United States
Environmental Protection
Agency
Air and Energy Engineering
Research Laboratory
Research Triangle Park NC 27711
Research and Development
EPA/600/S8-87/040 Dec 1987
&EPA Project Summary
Technical Support to the South
Coast Air Quality Management
District Toxic Chemical Accidental
Air Releases
D. S. Davis and G. B. DeWolf
The South Coast Air Quality Man-
agement District (SCAQMD) requested
technical support toward developing a
regulatory approach for controlling
potential accidental air releases of toxic
chemicals. This report provides some
of the technical input and describes
other support efforts. These efforts
included preparation of the technical
contents of an example draft rule ap-
plicable to facilities using or storing
seven specific toxic chemicals and
technical reference manuals concerning
hazards and their control in such
facilities.
This Project Summary was developed
by EPA's Air and Energy Engineering
Research Laboratory, Research Triangle
Park, NC, to announce key findings of
the research project that Is fully docu-
mented In a separate report of the same
title (see Project Report ordering In-
formation at back).
Introduction
Concern for accidental toxic chemical
air releases, and especially a Bhopal type
incident, has prompted considerable in-
terest in the prevention and mitigation of
such releases. In January 1985, the
Governing Board of the South Coast Air
Quality Management District directed a
study to be undertaken concerning pre-
vention of and preparedness for a large
toxic chemical air release in the South
Coast Air Basin of Southern California.
The two main objectives of the study
were to assess: 1) the ability of the
chemical industry to avoid a chemical
disaster of Bhopal proportions, and 2) the
ability of the four counties comprising the
district (Los Angeles, Orange, San
Bernandino, and Riverside) to respond
effectively if such a disaster occurred.
The resultant study was the South Coast
Air Basin Accidental Toxic Air Emissions
Study, issued in September 1985.
As a result of this study, the SCAQMD
decided to develop a rule for facilities that
use or store any of several toxic chemicals
in excess of certain quantities. The pur-
pose of the rule would be to ensure that
appropriate technical, administrative, and
operational controls existed at designated
facilities to minimize the potential for
accidental toxic chemical air releases.
SCAQMD approached EPA Region 9 for
technical support.
Region 9 decided to provide technical
support to SCAQMD under Section 105
State Grant Funds for the development of
their rule. In their proposal, the SCAQMD
identified a task to develop "implementa-
tion guidelines" which appeared to be
similar to a series of Prevention Reference
Manuals (PRM) that had been proposed
for development by the U.S. EPA. EPA
felt that support to the states in demon-
stration projects (e.g., a Region 6 inspec-
tion project and Region 2's interest in an
inspector's training course) would help
EPA increase its own expertise. The EPA
Office of Research and Development
(ORD) met with Region 9 and SCAQMD
and agreed to proceed with a technical
support project to SCAQMD with funding
from Region 9 for technical input into the
rule and the PRMs and from ORD for the
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PRMs. The Air and Energy Engineering
Research Laboratory (AEERL) was de-
signated as ORD's project monitor, and
subsequently contracted with Radian
Corporation to do the work on the PRMs
and simultaneously provide technical
information to support the rule develop-
ment. SCAQMD decided that the rule
would be similar in format and structure
to their existing air rules. SCAQMD also
felt that the PRMs would be the type of
technical support the rule needed, both
as a guide to industry and to the regula-
tors and inspectors in taking measures to
reduce the probability and severity of
accidental air releases of toxic chemicals.
A primary technical approach favored by
the SCAQMD for release prevention was
redundancy.
Roles of EPA, Radian
Corporation, and the SCAQMD
Roles were clearly defined for the U.S.
EPA, Radian Corporation, and the
SCAQMD in this effort:
• EPA was to provide technical assis-
tance in areas identified by the
SCAQMD where the SCAQMD felt
they needed support. This technical
information was to be supplied to
the SCAQMD in the form of a pre-
liminary draft of a rule, as well as
various PRMs when they were
available.
• The SCAQMD was to write a final
draft of the rule, conduct reviews,
and follow through on their usual
rulemakmg procedures. At that stage
further use of EPA input was to be
optional
• Radian Corporation was charged
with preparing the PRMs as well as
providing an example draft of how a
rule might be configured based on
the technical requirements of release
prevention through the technical
information developed in the PRMs.
These three groups were to work
together with a Technical Advisory Group
(TAG) to meet the program's objectives.
The TAG was to provide technical ex-
pertise and industrial experience as well
as ensure the technical quality of EPA's
input to SCAQMD. Members represented
industry, the States, associations, and
representatives from other EPA
components.
A fundamental principle of this program
is that the rule being developed is at the
initiative and overall direction of the
SCAQMD and does not represent any
official policy of the EPA and is not to be
perceived as EPA recommendations.
There is no intent that the example draft
rule developed in this program is neces-
sarily to be used by others. Reportable
quantities of chemicals in the draft rule
have no relation to other requirements
such as EPA reportable quantities, and
nothing in the rule is to take the place of
any existing or future EPA requirements.
Background Work By
The SCAQMD
In conjunction with the SCAQMD study
mentioned earlier, a formal survey was
conducted by the SCAQMD of facilities in
the District. This survey identified facilities
and their inventories of specific chemicals
on the SCAQMD list of chemicals of
concern which was presented in the
SCAQMD study. A summary of the find-
ings of the survey in terms of types of
facilities and reported inventories is pre-
sented in the full report for seven chemi-
cals that, as a result of the study and
survey, the SCAQMD decided might be
subject to the rule: chlorine (CAS No.
7782-50-5), hydrogen fluoride (CAS No.
7664-39-3), hydrogen cyanide (CAS No.
74-90-8), ammonia (CAS No. 7664-41-
7), carbon tetrachloride (CAS No. 56-23-
5), sulfur dioxide (CAS No. 7446-09-5),
and chloropicrin (CAS No. 76-06-2). The
technical effort described in the report
focuses on these seven chemicals.
SCAQMD identified its requirements
in the following general areas' (1) format
for the rule, (2) specific chemicals covered,
(3) types of facilities, (4) procedures
(applicability, registration, hazard identifi-
cation, control plan, risk reduction plan,
and record keeping), (5) emphasis on
redundancy or backup control systems,
and (6) technical aids for hazard identifi-
cation and evaluation for permitting and
inspection.
D S. Davis and G. B. DeWolf are with Radian Corporation, Austin, TX 78766
T. Kelly Janes is the EPA Project Officer (see below).
The complete report, entitled "Technical Support to the South Coast Air Quality
Management District Toxic Chemical Accidental Air Re/eases," (Order No.
PB 87-232 260/AS; Cost: $18.95, subject to change) will be available only
from:
National Technical Information Service
5285 Port Royal Road
Springfield, V'A 22161
Telephone: 703-487-4650
The EPA Project Officer can be contacted at:
Air and Energy Engineering Research Laboratory
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
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