of these tests.
 The fraction of  arsenic captured in the particulate matter ranges from a low
 of  29 percent  to a high of nearly 100 percent.   Significant variability is
 apparent even  for  tests performed on the same day.   During the test
 performed on November 4, 1982, the proportion of arsenic captured as
 particulate matter ranged from less than 30 percent to more than 60 percent.
 Similar variability is apparent in the data obtained from the test on
 November 30, 1983.   Additional data supplied fay Corning (docket entry
A-83-08, IV-D-28) show that the fraction of arsenic emitted in the solid
phase did not correlate to the production rate  of the furnace or the amount
of Gullet added to the fresh raw materials.

-------
           TABLE A-14.  SUMMARY OF ARSENIC EMISSIONS TESTING ON CORNIN6/CHARLEROI
                        ALUMINOSILICATE FURNACE

Date
4/21/83^
4/21/83°
4/22/83C
4/22/83c
Temperature9
(°F)
698
699
791
800
Solid
(Ib/hr)
0.82
0.88
0.67
0.80
Vapor
(Ib/hr)
0.04
0.05
0.08
0.09
Total
(Ib/hr)
0.86
0.93
0.75
0.89
Solid

95
95
89
90
.  Temperature of stack gas
  Main stack
  Auxiliary stack
                                         A-2 7

-------
         TABLE A-15.  SUMMARY OF ARSENIC EMISSIONS TESTING ON CORNING/MARTINSBURG
                      ALUMINOSILICATE FURNACE
Date
05/03/78
05/08/78
05/09/78
05/11/78
05/11/78
05/15/78
05/16/78
06/12/78
06/29/78
11/04/82
11/04/82
11/04/82
11/30/82
11/30/82
11/30/82
03/29/83
03/29/83
05/06/83
05/06/83
05/06/83
05/24/83
05/24/83
05/24/83
MEAN
Temperature3
(°F)
570
560
500
814
824
820
817
748
722
598
592
594
562
557
560
569
559
559
607
608
613
630
614
635
Solid
(Ib/hr)
10.40
10.90
9.60
6.57
8.33
7.74
8.23
4.18
2.43 .
1.15
1.09
2.23
1.14
0.91
1.17
1.95
1.95
2.43
4.12
4.19
4.85
4.58
2.92
4.48
Vapor
(Ib/hr)
0.19
0.02
0.27
1.10
1.30
1.30
1.20
1.80
1.50
2.88
2.06
1.41
0.80
1.70
1.29
0.58
0.33
0.76
0.56
0.54
0.86
0.55
0.44
1.02
Total
(Ib/hr)
10.59
10.92
9.87
7.67
9.63
9.04
9.43
5.98
3.93
4.03
3.15
3.64
1.94
2.61
2.46
2.53
2.28
3.19
4.68
4.73
5.71
5.13
3.36
5.50
Solid
(%)
98
100
97
86
87
86
87
70
62
29
35
61
59
35
48
77
86
76
88
89
85
89
87
75
Temperature of stack gas

-------
A.5.5  Summary of Data Provided by Owens-Illinois, Inc.
     Emissions from four furnaces located at two different Owens-Illinois
plants have been tested for arsenic.  All of these furnaces produce a
soda-lime glass.  The results of these tests are summarized in Table A-16.
In four of the eight tests, no arsenic was detected in the vapor phase.   In
one test, trace amounts of vapor-phase arsenic were detected,  but were too
small to be quantified.  However, in two other tests,  significant amounts of
vapor-phase arsenic were found.  The second test run on  the Shreveport "C"
furnace indicated that only about 78 percent of the arsenic was emitted  as
particulate matter.  In the second test run on the Shreveport  "A" furnace,
about 85 percent of the emitted arsenic was found in the particulate matter.

-------
             TABLE A-16.   SUMMARY  OF ARSENIC EMISSIONS TESTING ON OWENS-ILLINOIS
                           SODA-LIME FURNACES
Date
06/27/83^
06/27/83°
06/29/83°!
06/30/83°
08/02/83®
08/03/83e
08/05/831
08/05/831
Temperature3
570
560
500
490
640
630
480
470
Solid
(Ib/hr)
0.15
0.22
0.08
0.25
0.05
0.06
0.02
0.02
Vapor
(Ib/hr)
NDC
0.06
Trace
0.04
NDC
NDC
NDC
NDC
Total
(Ib/hr)
0.15
0.29
0.08
0.29
0.05
0.06
0.02
0.02
Solid
100
78
<100
85
100
100
100
100
.  Temperature of stack gas
  Shreveport furnace "C"
^ None detected
  Shreveport furnace "A"
I Toledo furnace "G"
  Toledo furnace "D"
                                          A *"»••*
                                          ,-i-OU

-------
                                  APPENDIX  B
                     UPDATED  COST AND  ECONOMIC  ANALYSIS

B.I   INTRODUCTION
      In the Background  Information Document  (BID) for the proposed  NESHAP
for the glass  industry, the costs  and  the  economic  impacts associated with
the proposed standard were analyzed.   Although  at the time of proposal
information was available on  the  financial characteristics of affected glass
companies, sufficient data were not available to estimate the cost  impacts
of controlling all arsenic-using  glass furnaces operated by those companies.
There was also some uncertainty as to whether all arsenic-using furnaces had
been identified.  Therefore,  the  capital and annualized costs of arsenic
emissions control were estimated  for six model glass melting furnaces
(Chapter 6).  Based on these  cost estimates, the economic impact on
potentially affected glass companies was evaluated  (Chapter 7).
     In order to more accurately evaluate the economic impacts associated
with this NESHAP, detailed information was gathered after proposal on
potentially affected furnaces and the plants at which those furnaces are
located.  This information enabled the costs associated with alternative
control options to be estimated for specific furnaces and specific plants.
On the basis of the updated cost analysis, the economic impacts  of
alternative control options were reassessed.
     This Appendix provides updated information on the costs and economic
impacts which  were considered in establishing the promulgated standard.   In
the following  section,  the changes made after proposal  in the methodology
                                     B-l

-------
 for estimating costs and economic impacts are reviewed.  Section B.3
 summarizes the results of the updated cost analysis, and section B.4 reports
 the results of the updated economic analysis.

 B.2  CHANGES IN COST AND ECONOMIC ANALYSIS SINCE PROPOSAL

 B.2.1  Changes in Cost Analysis
      The capital  and annualized costs associated with  controlling  emissions
 of arsenic from glass melting furnaces are a  function  of the  exhaust gas
 flow rate through the control  device  and  the  level  of  control  required.
 At proposal,  the  costs  of  reducing  total  particulates  to the  levels
 specified in  the  proposed  NESHAP for  glass manufacturing plants were
 estimated on  the  basis  of  exhaust gas flow rates  for model plants.  However,
 the  cost  estimates for  the promulgated standard are based on actual flow
 rates at  existing furnaces.  The required  level of control is assumed to be
 a  reduction in  particulate arsenic emissions  of at least 92 percent for
 soda-lime  glass and  at  least 95  percent for other types of glass.  On the
 basis of data provided  in  the BID for the  NSPS for glass manufacturing
 plants, the specific collection  areas  (SCA) of ESPs necessary to achieve
 these percent reductions were determined.   For soda-lime glass, an SCA of
      2
400 ft /l.OOO acfm was determined to be necessary to achieve a reduction in
particulate arsenic emissions of at least 92 percent.  For other types of
glass, an SCA of 1,000 ft2/!,000 acfm would be required to achieve a
95 percent reduction in particulate arsenic emissions.
                                     B-2

-------
      Because the exhaust gas flow rate is dependent on numerous site-
 specific factors including the capacity of the furnace, the type and
 amount of fuel used, the type of glass produced, the temperature of the
 exhaust gases, and other furnace operating parameters, actual flow rates
 were obtained for all arsenic-using furnaces emitting more than 0.4 Mg
 (0.44 ton) of arsenic per year.  The actual  flows were corrected to reflect
 a control  device temperature of 400°F and then multiplied by the required
 SCA to determine the total  plate area necessary to achieve the assumed
 control  level.  Capital  and annualized costs were then estimated on the
 basis of the required plate area for actual  furnaces using the same cost
 algorithms presented in  Chapter 6 of the  proposal  BID.
      In  the cost analysis  performed  prior to proposal,  it  was  assumed  that  a
 separate control  device  would  be installed on each  affected  furnace.
 However, the costs  of ESPs  and  fabric  filters do  not  increase  proportionally
 with  increasing  collection  area.  Therefore,  at plants with  multiple
 furnaces in  close proximity to  one another,  a single control device would
 likely be  installed  to control  emissions  from multiple furnaces.  The
 locations  of individual  furnaces within potentially affected glass
 manufacturing  plants were evaluated with  respect to the feasibility of
 controlling  multiple furnaces with a single control device.  In cases where
 it was determined technically feasible to do  so, the costs of controlling
multiple furnaces with a single control device were estimated.

B.2.2  Changes in Economic Analysis
     One objective of the economic analysis is to estimate the increase in
production costs that would be incurred in controlling emissions of arsenic
                                     B-3

-------
from glass melting furnaces.  The increase  in production costs can then be
used to estimate either the decline  in profits  (cost absorption) or
increases in prices  (cost pass-through) that would occur as a result.  At
the time of proposal, no data were available on the actual costs of
producing specific types of glass within the pressed and blown segment of
the glass industry.  Instead, production costs were estimated on the basis
of producer price indexes for various product categories.  However, the
producer price indexes related costs of production to the quantity of
products shipped rather than to the weight of the products shipped.  As a
result, rough estimates were made of the specific production costs
(i.e. $/unit weight of product) for various product types.  In order to gain
a more accurate perspective on the increases in production costs associated
with a NESHAP for arsenic-using glass furnaces, individual companies were
contacted for information on their current production costs for specific
arsenic-containing glasses.  This information was used in the updated
economic analysis.
     The previous analysis was also based on the assumption that all  of the
glass melted in a furnace was formed into a marketable product.   In reality,
however, a percentage of the glass produced does not meet quality
specifications and is discarded as cullet.  In the updated economic
analysis, it is assumed that 70 percent of furnace production is actually
sold as a final product.  The 70 percent value was selected on the basis of
typical cullet ratios for glass melting furnaces which average about
30 percent.
     In the previous economic analysis, both impacts on price and profit
were estimated.  However, in reviewing the overall economic climate of the
                                     B-4

-------
 pressed  and  blown  segment  of  the  glass  industry,  it was determined that cost
 absorption  (profit reduction) would  be  more  likely for all types of
 products.  Therefore, only impacts on profit were calculated  in the updated
 economic analysis,  and profit  ratios  of  indivuidual companies  were applied to
 furnaces of  these  companies.
     Finally, the  updated  economic analysis  is based on the estimated costs
 of controlling specific furnaces  rather than model furnaces.  Accordingly,
 profit impacts were calculated for specific  furnaces with known production
 rates of arsenic-containing glasses.  The estimated decline in profit from
 an individual furnace provides an indication of the probability that a
 furnace  would be shut down rather than  equipped with a control device.

 B.3  RESULTS OF UPDATED COST ANALYSIS
 B.3.1  Number of Furnaces Considered
     Control costs were estimated for the 11 uncontrolled furnaces that
 currently emit more than 0.4 Mg (0.44 ton) of arsenic per year.   In
 addition, control costs were estimated for 13 uncontrolled furnaces which
 individually emit less than 0.4 Mg/year (0.44 ton/year),  but are either
 located at the same plants as the higher emitting furnaces or at plants with
 relatively high total  plant-wide emissions of arsenic.   These 24 total
furnaces are located at 6 separate glass manufacturing  plants and  have
combined arsenic emissions of about 28.8 Mg/year (31.7  tons/year).
B.3.2  Estimated Control  Costs
     The estimated capital  and annual costs  of controlling each  of  the
24 arsenic-using glass furnaces  are given  in Table B-l.   Only costs  for ESPs
                                     B-5

-------
            TABLE B-l.  RESULTS OF COST ANALYSIS FOR UNCONTROLLED GLASS  FURNACES



Plant
Code
1


1
2








2
2
3
4
5
6








6
a) At a


Furnace
Code
A
B
C
A,B,C
A
B
C
D
E
F
G
H
I
A,B,C,D,E
F,G,H,I
A
A
A
A
B
C
D
E
F
G
H
I
A,B,C,D
temperature of
b) Assumes^a specific


Glass
Type
Soda-lime
Soda-lime
Soda-lime
Soda-lime
Soda-lime
Soda-lime
Soda-lime
Soda-lime
Soda-lime
Soda-lime
Soda-lime
Soda-lime
Soda-lime
Soda-lime
Soda -lime
Al'-Silicate
Al -Silicate
Al -Silicate-
Soda -lime
Soda-lime
Soda-lime
Soda-lime
Soda-lime
Soda-lime
Soda -lime
Soda-lime
Soda-lime
Soda-lime
400°F.
collection area
Control
Device
Flowrate
(acfm)
18,081
17,727
33,939
69,747
7,842
9,124
6,086
12,965
14,557
17,899
15,960
6,103
10,125
50,574
50,087
25,800
25,696
18,993
12,961
10,296
10,296
8,842
7,025
7,994
6,904
6,420
6,420
42,395
-)
of 400 ft VI ,000


Estimated . ESP Capital
PlateJ\reaD
(ft2)
7,232
7,091
13,576
27,899
3,137
3,650
2,434
5,186
5,823
7,160
6,384
2,441
4,050
20,230
20,035
25,800
25,696
18,993
5,184
4,118
4,118
3,537
2,810
3,198
2,762
2,568
2,568
16,958

acfm for soda-1
Cost
($)
1,342,100
1,328,100
1,873,800
2,746,300
862,000
933,900
753,700
1,125,200
1,196,500
1,335,000
1,256,200
754,700
987,000
2,352,500
2,297,900
2,633,500
2,627,800
2,238,800
1,125,000
995,800
995,800
918,600
813,200
870,900
805 ,800
775,300
775,300
2,108,300

ime glass and

ESP Annua
Cost
($/year)
268,000
265,100
376,500
555,800
170,700
185,200
148,900
223,900
238,400
266,500
250,500
149,100
195,900
474,700
463,500
532,500
531,400
451,300
223,900
197,700
197,700
182,100
160,800
172,500
159,300
153,200
153,200
424,600


1000 ft /I,000 acfm for other glass types.
                                           B-6

-------
were calculated.  Except for the very smallest furnace sizes, the capital
and annualized costs for EPSs are somewhat greater than those for fabric
filter systems.
     As mentioned above, the costs assume that furnaces producing soda-lime
glass are required to reduce particulate arsenic emissions by 92 percent,
and that furnaces producing other types of glass are required to reduce
particulate arsenic emissions by 95 percent.  At plants where it would be
technically feasible to do so, the costs of installing a single device to
control emissions from multiple furnaces have been estimated in addition to
the costs of controlling the furnaces individually.  The costs of combined
control systems are, in all instances, lower than the costs for controlling
each furnace separately.  For example, the annual cost of controlling the
three furnaces at plant 1 would be about $556,000 if a single control device
were installed, compared to a total  annual cost of about $910,000 for
controlling these furnaces separately.

B.4  RESULTS OF UPDATED ECONOMIC ANALYSIS
     Since the arsenic NESHAP for glass manufacturing plants was proposed on
July 20, 1983, additional information has been collected on companies that
operate arsenic-using furnaces.  Therefore, the purpose of this section is
to supplement the analysis of economic impact that was presented in the BID
for the proposed standard.
     Currently, three companies operate six plants having furnaces  with
potential arsenic emissions of more  than 0.4 Mg (0.44 ton) per year.
Twenty-four arsenic-using furnaces are located at these six plants.   The
three companies are Corning Glass Works, Owens-Illinois, Inc., and  Lancaster
                                     B-7

-------
Colony Corporation.  Background financial data for Corning Glass Works and
Owens-Illinois, Inc. are presented in Tables 7-10 and 7-14, respectively, of
the proposal BID and are not repeated here.  Background financial data for
Lancaster Colony Corp. are given in Table B-2.
B.4.1  Maximum Percent Profit Reductions
     Estimated maximum profit impacts are based on the assumption that
companies would be unable to increase their prices for products to cover the
costs of installing and operating an emissions control device.  If product
prices are not increased and net sales remain constant, profits before taxes
will be reduced.  Therefore, the assumption of complete cost absorption
presents a "worst case" from the standpoint of glass manufacturing
companies.
     The extent to which profit would be reduced can be estimated by
comparing the bas.eline (i.e. before control) return on sales to the return
on sales after emissions controls are installed.  Return on sales is defined
as profit before tax divided by total revenue (profit ratio).  Before tax
return on sales is used instead of after tax return on sales to avoid the
complication of varying tax rates.
     Financial data for glass companies are generally reported according to
major segments of the business.  For the glass industry, these business
segments generally correspond to broad categories of products.  However,
within any overall product category, for example machine-made consumer
glassware, a wide range of different individual products may be included.
Therefore, profit ratios derived from financial data for these broad
business segments may not precisely indicate the margin of profit on a
                                     B-8

-------
     TABLE B-2.  FINANCIAL CHARACTERISTICS OF  LANCASTER COLONY CORPORATION'
                                      ($105)
 Year
         Company
          Total
Machine-made
  Consumer
 Glassware
 1979
 1980
 1981
 1979
 1980
 1981
 1979
 1980
 1981
 1979
 1980
 1981

Average
 1979
 1980
 1981

Average
 1979
 1980
 1981

Average
          Sales

          267.5
          291.1
          307.7

    Profits Before Taxes

           20.6
           12.9
           19.6

         Assets

          174.6
          172.1
          182.1

      Return on Sales
        (Percent)

            7.7
            4.4
            6.4

            6.2

Before Tax Return on Investment

         (Percent)
           10.0
      Sales to Assets

          (Ratio)
           1.53
           1.69
           1.69

           1.63
       95.6
      111.2
      115.9
        9.1
        8.1
       11.1
       60.9
       65.3
       65.5
        9.5
        7.3
        9.6

        8.8
       14.9
       12.4
       16.9

       14.7
       1.57
       1.70
       1.77

       1.68
                                       B-9

-------
particular arsenic-containing glass produced  in a particular furnace.
Nonetheless, more disaggregated data on before tax profits and total
revenues are not publicly available, and the  available data are considered
sufficient for purposes of this analysis.
     The ratios of before tax profits to sales used to estimate profit
declines are shown in Table B-3.  These ratios were derived from the
financial data provided in Tables 7-10 to 7-17 of the proposal BID as well
as from the financial data for Lancaster Colony Corporation shown in
Table B-2.  With the exception of machine-made consumer ware, the ratios
reflect unweighted industry-wide averages for each product category
(business segment).  For furnaces producing machine-made consumer ware,
individual company-wide profit ratios were used.
     Table B-4 summarizes the profit declines estimated for the 24 glass
melting furnaces under consideration.  For each range of decline in profit,
the number of furnaces within that range are  shown, both when it is assumed
that each individual furnace is controlled separately and when it is assumed
that multiple furnaces are controlled by a centralized emissions control
device.  Assuming that all furnaces are individually controlled, profits
from 21 of the 24 furnaces would decline by 15 percent or more.  This range
of profit decline is considered significant.  Profit declines for 2 furnaces
would be moderate, in the range of 5 to 15 percent, and applying controls to
one furnace would have an insignificant impact of profit.  However, when the
more realistic situation is considered in which single control  devices are
applied, wherever feasible, to multiple furnaces, the overall  impact on
profit would be moderate for most furnaces.    In this case, significant
impacts on profit are estimated for 7 of the 24 furnaces.
                                     B-10

-------
       TABLE B-3.  SUMMARY OF FINANCIAL RATIOS FOR PROFIT IMPACTS
        Product
Before Tax
  Profi ts
 to Sales
 (Percent)
Machine-made tableware

T.V. envelope tubes
 7.5 to 8.3

    11.7
The financial ratios are for the business segments in the firms producing
that product
                                 B-ll

-------
                TABLE B-4.  SUMMARY OF PROFIT IMPACTS
   Range of
Maximum Profit
  Declines
  (Percent)
    Number of
    Furnaces
(Separate Control)
    Number of
    Furnaces
(Multiple Control)
    0-5

    5-15

   15-30

   30-50

    50+

   TOTAL
       1

       2

      10

       6

       5

      24
        1

       16

        1

        1

        5

       24
                                 B-12

-------
     The estimated impacts on profit for Individual furnaces are given in
Table B-5.                               :
B.4.2  Capital Availability
     The ability of the companies to finance the capital costs of emissions
control devices must also be considered. ; The ratio of long-term debt to
total capitalization (long term debt plus equity) provides a measure of
capital availability.  A high ratio (expressed as a percentage) generally
indicates that additional debt financing may not be possible.
     Table B-6 provides data on the ratio of long-term debt to total
capitalization for the three firms considered.  Data are presented for a
period of four years in order to identify any trends in company debt ratios.
                                         i        . '
The ratios of long-term debt to total capitalization for Owens-Illinois,
Inc. and Lancaster Colony Corporation are more than double that for Corning
Glass Works.  All. three firms show relatively stable debt ratios.
     For purposes of this analysis, it was assumed that the costs of
installing emission controls are financed solely through debt.  The impact
on capital availability of installing emissions control devices on arsenic-
using furnaces can be measured by comparing the debt ratio prior to control
to the debt ratio after control  for each affected company.  These ratios are
shown in Table B-7, along with the percent increase in debt ratio resulting
from installation of emissions control  devices.  Capital  availability does
not appear to be a major constraint.  The highest estimated percent increase
in debt ratio is for Lancaster Colony Corporation which increases by about
10 percent.  However, for all three companies the ratio of long-term debt to
total capitalization after controls is  within the range of debt ratios
experienced by these firms over the past four years.
                                     B-13

-------












CO
UJ
JJ
2=
oi
u.

CD
U.
CO
UJ
1 1
_J
o
UJ
a
t— 4
U.
o
a_
UJ
CO
UJ


*
tn
i
CO
UJ
§
















<4- CO
O •*-> C
CO <*- r—
en o o
C S- CU
ctj d. CD


tO CO -Q
in o r—
(O •! 	
i— S- *fl-
CO O- 	






>,
+•> i-
0 0
3 en
-0 CO
O •+"*
S- re)
a. o




. »
•a to
CO O
r— •«-> O
~O •r^'io^'
I— +J 3
U) C
UJC



D_
CO +J
UJ in
O
-o o
CO
fO to •%>*)•

•*-> a.
10 re)
UJ O



s.

I—
10
-
vo vo vo vo
co co co co
CD O O CD






CO CO CO CO
t- S— i- &->
(O rcJ (O fO
CO CO CO CO
_Q J/^ ,tf^) t^
(O fl3 (O fO
t-l— J- h-




O O CD O
CD CD O O
CD t-4 in co
co in vo in
vo vo !•••• in
CM CM CO in




O O CD O
o o o o
t— 1 •— 4 CO CO
CM OO CO VO
*J" ^^1 ^^ ^^*
co co co r*»*

i— t rH r-H CXI






03 d) 03 O)
^s _s _E _e
J3HJ3 H
co co co co




C_3
«=C CQ 0 CO
gj"

t— 4 t— 1



ooooooooo m in
cocoininincococoin «— i »-i
'0 ' ' ' ' 0 0 0 'o 0 '
uDinooc^Lninino in in
I— l^HCOCOCO.— l«-4l— 4CO


cococococococococo co co
ooooooooo o o






COCOCOCOCOCOCOCOCO CO CO
COCOCOCOCOCOCOCOCO CO CO
-Q-Q.a-Q-a-O.a-a_a J2 ^3
fO (O (& (d rt3 *O fO fO  r~- in
o in co co co vo o en m «* co
t^*» co **J" CM co vo in ^d* en r*^ vo
^-Ir-li— ICMCMCMCMi-l'-l «* •*




OCDOCDCDCDCDCDCD CD CD
OOOOOOOOO O O
oenr~»CMinoc\]r-o in en
CMcocoinvoinvo«a-t~> CM i*^
vocoincMcncoinmco in en
cocnr»«r-<»-4cocMr-^en co CM

i— 1 <— 1 t— < r-4 CM CM






COCOCOCOCOCOCOCOCO CO CO


cococococococococo co co


UJ
*
CD *~4
A A
ca co
A A

-------
              o> o o
              c i- o>
              «3 0. 0
              10 a> .a
              «/J O i
              03 -r-
o
o
oo
LU
O
       
    CD  O
f— M-> O

+->  E i— -
O -r-  «-
H- •*->  =J
    w  c
   LU  C
O
C£
a.

a
   Q.
   00 4->
   LU  10
       O
   T3 O
    0)

    iO  03 -fa^-
                 a.
                 
                    Q.
                    ra
                   5
                    QJ
                    o
                    (O
                    (O
                   SI
                    OOOOC3C3OOO
                    oororotnooooo
                     i   i   i  i t—i i—i i—i i—11—i
                    6-S&9&5&5A  A  A  A  A
                    in LO ir> o
                    t—I r—I r-> CO
                                                             in
                             co oo oo co co co co co co

                             o'o'o'o'o'o'ooo.
                                                    co
                                                     •
                                                    o
                              01(1)
                                           0)0)
                                                        0)
                                                              O)
                                                              S-
                             oooooooo
                             oooooooo
                             CMt— Ir— It— «
                                                             O
                                                             O
                                                             to
                                                             CsJ
                             OOOOC3CDOOO
                             OOOOOOOOO
                             OOOOOCMO'>COfOCO
                             CvJOICTli— li— i
o
o
CO
  A
§
                                                             evi

                                                             (LI
                   oooooooooooooooooo    oo
                                                             ca
                                                              f\
                                                             •=c
                                                                      B-15

-------
i    TABLE  B-6.   RATIO  OF  LONG-TERM DEBT TO TOTAL  CAPITALIZATION  (PRE-CONTROL)'


1978
1979
1980
1981
Average
1978
1979
1980
1981
Average
1978
1979
1980
| 1981
Average
Corning
Glass
163.4
147.1
153.6
200.1
166.0
905.1
975.1
1,066.3
1,165.5
1,028.0
18.1
15.1
14.4
17.2
16.2
Owens-
Illinois
Long-Term Debt
($ 106)
691.
697.
687.
618.
673.3
Total Capitalization
(Long-Term Debt Plus Equity)
1,797.
1,898.
2,003.
2,033.
1,932.8
Ratio of Long-Term Debt to
Total Capitalization
(Percent)
38.5
36.7
34.3
30.4
34.8
Lancaster
Colony
31.4
37.1
44.0
40.9
38.4
93.8
106.1
116.8
122.3
109. 7 1
33.5
35.0
37.7
33.4
34.9
                                        B-16

-------
    TABLE B-7.  RATIO OF LONG-TERM DEBT TO TOTAL CAPITALIZATION  (POST CONTROL)
Company
     Ratio of Long-Term
Debt to Total Capitalization
 Before      After      Percent
Controls    Controls     Change
 Corning Glass

 Lancaster Colony

 Owens-Illinois
  16.2

  34.9

  34.8
16.8

38.4

35.1
 3.7

10.0

 0.9
                                       B-17

-------
B.4.3  Regulatory Flexibility
     The Regulatory Flexibility Act (RFA) of 1980 requires that differential
impacts of Federal regulations upon small business be identified and
analyzed.  The RFA stipulates that an analysis is required if a substantial
number of small businesses will experience significant impacts.  Both
requirements, substantial numbers of small businesses and significant
impacts, must to met to require an analysis.  If either measure is not met,
then no analysis is required.
     The Small Business Administration (SBA) definition of small business
for SIC 3229 is a company that employs 750 persons or fewer.  Table B-8
shows recent employment levels for the three firms that will potentially be
affected by this regulation.  All of the firms have more than 750 employees.
Therefore, none of the firms meets the SBA definition of small business and
no regulatory flexibility analysis is required.
                                     B-18

-------
    TABLE B-8.  EMPLOYMENT IN AFFECTED COMPANIES, 19813"6
    Company
Employment
Corning Glass
Lancaster Colony
Owens-Illinois
  30,200
   5,900
  51,000
                          B-19

-------

-------
                                       APPENDIX C


                      AVAILABLE INORGANIC ARSENIC EMISSIONS DATA FOR
                            EXISTING ARSENIC-USING GLASS PLANTS
Plant     Furnace    Glass Type
Existing Control
   Device Type
    Baseline Arsenic Emissions
(kg/hr)    (Ifa/hr)    (Mg/yr)   (ton/yr)
1


2
3

4








5

6
7
8
9

10




11

A
B
C
A
A
B
A
B
C
D
E
F
G
H
I
A
B
A
A
A
A
C
A
B
C
D
E
A
B
Soda -Li me
Soda-Lime
Soda-Lime
Soda -Lime
Lead
Lead
Soda-Lime
Soda-Lime
So da -Li me
Soda -Li me
Soda -Li me
Soda-Lime
Soda -Li me
Soda-Lime
Soda -Li me
Strontium
Lead
Lead
Lead
Aluminosilicate
Aluminosilicate
Fluoride/Opal
Various
Various
Various
Lead
Lead
Aluminosilicate
Lead
None
None ',
None
None
ESP

None
None
None
None ;
None
None
None
None
None
ESP
ESP
ESP
ESP
None
None
MC/ESP
ESP
ESP
ESP
ESP
ESP
None
FF
0.089
0.095
0.102
0.048
0.023

0.024
0.024
0.024
0.010
0.009
0.033
0.026
0.024
0.024
0.003
0.001
0.010
0.005
1.581
0.390
0.001

0.006

0.008

0.095
0.005
0.196
0.209
0.225
0.105
0.050

0.052
0.052
0.052
0.023
0.021
0.073
0.058
0.052
0.052
0.007
0.002
0.021
0.010
3.486
0.860
0.003

0.013

0.018

0.209
0.010
0.75
0.80
0.86
0.40
0.19

0.20
0.20
0.20
0.09
0.08
0.28
0.22
0.22
0.22
0.03
0.01
0.08
0.04
13.28
3.41
0.01

0.05

0.07

0.80
0.04
0.82
0.88
0.95
0.44
0.21

0.22
0.22
0.22
0.10
0.09
0.31
0.24
0.22

0.03
0.01
0.09
0.04
14.64
3.75
0.01

0.06

0.08

0.88
0.04
                                            C-l

-------
Plant     Furnace    Glass Type
Existing Control
   Device Type
    Baseline Arsenic Emissions
(kg/hr)    (Ib/hr)   (Mg/yr)  (ton/yr)
12
13
14
15








16



17
fe

19

20
21
22


23

A
A
A
A
B
C
D
E
F
G
H
I
A
B
C
D
A
A
B
A
B
A
A
A
B
C
A
B
Lead
Lead
Borosilicate
Soda -Li me
Soda-Lime
Soda-Lime
Soda-Lime
Soda-Lime
Soda-Lime
Soda -Li me
Soda -Li me
Soda -Li me
Soda-Lime
Soda-Lime
Soda -Li me
Soda -Li me
Soda-Lime
Soda-Lime
Soda-Lime
Soda-Lime
Soda -Li me
Soda-Lime
Soda-Lime
Soda-Lime
Soda-Lime
Soda-Lime
Soda-Lime
Soda -Lime
ESP
ESP
FF
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
0.002
0.023
0.023
0.269
0.162
0.162
0.113
0.046
0.107
0.040
0.006
0.006
0.048
0.048
0.048
0.048
0.000
0.008
0.008
0.000
0.000
0.006
0.019
0.011
0.011
0.011
0.002
0.002
0.005
0.050
0.050
0.593
0.357
0.357
0.249
0.102
0.232
0.089
0.013
0.013
0.105
0.105
0.105
0.105
0.000
0.018
0.018
0.001
0.001
0.014
0.042
0.024
0.024
0.024
0.004
0.004
0.02
0.19
0.19
2.26
1.36
1.36
0.95
0.39
0.90
0.34
0.05
0.05
0.40
0.40
0.40
0.40
0.00
0.07
0.07
0.00
0.00
0.05
0.16
0.09
0.09
0.09
0.01
0.01
0.02
0.21
0.21
2.49
1.50
1.50
1.05
0.43
0.99
0.37
0.06
0.06
0.44
0.44
0.44
0.44
0.00
0.08
0.08
0.00
0.00
0.06
0.18
0.10
0.10
0.10
0.01
0.01
                                           C-2

-------
Plant
Furnace    Glass Type
Existing Control
   Device Type
    Baseline Arsenic Emissions
(kg/hr)    (Ib/hr)    (Mg/yr)   (ton/yr)
24





25



26




27


TOTAL
A
B
C
D
E
F
A
B
C
D
A
B
C
D
E
A
B
C

Soda-Lime
Soda-Lime
Soda-Lime
Soda-Lime
Soda -Li me
Soda -Lime
Soda-Lime
Soda -Li me
Soda-Lime
Soda-Lime
Soda-Lime
Soda-Lime
Soda-Lime
Soda -Li me
Soda -Li me
Various
Various
Various

None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None

0.003
0.003
0.003
0.003
0.003
0.003
0.002
0.002
0.002
0.002
: o.ooo
0.000
0.000
0.000
0.000
0.018
0.018
0.018
3.828
0.007
0.007
0.007
0.007
0.007
0.007
0.005
0.005
0.005
0.005
0.000
0.000
0.000
0.000
0.000
0.039
0.039
0.039
8.438
0.03
0.03
0.03
0.03
0.03
0.03
0.02
0.02
0.02
0.02
0.00
0.00
0.00
0.00
0.00
0.15
0.15
0.15
32.15
0.03
0.03
0.03
0.03
0.03
0.03
0.02
0.02
0.02
0.02
0.00
0.00
0.00
0.00
0.00
0.17
0.17
0.17
35.44
  ESP = Electrostatic Precipitator; MC = Multiple Cyclons; FF = Fabric Filter
                                            C-3

-------

-------
              APPENDIX D





INORGANIC ARSENIC RISK ASSESSMENT FOR



      GLASS MANUFACTURING PLANTS

-------

-------
     QUANTITATIVE EXPRESSIONS OF PUBLIC CANCER RISKS FROM  EMISSIONS OF
             INORGANIC ARSENIC FROM GLASS MANUFACTURING PLANTS
D.1  INTRODUCTION                        :
D.1.1  Overview The quantitative expressions of public cancer risks presented
     In this appendix are based on (1) a dose-response model  that numerically
relates the degree of exposure to airborne inorganic arsenic  to the risk  of
getting lung cancer, and (2) numerical expressions of public  exposure to
ambient air concentrations of inorganic arsenic estimated to  be caused by
emissions from stationary sources.   Each of these factors is  discussed
briefly below and details are provided in the following sections of this
appendix.
D.I.2  The Relationship of Exposure to Cancer Risk
     The relationship of exposure to the risk of getting lung cancer is
derived from epidemic!ogical studies in occupational settings rather than
from studies of excess cancer incidence among the public.   The epidemic!ogical
methods that have successfully revealed associations between  occupational
exposure and cancer for substances such as asbestos, benzene, vinyl  chloride,
and ionizing radiation, as well as for inorganic arsenic, are not readily
applied to the public sector, with its increased number of confounding
variables, much more diverse and mobile exposed population, lack of consoli-
dated medical records, and almost total absence of historical exposure data.
Given such uncertainties, EPA considers it improbable that any association,
short of very large increases in cancer, can be verified in the general
population with any reasonable certainty by an epidemic!ogical study.
Furthermore, as noted by the National Academy of Sciences (NAS)1, "...when
there is exposure to a material, we are not starting at an origin of zero
cancers.  Nor are we starting at an origin of zero carcinogenic agents in
our environment.   Thus, It is likely that any carcinogenic agent added to
the environment will act by a particular mechanism on a particular cell
population that is already being acted on by the same mechanism to Induce
cancers."  In discussing experimental dose-response curves, the NAS observed
                                   D-l

-------
 that most information  on  carcinogenesis  is  derived  from  studies of ionizing
 radiation with  experimental  animals  and  with humans which indicate a linear
 no-threshold dose-response  relationship  at  low doses.  They added that although
 some evidence exists for  thresholds  in some animal  tissues, by and large,
 thresholds have not been  established for most tissues.   NAS concluded that
 establishing such low-dose  thresholds "...would require  massive, expensive,
 and  impractical  experiments ..."  and recognized that  the U.S. population
 "...is  a  large,  diverse,  and genetically heterogeneous group exposed to a
 large variety of toxic agents."   This fact, coupled with the known genetic
 variability to  carcinogenesis and the predisposition  of  some individuals to
 some form of cancer, makes  it extremely  difficult,  if not impossible, to
 identify  a threshold.
      For  these  reasons, EPA has taken the position, shared by other Federal
 regulatory agencies, that in the  absence of sound scientific evidence to
 the  contrary, carcinogens should  be  considered to pose some cancer risk
 at any  exposure  level.   This no-threshold presumption is based on the view
 that as little  as one  molecule of a  carcinogenic substance may be sufficient
 to transform a  normal  cell  into a cancer cell.   Evidence is available from
 both the  human  and  animal health  literature that cancers may arise from a
 single  transformed  cell.  Mutation research with ionizing radiation in cell
 cultures  indicates  that such a transformation can occur as the result of
 interaction  with as little as a single cluster of ion pairs.   In reviewing
 the  available data  regarding carcinogenicity, EPA found no compelling
 scientific  reason to abandon  the no-threshold presumption for inorganic
 arsenic.
      In developing  the exposure-risk relationship for inorganic arsenic,  EPA
 has  assumed  that a  linear no-threshold relationship exists at and below the
 levels of  exposure reported  in the epidemiological  studies of occupational
 exposure.   This means that any exposure  to inorganic arsenic is assumed
 to pose some risk of lung cancer and that the linear relationship between
cancer risks and levels t>f public exposure is the same as that between cancer
 risks and  levels of occupational  exposure.   EPA believes that this assumption
                                    D-2

-------
is reasonable for public health protection in light of presently  available
information.   However, it should be recognized that the case  for  the  linear
no-threshold dose-response relationship mbdel for inorganic arsenic is  not
quite as strong as that for carcinogens which interact directly or in
metabolic form with DNA.  Nevertheless, there is no adequate  basis for
dismissing the linear no-threshold model for inorganic arsenic.   At low
concentrations it is the Agency's belief that the exposure-risk relationship
used by EPA represents only a plausible upper-limit risk estimate in  the
sense that the risk is probably not higher than the calculated level  and
could be much lower.
     The numerical constant that defines the exposure-risk relationship
used by EPA in its analysis of carcinogens is called the unit risk estimate.
The unit risk estimate  for an air pollutant is defined as the lifetime  cancer
risk occurring in a hypothetical population in which all individuals  are
exposed throughout their lifetimes (about 70 years) to an average concentra-
tion of 1 ug/m3 of the  agent in the air which they breathe.   Unit risk
estimates are used for  two purposes:  (IKto compare the carcinogenic potency
of several agents with  each other, and  (2) to give a crude indication of
the public health risk  which might be associated with estimated air  exposure
to these agents.
     The unit risk estimate for inorganic arsenic that is used in this
appendix was prepared by combining the  five different exposure-risk  numerical
constants developed from four occupational studies.2 The methodology used
to develop the unit risk estimate from  the four studies is described in D.2
below.
D. 1.3  Public Exposure
     The unit risk estimate is only one of the factors needed to produce
quantitative expressions of public health risks.  Another factor needed
is a numerical expression of public exposure, i.e., the numbers of
people exposed to the various concentrations  of inorganic arsenic.   The
difficulty of defining  public exposure  was noted  by the National  Task Force
on Environmental Cancer and Health and  Lung  Disease in their 5th Annual
Report to Congress, in  1982. 3  They reported that "...a large proportion of
                                    D-3

-------
the American population works some distance away from their homes and
experience different types of pollution in their homes, on the way to and
from work, and in the workplace.  Also, the American population is quite
mobile, and many people move every few years."  They also noted the necessity
and difficulty of dealing with long-term exposures because of "...the long
latent period required for the development and expression of neoplasia
[cancer]..."  [The reader should note that the unit risk estimate has been
changed from that value used in the inorganic NESHAP proposal as a result
of EPA's analysis of several occupational epidemic!ogical studies that have
recently been completed.]
     EPA's numerical expression of public exposure is based on two estimates.
The first is an estimate of the magnitude and location of long-term average
ambient air concentrations of inorganic arsenic in the vicinity of emitting
sources based on air dispersion modeling using long-term estimates of source
emissions and meteorological conditions.  The second is an estimate of the
number and distribution of people living in the vicinity of emitting sources
based on 1980 Bureau of Census data which "locates" people by population
centroids in census tract areas.  The people and concentrations are combined
to produce numerical expressions of public exposure by an approximating
technique contained in a computerized model.   The methodology is described
in D. 3 below.
D.I.4  Public Cancer Risks
       By combining numerical  expressions of public exposure with the unit
risk estimate, two types of numerical expressions of public cancer risks are
produced.   The first, called individual risk, relates to the person or
persons estimated to live in the area of highest concentration as estimated
by the computer model.   Individual  risk is expressed as "maximum lifetime
risk."  As used here, the work "maximum" does not mean the greatest possible
risk of cancer to the public.   It is based only on the maximum annual  average
exposure estimated by the procedure used.   The second, called aggregate risk,
is a summation of all the risks to people estimated to be living within the
vicinity (usually within 50 kilometers) of a source and is customarily summed
for all the sources in a particular category.   The aggregate risk is expressed
                                    D-4

-------
as incidences of cancer among all  of the exposed population  after 70 years
of exposure; for convenience, it is often divided by  70  and  expressed  as
cancer incidences per year.   These calculations are described  in more
detail in D.4 below.
     There are also risks of nonfatal cancer and other potential health
effects, depending on which organs receive the exposure.   Mo numerical
expressions of such risks have been developed; however,  EPA  considers  all
of these risks when making regulatory decisions on limiting  emissions  of
inorganic arsenic.
D.2  THE UNIT RISK ESTIMATE FOR INORGANIC ARSENIC2
     The following discussion is summarized from a more detailed description
of the Agency's derivation of the inorganic arsenic unit risk  estimate as
found in EPA's "Health Assessment Document for Inorganic Arsenic (EPA-600/
8-83-021F).
D.2.1  The Linear No-Threshold Model for Estimation of Unit Risk Based on
       Human Data (General)
       The methodologies used to arrive at quantitative estimates  of risk
must  be capable of being implemented using the data available  in existing
epidemiologic studies of exposure to airborne arsenic.  In order to extrap-
olate from the exposure levels and temporal exposure patterns  in these
studies to those  for which risk estimates are required, it is  assumed that
the age-specific mortality rate of respiratory cancer per year per 100,000
persons for  a particular 5-year age  interval, i, can be represented using
the following linear absolute or additive risk model:
                          a-j(D)=ai + 100,OOOa'D                   (1)
With  this model,  a,  is the age-specific mortality  rate per year of respira-
tory  cancer  in  a  control population  not exposed  to arsenic, a1 is a parameter
representing the  potential of airborne arsenic  to  cause respiratory cancer,
and D is  some measure  of the exposure to  arsenic up  to  the  ith age interval.
For example, D  might be the  cumulative dose  in years-ug/m3, the cumulative
dose  neglecting exposure during the  last  10 years  prior to  the ith age inter-
val,  or the average  dose in  ug/m3  over  some  time period prior to the ith
age  interval.   The  forms to  be  used  for  D are constrained by the manner in
which dose was  treated in each  individual epidemiologic study.  At low
exposures the extra  lifetime probability  of  respiratory cancer mortality
will  vary correspondingly  (e.g.,  linearly).
                                     D-5

-------
     The dose-response data available in the epidemiologic studies for esti-
mating the parameters in these models consists primarily of a dose measure
Dj for the jth exposure group, the person-years of observation Yj, the
observed number of respiratory cancer. deaths Oj, and the number Ej of these
deaths expected in a control population with the same sex and age distribution
as the exposure group.  The expected number Ej is calculated as
                               zYjiaj/100,000                      (2)
                         Ej  =
                                i
where  Yj,-  is  the  number of person-years of observation in the ith age cate-
gory and  the  jth  exposure group  (Yj = z Yj,-).  This is actually a simplified
                                      i
representation, because the  calculation also takes account of the change in
the age-specific  incidence rates with absolute time.  The expected number
of respiratory cancer  deaths for the ith exposure group is
                  E(0j) =   zYj,  (a, + 100,OOOa'Dj)/100,000

                  « EJ  + a'Yj°j                                      (3)
under  the  linear  absolute risk model.  Consequently, E(0j) can be expressed
in terms of quantities typically available from the published epidemiologic
studies.
     Making the reasonable assumption that Oj has a Poisson distribution,
the parameter a'  can be estimated from the above equation using the method
of maximum likelihood.  Once  this parameter is estimated, the age-specific
mortality  rates for respiratory cancer can be estimated for any desired ex-
posure pattern.
     To estimate  the corresponding additional lifetime probability of res-
piratory cancer mortality, let bi,...,bi8 be the mortality rates, in the
absence of exposure, for all  cases per year per 100,000 persons for the age
Intervals 0-4, 5-9	80-84, and 85+, respectively;  let ai,...,ai8 represent
the corresponding rates for malignant neoplasms of the respiratory system.
The probability of survival  to the beginning of the ith 5-year age interval
is estimated as
                           n  [1  - 5bj/100,000]
                          3=1
                                    D-6
                                                                    (4)

-------
Given survival to the beginning of age interval i, the probability of dying
of respiratory cancer during this 5-year interval is estimated as
                           5ai 7100 ,000                              (5)
     The probability of dying of respiratory cancer given survival to age
85 is estimated as aiQ/biQ.  Therefore, the probability of dying of respir-
atory cancer in the absence of exposure to arsenic can be estimated as:
                      17             i-1
                 PQ • £ [5ai 7100 ,000) n (l-5bj/100,000)]            (6)
                      i=l            j=l
                                17
                      +(ai8/bi8) n (1 - 5 bj 7100,000)
                                j=l
Here the mortality rates a-j apply to the target population for which risk
estimates are desired, and consequently will be different from those in
(l)-(5), which applied to the epidemiologic study cohort.   If the 1976 U.S.
 mortality rates (male, female, white, and non-white combined) are used in
this expression, then PQ = 0.0451.
     To estimate the probability PEP of respiratory cancer mortality when
exposed to a particular exposure pattern EP, the formula (6) is again used,
but a^ and bj are replaced by a-j(Di) and b-j(D.j), where D-j  is the exposure
measure calculated for the ith age interval from the exposure pattern EP.
For example, if the dose measure used in (1) is cumulative dose to the be-
ginning of the ith age interval in ug7m3-years, and the exposure pattern
EP is a lifetime exposure to a constant level  of 10 ug7m3, then D^ =
(i-1) (5) (10), where the 5 accounts for the fact that each age interval has a
width of 5 years.   The additional  risk of respiratory cancer mortality is
estimated as
                                 PEP - PO                           (7)
EP
   - P  is
If the exposure pattern EP is constant exposure to 1 ug7m3, then P
called the "unit risk."
     This approach can easily be modified to estimate the extra probability
of respiratory cancer mortality by a particular age due to any specified
exposure pattern.                         ,
                                   D-7

-------
D.2.2  Risk Estimates from Epidemlologlc Studies
     Prospective studies of the relationship between mortality  and exposure
to airborne arsenic have been conducted for the Anaconda, Montana smelter
and the Tacoma, Washington smelter.   Table D.I summarizes the fits of both
absolute and relative-risk models, with either k = 1 or k = 2,  to dose-
response data from 4 different studies at the two smelters.  (See the
"Health Assessment Document for Inorganic Arsenic," chapter 7,  EPA-600/!
8-83-021F for detailed description of occupational studies.)
     Table D.I also displays the carcinogenic potencies a1.  It should be
noted that the potencies estimated from different models are in different
units, and are therefore not comparable.
     In every case, a linear model (k = 1) fitted the data better than the
corresponding quadratic model (k = 2).  In every case but two, the fits of
the quadratic model could be rejected at the 0.01 level.  The two exceptions
involved the two smallest data sets  (Higgins et al. absolute risk, and Ott
et al.) and in the former case the fit was very marginal (p = 0.017).  On the
other  hand, for each data set a linear model provided an adequate fit.  Also,
in every case, an absolute-risk linear model fit the data better than the
corresponding  relative-risk linear model.  The p-values  for the fits of the
absolute-risk  linear model ranged from 0.025 to 0.75.
     The estimated unit risk is presented for each  fit  for which the chi-
square goodness-of-fit p-value is greater than 0.01.  The  unit risks derived
from linear models—8 in  all—range  from 0.0013 to 0.0136.  The largest of
these  is from  the Ott et  al. study,  which probably  is the  least reliable for
developing quantitative estimates, and which also  involved exposures to penta-
valent arsenic, whereas the other studies involved  trivalent arsenic.  The
unit risks derived from the linear (k =  1)  absolute-risk models are considered
to be  the most reliable;  although derived from 5  sets of data  involving 4  sets
of  investigators and 2  distinct exposed  populations, these estimates are quite
consistent,  ranging  from  0.0013 to 0.0076.
     To  establish  a  single point  estimate,  the  geometric mean  for  data sets  is
obtained within distinct  exposed  populations,  and the  final estimate  is  taken
to  be  the  geometric  mean  of those values.   This  process is illustrated in
Table  D.2.
                                     D-8

-------
u
1



















oo
UJ
oo
j
^^
-y*
^£

v;
»— i
C£
UJ
P
r-
1—4
t—

O"

U_
O

^_
C£

*^*
j=
±5
OO


T— 1

UJ
_J
§





























I






•P
to
CO
t—
4^>
•p—
U.
o
to

CO
c
, "O
§
w
CD
tj-
o

•p
f— •
^g
to
CO























































^
v^
to «.
*Jjj

s
•r-
C
3
s


CO

"io
Q.


^^
•
•
3
°X


ro
O *—
p—
C ro

O >>
C O
i!
o a.

jy»








i_
CO

o

*—





CO
•o o
C S-
rO 3
O

^5
3 ro
•P +•>
OO ro
O












c
o

CO "P
to ro
O P-
O. 3
X Q-
UJ O
a.
•n
•p -p -p

•—.**" **~ **""
OO *l <4— ^4—
t O O O
00 U U U
CM i— i— <—


p-4 ^- p-4
O O O
to o o o
CM 0 0 0
o o o o
o o o o



—~
to
r*1* to to to
CM CO 00 O"l
t-4 VO CM l~~






• — '
l-» i-4 «*• 00
1 1 1 1
OO O"t O C71
«* o o o
CM CM OO* CM

i-4 CM i-4 CM

^ ^
to to
•1— »p-
S- S_

CO CO
•p >
3 ••-

O ro
CO P-
ja co
> CO
U. > -P
CO CO -r-
CO JC E
1 ~_~ Q














ro
-O 4- CO
C CO t-
0 4-> CO
O i— J*
 lO ^~
t-5 CD CM to
t— 1 t-l






"~-
r-. t-i «* oo

vo <* r~> oo
oo r~ i— 1 1— i
CNJ i-H CO CM

rH CM r-4 CM

^ ^
to to
E si

CO CO

3 f
r- +»
O ro
V) r—
_a co
ra t-





ro

+J
CO

CO
c

*5>
•^























<-_
oo
1
to
CM
«— 1




^H
•Sf
O



«"~
C^
o
•^






•— •
vo
1
to
CTi

t-l

^
to
•r-
S-

co

3

*o
to
i*^
ra






3
J=
CJ

oB

C
o
CO





















4^ 

• 3 -r- r- +J o n 10 i— ja co ro S- 1 J= to S- ^o s: OiJJ <•-•» CD O) c 4-> 4-> *» t* »• *^~ *t*~ *^~ CO H— 4— H— 1 O O O vo u u o • (O t3 fO ^** P"" ^^ l~~ 00 CM o o O VO O «* o o o t-l O O O o o o o «*«*«*<• o t-i to cy> r— vo «* oo CM r-l CM *^' — *-.~* r-- S «d- ? till to t-i oo vo 00 O t-l O CO CM to t-4 t-l CM t-4 CM .* .* to to •1— •!— s- s- CO CO •p > 3 ••- r- -P ^3 t5 to f— j=i co ro S. J- to s- ro 21 "en oo ra p— CO c s- •^ ^^ •— 1 — 1 ~^1_J CM to cr> t-i t-4 CM ^ to ^ CO ^ •p- 40 ro p— CO i. co S- 3 to . o i— 0- ra X — CO T5 •P CO CO J= -P •p j= 'i o«— o to s_ CO &- o CO 2 •o •i- CO 0 S. •P 4<^ to o CO P CO T- CO P— to •o ° CO t|- to p— *p- CO P- •§5 0 c S o CL S- 3 CO u cn c: c S-3 ^3 fl3 S- "•p- CO O. •p to •p- CO c J- 3 t-r •P O c: CO *"* i_ to CO -P- t|_ S- tp. •p- CO •a e c 5 •p- CO t4— CO t- S. r— ro 1^ to . 1 VO CL o -o cn 1 0


-------
TABLE D.2  COMBINED UNIT RISK ESTIMATES FOR ABSOLUTE-RISK LINEAR MODELS
Exposure Source    Study
               Unit Risk
Geometric
Mean Unit
   Risk
Final Estimated
   Unit Risk
Anaconda smelter
ASARCO smelter
Brown & Chu    1.25 x 10~3
Lee-Feldstein  2.80 x 10'3
Hlgglns et al.  4.90 x 10-3
Enter!Ine &
  Marsh        6.81 x 10-3
               7.60 x ID'3
                                                 2.56 x ID"3
                                                                4.29  x  10-3
                                                 7.19 x 10-3
D.3  QUANTITATIVE EXPRESSIONS OF PUBLIC EXPOSURE TO INORGANIC ARSENIC
     EMITTED FROM GLASS MANUFACTURING PLANTS
D. 3.1  EPA's Human Exposure Model (HEM) (General)
     EPA's Human Exposure Model is a general model  capable of producing
quantitative expressions of public exposure to ambient air concentrations
of pollutants emitted from stationary sources.   HEM contains (1)  an  atmos-
pheric dispersion model, with included meteorological  data, and (2)  a
population distribution estimate based on Bureau of Census data.   The  only
input data needed to operate this model are source  data,  e.g.,  plant location,
height of the emission release point, and temperature  of  the off-gases.
Based on the source data, the model  estimates the magnitude and distribution
of ambient air concentrations of the pollutant in the  vicinity  of the  source.
The model is programmed to estimate  these concentrations  within a radial
distance of 50 kilometers from the source.   If the  user wishes  to use  a
dispersion model  other than the one  contained in HEM to estimate  ambient
air concentrations in the vicinity of a source,  HEM can accept  the concen-
trations if they  are put into an appropriate format.
     Based on the radial distance specified, HEM numerically combines  the
distributions of  pollutant concentrations and people to produce quantitative
expressions of public exposure to the pollutant.
                                    D-10

-------
D. 3.1.1  Pollutant Concentrations Near a Source
     The dispersion model within the HEM is a climatological  model  which  uses
a sector-averaged gaussian dispersion algorithm.   The algorithm has been
simplified to improve computational efficiency.5  The algorithm is evaluated
for a representative set of input values as well  as actual  plant data, and
the concentrations input into the exposure algorithm are arrived at by
interpolation.  Stability array (STAR) summaries are the principal  meteoro-
logical input to the HEM dispersion model.  STAR data are standard climato-
logical frequency-of-occurence summaries formulated for use in EPA models
and available for major U.S. meteorological monitoring sites from the
National Climatic Center, Asheville, N.C.  A STAR summary is a joint
frequency-of-occurrence of wind speed, atmospheric stability, and wind direc-
tion, classified according to Pasquill's categories.   The STAR summaries  in
HEM usually reflect five years of meteorological data for each of 314 sites
nationwide.  The model produces polar coordinate receptor grid points
consisting of 10 downwind distances located along each of 16 radials which
represent wind directions.  Concentrations are estimated by the dispersion
model  for each of the 160 receptors located on this grid.  The radials are
separated by 22.5-degree intervals beginning with 0.0 degrees and proceeding
clockwise to  337.5 degrees.  The 10 downwind distances for each radial are
0.2, 0.5, 1.0, 2.0, 5.0, 10.0, 20.0,  30.0, 40.0, and 50.0 kilometers.  The
center of the receptor grid for each  plant is assumed to be the plant center.
D. 3.1.2 Justification for 50 Kilometer Modeling
     At proposal, exposure  and risk were estimated for people residing
within  20 kilometers of  the smelter.  Some commenters pointed out that
since  people  beyond 20 kilometers  are exposed to some level of arsenic due
to a source's emissions, EPA's proposal  analysis underestimates the  total
exposure and  risk.  EPA  agrees with this comment and has expanded its
analysis out  to 50 kilometers.  There are several reasons for EPA to extend
its analysis  out to 50 kilometers.  When applying air dispersion models,
the EPA's modeling guidelines recommend  that, because of the increasing
uncertainty of estimates with distance  from  the modeled  source and because
of the paucity of validation studies  at larger distances, the impact may
                                     0-11

-------
extend out to 50 kilometers, but the analysis should generally be limited
to this distance from the source. ^  Such site-specific factors as terrain
features (complex or flat), the objectives of the modeling exercise, and
distance to which the model has been validated will determine the appropriate
distance (whether greater than or less than the guideline distance) for which
the Agency should apply the model.
     Unless the technical or other considerations do not allow it, EPA has
decided to extend their hazardous air pollutant regulatory analysis for
inorganic arsenic out to 50 kilometers.  The Administrator believes that
the potential to identify additional significant public exposure outweighs
the increased inaccuracies of applying the models beyond the previously
accepted 20 kilometer radius.
D. 3.1. 3  Methodology for Reviewing Pollutant Concentrations
     Before making HEM computer runs, EPA reviewed U.S. Geological Survey
topographical maps (scale 1:24000) to verify locational data for each glass
manufacturing plant.   Plants were given exact latitude and longitude values
which were then incorporated into the HEM program.   Such information was
critical to the accuracy of the model in utilizing STAR data for each site.
The other major inputs for the HEM, emissions data, were also carefully
screened to insure accurate model  predictions.
     After completing the HEM runs, nearby monitoring sites with ambient
air quality data were identified by computer from the National Aerometric
Data Bank (NADB) (Table D. 3).   In some cases, data for several years at
individual monitors were included in the NADB retrieval and were expressed
as average values with different sample sizes for the years monitored.   In
these instances, weighted multi-year averages were calculated to provide an
overall mean for each monitoring site.   For purposes of mean calculations,
values measured below minimum detection limits were considered as equal to
one half the detection limit.   These ambient arsenic data were then compared
to HEM predicted values in order to gauge the accuracy of the air dispersion
model's estimates.   As noted above, HEM predicted values were based on
concentrations calculated to occur at 160 polar coordinate receptor grid
                                    D-12

-------
points consisting of 10 downwind distances located  along  each of 16 radials
which represented wind directions.   Because the actual monitoring  site
locations identified in the NADB retrieval usually  did not correspond to
exact grid point Vocations, a log-linear interpolation scheme was  used  to
caluclate an HEM estimated concentration at the site (Figure D-l).
D. 3.1. 3.1  Use of Ambient Data
     Certain criteria were considered in review of ambient levels.  Mean
concentration values derived from smaple sizes of less than 25  data points
were  disregarded.  When reviewing the available monitoring data,  it appeared
that  monitors situated at distances greater than 15 km  from the glass plant
were  considered  too far from the source to accurately measure emissions with-
out interference from other arsenic sources.  Furthermore, at distances
greater than 15  km from the source, plant impacts were often predicted  to be
significantly lower than minimum detection limits (Table D. 3).   These  data
were  not incorporated  in the analyses.  A third consideration in reviewing
ambient data concerned the percentage of monitored data which fell below
minimum detection  limits.  Although some  monitoring  sites  registered data
with  over 90 percent  of the values  above  minimum detection levels, many had
about half the  data points below  such levels.   Instances where more than 50
percent of the  data were below MDL  were disregarded.
      Although  fifteen glass manufacturing plants were included in the
analyses, review of National  Aerometic Data Bank data revealed that only four-
 sites had monitors located within a 15 km radium of the  source (Table D.I).
Three of these  listed only one  monitor  -  Glass Plant Numbers 1, 4 and 14.
Because concentration was expressed as  a  single weighted mean value for
 each monitoring location,  the result was  a single  data point.  This was
 insufficient information  on  which to run  a regression analysis.   The fourth
 location, Glass Plant Number 6, cited four monitors inside 15 km.  However,
 this plant could not be analyzed due to the fact that between 95  and 99  per-
 cent of the monitored concentrations were below analytical detection limits.
                                     D-13

-------
  flgur*  D-l  Craap 2 KC/EH lattraolatton
 Gives:
 A •» Uia a&fla Sa radians aubtaadtd elocfcvlat about tha aourea froa due south to  the
                                             •»*
     BC/ED eantroid;
 Al - the aaflo froa 4m ooutk to th* radial liaa taaodlataly eoontar-clockwis* of  A,
     ar fault* thraufli A if tfeara ia aa axaet Mtc&;
A2 • lha aagla froa tfoa aoutb to tha radial llaa faa«diataly eloekviaa of Al (42 ia 0
     if it ia *•* aontb);
m  »»• ilataaea in an froa taa aovrea to taa BC/CD caatraid;
«1 • &a iiataaea from taa aeorea to tka iart»st circular are of radiua iaa* than B;
»2 *iaa «iataaea fraa tha •oarea to tba ia^llaat cirealar are af *adf«a ftraatar than
     •r «faal ta B;           ._/'            - *
CI » Aa aatoral lagaritta «f tba caaeaatratioa valsa at Cal.BDs
 C2 • Tk« aataral logaritW »f taa caaeaatratioa valaa at C*l,B2)s
                                        •                       .
 C3 • Iaa aatural logarithm of tba eoeeaatratioa ^alna at (A2.B1);
                                                          S
                                      D-14

-------
€4 « The Mtitral logarithm of the coaeeatreftion valve at CA2,ft2) ;
                    •


then:                                      :           •    •  •- •



VISIT » to(R/tl)/lB(ft2/Ri);
               CC2-Ci)s%T!MP);
CZ » CAl •*• (CA2-CM)sAT»SP.


vhsrc CX is the interpolated cenceatratiee at the BC/EO centroid
                                       D-15

-------
 D. 3.1.4  The People Living Near A Source
      To estimate the number and distribution of people residing within 50
 kilometers of the glass manufacturing plant, the HEM  model  uses the 1980
 Master Area Reference File (MARF) from the U.S.  Bureau of Census.   This
 data base consists of enumeration district/block group (ED/BG)  values.
 MARF contains the population centroid coordinates (latitude and longitude)
 and the 1980 population of each ED/BG (approximately  300,000) in the United
 States (50 States plus the District of Columbia).   HEM Identifies the
 population around each plant,  by using the geographical  coordinates of the
 plant, and identifies, selects, and stores for later  use those  ED/BGs  with
 coordinates falling within 50  kilometers of plant center.
      For each of the 15 glass  plant locations,  a detailed check  was made to
 determine whether the exposed  population as predicted by the HEM  was located
 accurately.   Based on information obtained from  a U.S. Geological Survey
 map  of the area  around Glass Plant 15,  a revised maximum exposure con-
 centration was used.   Plants 1 and 8 were modeled using  site-specific
 terrain  and plant parameters (Section D.4. 2.1).   For  these plants,  exposure
 concentrations were taken  from the site-specific  model predictions.   These
 results  are summarized 1n  Table D.4.
 D. 3.1.5   Exposure5
     The Human Exposure Model  (HEM) uses the estimated ground level
 concentrations of a pollutant  together with population data to calculate
 public exposure.  For  each of  160  receptors located around a plant,  the
 concentration of  the pollutant and the number of people estimated by the
 HEM  to be exposed  to that  particular concentration are identified.  The
 HEM  multiplies these two numbers to produce exposure estimates and sums
 these products for each plant.
     A two-level   scheme has been adopted  in order to pair concentrations
 and  populations prior to the computation of exposure.   The two-level
 approach is used because the concentrations are defined on a radius-azimuth
(polar) grid pattern with non-uniform spacing.   At small  radii,  the  grid
cells are usually smaller than  ED/BG's; at large radii, the  grid cells  are
usually larger than ED/BG's.   The area surrounding the source is divided
into two regions, and each ED/BG 1s classified by the  region in  which its
                                    D-16

-------
centroid lies.   Population exposure is calculated differently for the ED/BG's
within each region.  For ED/BG centroids located between 0.2 km and 3.5  km
from the emission source, populations are divided between neighboring concen-
tration grid points.  There are 64 (4 x 16) polar grid points within this
range.  Each grid point has a polar sector defined by two concentric arcs and
two wind direction radials.  Each of these grid points and respective concen-
trations are assigned to the nearest ED/BG centroid identified from 1980 U.S.
Census Bureau data.  Each ED/BG can be paired with one or many concentration
points.  The population associated with the ED/BG centroid is then divided
among all concentration grid points assigned to it.  The land area within
each polar  sector  is considered in the apportionment.
     For population centroids between 3.5 km and 50 km from the source,  a
concentration grid  cell, the area approximating a rectangular shape bounded
by  four receptors,  is much larger than the area of a typical ED/BG.  Since
there  is an approximate linear relationship between the logarithm of concen-
tration and the  logarithm of distance for receptors more than 2 km from the
source, the entire population of the ED/BG is assumed to be exposed to the
concentration that is logarithmically interpolated radially and arithmetically
interpolated azimuthally from the four receptors bounding the grid cell.  Con-
centration  estimates for 96  (6 x 16) grid cell receptors at 5.0, 10.0, 20.0,
30.0,  40.0  and 50.0 km  from  the source along each of 16 wind directions are
used  as reference  points for this interpolation.
      In  summary, two approaches are used  to arrive at coincident concentration/
population  data  points.  For the 64 concentration points within  3.5 km of the
source, the pairing occurs at the polar grid points  using an apportionment of
ED/BG population by land area.  For the remaining portions of the  grid, pairing
occurs at  the ED/BG centroids themselves  through the use of  log-log and linear
interpolation.   (For a  more  detailed discussion of the model used  to  estimate
exposure,  see Reference 5.)
D. 3.2  Public Exposure  to  Inorganic Arsenic Emissions  from Glass Manufacturing
        Plants
D. 3.2.1  Source  Data
      Fifteen  glass manufacturing  plants  are  included in  the  analysis.
Table D.5  lists  the names  and addresses of the  plants  considered,  and Table
                                    D-17

-------
D.6 lists the plant data used as input to the Human Exposure Model  (HEM).
D. 3. 2.2  Exposure Data
     Table D.7 lists, on a pi ant-by-plant basis,  the total  number of people
encompassed by the exposure analysis and the total  exposure.   Total  exposure
is the sum of the products of number of people times the ambient air concen-
tration to which they are exposed, as calculated  by HEM.  Table  D.8  sums,
for the entire source category (15 plants), the numbers of  people exposed
to various ambient concentrations, as calculated  by HEM.
                                    D-18

-------
                                         Table 0.3
Plant
           Arsenic Concentrations Near Select
               Glass Manufacturing Plants

                                        ISCLT/
                              HEM       Valley      MAOB
# Obs. Distance1  Bearing  Predicted2 Predicted  Measured
MDL3  Percent!le4
Gl ass PI ant #6



Glass Plant #14
Glass Plant #1
Glass Plant #4

76
77
77
69
41
65
24
84
.5
.6
.6
.7
8.6
3.2
1.0
2.1
73.7
246.1
43.4
23.2
168.7
66.1
189.6
172.7
0.00154
0.00097
0.0017
0.0017
0.000115
0.0025 0.0035
0.013
0.0062
0.025
0.025
0.026
0.026
0.007
0.003
0.003
0.003
0.05
0.05
0.05 95< 3
0.05 95< 3
0.0055 5099*
>99*
t..<99*
I <99*
I <70*
I <95*
>99*
I <90*
* Indicates data point was disregarded; see Section 0.3.1.3.1
1 Distance from source to monitor (km)
2 Concentration predicted by Human Exposure Model (HEM) - see Section 0.3.1
3 Minimum Detection Limit
4 Percentile indicates percentage of data falling below minimum
  detectable levels
                                             0-19

-------



























.
*
a
S
/2
r—


























C
4.
c u
•2 2

"T— *T"
re a
u
0
— J •£
«= *£ CO
O — O
•r- J-
4-> CO 3
re o o
r— • C CO
3 re
CX4J E
O 10 O
0. -r- J-
^— * 1 •
— J IL.
«


t~l
O CD <
t- CO C
4-> f- C
c > o
o co o
s=. o cu
u
•i—
3= COCM
c xj •
O "r- CO 0
*•> i— VI C
CO -I- O
«/> XJ  > O
c co re co
O to CO C£
4-> CX
re x
y it i

C CO r- XJ
CO S- O CO CO
u re t_ r— to
C •«->«*- CX O
o co c o o a.
Or- O CO X
re o *tts a. ui
§ "O
j^ ,^
•i— > CO
£ S £ 01 «
«er* c* ,U1, IA
•Cii «•• !••• f^ l/f
*-* CO «*- CX O
"O CO O O D.
co re co x
•M co ^ a. ui
l]*^
tn
CO
ex.
"0^-4
S- •
•M U
c c
0 0
o o

^


Ci-l
•t— •
r— U
CO C
CO O
re o
CO







e\
sf
0
CO

* * * *
Ul Z Ul Z Ul
co co
Ul Ul






* * * * in
CM CM in in CM
o o o o o








1


1
o
I-H
X
CO




CO —1 -4




i-4 CO VO ^- CTi
CO —1 -H



•K -Jc 4c ^c CM
•i" co co co i
1 1 1 1 O
O O O O i-l
i-l rH >-4 i-l
x x x x x
VO
CO p~ VO «3- CM
»* VO CM CO i-H



•1
* * * * ^H
^* co co cO i
1 1 1 t O
O O O O 1-4
x x x x x
CO P** VO ^" Cf»
«4- VO CM CO i-H








in vo ** co co
1— 1 f— 1



UIUIUIUIUIUIZLUZU1
CO Z Z CO Z Z
Ul Ul Ul






****** •}:*
ininooeMCMomcMCM
OO»-»«-IOO-HOOO




CM
1
o
i-H
, x
1
1 C7^
co
CM
O 1
•-4 0
X ""*
<*>
00 CM
i-4 CM




3C2S~*£2CSIOP''>00
como ooincMcrip^.
P«« i-4 -— 1 f~. po
A
i-H



COCOCOO-4COOOCMOO
co in o co in CM P-



* *
ICO^COCOCO ICMCO 1
i-HOOOOOi-HOOi-H
rHi-4i-4^Hi-4 ^ ^H
xxxxxxxxx
•— » o^ in
VOVOi-HCMincrtCMOfHCO
^H«i-VOCOin«3-i-Hr-4CMi-H



* *
>******CMCM*
ICM^-COCOCO 1 ICMCM
O 1 1 1 | | o O 1 1
i-4OOOOO,_4i-lOO
^xxxxx _xx
vocM-i-icoincnp^oo'*
•-ia>vovoin«3-i-H.-i T-
w ••-
c: o
O CO
•i- CX
(13 1
O CO
O -P
• *""
e
0 2?
•r- jQ
fw V
•35
CX 0
O •!-
CXXI
O)

at ex
4J
U (/>
•r* C
•a o
I- +J
as
3: co
u
0 0
u
o c
to o •
'£ TS •
re co CM
CX CO •
es re •%!
u a CM
00 1
t- c o
o -o o
re '-M


co c co re
CS « CO 4-
C/J •— 3
**^ Q™ C^
• 0
t-. o co re
0 4-> •«->
» « S"?
x co re co
• CO C i— i.
i — -r- O CX CO
••- -O
X» CO  O -r-
O t- T- 2 to
E > +•> c
C CO O
1- O Q£ CO O
co co
4-> X> O CO
3 CO • JC J-
ex to  4-> re
E re co
O -i- O 4->
in  t-
>> re +J o
JQ i— c 3 s:
a. co -o ui
xj -oca:
CO O ••— O 1
+->•»-> CO O 1
re co x>
O C i.  CO
•r- O CO O)
XJ -i- i — 10 c
c  re >, re
*~ "> *J *« 0
CO CO O C C

-------
                 TABLE D.5



IDENTIFICATION OF GLASS MANUFACTURING  PLANTS
Plant Number Code
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
1
Plant Name and Address
Owens-Ill 1nois
Shreveport, LA
Owens-Illinois
Mt. Pleasant, PA
Owens-Illinois
Pittston, PA
Owens-Illinois
Toledo, OH
£CA
Circleville, OH
GTE
Versailles, KY
Fostoria
Mouridsville, WV
Corni ng
Marti nsburg, WV
Corning
Charleroi, PA
Corning (Fall Brook)
Corning, NY
Corning (Main Plant)
Corning, NY
Corning
State College, PA
North American Phillips
Danville, KY
GTE Sylvania
Central Falls, RI
Indiana Glass
Dunkirk, IN .
                    D-21

-------
 O  4->
T-  c
 to  t-
                  cu
                  DU
           LU
 o  o
  P
CO  CO t/»
O
IB
Jit J*
 O  O
   -P -P
CO  CO CO
                                                                                                                                        o
                                                                                                                                        Q.










c:
*r™
1
O
>
O CD -P O
CO 4-> T- O CO
CO C X O --.
»i— "r- LU r— P-
SO CU
LU a. >

* r- — >
C (BCM
O C E
i- -P CO O —
CO C CO -r-
CO -r- O -P IB
f- O t- O CU
E CX. O CU X-
LU CO «C
C J_
o cu — •
•r* -P -P CO
CO C CU S-
CO 'r- £ CU
T- O IB -P
* 1 1 f^\ j^
^--

C
c= o «-»
O -P T- W»
i- C -P t_
«/» f- «B CU
to o > +J
•r- Q. CU CU




invo cn CM o vo co cot->.>-i
cjco cn r— ^- vo oo 4*envo
in ^t- vo «a- «* vo 5- vo vo ^





ocn oo in in «a- CM ovo^-
^"O^ ^" OO ^ CO ^- COCOP-.
**"" f~* CM r— «— 1



gg g g g g g ggg



S£ g g S 3 g ESS
* * * * • • • •••
i— O *H O f— CM f— O O — 1


*4


OO C3 O O O O OOO
CMO VO O r-^ f-I VO CnOOi-4
CM ^ ^ «* «* * 3h CO




r^ in t»» CM
t-» in i^ CM
^J" ^^ ^^ ^O





cn o CM to
CM «3- in CM
CM r— i— •-(



0 00 0
in in in in



o o en CM
CM t— VO 10
• • • •
•— r- O fH





O O O O
• • • •
vo r-» r^ cn
CM CM CM CM




vo
co





vo
CO




o
in
"


<— i
vo
•
O





o
co
f— 1




C3 *5t" cn
co »* vo
in in in





CM CM <-4
CM CM CM
^H --I CM



OOO
in in in
"^


o o in
OOO
• • •





OOO
ro co cn
in in CM
w
o
•r—
CO
Vt
•i—
CU
•P
«•-
o

IB
£
IB
IB
c
•r—
O
CU
CO
CO
CO
e
fH*
IB
O
1_
CU

•
fit ^
VW *lto
•P IB
2
.^ =
•r-
—>


c
o
•1—
CO
CO
iS


cu s-
** >>
IB "^
oc cn
^


vo cn o
r~ in in
CM r>.



in
o
cn



o
o
cn
t-4




cS
CM
CO


•*
co
CM



0
oo
rv.
r—l


O OO
cn CM
CM r*.
vo
<— i


0
•
o
CM
i— i



0 r-
in co
cn cn

                                                                                                               in
                                                                                                                      ooo
                                                                                              o    oo    r*. in  ao
                                                                                              o    co    «t cn  in
                                                                                              «*           r*. r^  co
«*s
o
cu
1^






1 Longitude
1 Latitude
i i





CO
cu
cu
cn
cu
o
to
t_
cn
s





1 Mi nutes
CO
cu
•P
c





Seconds)
i Seconds)!
1
CU
o
IB


0825718
1-1
1-1
co
cn
co





0844504
VO
CM
O
CO
CO





0712320
VD
«d-
CO
m





0844948
CM
in
r^
co





0780103
CM
co
CM
CO





0774728
VO
O
O
in
o





0795403
in

                                                                                                                                      IB
                                                                      in     CM    vo
                                                                      O     —t    O
                                                                      !-••     in    oo
                                                                      •HI     in    CM
                                                                      r-c     cn    CM
                                                                      «*     co    co
        •P

         IB

        a.
                               t— CM
                               in
                                                                             CM CO
                                                                                                 CM
                                                                                                                        CM CO
                                         VO
                                                      CO
                                                             00
                                                                          CTi
                                                                                                        CO
                                                                                                              r-.     t-i
                                                                                                                                     f— O
                                                                                                                                     c— CU
                                                                                                                                      IB J-
                                                                                                                                         •r"
                                                                                                                                      i. -O
                                                                                                                                      O
                                                                                                                                     «*- TJ

                                                                                                                                     CM  ••-
                                                                                                                                      E 3B

                                                                                                                                     o «=
                                                                                                                                     in 
-------



cu
•o
o
o
en
c
•1—
i_
5

U C
•o o
o o
S c
i. ••-
en cv
O CO
a. 
!e>

•.- c o
«/>••— o.
*" P 4^»
•i— OL f—
5
CO
c= ia
o en •
co +J E a*
CO C 9) o
E o
uj a.
CO
C >
O 13 •»-> O
•i- 4-> T- 
LU a. =»
* »— ^~
C flSCM
0 C E
.,- 4-> CO O —
CO C CO •!-
CO T- O 4-» <8
E a. o  +J CO
co c a> s-
co •!* E O
•i- O 
J^5 §
c
c o —•
O +•> t- CO
co T- fa a>
•r- a. a> a>
e r- s:
us ui *-*
c
o — .
CO 4-» >,
CO (O • —
•i- Q£ O>
E ^
UJ —
 C
•r- S- =3 O
O> O> C O
c 
o a s to
_j ^-
d; co co co
•o a» a» ~o
3  C
4-> S_ =3 O
•i- 01 C 0
•«-> 0) T- inioir>vo

COI^COP~«*'-4lf>P-.CO
csjcMi-H«d-cviir>
•-< <-l CM
ooooooooo
mmininininminin

ooooooooo
tnir><4-aocooooocMCM

ooooooooo
^-Ir-l^- lOOOOO<-«'^

( — f*»P««^-tOr-ltOP»-P*-
OOOOOOr^CrtCOOOOOO
OICTiCTiOOl — ^f»~fMCftCT>
,-1 ^-i ,— i CM CM i— 1 •— 1
CM
O
^H
CO
CO
OO
o
t— (
1— 1
o
<*
— 1
«*
•-ieMco^-ir>ior^.oocr>
«*
^Jl£^£^^^^£^^
OOOOOOOOO
fljj t/)tOt/>OOun


C7) CTk O> O^ C7) CTt C7) O> CT)
OOOOOOOOO
OOOOOOOOO
CMCMCMCMCMCMCMCMCM
^ooaioa^ooo
o«d-oaO'*co«d-«*^-

i—  O
r-  
-------










O)
•f"
3
4*}
u
1—
3
C
CO
SE
t/j
(d
3
r- •
0) .-.
•o to
Or-
CO 4->
t- {=
3 O
*A / ^
MO
M. « __
xfe
UJ CO
o cn
fl3 fe*
4-> 3
to to
C J vi
4-> "I— ^
3
C
>— l

JQ
0
S










0 •«->
f- C CO
in .— pi
UJ
in
C A3
0 CO •
tn B co o
•t— »f— ^— *•-*
E 0
UJ O.
in
c to >,
O CD 4-> O
f- 4-> f- CO
10 C X O — .
^- -t- UJ r— £
S O CO
UJ Q- >•

* r- •"—
C  tO O —
t/) f* I/) *r~
v) *f* O 4-* CO
•r- O S» O CO
E O. O CO i-
UJ CO «C
	 __ 	
C i-
O CO — •
•r- 4-» 4-> IO
to C QJ t.
c/t i** E co
•t— o to 4^
E Cx. T— CO
uj Q z:


c= o *—
O 4-> i- «/)
w> «r- re co
tO O > 4->
•r* CU CO CO
E r— E
UJ UJ -^

c
o *—
*f— (D (_
^1^ ^
•r- a: en
UJ «—


CO ^-»
3 CO CO T3
4^> CO 4-> C
•r- L. 3 O
cn cn c o
C CO ••- CO
O O S CO
I ^ 	 -~
co to to to
•o co co -o
3 CO 4-> C=
4J fc. 3 O
f- cn c: o
4-> CO -r; CO
to a E co
"co
o
03
c
3
xj It
c «^
(O
Q-


u
to
CO

5





•^j
t-H
CM







o
in





CM
-1




o
in
CO




o
0
vo
co



0934753
vo
0
CO
CM
CM
co







~*

to
co
CO
in
vo




o

CM







o
in





vo
0




o
CO




o
§



0793201
f--.
CO








CM
.1C
u
<0
CO
CM
CM
in





vo
CM







0
in





CM
in
t-H




o
co
CM




o
o
o



0754619
in
o
t-4







CO

u u

-------


>nduded)
o
o>
•^
+J

CL tO
X CO
C3>
0 C
4-> •!-
 W)
0 <
*>'"'
CL
I-H
«3
•
O


"i
UJ
Emission*
C
o
•^

•7-
ut
o
«/»

•f
o>
o
_l
Latitude
+•»

C
tt.
«/»

C
•r-
O
O-
tn
(O
ID
+J
C
•f—
o
Q-
4-»
C
•*-
O
o.
+J
C
o
Q.
4J
*f«.
O
o.

4->
It)
0£



V
ta-
ll'
•
t

O>
UJ


(Degrees
Mi nutes
(Degrees
Minutes



Q
o
'o
C/)
^f
5
«3


o>
s:

^
o>
^
Seconds)
1
Seconds )
(Furnace)
^
o

^"
0
U3
>*
•*
CO

o
CM
CO
CM
ff—
e^
0
3
in
5
«*
t— i
.*£
u
 W
§8
CM CM
CM CM
O O
•* «*
0 0
O O
in in
^ t-4
0 O
in in
•* «*


CO CT>
in
CM
 i
o

-------
       TABLE D.7  TOTAL EXPOSURE AND NUMBER OF PEOPLE EXPOSED
                         (GLASS MANUFACTURING PLANTS)*
  Plant
     Total
   Number of
People Exposed
      Total
     Exposure
(People - M9/m3)
5
6
14
13
8
12
9
10
11
3
7
1
2
4
15
835,000
434,000
2,530,000
428,000
346,000
257,000
2,080,000
270,000
268,000
697,000
372,000
369,000
1,450,000
834,000
408,000
5
10
148
7
1620
1
1830
17
82
87
21
690
163
1070
627
A 50-kilometer radius was used for the analysis of glass manufacturing
plants.
                              D-26

-------
                                       TABLE D.8

                      PUBLIC  EXPOSURE FOR GLASS MANUFACTURING PLANTS
                         •AS  PRODUCED BY THE HUMAN EXPOSURE MODEL
            Concentration
            Level  (M9/nr)
Population
Exposed
(Persons)*
     Exposure
(Persons - ug/m3)**
                0.216
                0.1
                0.05
                0.025
                0.01
                0.005
                0.0025
                0.001
                0.0005
                0.00025
                0.0001
                0.00005
                0.000025
                0.00001
                0.000005
                0.0000025
                0.000001
                0.000000593
       0
     486
    4740
   20800
   79800
  189000
  523000
 1210000
 2380000
 3900000
 5100000
 6770000
 7570000
 9580000
10800000
11400000
11500000
11600000
         0
        64
       346
       907
      1830
      2580
      3740
      4820
      5610
      6180
      6370
      6500
      6530
      6560
      6570
      6570
      6570
      6570
 *Column 2 displays the computed value,  rounded to  the  nearest whole number, of the
  cumulative number of people exposed to the matching and higher concentration levels
  found in column 1.  For example,  0.5 people would be  rounded to  0 and 0.51 people
  would be rounded to 1.                                                           ,

**Column 3 displays the computed value of the cumulative exposure  to the matching
  and higher concentation levels found in column 1.
                                           D-27

-------
 D.4   QUANTITATIVE  EXPRESSIONS OF PUBLIC CANCER RISKS FROM INORGANIC ARSENIC
                   EMITTED FROM GLASS MANUFACTURING PLANTS
 D.4.1  Methodology (General)
 D.4. 1.1  The Two Basic Types of Risk
     Two basic types of risk are dealt with in the analysis.  "Aggregate
 risk" applies to all of the people encompassed by the particular analysis.
 Aggregate risk can be related to a single source, to all of the sources in
 a source category,  or to all of the source categories analyzed.  Aggregate
 risk is expressed  as incidences of cancer among all of the people included
 in the analysis, after 70 years of exposure.  For statistical convenience,
 it is often divided by 70 and expressed as cancer incidences per year.
 "Individual risk"  applies to the person or persons estimated to live in the
 area of the highest ambient air concentrations and it applies to the single
 source associated  with this estimate as estimated by the dispersion model.
 Individual risk is  expressed as "maximum lifetime risk" and reflects the
 probability of getting cancer if one were continuously exposed to the esti-
 mated maximum ambient air concentration for 70 years.
 D.4.1 .2  The Calculation of Aggregate Risk
     Aggregate risk is calculated by multiplying the total  exposure produced
 by HEM (for a single source, a category of sources, or all  categories of
 sources) by the unit risk estimate.  The product is cancer incidences among
 the included population after 70 years of exposure.  The total  exposure, as
 calculated by HEM,  is illustrated by the following equation:
                                       N
                     Total Exposure =  I
where
      I - summation over all grid points where exposure is calculated
     Pf - population associated with grid point i,
     C-j = long-term average inorganic arsenic concentration at grid point i,
     N  * number of grid points to 2.8 kilometers and number of ED/BG
          centroids between 2.8 and 50 kilometers of each source.
                                    D-28

-------
To more clearly represent the concept of calculating  aggregate risk, a
simplified example illustrating the concept follows:
                                  EXAMPLE
     This example uses assumptions rather than  actual  data  and uses only
three levels of exposure rather than the large  number produced by HEM.  The
assumed unit risk estimate is 3 x 10~3 at 1 M9/m3 and the assumed exposures
are:
            ambient air                    :  number of people exposed
          concentrations                      to given concentration
          2    Mg/ro3                                   1,000
          1    (jg/m3                                  10,000
          0.5  M9/m3                                 100,000
The probability of getting cancer if continuously exposed to the assumed
concentrations for 70 years is given by:
   concentration
   unit risk
                                                       probability of cancer
                                                           6 x 10-3
                                                           3 x 10-3
                                                         1.5 x 10-3
    2   ug/m3         x      3  x  TO'3!
    1   M9/m3         x      3  x  10~3
    0.5 ug/m3         x      3  x  10~3
The 70 year cancer incidence among  the  people exposed to these concentrations
is given by:
                                                           cancer incidences
                                   number of people at        after 70 years
                                   each exposure  level
                                           1,000
                                          10,000
                                         100,000
     probability of cancer
     at  each exposure level
        6   x 10-3
        3   x 10-3
        1.5 x 10-3
                                   of exposure
x
x
x
                                                                    6
                                                                   30
                                                                  150
                                                          TOTAL =  186
The aggregate risk, or total  cancer incidence,  is  186 and, expressed as
cancer incidence per year,  is 1864- 70,  or  2.7  cancers  per year.  The total
cancer incidence and cancers  per year apply to  the total of 111,000 people
assumed to be exposed to the  given concentrations.
                                    D-29

-------
 D.4.1.3  The  Calculation of  Individual Risk
      Individual  risk, expressed as "maximum lifetime risk," is calculated by
 multiplying the  highest concentration to which the public is exposed, as
 reported  by HEM,  by  the unit risk estimate.  The product, a probability of
 getting cancer,  applies to the number of people which HEM reports as being
 exposed to  the highest listed concentration.  The concept involved is a
 simple  proportioning from the 1 |jg/m3 on which the unit risk estimate is
 based to  the  highest listed  concentration.  In other words:
        maximum lifetime risk          the unit risk estimate
     highest  concentration to   =           l jjg/m3
     which  people are exposed
 D.4.2   Risks  Calculated for  Emissions of Inorganic Arsenic from Glass
        Manufacturing Plants
     The  explained methodologies for calculating maximum lifetime risk and
 cancer  incidences were applied to each glass manufacturing plant assuming
 a baseline  level of  emissions.  A baseline level of emissions means the
 level of  emissions after the  application of controls either currently in
 place or  required to be in place to comply with current state or Federal
 regulations but before application of controls that would be required by a
 NESHAP.
     Table D.9 summarizes the calculated risks.  To understand the relevance
 of these  numbers, one should  refer to the analytical  uncertainties discussed
 in section D.5 below.
 D.4.2.1   Site-Specific Analysis
     In its original risk assessment, EPA did not consider terrain effects
 or the full effect of building downwash on stack emissions from glass manu-
 facturing plants.  These plants oftentimes have short stacks whose effluents
can be entrained in the building wake on the leeward side of the furnace
buildings or other adjacent structures.   As a consequence, it was regarded
as likely that airborne arsenic concentrations to which persons might be
exposed near or adjacent to these plants could be underestimated.   In addi-
tion, it was felt that the extent of building downwash could be expected to
be different depending on the degree of control  applied.   If so,  the  relative
                                    D-30

-------
 reduction in risk  achieved  by  any particular control option might differ
 from that estimated  previously.
      For these reasons,  additional  dispersion analyses were carried out to
 examine these concerns further.  These  analyses were done for two glass
 plant locations, Martinsburg,  Virginia  and Shreveport, Louisiana.  For the
 Shreveport analysis, the Industrial  Source Complex  Long Term (ISCLT) model
 was used in conjunction  with a joint frequency distribution of wind speed,
 stability class, and wind direction derived from  surface weather observa-
 tions at Greater Shreveport Municipal Airport.  In  order to better assess
.the impact of building downwash  on  the  rise of the  hot furnace gases, a
 modified plume rise  treatment  similar to that in  the Buoyant Line and Point
 Source (BLP) model was used in addition to the standard ISCLT plume rise
 treatment.  Both  the building  downwash  and standard ISCLT analyses included
 an enhancement to  the dispersion of the plume as  appropriate, an enhance-
 ment which is a part of  the ISCLT model. The two sets of analyses were
 intended to bracket the  expected effects of building downwash on airborne
 inorganic arsenic  concentrations.
      Results obtained from HEM and the  two  site-specific analyses  for
 Shreveport can be  seen in Tables D.10 - D.12.   Table D.10 outlines arsenic
 concentrations estimated by the Human Exposure Model  (HEM)  to occur at  16
 wind directions and eight distances downwind  from the  Shreveport  plant
 center.  Table D.ll shows corresponding values  based on  the standard  ISCLT
 model  run in conjunction with a joint frequency distribution of wind  speed,
 stability class and wind direction.  Table D.12 shows  values based on  the
 ISCLT  model used  in conjunction with modified plume rise  treatment.   Agree-
 ment between the  HEM and ISCLT estimates is fairly good with  differences
 rarely exceeding  a  factor of  1 or 2.  The HEM tends to underpredict slightly
 in  regions  of higher and lower concentration.
      For the Martinsburg analysis, the  same approach was taken, except that
 the effects of terrain were also considered.   Martinsburg is located on a
 broad  plateau at  the foot of  a long ridge.  ISCLT was used to estimate air-
 borne  inorganic arsenic concentrations  at any receptor located at or below
                                     D-31

-------
the top of the furnace stack.  However,  for receptors  above  the  top of the
furnace stack, the Valley model was used.   The Valley  model  allows the plume
to intersect terrain features under stable conditions, resulting in high
concentrations.  For receptors well above  the plume center!ine,  the impact
of the plume is gradually reduced.   Both models were used in conjunction
with a joint frequency distribution of wind speed,  stability class, and wind
direction derived from surface weather observations at Martinsburg Airport.
The modified plume rise treatment described for Shreveport was also included
as part of the Martinsburg analysis in addition to  the standard treatment of
plume rise in ISCLT and Valley.  This again resulted in two  sets of disper-
sion analyses, which, as before, were intended to bracket the expected
effects of building downwash.
     Results obtained from HEM and the two site-specific analyses for
Martinsburg can be seen in Tables D.13 - D.15.  Table D.13 outlines arsenic
concentrations estimated by the HEM to occur at 128 points (see above)
around the Martinburg plant.  Table D.14 shows corresponding values based
on the standard ISCLT and Valley models run in conjunction with a joint
frequency distribution of wind speed, stability class, and wind direction.
Table D.15 shows values based on the ISCLT/Valley models with modified
plume rise treatment.  Agreement between the HEM and  ISCLT runs is fairly
good with differences rarely exceeding a factor of 2.  The HEM tends  to
overpredict slightly at regions of higher concentration with more varied
results at regions of lower concentration.
                                    D-32

-------
                   TABLE D.9  MAXIMUM LIFETIME RISK AND CANCER
                     INCIDENCE FOR GLASS MANUFACTURING PLANTS
       Plant
Maximum Lifetime Risk

Baseline       Control
Cancer Incidences Per Year

    Baseline   Control

Owens-Illinois
Shreveport, LA
Owens-Illinois
Mt. Pleasant, PA
Owens-Illinois
Pittston, PA
Owens-Illinois
Toledo, OH
RCA
Circleville, OH
GTE
Versailles, KY
Fostori a
Moundsville, WV
Corning
Marti nsberg, WV
Corning
Charleroi, PA
Fall
Corning - Brook
Cornint, NY
Corning - Main
Corning, NY
Corning
State College, PA
N. Amer. Philips
Danville, KY
GTE Sylvania
Central Falls, RI
Indiana Glass
Dunkirk, IN
7
8
4
2
3
1.8
3
2
8
1.6
4
3
3
7
1.4
1.1
9
x 10-5
x 10-5*
x 10-5
x 10-5
x 10-^
x 10-6
x 10-5
x 10-5
x 10-4
x 10-3*
x 10-4
x 10-6
x 10-5
x 10-7
x 10-5
x 10-5
x 10-4
6 x 10-6
4 x 10-5
2 x 10-5
9 x 10-6
1.8 x 10-6
3 x 10-5
2 x 10-5
5 x 10-5
2 x 10-5
3 x 10-6
1.4 x 10-5
7 x 10-7
1.4 x 10-5
1.1 x 10-5
1.7 x 10-4
0.035
0.042*
0.010
0.0053
0.066
0.0003
0.0006
0.0013
0.12
0.099*
0.11
0.0006
0.0050
0.0001
0.0011
0.0091
0.038
0.0037
0.010
0.0053 .
0.0066
0.0003
0.0006
0.0013
0.013
0.012
0.0006
0.0016
0.0001
0.0011
0.0091
0.0085
*  Represents risk estimates calculated  from site-specific  analyses  using
   ISCLT model.
                                    D-33

-------
C3
.O
17E-Q
i/i
n


Ul
c
o
*•»
«j
i
o
o
u.
Xt
Ul
V>J
re-
i
r.
0
Ul
Ul
id
IT
Ul
Ul
C
Cf
U.'


in
ro
o
ro
Ul
l
c
o
Xt


to
o
*+
c,
CO
I
C."
o

>J\
m


Xt
,_,
Xt
LU
*•
1
(_>
•_>
Ul
vn
03
vn
Ul
1
cs
Ul
~
ro
o-
o»
vn
1
c.
o
Ul


-J
o
•J
U
i
o
o



to
Jj
c.
•0
o

o
m
m


ro
•o
o-
JCt
^»
1
Vw
U
UJ
*
UI
o
OC
1

u-
Ul
o
ro
ro
vn
c
o



•J
«o
-J
Ul
1
c
a
x-


Ul
J*
u.
ro
Ul
i
0
Ci

m


UJ
Xt
-o
0
tr
1
0
O
u
Xr
vn

o-
1
Vr.
0
UJ
Ul
o
n
z
m


UJ
^j
M
^
«fi
i
0
o
Ul
Xf
o
•o
»-»
1
Vr.
Ul
u
o

m


Xt
Ul

*»J
•»
1
u<
t_>
UJ
vn
Ul
H*
O
1

UJ
JS
O
z
rn


Xt
O
0-
JB
o.
1
l^
0
Ul
vn
00 i
t—
X:
1
b
UJ
ft
CO
z
z z


i-* vn
i* Id
C vn
*\) f
rv «-
1 i
O */
1
UJ
0
Ul
•o
ro
o
X:
1

UJ
-O
ro
«j
-o
"i4
c.
c o u o
ui ro ui




«j -o ro f*
co
•o
CO
1
Xt
•J O-
vn ui i"»
vn ro ro



UJ


NO e-


CD
0» 0 Ut *

Xr
•
^i U
h- Ul
Xt Ul
1 1
o 6 o
O c U
»• • . ««
oo
o
Ul
1
o
o
-ff
C
c


Xt
Ul
Ul
'-4
er
1
C
Q
UJ
O
^
ro
a:
1
fe-.
0
UJ
o-
ro
Ul
o?
ro
C
o
UJ


M
Ul
Ul
CD
ro
i
o
o
Ul


Ul
UJ
Cf
o-
**
1
o
o
•*.
•V.
M
|d
ro
Cf
i
o
o
JBt
^,
UJ
CO
ro
Ul
i
o
o
Ul
Ul
UJ
ro
1
o
o
Ul
••••••i
**
Ul

•o

{y
Ss
•0
•o
4*
4*
Ul
|
O
a
Ul
.g
£.
0s
00
•o
0
0
Ul
•••
tj
o-
•o
1
o
2
ro
o

Ui
ro
i
o
o
Xt
M
00
ro
e
i
o
o
Xf
(M
t«J
Xt
oo
1
ro
u
•j
Eh UJ
O UI
h* 0-
•*
«j
o
OO 00 0 >*
i
1 1
1
w GJ o a o
2
£
2 2
id id H» >• >* ui ro

Q«
o»

1
o
o

CO
Xf
ro
00 " '
?
o
o
Ul
UJ
•o
Ul
Oo
1
o
o
Xt
«o

j»
-j
ro
1
o
o
Ul
ro
e

t*
•
o
o

00
-J
Ul
K
1
€
Ul
2
UJ
»d UJ «O UJ I-
Ul
M
Ul
1
O
o
*
00
Ul
ro
o
l
o
o
Ul
••J
•O Ul
!«• O OB
UI
1
o
o
4»
0
•0
o
00
Ul
1
a
o
Ul
-j to
1 1
o o
o o

ro »•»
03 -J
0- O
-J *
-J ao
1 1
0 0
o o
«*
Ul
•4
1
O
a
*
ro
ro
•0
00
ro
l
o
9
UJ
o
ro
0
i
0
0
Xt
ro
o
0
UJ
o
1
o
o
*
M
X-
Xt
60
€
XT
•E:



Xt
c
•c
lid
o
1
o
o
Ul
*
o
-J
c
1
cr
O
UJ
vn
M
to

o
1
o
e
Ul


o
oo
H*
oo
|
C
o
Xr


Ul
oo
C
OD
OD
I
O
o
1*.

ro
td
Ul
5
i
0
o
Xt
~
Xr
O
00
Ui
1
o
0
£
~
0
^*
a-
i
*
c
c


to
x:
0
«*J
Co
i
w
Vj
UJ
UJ
t>
o>
OC
1
H
Ul
ro
•o
^
|d
Xt
1
C
o
Ul


Ul
ro
X!
00
Ul
1
0
o
Xt


ro
o
0*
Ul
1
c
a
-»•

**
»*
ro
Ul
i
&
2
^
*
M
O
ro
i
o
o
Ul
Ul
UJ
Ul
o
1
o
o
Ul

c:


ro
Ul

Co

-J
U-'
1
O
Ul
»•
OD
x-
0
0-
1
o
o
U!


**
ro
vn
Ul
ro
l
o
o
UJ


*
00
X
c
Xt
1
o
0

ro
«j
(d
00
1
0
0
Xf
M

0>
o-
Ul
1
o
o
*
*-
ro
CD
1
o
e
*
o
rn ^3
o «-*
1- C"
o
z



•
v<-
CJ
^/




.
t.
*,
^



rv>
• o
o o
c. r
o z
c
1— <

0
o

C. I/*
C- J»
o z
o n
m



Jt
ro
c
b
o
o


UJ
o
o
a
a


«
o
•
o
o
o



Ul
o
o
o
o
























• — -oo «c rn
m -s o ri-
3 ro ->•->•
•—< 3 3
,-,-ffi ;iS.
OT3 c-h r+
fa O << TO
— ' -S Q.
0 rt- O
5i" "** ^
fl> r— 3= (f>
c+ 3=> ro — l
— '•*• CD 3 QJ
0 —a _J. CT
3 oa CD n — >
(/} (/) C™"5
fD o a
Q- IS 3 .
Cu O I—1
o 3 ro o
3 C 3
-b c*-
3: cu -s
3 t-f c-t-
O> C. -J.
3 -5 O
— »• 3
m 3 to
X IQ
•a ->•
O ID 3
tn — i
C OK c+
-$ 3 3-
fD c+ ro

0 3*
rt
ro



















-------
 O)
.o
 10
              (O
           C -r-
       ^1  C  3 i—
       4->   T3 O)
          •—  C 13
        C D- >-< O

           cn-o
        «/>  C  S-'—-
        E: -r-         CU
 S=  S T3 r-
 O      Q)
CJ>    t/) CD
    «/)  "0 £=
 o  n) co o
        CU      E O
       T3     i_  O -r-
        CU  >> O O 4->
       +J ^J Q.    (O
        to •!- CU  CU i—
        E  E >  O 3
       •i- •!- CO  S_ O
       4-»  O S-  3r—
        OO *r— J^  O *O
       UJ 5> 1/1 OO O
                                  o
                                  c
                                  o
                                   •
                                  a
                                  to
                                  o
                                  o
                                  o
                                   •
                                  a
                                  CM
                                         O
                                         O
                                         o
                                   D
                                  C-
                                  -3

                                  CM
                                  o
Q
1
ar
•O
to
ar
*-»
a»
O
O
1
co
to
o
. 9
ar
o
o
1
CM
CO
in
CO
CM
ar
O
a
i
o
m
ar
o
in
<0
O
f
o»
co
o
CM
-*
to
°D
^5
1
fO
Ul
CM
•H
Ul
to
O
O
1
,\4
7)
-M
fi
a-,

""•
CM
ar
O
.0
sr
ro
0
tn
in
ro
r>
^
i
•o
CM
O
lf>
AJ
ro
O
T
1
-a
CO
in
eo
CM

Ul
O
O
i
-a
CO
CM
CM
Ul
m
o
o
o
a
in
•o
a
ar
o
0
1
in
CM
af
O
-
&
0
o
1
ar
O
ar
CO
r-i
ar
ra
o
r>
r»
•o
•o
ar
ro
••^
O
1
!*%
CM
o*
-*
N
fO
o
-^
1
r-
ar
CM
f"
ru
ro
?3
T3
1
*-*
ffl
0*
ar

3
U".

in
O
•3
1
0
^M
°
•°
0
O
t
o
CM
9
CO
ar
o
o
t

fO
o
CM
^
ar
O
O
i
to
0
CM
1-1
CM
ar
O
' '?
CM
CM
O
ro
in

1
. S4
ar
•"^)
0
*•
•o
o
o
i
o
o
ro
a-
ar
x>
0
3
t
X>
"5
-O
^

2
D-35
O
•-•3 •
1

'^}
•*>,
*- .
O
o
1
to
CM
&
O
o
1
CO
at
O
«-*
".
ar'
O
O
1
I"":
U^
3»
in
tn
JO
O
O. '
PI
in
r»
fO;
"
fO
b1
o
i
o*
ar
in
CO
•ar:
ro
&
O'
1
5T
O
ar
«-«
Ul
ro
O
O
g
P*
r-
*H'
•=•
3

Z3
O
0
1
ar
m
in
CM
ar
O
O
1
CM
ar
CM
ar
a?
0
O
1
o
VI •
=r
o
in
ar
O
O
1
•o
CO

CO
CO
to
n
Q
0
CM
•o
•-«
CM
fO
o
o
1
tM^
cr
00
.en
•°
ro
^1
o
1
'O
in
or
to .
-"
fO
O
•3
1 .
sr
•O
f,
ar
-3
Z

' 0
i

0
0
-*
ar
O
O
1
CM
CM
O
Ul
CM
ar
O
O
1
e«
i>^
G*
P-
to
ar
O
O
1
«_i
^3
fO
r-
«o
tn
>^
o
i
ro
«>»f
O
f*
*••
^
T1
O
1
*o
en
to
ItA
•O
.0
,7^
•^
1
j^
O
ro

i
CM
O
co
ar

—a

. ar
O
i
rH
-O
(O
*•«
^
•ar
O
O
1
1
CM
in

o
0
1
ou
0
-o
CM
CM
ar
O
O
1
to
p*»
CM
o
ar
JO

1
o-
CM
ar
"S
-
.•o
TT*
"^
1
<^
CO
^.^
.1
Ul
ro
•rj

i
^
r»
•o
in
-o
-o
o

1
CM
O

*

jj.
-z.
P
J

o
-"M

0
ar
O
0
m
0
CO
«M
ar
O
O
1
co
o
co
co
•*
^
o
o
1
SO
o
CM
to
to
ar
o
o
o
CM
«-4
<0
00
^
'"
rs
t
o*
ro
iO
!fl
rO
••o
~^\
—i
1

'/)
^
ar
ar
iO
^
•3
1
=r
O
0
CM
LJ
£1

•=r
r^
^

^
•c,
»-i
ar
O
-O
ar
to

O
0

f«.
in
•o

**

o
o
1
•o

CM
ar
to
ar

d>
y
f3
O
to
CO
*o

"5
1
P^
.->
r»-

.0
ro
O

1
"3
ro
•j.
ca
ro
iO
rj
-j
i

r-
0
-
Ul

U)
a-
1
0
co
fO
•-4
-
O
o
CM
ii
in
ar •
O
o
1
f-
CM
CM
CM
CM
ar
o
O
1

CO
5O
co
to
ar
O

f»
o*
CM
m
*
-o
•n.
3
|
-j^

-s..,
<\,
HO
t<\
-2
3
1

ai
CM
-o
M
.0

75

(O
C2,
-o

-

Lu

^-j

'M
O-
Ul
o
JT
O
o
m
r*-
CM
ar
o
0
1
CM
to
co
cc
•-t
• a-
O
O
1
CM
H^
CM
to
to
ar

CD
n»
i>
m
ro
oo
ro

-3
1

CO
fO

-0
.•o
1-5
-5
1

r-
•>.
•o
r^
iO
-5
-5
1

|
—4
•41

1C
ro
JO
<-^
-»
i
fO
-o
•o
CM
Ul
i/:

n
.
^
£
,—.

-o
ar
a-
ff\

O

!»
0
3-
ar
Ul

1/1
ir

-------












f— c-
•r- U) r~-
03 CU
CU 4-> 3 -0
J= C C 0
C O- O E
CD CD d)
l/> C C 1—
C T- •!-
O S- "O CD
•r- 3 r— C
•»-» •*->•!- O
(d U 3 _J
J- (13 CO
OvJ H-> <4~ X
r-l C 3 C CU
* OJ C O i— •
o u >o a,
C S T3 E
tt> O CU O
t— o tn in o
_O (/) eg
rc> o no aa cu

C CD •> $_
CO «=t 3
f> ra _J O
i- CO l/l
 r— O
•a s- rcs-r-
OJ >» O «r- 4->
H-> H-> O. J- 03
(TJ •!- CU •*-> r—
E C > CO 3
•i- T- CU 3 U
H-» U S- -O •—
t/> -r— JZ C tf
LL! >» 1/3 r— I CO























D
in

O
O
o
o
*




o
o
o






o
o
o
rM




r»
o
^)

•r-l







"^
o
3
OJ




"3
"3
uj -o




1^
I™"
or, ^

rH **
_ 1
I
a:
r-4
O

sr
-3
1
•o

=r
C
03
sr
-o
o
rH
sr
o
o
1
0
cc
CM
O
CM

sr
0
o
1
CM
p^
CM
in


m
r>
CJ
ft
sr
f*»
•o
rH



2
"
"^
1
•O
CM
ul

O
•^
•T*
t
o-
IX1*
•—4
CM
•Tt
fl
•3
3
1
n
•O
O
CM


irt

ui
t>
1
ut
;n
sr
«-i

O
1
o
•o
CO
sr
o
o
1
CO
0
sr
CM

in



"}
JT *
-J
i
vM
r-l
^

f,
.^
:r*
1
•a
.-*
CM
CM
•"•
fl
O
3
1
*O
•1".
O
•""
*""

to
U)

o
1
o
-o
r—
CM

in
0
o
•o
sr
r-
-r
o
o
1

sr
•o
o
**

if
o
o
1
r-l
f»
O
o
«H


sr
O
7
^u
-o
o
o
sr



.0
-~
TJ
i
r-t
\^>
>>

CM
•n
o
i
'""O
o
p-
(X)
f,
fl
o
^>
1
fl
cr
r^
CM

3


O
O

O
o
1
•o
r-
f»
CO
sr
o
0
1
r-l
O
CM
CM
^

sr
0
0
1
«•<
K*\
Q
CM
CM


sr
o
o
sr
rH
CO
<—
in



f «K

t3
1
|-~
fl
f>

^
fl
•O
1
•M
CM
sr
CM
ar
CO
"3
-^
1
,"™^
in
!M
vO

3
3

sr
i
in

o
-3
I
CM
•H
in
(n
«"'
^
^
o
t
in
fw
0

CM

.j.
O
o
1
*O
f*"%
CM
sr


fl
o
"l

sr
r*
•D
-H



^}

"^
|
*\
3r
T-4

•"
n
r^
i
CM
•J>
•^»
U\
^J
f>
C^
^S
T
^«
—<
c*
fi
0

3

o
i
r-

0
0
1
.0
rH
CM
CM
.f
a
o
I
o
in
o
CM
f>

.^
O
o
1
in
O-
O)
CO
in


f>
1

i^»
CM
U1
rH



'0

3
1
•n
0
»

r-
fi
~5
^

sr
fl
fi
CD
fl
"3
*^
1
rj*
CM
AJ
•>
•-
3
3
D-3
i
o
in

sr
O
i
o
«
.,.
o
o
1

rn
rH
CM
in

sr
O
o
1
CM
|S^
n
o


o
o
r-l
fl
CM

CM



ro
•j
3
1

u^
*°

~
CM
— »
1
sr
in
•~M
^
«
n
r^J
^
1
CM
fl
sr
in
O-
3

16
o
o
1
•c
c>
«-
•sr
0
T*
o
CM
sr
o
o
1
-o
m
r-l
o>
fl

sr
0
o
1
^^
-o
o
(*-


o
o
fl
in
03
30
^



'!?
,.'
3
1
a
CM
r—
*A~<
O
CM
O
^
{••«
j.
D
Og
"•
CM
O
O
i
O1*
CM
CO
;'^
*-*
3


-5T
O
"l
rH
Cv)
M
O
i
r-
G
fi
sr
.,.
O
o
1
CM
rH
O
in
•0

ft
o
o
l
>o

CO
rH


n
"3
JO
JO
sr
«-<
fi



-J
1 .'
-3
I
••H
tO
r-l

-«
^
-I
—1
I

•"1
'*O
cc
-
•M
fT:
_— \
1
.*-)
r»
o
^
r-t

*~

1
rH
~
»
'a
i
rH
in
-
^
O
o
1
CO
o
ft
fl
CM

sr
o
o
1
r*»
sr
CM
sr


rt
a
i
•0
•u
m
-»
—4



•o
~
"^
1
n
C>
T

'-
."M
-7^
t
•r

_ (
rH
rH
•M
"3
— >
1

•O
,r\
-U
•rH
UJ
^

-0
o
sr
3
1
O
in
r-4
0
sr
o
o
1
o
sr
m
o
rH

sr
o
0
1
. sr
CM
in
ft


sr
O
?
CO
O
fO
ft
0*



-I
_7/
*)
1
•J
lv'l


a^
-1

1
o
rH

•>
•il
."1
..-
"V^
T
^
,—•
^
T-*
*
LJ


^~
O
1
JO
.M
-
sr
c^
o
sr
CO
-
sr
o
o
1

r»
«r
o
CM

•sr
o
o
1
r**
O*
o
•o
ft


•sr
b
r-l
O
fN.
•o
0



0
~TJ
"^
1
T'"l
|^-
r»»

»
'M

1

jX,
•fc^
CJ
Hr
-1
.-)

~?
'M
O-





V,
^J
••J
1
o

j.

sr
ro
,-.
3
1
Q


*
u,

'_
JM.
"
'
,'
J

U',
LU
on

•5
t
-3
CX

-------
                               o
                               §

                               o
                               
                                                   o
                                                   o
                                                    I
                     CM
                     o
                       •
                                   ea
                                    i
                                  §

                                  •9
                                  03
                                  CM
                     O     O,
                     o     3
                      i      t
                     S     S
                                                              P.    P-     «n
                                                                                    a
                                                                                    o
                                                                                         O
                                                                                         CO
                                                                                         o
                           o
                           C3

                           CM
                                                                              •O
                                                                               •     •      •
                                                                              1=4    •"!     CM
                                                                           co
                                                                           o
                                                                           ar
                                                                            •
                                                                           CM
                                  Q     o
                                  3     o
                                   I      i
                                  o     "•
                                  CM     »•«
                           O

                           in
                           co
                                                                                                        tn
                                                                                 -o
                                                                           a      •
                                                                          m     **
                                                                                                                                  o
                                                                                                                                  o
                                                                                                                             1*1
                                                                                                                             !*\
                                                                                                                             •O
                                                                                                                           CM     «*
                           CS,    O
                           o     cs

                           ft,     CM
                           in     o
                           sr     co
                           o     -H
                            •      •
                           CM     •*
O
e
o

o
«r
                                          o
                                          o
                                           i
                                          o
                                           •
                                          CM
                                            O
                                            0
                                             1
 1*1     J*
 O     O
 &     o

 *4     O
f.     «=«
 w     co
 m     o
                                            m    »
                                             «     •      •
                                            ,*«"•«•
O
o
 I
o

o
CO
 •
CO
o     o
o     a
 i       i
                                                                       co

                                                                       tn
                                                                        a
                                                                       00
                                                (M
                                                CO
                                                O
                                                 a
                                                CM
                                                                                     i
                                                                                    in
e
o
 i
o
CM

•«*
                                                                                                  O
                                                                                                  O
                                                                           O
                                                                            e
O     O
o     a

d     CM
CO     O
««     o
CM     *«

ar     eg
                                                                                         O
                                                                                         O
                                                                                         1
                                                                                         CO
                                                                                                      o
                                                                                                      o
                                                                                                       1
                                                                                                                           CM     «M
              O     O
              O     O


              CM     *
              •O     CO
                                                                                                •

                                                                                               CM
                                                                                                •
                                                                                              CM
                                                                                  •0

                                                                                  CM
                                                                                                                                               in
      CO 4->
     -E C
     +-> (t)
         r— C
      C Q- (O
 c T-
 o s.
•i- 3

 (O O
 s- '
 (O -r-
-|_J  (J
CO -r-
            s=
            O

            T3  CO
            ai  c
            to  O
            « •«-
            ca -t-J
                fO
            S»  U
               i —
            +->  
             •••a
            O> O
            s- s
            co  S-
            C  3
            -i-  CO
            +J  O
            i.  Q.
            (O  X
            s: LU
                              e
                              a
                              o
                               9
                              a
                              it
o
o
o

3
CM
                             O
                             O
                                          o
                                          o
                       a

                       o
                       3
              o
              o
               I
              CO
              o
                                      9
                                     •o
                                    CM
                                    o
                                    o
                                    at
                                    CM
                                    in
                                           O
                                           O
                                            I
                                           CO
                                           «•*


                                           CM
             0

             co
             in
              »
             »t
              o
               i
                                                 a
                                                CO
                                                        I
                                                       O
                                                       ar
                                                       09
                                                       CO
O
o


CO
•o
o
 a
                     I
                    m
                            S
                            ca
                            i
                            in
                            ru
                            CM
                                                          i
                                                         Sf
                                                         CM
                                  O
                                  a
                                   i

                                  co
                                  O
                                  p-
                                   a
                                  CM
                                                                     o
                                  CM
                                   «
                                                                    O
                                                                    o
                                                                Q
                                                                 o
                                                                CM
                                                               O
                                                               O
                                  •O

                                   a
                                                O    O
                                                O    O
                                                I      t
                                                GO    f\
                                               O
                                               CM
                                                      I
                                                      in

                                                      in
                                                      o
                                                                             CM     «4
       t*\    r?i
       O    O
       3    3

       ar    CO
       O    I-
       P-    CM
                                        O
                                        O
                                         I
                                                      O
                                                      o

                                                      CO
                                  o
                                  o
                                   I
                                        o
                                        o
                                        •o
                           CO
                           o

                                                                                            t
                                                                                           •o
                  *v

                    n

                    •3
                     t
                    o
                                                                                           o
                                                                                            9
                           CM
                           o
                           a
                            i
                           o
                           in
                            a
                                                O
                                                O
                                                 I
                                                m
                                                                                                 CM
                                                                                                   9

                                                                                                 Sf
       fO
       o

       i
       •o
                                         o    o
                                         o    o
                                         I      I
                                         p.    o>
                                         «•    co
                                         CO    O
                                         r*    co
                                          •     ••
                                         in    CM
O
o
 I
                                                                                                                1
                           ;M
                           O
                           a
                           i
                           o
                           in
                            e
                                                                                 CM    'O
                                                                                 O    3
                                                                                 •1    >O
                                                                                   a     •
                                                                                 O    ar
             CM     «M
             O     O
             ?     ?
                                               o
                                               o
                                                I

                                               •a
                                               CO
                                               p»
                                                 a
                                               n
o
o

in
-o

ni
 •
•o
             o
             o
              I
                                  PV
                                  o
                                  o
                                  I
                                  co
                                  co
                                  •o
                                  o
                                   *
                                  CM
                                                                                                                             O
                                                                                                                             O
                                                                                                                            a"
       c
       o

       cp
                           f*\     K>
                           O     O
                           O     O
                            a      i
                           •o     o
                           <*l     ro
                           p»     »

                            a      •
                           tn     CM
m
o
o

n
•o

b-
 a
CM     **>
O     O
O     -5


rr\     CM
•O     !>
                                                                          O    O     ft     «H     rt    "4
                                                                           a     •      a      9      ,     a

                                                                          CM    »H     «^     i-(     ^4 .   CO

o
o
^
a
M



CM
O

1
1-t
ft
^4
•O
a
O
.>J
O
1
CM
ar
JO
sr
a
ut
rM
rs
o
i

m
—i
it
a
a?
.M
O
1
S)
ft
r*»
p-
a
••*
--M
O
3
1

O
CO
CO
e
CM
CM
O
0
1
in
a-.
rt
O
a
VM
CM
O
1
CM
ft
P-
p-
a
•O
CM
•3
O
1

CM
v4
O*
a
jy
.^
•3
I
0
.-1
i«4
3
e
i-»
CM
O

1
CO
•3 .
ar
ar
e
0
5
o
1
t3
CO
ar
C\J
a
»"«
3
CS
1
00
vH
v^
p-
a
-O
•:\j
rs
o
i
o
^
/7»
ft
a
f?
0 0
0 O
1 1

ft p*
p« at
«-( 1-1
a a
CO O
CM
rt
i

••>*
•o
•o
a
ut
                                                                                                                                                     co
                                    <3,
                                     I
                                    .t
                                    CM
                                           CM



                                            I


                                           ar
                                           -JO


                                            a
                    CM



                    ?
                    CM
                    O
                                                             CM
                                                             O

                                                             Lit
                                                             CM

                                                              a
                                        CM



                                         I


                                             C3

                                                                           I      i
                                                                      CM
                                                                       e
                                                                             O
                                                                             O
                                                                                   CM

                                                                                   P.
                                                      CO
                                                      CM
                                                                                                M
                                                                                          p»
                                                                                          •O
                                                                          CJ
                                                                          I
                                                                          -o
                                                                    ut
                                                                     a
                                                              I
                                                             r—

                                                             cvi
                                                      n

                                                      I

                                                      O
                                                      rj

                                                      I
                                                      ar

                                                      •JO
                                                      a-
                                        -3

                                         I
                                                                                                                                         CVJ
                                         O     U
                                         •3     o
                                         I      I
                                         -o      g

                                         ft     at
                                         CO     CM
                                                «1    CO
                                                             CM
                                                             O
                                                        CM

                                                        sr
                                                                I
                                                               ut


                                                               at
                                                               CM
                                                                o
                                                               •o
                                                                      CM     ^i
                                                                      c>     o
                                                                      o     o
                                                                       I      I
                                                                      ^*     '-tl

                                                                      co     ij-
                                                                           •O     «4
                                                      -3

                                                       9
                                                                    •O
                                                                    p-
                                                                     9
                                                                   O
                                                                   o
                                                                    I
                                                                   o
                                                                   -o
                                                                   CM
                                                                   Ut
                                                                    a
                                                      CO     f^>


                                                       I       I



                                                      rt     t>
                                                      CO     ^
                                                                                                                     O


                                                                                                                      I
                                                                                                                      O
                                                                                                                     =0
                                                            •-J
                                                             I

                                                            •o
                                                            !^\
                                                            oO
                                                              a
                                                                                                                                        O
                                                             3-
                                                             JO
                                                                                                             •O
                                                                                                            OvJ
O    •-•


M    O

3    fe
                                                JS
                                                I/
                                                in
                                                        3
                                                        «/•
                                                        3
                                       a-5     ^B


                                       3D-37
                                                                                        3
                                                                                                      Ul
                                                                                                             UJ
                                                                                                              UJ


                                                                                                              UJ
                                                                                               LJ
                                                                                               l/i
                                                                                               Ul
                                                                                                                                        I/'
                                                                                        i/i

-------
                                   o
                                   n
                                   o
                                   o
                                   o
                                   o
                                    •
                                  .o
o

 CO
JO
 (O
          o
 co 4-> -a to
j=  c i- HH
4->  ro ro •—
   r—-a
 c a. c E

    cn*j co

 C -r-
 O  S- C C71
•r-  3 O C  10
+J 4J    O  C
 «  O-O _1  O

4.) lj_ CO X -f->
 C  3 (O CO  ra
 CO  C 00 i—r—
 u  ro    a. 3
 c S  • E  <->
 O      rO
    w>       o
 O  ro 4-> CO
•r- r— V) O i—
 E CD CO I-  CO
 CO    S 3T3
   (O    O  O

eC It- 0>
    O S- •—  >»
T3     3 rO  CO
 CO  >>J3 -r-r—
4J ^J to $-•—
 ra -i- c 4J  ro
 E  C T- to >
•r- •!- 4-> 3
4->  O S. T3T3
 W -i- rO C  C
UJ > S »-H  «
                                   O
                                   O
                                   o

                                   o
                                   to
                                   o
                                   o
                                   o
                                    •
                                   o
                                   CM
                                   O
                                   o
                                   o
                                   D
                                   c-
                                   CM
                            UJ

                            O
                            I/!     -C
                            a:

                            a
rO
O
•x»
CM
.•o
O
•3
0
in
ro
«-i
CM
O
O
|
to
ro
T^
CM
to
fO
O
O
1
o
ar
a-
to
tn
CM
o
o
1
,T
04
r-
~*
**
.,
-3
7>
1
O-
>
ilO
o
CM
O
-»
1

<->
CO
CM
a"
.VJ
O
->
1
.T
1C
T
*»"
sr

V)
O
OO
Jt
o
o
o
t-l
0
r-
o
to
o
o
1
•0
r»»
CM
**•
CM
to
0
O
1
<>
CM
•O
in
ro
ro
O
f
0
tn
«-i
•"•
"
CM
r-j
.3
1
t>
,>»
CM
;M
CM
0
^
1
^y
O
^
o
ro
CM
O
0
1

r-
m
0-
CM
3
l/»
0
0
1
o
o
o
o
1
CM
-O
in

O
o
|
o
in
to
•"•
CM
to
0
O
1
to
CO
if\
•^
to
ro
O
?
«-«
r*-
ro
ar
«-
v\l
•3
-3
1
£
«~|
-O
-
CM
••3
3
1
•O
,_,
fO
co
-
CM
;3
0
1
r-
-o
73
-O
«
3
4/1
a*
O
1
in
«-4
O
lit
0
0
CM
CO
oo
*°.
fO
a
o
l
in
0
•0
0
*
to
0
a
i
CM
0
ar
ar
-
to
f3
O
ar
O
a"
O
ro
.0
;••*
.-}
1
3
CM
O
33
CM
O
^
1
-3
CM
CM
CM
-
iO
*75
'O
i
r-
oo
O
CM
0-
3
3
O
1
ar
•0
ar
CO
.•o
O
o
ar
ar
"
0
o
1
in
00
•o
fO
rH
to
O
o
1
r-
-o
r*
*"•
CM
rO
O
Cl
ro
r*
ro
CO
ro
CM
.-"I
"3
1
to
IO
ra-
ft
!M
O
*•}
I
3Q
»-«
>n
iii
•-4
01
o
tD
|
0
co
CM
rv:
^

3
ar
O
1
O
•o
o
1
co
-o
»-l
1
o
0
1

ar
CM
•*
0
10
0
o
1
tH
*"O
o
00
CM
to
t5
3
CO
•-(
l>-
3s
ro
•M
»-•,
•^i
1
u]
«H
IO
iM
iM
C'3
15
1
•n
r—
Ovl
t>
-
-M-
«*
~3
1

.—
•>
to
-1
^
3
)
O
•O
to
o
o
1

o-
in.
to
to
to
o
o
1
a*
ar
*^
oo
to
rO
"3
?
a*
to
CO
ar
^-
N
-^
5
i
r-
u^
'-^
sr
CM
~
t3
1
o
ro
O
«-4
ar
CM
CJ
't^
1
^D
fO,
7)
-O
CM
3
Z
(O
"3
O
1
ar
b
o
i
-o
C\i
ro
O
O
1
CO
oo
0
•o
~
to
0
o
1
o
r««
to
o»
ro
ro
O
••3
r»
«H
ar
ar
0
N
•3
D
1
(^
r^
'*•
CM
CM
O
o
1
•o
•o
•o
r~
*
CM
O
75
1
ro
fi
r~
-'
ro
3

(0
C
1
ar
p-
-a
CM
ro
c
0
1
co
T-t
CM
CO
ro
to
o
o
I
in
o-
in
o
m
to
o
o
i
in
to
flO
o
ar
CM
n
O
1
3»
O
O
ar
rl
:M
•"~'
^5
1
cr
^
-"
•O
Al
O
""^
1
*o
-o
ar
•*•
»
Cvj
T*
*7)
i
o
p-
•-1
sr
(0

E
j[
CM
U1
O
•r-l
O
O
1
O
to
o
o
1
>H
c

o
CM
to
o
o
1
CO
in
o
•*•
ar
to
^
a
l
ro
in
ro
•23
*
••j
*~*
••71
i

t>
•^
•^
CM
T/1
~>
1
3D
i»»
'-^
rj
fO
.•M
/-\
*^
1
-.3
f
0
0-
O-t
UJ
2
i
O
r-
c\.
ro
1
to
OC
CM
^-
CM
O
O
1

sf
CM
UP.
to
^
0
o
(1
»H
ro
CM
•O
u-v
CM
^
P
i>j
u>
ar
•^
«
•4
•
S
1

sr
-'"
.M
";M
••".
^3
1
J"
O
~3
if
m
,M
» ^
""?
1
Tw
-
ex
,M
IM
7>
^
1
iT

p^
C>J
,0
rj
~ t
b
i

fi
•a"
-o
ro
UJ
5?
UJ
T
iO
o
tJ
CM
O
0-
to
o
o
1

,.4
CM
r~
CM
to
o
o
1
ro
•o
-0
sr
ar
ro
n

ut
CM
—4
ro
*
•M
~
1
1
-0
•n
.1
,o
•M
"?.'
*^
1
O
t>
o
l^1
u-v
CM
*™^
*^
1
•O
sr
o
'"'
'"•

lu
.•o
.M
iO
c.
ii
l*~
•4J
to
o
o
1
^,
f>.
ar
ec
CM
to
O
O
1
-o
r*
o
CO
to
ro
«*3
"i
-o
o
•H
9*
30
iM
•^^
~3
1

7?
f\r
*
^
•~
*^
i
j*
•o
-J
r*
•o
CM
O
•~^1
1
n
r-t
0
£*„*
20
UJ
UJ
"1
.1
r-
O
1
^-4
CM
Ul
to
o

1
o*
o-
r"
c
ro
ro'
O
O
I
>-Q
CM
r-.
"^
ar
ro

P
U)
3

iM
*
M
•••^
•j
1

a

cr
M
., »
*^j
1
j
_
•O
>o
4*
w
"%
TV
1

ro

0-
-c
UJ
I/I
1
o-
o
IJ
•o
CM
ro
o
0
1

to

CO
, rH
»o
o
•o
1
ah
in
o
*-"
to
ro
O
'l

tn
o
p-
-0
CM
-;
—)
1
in
in
r-.
04
iM
T5
-I
1
^
«-*
"M
*-•
if
^
• ^
"5
1
O
Cv.
*^
O
a-
UJ
tn
to
                                                                        D-38

-------





S E
E O O (/)
O
OJ 4-> cn x •r-
•4—} fO »r~* .•"• fl3
r"" "X^J f^)L r" •
E O- i — £= 3
•i- -t- 0 0
CD =J C_3 r—
t/> E co rd
c T- oj c_j
0 S- E 0
•r- 3 O S- i —
4-> 4-> 3 OJ
re O T3 O T3
s- re oj oo o
4-» 4-  21
LO C 3 re r-
i—i oj E co re >>
• o re T- oj
Q c s: " s- •—
o =c -i-> »—
oj c_> t/> ^» i/> re

re 'r- r— t/) E "O
f— E CD OJ t-H E
oj ^ re
i/> re T3
s_ « s_^~.
«=t M- en re l —
o s- -a _i
T3 =J E O
OJ >» .0 re co
4-3 4-* (/) -f-^ *— 1
re -i— E co — •
EC" »p—
L_ f^
•r-" "i— i * f*- f~
-4-> O &. I/) i-
i/) -r— re re oj
UJ > S 3 1 —









'.J
U
z
^f
•^

r-

t/l

•-*
O
ct
o
T° -)
C r-
O CM
• in
U\ CM
c:
i
O fl
C5 • ro
3 0
• CM
O
o
1
o o»
{^ ^^
O *Q
• sr
f> M
o
i
0 C
0 «-l
?"i ?1
• o
CM m

.M
1
T> CM
Ti CM
T-< «H



•"M
^2
5
1
T Is-
'"* '!>
D in
. v>

CM
O
^3
1
*"^ O
-> o
-^ -o
• sr
O-
T-1
O
o
1
r f~i
^ f*.
m ^j
« M
•"

IA.
••o
o
1
•X)
CM

fO
o
-3
1
ar
O
n
o
o
CM
O
O
o
o
1
KQ
0
-o
o
'fl

o
-3
O
CM
O
in




•M
•*^
->
1
O
~~-
o*
•-D
^
l\i
*m
."•>
i
"^j
c?*
o
fO
^
rvj
O
*3
1
•M
CO
••M
"•
O
3
VI
l/J
ar
1
Cf)
03
1
in
a
•o
iii
o
0
1
in
*H
o
o
i
Q
T-I
sr

o
a
i
sr
•0
33



-M
"7^
O
1
r»»
T^
^
s-n
-N
nj
*^
-^
i
•H
-o
^J
o
fO
:xj
i*5
.73
i
cr
Tl
r—
r*.
Ui
3
V)
-3T
O
1
U)

«•
a
0
i
r-
0
o
0
1
T-I
CM
in
o
a
i
31
"•

b
o
«r
T-I
CO
*



r>j
o

l
•U
»-1
iO
J1
-
CM
*3
-3
1
j^
ar
n
ar
<>,
,M
*"*
b
i
CO
r-
CM
r-
CM
3
1/1
2
sr
O
1
CM
ar
CO
ro
O
O
1
r-
o
o
o
o
1
•o
r-
r-
O
O
ar
CM
CO
CM

O
O
o
CO
in
»



.M
•3

1
r-
o*
i sj
ar
CM
CM
O
O
1
U"\
ij-
CxJ
C\i
fO
IM
0

1

oc
Is-
0
r,

3
o
1
CO
oc
o
o
1
co
0
0
sr
00
o
o
o
1
flO
CM

O
•ts
ar
oo
=r



M
^
->
1
X**
cr,
-1!?*
j-l
••n
'.M
rr
-s
i
M
Is-
T^
" "'
»
CM
T!)
-^
1
i'O
•T^
Is-
I'l
sr
3
3
O
1
r-

o
o
1 ;
-O
P-
co
o
1
O
ar
in
o
o1
1
in
T5
0
f,

fl
n
o
CM
«o
0
0



•M
.••^j
-3
1
«•»
CD
~^O
J5
•°'
r-d
^>
-^
I ;
~^
^
•o
>"*
eft
^
•*"3
^3 •
1
-o
c
sr
CM
a '
3
2 ;'
p
1
O-

b
3
1
-O
O-
oo
o
o
1
•o
If
CO
fl
o
o
•Q
»

CM
O
sr
O
-



•j
o

1
U
T-I
sr
-0
*
CM
0

1
^*
T-i
T-4
at
o«
Csl
^
O
1
TM
!!••.
X>
O-
Oi
3
g
O
•5
1
-O
CM
O
o
1
-o
fl
0
0
o
CO
CM
in
o
o
1
CM
o
in

CM
o
o
r-
Sf
-o
~<



^*M
~ •,
.3
1
-3
CV»
^\J
r*
o.
r-1
r^
•3
1
^4
CO
O
c;
~
T-1
.^
"3
1
r-
o
CM
^
~

Z
O
1
c

T^
ar
03
CM
CM
0
o
1
•o
o
o
CM
0
0
o»
0
ar
m

CM
o
n
CM
CM
-



'."J
.--;
T
1
•^
sr
OJ
rvi
U1
.-J
••7
— ^
1
3-
151
,»»
-0
•-
TH
-V
-s
1
f\ '
*-+
r-t
""^
-
UJ
^
o
J
CO
co

r?
i
CO
cv
b
t
o
ft.
0
fl
o
0
1
•~o
sr
•o

iM
CM

-



•M
-•
'3
i
-O
ft
O*
OJ
n
i^
^j-
"•
I
•*"l
r^»
•J»
sr
0.
_
r.

i

o
T-I
-1
-
UJ
K
t
r-

O
1
d>
sr
t>
o
0
1
in
-o
o
•0
CM
O
0
1
o
sr

b
i
CM
T-I
UI
O



"•J
. -j

1
^r»
^i
JO
•i
^
N
•^
^
l
o
|V.
ivj
T-I
r>-
^
•'3

1
fl
•AJ
|0.
..,'
T-I
UJ
UJ
1
T!
=r

I
ar
0
CM
fl
O
O
1
in
0
CM
o
o
01
o
u>

CM
O
O
ar
o
CM
•H



•\J
••*
~
1
t^
<-l
t^
--r
O
_,
~*
—l
1
^*
-r
-O
«-'
-
»-l
;*^
*">
i
•^
~
fi
o
r*

u,
fi .^ .-•>
3 3 °
/ / ^
O -r> "J
•0 Cf- C
t^J cr C

fl CO l*»,
O C: O
000
1 t 1
o CM m
CM a- o
fl CM O
0 O 0
O O 0
1 1 1
"• o a>
CM O* sf"
in ~o o
000
ft fl CM
fO f*O f\
o o o
O o O
1 1 1
in r* in
ft fi .0
ar -0 "n
fi ^3 in
ar ar f»

CM ^4 fl
f^ O **^
? ? ?
»H « 2
^ »-4 nj
«-« t-t oo



••M .M M

" ^ 13 'TJ
i i i
\i J ,->
Is- co . -•
r*- ^r Ti
-il i— tr\
o o sr
.-> -t .j
—; - «; .' >
— ^ ^j -^
1 1 1
*; o ••*»
•o ^ -o
o ~r CM
Cu „ fn
^< r-i m
TH ,-1 T-1
-5 -2 ~
"3 '"S "^
i i F
iM O 'M
•*•' u\ *^

C'J vj- i".
C\J T-I *-•
UJ uj UJ
UJ ' l/">








en
CO
i
O

































D-39

-------
D.5  ANALYTICAL UNCERTAINTIES APPLICABLE TO THE CALCULATIONS  OF  PUBLIC
     HEALTH RISKS CONTAINED IN THIS APPENDIX
D.5.1  The Unit Risk Estimate
     The procedure used to develop the unit risk estimate is  described  in
reference 2.  The model used and its application to epidemiological  data
have been the subjects of substantial comment by health scientists.   The
uncertainties are too complex to be summarized sensibly in this  appendix.
Readers who wish to go beyond the information presented in the reference
should see the following Federal Register notices:  (1) OSHA's "Supplemental
Statement of Reasons for the Final Rule", 48 FR 1864 (January 14, 1983); and
(2) EPA's "Water Quality Documents Availability" 45 FR 79318  (November  28,
1980).
     The unit risk estimate used in this analysis applies only to lung
cancer.  Other health effects are possible; these include skin cancer,
hyperkeratosis, peripheral neuropathy, growth retardation and brain
dysfunction among children, and increase in adverse birth outcomes.   No
numerical expressions of risks relevant to these health effects is included
in this analysis.
     Although the estimates derived from the various studies are quite
consistent, there are a number of uncertainties associated with them.  The
estimates were made from occupational studies that involved exposures only
after  employment age was reached.  In estimating risks from environmental
exposures throughout life, it was assumed, through either the relative-
risk model  (1) or the absolute-risk model  (2), that the increase in the age-
specific mortality rates of lung cancer was a function only of cumulative
exposures,  irrespective of how the exposure was accumulated.   Although  this
assumption  provides an adequate description of all of  the data, it may  be
in error when applied to exposures that begin very early in life.  Similarly,
the  linear  models possibly are  inaccurate  at low exposures, even though they
provide excellent descriptions of the experimental data.
     The risk assessment methods employed  were  severly constrained by the
fact that they were based only upon  the analyses performed and  reported by
the  original authors—analyses  that  had been performed for purposes other
                                    D-40

-------
than quantitative risk assessment.   For example, although other measures of
exposure might be more appropriate, the analyses were necessarily based upon
cumulative dose, since that was the only usable measure reported.   Given
greater access to-the data from these studies, other dose measures, as well
as models other than the simple relative-risk and absolute-risk models, could
be studied.   It is possible that such wide analyses would indicate that other
approaches are more appropriate than the ones applied here.
D.5.2  Public Exposure
D.5. 2.1  General
     The basic assumptions implicit in the methodology are that all exposure
occurs at people's residences, that people stay at the same location for 70
years, that the ambient air concentrations and the emissions which cause
these concentrations persist for 70 years, and that the concentrations are
the same inside and outside the residences.   From this it can be seen that
public exposure is based on a hypothetical premise.   It is not known whether
this results in an over-estimation or an underestimation of public exposure.
D.5.2.2  The Public
     The following are relevant to the public as dealt with in this analysis:
     1.  Studies show that all people are not equally susceptible to cancer.
There is no numerical recognition of the "most susceptible" subset of the
population exposed.

     2.  Studies indicate that whether or not exposure to a particular
carcinogen results in cancer may be affected by the person's exposure to
other substances.   The public's exposure to other substances is not
numerically considered.
     3.  Some members of the public included in this analysis are likely to
be exposed to inorganic arsenic in the air in the workplace, and workplace
air concentrations of a pollutant are customarily much higher than the
concentrations found in the ambient, or public air.   Workplace exposures
are not numerically approximated.
                                   D-41

-------
     4.   Studies show that there is normally a long latent period  between
exposure and the onset of lung cancer.   This has not been  numerically
recognized.
     5.   The people dealt with in the analysis are not located by  actual
residences.   As explained previously, people are grouped by census districts
and these groups are located at single points called the population centroids.
The effect is that the actual locations of residences with respect to  the
estimated ambient air concentrations are not known and that the relative
locations used in the exposure model may have changed since the 1980 census.
However, for the population sectors estimated to be at highest risk, U.S.
Geological Survey topographical maps were checked to verify that people did
live or could live in locations near the sources as modeled predictions
estimated.  Maps in certain instances were old and the possibility could
not be excluded that additional areas near sources have been developed
since publication of the maps.
     6.   Many people dealt with in this analysis are subject to exposure  to
ambient air concentrations of inorganic arsenic where they travel  and  shop
(as in downtown areas and suburban shopping centers), where they congregate
(as in public parks, sports stadiums, and schoolyards), and where  they work
outside (as mailmen, milkmen, and construction workers).  These types  of
exposures are not numerically dealt with.

3.5.2. 3.  The Ambi ent Ai r Concentrati ons
     The following are relevant to the estimated ambient air concentrations
of inorganic arsenic used in this analysis:
     1.   Flat terrain was assumed in the dispersion model.  Concentrations
much higher than those estimated would result if emissions impact  on elevated
terrain or tall buildings near a plant.
     2.   The estimated concentrations do not account for the additive  impact
of emissions from plants located close to one another.
     3.   The increase in concentrations that could result from re-entrainment
of arsenic-bearing dust from, e.g., city streets, dirt roads, and  vacant  lots,
is not considered.
                                     -D-42

-------
     4.   Meteorological data specific to plant sites are not used in the
dispersion model.   As explained, HEM uses the meteorological data from the
STAR station nearest the plant site.  Site-specific meteorological  data
could result in significantly different estimates, e.g., the estimates of
where the higher concentrations occur.
     5.   In some cases, the arsenic emission rates are based on assumptions
rather than on emission tests.
                                  D-43

-------
D.6  References

1.  National Academy of Sciences,  "Arsenic,"  Committee  on Medical and
    Biological Effects of Environmental  Pollutants, Washington, D.C. , 1977.
    Docket Number (OAQPS 79-8) II-A-3.

2.  Health Assessment Document for Inorganic  Arsenic  -  Final Report EPA-600/
    8-83-021F March 1984, OAQPS Docket Number OAQPS 79-8, II-A-13.

3.  U.S.  EPA, et.al., "Environmental  Cancer and Heart and Lung Disease,"
    Fifth Annual Report to Congress by the Task Force on Environmental Cancer
    and Health and Lung Disease, August, 1982.

4.  OAQPS Guideline Series, "Guidelines on Air Quality Models."  Publication
    Number EPA-450/2-78-027 (OAQPS Guideline  No.  1.2-080).

5.  Systems Application, Inc. , "Human Exposure to Atmospheric Concentrations
    of Selected Chemicals."  (Prepared for the U.S. Environmental Protection
    Agency, Research Triangle Park, North Carolina).  Volume I, Publication
    Number EPA-2/250-1, and Volume II, Publication Number EPA-1/250-2.
                                   D-44

-------
                                    TECHNICAL REPORT DATA
                             (Please read Instruction! on the reverse before completing)
    EPA-450/3-83-011b
                                                                RECIPIENT'S ACCESSION NO.
 TITLE AND SUBTITLE
    Inorganic Arsenic Emissions from Glass Manufacturing
    Plants  - Background  Information for Promulgated  Standarc
                                                               .REPORT DATE
                                                               May 1986
             i. PERFORMING ORGANIZATION CODE
 AUTMOR(S)
                                                              8. PERFORMING ORGANIZATION REPORT NO.
 •ERFORMING ORGANIZATION NAME AND ADDRESS
   Office of Air Quality  Planning and Standards
   U.S.  Environmental Protection Agency
   Research Triangle Park,  North Carolina  27711
            10. PROGRAM ELEMENT NO.
            11. CONTRACT/GRANT NO.


               68-02-38/6
 2. SPONSORING AGENCY NAME AND ADDRESS
    DAA for Air Quality  Planning and Standards
    Office of Air and  Radiation
    U.S.  Environmental Protection Agency
    Research Triangle  Park,  North Carolina  27711
                                                               13. TYPE OF REPORT AND PERIOD COVERED
                                                                       Final
             14. SPONSORING AGENCY CODE

                 EPA/200/04
 5. SUPPLEMENTARY NOTES
 6. ABSTRACT
         Standards  to control emissions  of inorganic arsenic from glass manufacturing
    plants are  being promulgated under the authority of  Section 112 of the Clean  Air Act
    This standard applies to new and  existing glass manufacturing plants.

         This document contains a summary of public comments,  EPA responses, and  a
    discussion  of differences between the proposed and promulgated standard.
17.
                                  KEY WORDS AND DOCUMENT ANALYSIS
                   DESCRIPTORS
                                                 b.lDENTIFIERS/OPEN ENDED TERMS  C.  COSATI Field/Group
    Air Pollution
    Glass Manufacturing Plants
    Pollution  Control
    Emission Standards
    Arsenic
Air Pollution  Control
13-B
tie. DISTRIBUTION STATEMENT
                                                 19. SECURITY CLASS (This Report)
                                                     Unclassified
                           21. NO. OF PAGES
                                148
                                                 20. SECURITY CLASS (Thispage)

                                                     Unclassified
                           22. PRICE
 EPA Form 2220-1 (Rev. <_77)
                        PREVIOUS EDITION IS OBSOLETE

-------

-------